POLICY ISSUE

NOTATION VOTE

October 17, 2006 SECY-06-0212

FOR: The Commissioners

FROM: Luis A. Reyes

Executive Director for Operations

SUBJECT: PREPARATION OF ANNUAL REPORTS ON RADIOACTIVE

MATERIALS RELEASED IN GASEOUS AND LIQUID EFFLUENTS AND

IN SOLID WASTES SHIPPED FOR DISPOSAL BY COMMERCIAL

NUCLEAR POWER PLANTS

PURPOSE:

To respond to the Commission request for a staff proposal for the preparation of annual reports

summarizing information on the types and amounts of radioactive materials released in

gaseous and liquid effluents during normal operations from nuclear power plants, and the types

and amounts of solid wastes shipped by commercial nuclear power plants to low-level

radioactive waste disposal sites.

SUMMARY:

The NRC sunset the reporting of similar annual reports in the mid-1990s due to their limited use

and to allocate NRC resources to higher priority activities. If the Commission determines that

such reports are needed, the staff has identified two alternatives for producing the reports using

data submitted by licensees. Under the first alternative, the staff would compile the reports

submitted annually in accordance with existing requirements in 10 CFR Part 50.36a. Under the

second alternative, the staff could revise existing requirements as an e-government initiative to

have licensees submit the information via a secure website.

CONTACT: Jean-Claude Dehmel, NRR/DIRS

301-415-6619
The Commissioners -2-

BACKGROUND:

As requested in the Staff Requirements Memorandum for the FY 2006 Midyear Resource

Review (COMSECY-06-0017), the staff has prepared a proposal for issuing annual reports

describing radioactive materials released in gaseous and liquid effluents and information on

volumes of solid wastes shipped by nuclear power plants. The Commission requested that the

staff consult with the Environmental Protection Agency (EPA) and State officials to ensure that

this effort does not duplicate other reporting requirements. In addition, the Commission

requested that the proposal include an estimate of the resources needed to prepare such

annual reports routinely.

In accordance with “Technical Specifications on Effluents from Nuclear Power Reactors,”

10 CFR 50.36a, nuclear power reactor licensees are required to submit annual reports on liquid

and gaseous effluents. Regulatory Guide (RG) 1.21, Revision 1, “Measuring, Evaluating, and

Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and

Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants,” describes acceptable

formats to use in reporting the amounts of radioactive materials released in liquid and gaseous

effluents and contained in solid wastes shipped for disposal. Nuclear power plants must submit

their annual reports (known as Radioactive Effluent Release Reports) by May 1 of each year for

the preceding year. The reports address both routine effluent releases and releases classified

as abnormal occurrences. Briefly, the information typically contained in annual reports

addresses the following:

C Regarding liquid and gaseous effluents, the reports contain descriptions of releases by

major categories of effluents (fission and activation products, dissolved and entrained

gases, radioiodines, particulates, tritium, and gross alpha activity), breakdown of

releases by radionuclides and radioactivity totals, effluent discharge rates, volumes of

liquid effluents released, and volumes of dilution water used during releases. 

C Regarding solid wastes, the reports contain descriptions of the types of wastes

(low-level waste and spent fuel), breakdown of radionuclides and radioactivity totals by

types of wastes, waste volumes, number of shipments, modes of transportation, and

destinations. Low-level waste is grouped in four generic categories as (1) spent resins,

filter sludge, evaporator bottoms, etc., (2) dry compressible waste, contaminated

equipment, etc., (3) irradiated components, control rods, etc., and (4) others. 

In practice, licensees use varying formats to present the information outlined in RG 1.21. In

some instances, reports present additional information, such as in differentiating the amounts of

solid waste shipped for burial directly from the plant versus that shipped by a waste processor

on behalf of the utility.

Until the early 1990s, the NRC published yearly reports on radiological effluents released by

nuclear power plants and estimated doses to the public. Brookhaven National Laboratory

compiled the information on effluents for the NRC. The annual compilations were published as

NUREG/CR-2907, “Radioactive Materials Released from Nuclear Power Plants,” ending in

December 1995 with Volume 14 for effluents released in 1993. The yearly reports contained

tabulations of gaseous and liquid effluent releases, volumes and activity levels of solid wastes 
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shipped for disposal, net electrical and thermal energy generation, and supporting data as

reported by licensees. The staff seldom used these reports and had few indications of

stakeholder interests in or the use of the reports. 

