NRC Decommissioning Lessons Learned

Search Criteria: Year: 2002 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2002-01 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Licensees are encouraged to use the data quality objectives (DQO) process in planning and designing the final stDiscussion: In developing the final survey design, the licensee needs to identify all appropriate data quality objectives (DQ

designing the final status survey plan. The process of identifying the applicable DQOs ensures that the survesurvey results, and data evaluation are of sufficient quality, quantity, and robustness to support the decision o

criteria have been met using statistical tests.

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Lesson ID: 2002-02 Facility Type: Reactors, Material Facilities Stage: Decommissioning WorkBenefits: Facilitates Decommissioning WorkSubject: In-process inspections are more than one-time confirmatory surveysDiscussion: In-process inspections are more efficient than one-time confirmatory surveys. In one case, the confirmatory s

after the licensee had completed most of the final survey and many of the staff supporting the final survey weaddress questions and issues that were discovered while conducting the confirmatory survey. Simply put, the was conducted too late in the process. The in-process approach has allowed the licensee and NRC to take smeasurements, compare instrument readings and sensitivity, and address survey issues early in the process 

of the process. The in-process approach has resulted in significant savings in cost, assured a more accurate licensee in maintaining its release schedule.

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Monday, September 10, 2007 
Search Criteria: Year: 2002 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2002-03 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning Licensing, Facilitates Decommissioning WorkSubject: Continued communications between NRC staff and the licensee during the staff's review is encouraged to help th

advantage of the inherent flexibility in NUREG-1575 and NUREG-1757

Discussion: Continued communications between NRC staff and the licensee during the staff's review is to help ensure tha

take full advantage of the inherent flexibility in NUREG-1575, "Multi-Agency Radiation Survey and Site Invest(MARSSIM) and NUREG-1757, "Consolidated Decommissioning Guidance." In reviewing license termination decommissioning plans, the staff has observed that licensees are often boxing their approaches into rigid stru

thereby locking out any operational flexibility in implementing MARSSIM and negating cost savings. This apppart, the interpretation of NRC guidance as regulatory requirements. However, it is possible to meet NRC reqinstilling operational flexibility into the overall decommissioning process.

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Lesson ID: 2002-04 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Licensees are encouraged to submit assumptions and justification for parameters used in developing site-specific 

guideline levels (DCGLs) and application of those DCGLs

Discussion: The derivation of DCGLs should include the assumptions and justification for parameters used, and justificati

DCGLs will be applied to various survey units on site. DCGLs will be captured by license condition as part of plan approval process, and will require NRC approval for changes to the approved DCGLs. During derivation should consider: a) area factors, volumetric contamination, model results, etc.

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Monday, September 10, 2007 
Search Criteria: Year: 2002 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2002-05 Facility Type: Reactors Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Licensees should establish a clear relationship between the planned decommissioning activities and the associat

estimate.

Discussion: There needs to be a clear relationship between the planned decommissioning activities and the associated co

license termination stage, the Commission must make decisions on the proposed actions described in the liceThe Commission typically considers: 1) the licensee's plan for assuring sufficient funds will be available for fi

radiation release criteria for license termination; and 3) the adequacy of the final survey required to verify that have been met. 10 CFR 50.82(a)(9)(ii)(F) requires the licensee to provide, in part, an updated site-specific deestimate. If little decommissioning has been completed, and inflation and disposal costs have not changed, trequired by 10 CFR 50.82(a)(8)(iii) may be acceptable.

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Lesson ID: 2002-06 Facility Type: Reactors, Material Facilities Stage: OperationsBenefits: Facilitates Decommissioning WorkSubject: Old records may be inadequate or inaccurate for the purpose of developing either the historical site assessment (

characterization.

Discussion: Old records may be inadequate or inaccurate for the purpose of developing either the HSA or site characteriz

suggests that these records not be relied on as the sole source of information for the HSA or site characterizacurrent and former staff and contractors play an essential role in formulating the HSA. Experience has shown 

results of operational surveys and post-shutdown scoping surveys have been submitted as substitutes for cha

To achieve the purpose of the HSA, a complete history of the residual contamination is needed.

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Monday, September 10, 2007 
Search Criteria: Year: 2002 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2002-07 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Licensees should address the non-radiological impacts of the proposed action in the environmental report when s

to the NRC requesting approval of a decommissioning plan or license termination plan

Discussion: Environmental reports need to address non-radiological impacts of the proposed action. In accordance with t

National Environmental Policy Act (Public Law 91-190), all agencies of the Federal Government are required environmental impact of any major Federal action that may significantly affect the quality of the human enviro

NRC's approval of either a decommissioning plan (DP) or a license termination plan (LTP) , NRC is required tapproval is a Federal action. Therefore, the impacts on the human environment associated with NRC approvLTP must be assessed. Further, this assessment must include both radiological and non-radiological impactslicensees normally provide sufficient information for the staff to assess the radiological impacts on the human licensees have not provided sufficient information related to current site-specific non-radiological impacts.

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Lesson ID: 2002-08 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Licensees should submit the decommissioning plan (DP) or license termination plan (LTP) only after sufficient site 

occurred.

Discussion: The NRC staff recommends that submittal of the DP or LTP occur only after sufficient site characterization ha

suggests that the LTP or DP provide sufficient information demonstrating the characterization of the radiologi

structures, facilities, surface and subsurface soils, and groundwater. The staff has observed that some LTPs submitted with incomplete or inadequate characterizations of radiological conditions. A review of such LTPs the lack of information makes it difficult to agree with the rationale justifying the proposed classification of surv

References: Regulatory Issue Summary 2002-02: Lessons Learned Related to Recently Submitted Decommissioning Pla

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2002/ri02002.html

Monday, September 10, 2007