NRC Decommissioning Lessons Learned

Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-01 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning WorkSubject: Benefits of early coordination with all regulatory agencies and waste disposal facilities when considering waste diDiscussion: As part of the planning process, it is important that licensees coordinate early with all regulatory agencies (i.e

regarding waste disposal options. If on-site disposal is being considered an option for a project, early consulta

the approach with all regulatory agencies can help identify concerns and alternatives for waste disposal. For o

important to coordinate early with the receiving facility and ensure that applicable permits will allow such dispthe permit is needed to allow the disposal, this should be discussed and coordinated early with the receiving fagencies. Licensees should also obtain written certification from the disposal facility being considered in a debefore submitting a formal request to the NRC for approval of waste disposal under 10 CFR 20.2002. This is dose assessment that the NRC staff will conduct during the review of a licensee's request is specific to the diaddition, this written certification can be useful to licensees in two ways:• The certification serves as written evidence that the waste disposal facility being considered by the license

and

• It avoids the need to reconsider other disposal facilities at a later stage in a decommissioning project, thus 

licensee staff time needed to find an alternate disposal site and reducing delays in decommissioning activi

These advantages can result in time and money savings for both the NRC and licensee staff.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-02 Facility Type: Reactors, Material Facilities Stage: Decommissioning WorkBenefits: Facilitates Decommissioning LicensingSubject: Benefits of using a "split sample" approach during the analysis of radiological samples to support a decision or co

decommissioning activities.

Discussion: Even though it is not required, splitting samples to conduct independent laboratory analyses by the NRC staff 

beneficial during the early stages of decommissioning activities. One example is the Pathfinder site in South Dused historical data from the site, which included some sampling data, to conclude that there were no impacts radiological operations at the site. Concurrent with NRC's review of the decommissioning plan (DP) for the sittaken from some onsite wells and each liquid sample was split between the licensee and the NRC staff. Indepconducted and the laboratory results were attached to the NRC's inspection report. The results were also refeenvironmental assessment (EA). This approach resulted in several benefits to the licensee and the NRC staff• It helped the NRC staff verify the licensee's conclusion (i.e, no groundwater contamination) that was based the facility;• Laboratory results from independent sources provide quality assurance for results that are obtained from on• It facilitated the review of the draft EA by the Department of Environmental and Natural Resources in Sout

of the split groundwater samples were available prior to the completion of the EA, the groundwater sampling incorporated into the draft EA and reviewed by the state.

This approach helped the licensee to streamline the final status survey process by eliminating groundwater frconsideration, thus avoiding unnecessary expenses and staff resources by the licensee.

References: Safety Evaluation Report for License Amendment to Authorize Decommissioning of Xcel Energy's Pathfinder 

South Dakota.http://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML051430520

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-03 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning WorkSubject: Benefits of conducting a comprehensive characterization of the site before starting decommissioning activities.Discussion: As discussed in the Regulatory Issue Summary 2002-002, the NRC staff noted in some submittals that chara

plant structures, systems, and components; surface and subsurface soils; and groundwater were, at times, instill occurring in some submittals reviewed by the NRC staff. A comprehensive site characterization is a key sdecommissioning project. Adequate characterization before commencing decommissioning activities helps licquantify the amount and extent of contamination that needs to be remediated. At a minimum, the site charact

sufficient information to allow the NRC to determine the extent and range of expected radioactive contaminatdecommissioning site. The purpose of the site characterization is to define relevant features of the soil, waterto assess risk and develop adequate plans to complete decommissioning. By ensuring that enough reliable ccollected during the planning of the project, licensees can obtain several benefits including:

• Early identification of potential issues that could complicate or delay cleanup activities (e.g., unexpected sugroundwater contamination), and take any necessary actions;• It reduces the likelihood of revising plans and documents already approved by the NRC; and• Aids in planning and justifying the final status survey.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-04 Facility Type: Reactors, Material Facilities Stage: OperationsBenefits: Facilitates Decommissioning LicensingSubject: Licensees should define, describe and document any new processes or modifications to existing processes or fac

files.