The staff envisions that annual reports on gaseous and liquid effluents and solid waste disposal

could serve multiple purposes. The NRC could use them to communicate information to the

public by comparing abnormal releases through unmonitored pathways with radioactivity levels

associated with monitored effluents and wastes shipped for disposal.

DISCUSSION:

If the Commission directed resumption of the development and distribution of annual reports,

the staff could pursue a number of alternatives to prepare the reports. These include:

C using NRC staff or contractor support to compile data characterizing liquid and gaseous

effluents and solid wastes reported by commercial nuclear power plant licensees, and

C revising the regulations to require licensees to submit the data using a secure website

and using software to compile and assess the data.

Under both approaches, the staff would plan to make the information accessible on the NRC

Web site. This approach builds on the wide use of the NRC Web site and provides an easier

method for processing and disseminating such information. This approach will result in more

comprehensive availability of data, provide the means to evaluate trends among power plants,

and offer the means to access information contained in annual effluent release reports via a

process that cannot be accomplished using reports published by conventional methods. 

The Environmental Protection Agency (EPA) Office of Drinking Water does not routinely

compile information on the presence of radioactivity in ground and surface water associated

with nuclear power plant operations. However, EPA has conducted studies on radioactivity in

water in support of specific rulemaking activities and projects, and it routinely monitors

radioactive effluents from Federal facilities as part of its mandate. 

For additional information on solid wastes, the staff has considered data compiled by other

organizations, including the Department of Energy (DOE), EPA, Low-Level Waste Compacts

and Unaffiliated States, and the Conference of Radiation Control Program Directors (CRCPD).

Based on a review of the type of information available from such sources and the merits of

using such information, the data extracted from annual effluent release reports submitted by

each nuclear power plant licensee, as opposed to using data from other sources, is preferred to

ensure that waste volumes and activity levels reported by the NRC are consistent with that

provided in annual effluent reports issued by licensees. 

However, such information may not be in agreement with data presented in DOE’s Manifest

Information Management System (MIMS) database, or that published by States and Low-Level

Waste Compacts. The information in the MIMS database reflects the use of the uniform
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1 NUREG/BR-0204, Revision 2, “Instructions for Completing NRC’s Uniform Low-Level Radioactive Waste

Manifest,” issued July 1998. The use of the uniform manifest is specified in 10 CFR 20.2006, “Transfer for Disposal

and Manifests.”

shipping manifest1 in describing low-level wastes shipped for disposal. Differences between

yearly waste volumes and radioactivity levels shipped by nuclear power plants and that reported

by disposal sites and DOE are associated with waste processing done by waste brokers and

processors on behalf of nuclear utilities. Waste processing methods that could result in

differences in waste volumes or radioactivity levels include decontamination, material

segregation, volume reduction, storage for radioactive decay, etc. As a result, the annual

effluent summary reports issued by the NRC would have to provide explanations for such

differences and refer to the MIMS database Web site for waste volumes and activity levels

actually reported by disposal sites. The MIMS database can be accessed via

http://mims.apps.em.doe.gov. 

I. Alternative A

Manual Compilation of Effluent and Waste Data

The staff proposes to use a modified version of a current program, based on MS Access, to

generate annual reports characterizing the amounts of radioactivity discharged in gaseous and

liquid effluents from commercial nuclear power plants, and solid waste shipped for disposal

from nuclear power plants. This database was developed by the staff to maintain information

extracted from annual effluent release reports submitted by nuclear power plants for all

operating power plants from 2001 to 2004. This information is available through the NRC’s

Radiation Exposure Information and Reporting System (REIRS) database, via

http://www.reirs.com/effluent. This approach would offer some savings and allow faster update

of the program. 

Modifications would include adding features for displaying trends over specific years, facilitating

the compilation of yearly reports, reformatting screen displays, and incorporating provisions for

the automated preparation of annual effluent reports. The program would be used by the staff

to generate annual summary reports, which would be uploaded on the NRC Web site as selfcontained read-only data files (e.g., as pdf or HTML). The annual reports posted on the NRC

Web site would not contain sensitive information and would not provide any links to any

databases. Finally, the staff could update the program as needed, such as by expanding query

functions or by providing more details on current contents. 

Resource Estimates - Alternative A

Approximately 1.0 FTE and $100K are needed in Fiscal Year (FY) 2007, and 0.05 FTE and

$40K each year thereafter for maintenance. The Commission has approved the necessary

funding from available midyear resources, as indicated in Staff Requirements COMSECY-06-

0017 - Results of the FY 2006 Midyear Resource Review. The funding will be made available

pending the approval of this proposal, as may be modified by the Commission. The staff FTE

for the initial year to cover the development of the of the program will be allocated from the 
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2 The database would be based on a production-grade database management system, such as MS SQL,

which will provide more robust security and scalability. The database would offer data and query functions beyond

that offered by a program using MS Access. The database would provide the means to conduct online searches and

queries, display trends over specific years, customize the production of yearly reports, offer graphic data displays,

and include provisions for the local printing of reports or saving them as electronic files. The staff would work with

the OIS Web Content Services Team (WCST) in identifying the requirements for putting static and dynamic pages of

the database on the NRC Web site, and defining page formats of the database’s annual report results using

approved NRC templates for public site content. A CPIC screening form will be submitted to initiate this effort, and

the staff will plan the development of the database with WCST. Once the CPIC screening form is approved, the staff

will proceed with the business case for the development effort. When the business case is approved, the staff will

move forward with the necessary documentation required for certification and accreditation before expending

resources.

following reactor licensing tasks: EE&GC: OpE Program Support, EE&GC: Event Review &

Follow-up, and General IT: Rx Licensing. There would be a moderate impact on the Operating

Experience Program by deferring planned infrastructure program improvements. These

improvements resulted from a recent program effectiveness review and include development of

guidance for event screening and Issues for Resolution (IFRs), maintenance of the Operating

Experience Gateway web site, and revising NUREG-1022 “Event Reporting Guidelines

10 CFR 50.72 and 50.73.” The FTE for the following years will be budgeted, starting in FY

2008, via the PBPM process. 

 

II. Alternative B - Web-based System

Development of an Effluent and Solid Waste Database

This alternative proposes the development of a web-based database to generate annual reports

characterizing the amounts of radioactivity discharged in gaseous and liquid effluents from

commercial nuclear power plants, and solid waste shipped for disposal from nuclear power

plants. This alternative would use the same source of information on effluents and solid waste

as discussed earlier. The database would be accessible via a secure direct link on the NRC

Web site. Licensees could be required, through a rulemaking, to submit information via a

secure web page, similar to the secure database used for Category 1 to 3 radioactive sources,

as described in the National Source Tracking System. Finally, the staff could update the

database as needed, such as by expanding query functions, providing more details on current

subjects, or accommodating supplemental data. In developing the database, the staff would

follow:

(1) the Capital Planning and Investment Control Process (CPIC) using the requirements of

Management Directive 2.2, "Capital Planning and Investment Control."

(2) Project Management Methodology (PMM) using the guidance on the PMM website

(http://www.internal.nrc.gov/pmm) and requirements of Draft Management Directive 2.8,

"Project Management Methodology."

(3) the requirements of Management Directive 2.1, "Information Technology Architecture."

This approach will ensure that the development of the database is consistent with the CPIC

process2

 and NRC Federal Information Security and Management Act (FISMA) of 2002.

However, this approach would require a longer developmental period to complete the design,
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assessment, approach, procurement, and development of the database. The staff would move

forward with the necessary documentation required for certification and accreditation before

expending resources on the development effort. 

Resource Estimates - Alternative B

At this time, only preliminary cost estimates are available because the cost for the development

of the database would be driven by a rulemaking and business case requirements, to include

security, established through the CPIC process. For these reasons, the staff has not yet

developed an independent government cost estimate. If the staff begins work on the

development of alternative B in FY 2007, the program will be budgeted through the add/shed

process. The FTE for the following years will be budgeted, starting in FY 2008, via the PBPM

process. The following table provides a preliminary estimate of the costs associated with

Alternative B. 