Discussion: Whenever licensees want to add or modify facilities or processes at an operating site that involves radioactive 

describe these changes, the physical boundaries of the processes or operations, and the potential impacts to safety, or the environment that could result from these changes in detail. Licensees should document and rev

before submitting the license amendment package(s) to the NRC for review and approval. Any pertinent inforincluded in the license amendment. For Part 50 licensees, if these changes can be addressed under the 10 Cthe licensee chooses to use it, the licensee should document such changes in their 10 CFR 50.59 files. Havin

provide several benefits to licensees, including:

• Ensuring that physical boundaries of the licensed site are clearly defined so that when it is time to decomm

be any question as to what area the licensee is responsible to address. Physical boundaries of operations mathe Environmental Assessment that will be performed by NRC as part of the license amendment process. Phoperations may also impact issues related to dose compliance for decommissioning, especially if the licensee 

site release or if parts of the site are being cleaned up under other programs such as the U.S. Army Corps of Utilized Sites Remedial Action Program or the West Valley Demonstration Project.

• Assisting the licensee in planning any additional data gathering for baseline purposes or during the scoping decommissioning to describe the radiological status of the site.• Streamlining the review of the DP or License Termination Plan (LTP).

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-05 Facility Type: Reactors, Material Facilities Stage: OperationsBenefits: Facilitates Decommissioning LicensingSubject: Licensees should define, describe and update any program plan documents required by their licenses before sub

approval. The information should be included in the license amendment request.

Discussion: Information related to a licensee's program that is required by an NRC license, including updates to such prog

included in the license amendment request(s), or submitted in parallel as a separate request for a license am

additional or supporting information, such as procedures relevant to these program plans, should also be updlicense amendment request. This may result in more timely implementation of the changes after the NRC lice

the approval of the DP or LTP can not be accomplished without NRC review and approval of the program plalicense to ensure that they are consistent and appropriate for the proposed decommissioning activities, this a

streamline the review of the 

DP or LTP.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-06 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Benefits of demonstrating the appropriateness of ratios used to calculate Derived Concentration Guideline Levels 

survey.

Discussion: If a licensee proposes to use ratios for calculations of Derived Concentration Guideline Levels (DCGLs), the u

demonstrate that these ratios are still appropriate at the time of final status survey will be needed. Even when when the DP is submitted, NRC will ask the licensee to verify that these ratios are still appropriate to support 

supporting data is not available for this purpose at the time the DP is submitted, the licensee is taking a channot be appropriate and NRC may require verification of such assumptions before it will terminate the license orequire, as part of the DP approval, a license condition requiring that the licensee verify these ratios before ac

status survey reports. Licensees that want to calculate the ratio of radionuclides for derivation of DCGLs base

before decommissioning activities are completed will be required to verify that these ratios are still applicable 

status survey. If these ratios are not applicable, licensees may be required to conduct additional decommissiostatus survey is completed and determine if related documentation must be submitted to the NRC for review 

Understanding this approach can avoid the need for additional resources and expenses for both the licensee 

during DP review and/or at a later stage in a decommissioning project, thus resulting in savings and avoiding 

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-07 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Benefits from understanding the differences between decommissioning in stages and phased decommissioning. Discussion: A clear understanding of the differences between submitting a DP or LTP in stages and phased decommissio

plan and conduct decommissioning activities in a more streamlined manner. Submitting a DP or LTP in stage

nature and should be coordinated with the NRC staff. Unfortunately the term "phases" has been used interch"stages" and this has led to confusion. Each submission of a portion of a DP or LTP must be approved by NRunderstood that these submissions will not allow the licensee to implement decommissioning in stages becau

incorporate the submissions into the license until all the DP work is completed. Under these circumstances, oreview would be conducted after all portions of the DP or LTP are submitted. It is generally not desirable to sustages (i.e., piecemeal approach) for inclusion into the license. Each submission will require a concurrent oppIn addition, NRC will have to review each submission and then the entire DP or LTP to determine if the plan iTherefore, this practice is discouraged.