Timeframe Type of Report/Activity

Level of Effort/Funding

Staff FTE

and

Funding

Contractor 

Support

Rulemaking, 

2-year effort

Development of regulations and

regulatory guidance

2.5

($50K)

n/a

Initial year Gaseous and liquid effluents, and

solid wastes 

4.0 $700K(*)

Subsequent years Gaseous and liquid effluents, and

solid wastes

0.1/yr $100K/yr

Three-year intervals FISMA re-certification of database 0.1 $100K

(*) Estimate assumes $500K for the purchase of software and modifications to address data

processing functions, and $200K for the initial FISMA security certification. 

SCHEDULE:

If the Commission decides to proceed with the development of annual reports, the staff

envisions that the initiation of the work could start in FY 2007, with the first annual report being

available in late FY 2007 under Alternative A. 

For Alternative B, the schedule is difficult to define given that the development of this alternative

would be dependent on the outcome of the rulemaking to revise reporting requirements and the

CPIC process and FISMA requirements attendant to the business case review. It is expected

that the development effort for the database would be contracted out, thereby, requiring more

time for the procurement process and selection of a qualified vendor. Given these

uncertainties, it is estimated that the rulemaking effort would take about 2 years to complete,

and another year would be needed to obtain the necessary documentation required for the

certification and accreditation of the database. Consequently, no definitive schedule is provided

at this time.
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COORDINATION:

The Office of the General Counsel has reviewed this Commission paper and has no legal

objections. The Office of Information Services has reviewed this Commission paper and has no

objections. The Chief Financial Officer has reviewed this package and agrees with the

preliminary resource estimates, given the funding set-aside provisions of the Staff

Requirements Memorandum for the FY 2006 Midyear Resource Review (COMSECY-06-0017). 

RESOURCES:

The staff’s recommendation is to not issue annual reports on gaseous, liquid, and solid

effluents. No resources are associated with the recommended option.

RECOMMENDATIONS:

This paper presents a proposal for preparing annual reports of liquid and gaseous effluents and

disposal of solid wastes associated with the operation of commercial nuclear power plants. 

The staff makes the following recommendations:

(1) At this time, the staff does not recommend proceeding with the development of a

process to prepare annual reports on effluents and solid waste generated by

commercial nuclear power plants. 

(2) If the Commission decides to proceed with the development of annual reports, the staff

recommends Alternative A as the preferred approach. NRR would implement and

manage the compilation of data on effluents and solid waste, generate annual effluent

reports, and post annual reports on the NRC Web site.

/RA/

Luis A. Reyes

Executive Director

 for Operations
The Commissioners -7-

COORDINATION:

The Office of the General Counsel has reviewed this Commission paper and has no legal

objections. The Office of Information Services has reviewed this Commission paper and has no

objections. The Chief Financial Officer has reviewed this package and agrees with the

preliminary resource estimates, given the funding set-aside provisions of the Staff

Requirements Memorandum for the FY 2006 Midyear Resource Review (COMSECY-06-0017). 

RESOURCES:

The staff’s recommendation is to not issue annual reports on gaseous, liquid, and solid

effluents. No resources are associated with the recommended option.

RECOMMENDATIONS:

This paper presents a proposal for preparing annual reports of liquid and gaseous effluents and

disposal of solid wastes associated with the operation of commercial nuclear power plants. 

The staff makes the following recommendations:

(1) At this time, the staff does not recommend proceeding with the development of a

process to prepare annual reports on effluents and solid waste generated by

commercial nuclear power plants. 

(2) If the Commission decides to proceed with the development of annual reports, the staff

recommends Alternative A as the preferred approach. NRR would implement and

manage the compilation of data on effluents and solid waste, generate annual effluent

reports, and post annual reports on the NRC Web site.

/RA/

Luis A. Reyes

Executive Director

 for Operations

W 200600233

ADAMS ACCESSION NUMBER: ML062140023 *via e-mail

OFFICE IHPB:DIRS Tech Editor BC:DIRS D:DIRS PMAS

NAME JDehmel HChang* TFrye MJCase JDavis

DATE 08/08/2006 08/07/2006 08/08/2006 08/08/2006 9/21/06

OFFICE OIS OGC CFO OD:NRR EDO

NAME JGolder* JMoore LBarnett* JDyer LReyes

DATE 09/12/2006 09/12/2006 09/27/2006 09/13/2006 10/17/2006

OFFICIAL RECORD COPY