On the other hand, "phased decommissioning" means dividing all the decommissioning work into separate phand on-site remediation activities. In order for phased decommissioning to be approved by NRC, careful conssegmentation issues under the National Environmental Policy Act (NEPA) and potential dose modeling issueNRC early in process. Understanding these differences early in the process can result in many advantages to including:• Ensuring an adequate approach to address NEPA requirements, which is necessary for amending the lice

decommissioning activities;

• Reducing the likelihood of misinterpretation of phased decommissioning versus submitting a DP in stages; • Reducing the likelihood of rejections and resubmittals of licensee's documents to support decommissioning These advantages can reduce significant delays in the licensing process and can help licensees save time an

having to redo work.

Note: With regard to Environmental Impact Statements (EISs), regulations from the Council of Environmental 1508.25(a)) state that an agency should analyze "connected actions" and "cumulative actions" in one EIS. An analyze "similar actions" in one EIS when that is the best way to adequately assess the combined impacts of 

reasonable alternatives. "Connected actions" are those that automatically trigger other actions that may requiproceed unless other actions are taken previously or simultaneously, or are interdependent parts of a larger a
the larger action for justification. "Cumulative actions" are those that, when viewed with other actions propose

cumulatively significant impacts and, therefore, should be discussed in the same EIS. "Similar actions" are thwith other reasonably foreseeable or proposed agency actions, have similarities that provide a basis for evaluenvironmental impacts together, such as common timing or geography. NRC has taken the position of analyz

with this regulation. (See 40 CFR 1508.25(a)).

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-08 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Licensees should work with NRC staff to complete the checklist in NUREG-1757, Volume 1, Appendix D, and als

before formally submitting a license amendment request for decommissioning.

Discussion: Licensees and NRC staff should work together to develop information for inclusion in the DP/LTP using the c

1757, Volume 1, Appendix D, and review the guidance in NUREG-1748 for preparing an Environmental Repopreparation of a license amendment request for decommissioning activities. Some licensees have not considpart of the Appendix D checklist. In addition, it is recommended that licensees take time to review Section XIc

Program," of the Appendix D checklist carefully for decommissioning activities before submitting its license amdecommissioning. When sites are no longer in production or no longer conducting the same operations as themonitoring may shift from point source monitoring to fugitive emission monitoring. By understanding the guidaand NUREG-1748, licensees should be able to provide NRC with the information required to have a DP/LTP technical review. Ultimately, this will help to reduce the review process by the NRC staff, thus resulting in cos

licensee.

References: NUREG-1757: Consolidated Decommissioning Guidance, Volume 1, Revision 1

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1757/v1/NUREG-1748: Environmental Review Guidance for Licensing Actions Associated with NMSS Programshttp://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1748/

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-09 Facility Type: Reactors, Material Facilities Stage: Decommissioning Planning, Decommissioning Benefits: Facilitates Decommissioning LicensingSubject: Use of NRC's electronic submittal system is voluntary, but it can save time and money to licensees and members Discussion: Licensees and members of the public are encouraged to take advantage of the NRC's electronic submittal sy

Information Exchange (EIE). This feature can help reduce the time and expenses incurred by making hard cosubmitted for NRC approval, particularly those that are long. Electronic submittal is also beneficial if a decomneeds to be revised or supplemented with additional information. Licensees, vendors, and members of the pu

the EIE. The EIE is designed to ensure that electronic documents can be transmitted via the Internet in a secmanner. Submittals such as those that are required to be submitted under oath or affirmation may be safely tsystem. However, applicants, licensees, vendors, etc. must designate individuals who have the responsibility or sending documents to the NRC in compliance with regulatory requirements. This can only be done through process. Some licensees have mistakenly used their internally approved electronic signature systems (i.e., Eelectronic signature systems are not recognized by NRC. Only individuals on an Authorized Certificate List (Adocuments electronically to the NRC. Each licensee prepares an ACL of the names and e-mail addresses of submit documents electronically to the NRC. All documents submitted or transmitted electronically shall be sisignature software. The digital signature provides for the authentication, certification, and security of documenelectronically.

References: Electronic Submittals - Electronic Information Exchange

http://www.nrc.gov/site-help/e-submittals.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-10 Facility Type: Reactors, Material Facilities Stage: OperationsBenefits: Facilitates Decommissioning LicensingSubject: Licensees should revisit their technical basis documents for specific programs used during the operation of their f

them, as appropriate, before submitting license amendment requests for decommissioning activities.

Discussion: Licensees that have their technical basis documents for operational facilities programs, such as environmenta

control, materials control and accounting, etc., need to revisit and update, as appropriate, these documents b

conducting any decommissioning activities. Licensees should review their technical basis documents prior to ensure that:

• Programs that were in place during the operation of the facility are still applicable and representative of the 

conducted at the site (i.e., building demolition, soil excavation, etc.);

• Licensees' documents comply with applicable regulations to decommissioning; and• Routine environmental monitoring programs that were executed during the operation of the facility are revi

necessary, to reflect future decommissioning activities.

These actions may result in a faster DP review and approval, thus saving money for licensees.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-11 Facility Type: Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Adequate supporting documentation for decommissioning cost estimates should be submitted to facilitate detailed Discussion: Materials facilities have not always submitted adequate information for the NRC staff to conduct a detailed re

estimate for decommissioning activities at these facilities. The acceptable content and format of all required d

specific decommissioning cost estimates can be found in Appendix A.3 of NUREG-1757, Volume 3. Failure to documentation in an acceptable format to the staff has resulted in additional RAIs and more NRC staff time nadequacy of the decommissioning cost estimates, thus resulting in delays, more time being charged to the lic

costs.

References: NUREG-1757: Consolidated Decommissioning Guidance, Volume 3

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1757/v3/

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-12 Facility Type: Reactors, Material Facilities Stage: Design, OperationsBenefits: Facilitates Decommissioning WorkSubject: The Radioactivity and Effluents Monitoring Program (REMP) may not be sufficient to characterize subsurface con

sites.

Discussion: The Regulatory Information Summary (RIS) 2002-002 stated that the data derived from REMP tend to be insu

NRC staff to fully understand the types and the movement of radioactive material contamination in groundwatas the extent of this contamination. In addition to REMP, mechanisms to monitor the existence and extent of contamination at a site are needed. REMP is designed to protect human health at the site boundary, not to de

site conditions. Because there is not a characterization and monitoring plan specifically for on-site conditions, these reasons has resulted in:

• Insufficient subsurface hydro-geologic characterization data;• Insufficient data on the amount of existing on-site groundwater contamination; and• Inaccurate estimates of the amount of material that needs to be disposed of in order to address groundwatThese conditions could result in off-site migration of radionuclides, delays in decommissioning and increased disposal costs that exceed the decommissioning fund.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-13 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Benefits from early coordination and agreement between NRC and licensees on the format and content of any re

conduct decommissioning.

Discussion: RIS 2002-002 stressed the importance of early coordination and agreement between the NRC staff and licen

content of any report or plan required to conduct decommissioning. Recent experience has shown that this caadvantages to the NRC staff and licensees. This lesson could be of special interest to power reactor licensee

approval before conducting certain decontamination activities. A good example is the Trojan site in Rainier, Oreactor licensee to have its license under 10 CFR Part 50 terminated under the License Termination Rule. Thand coordinated the content and format of their final status survey reports with the NRC staff prior to their devapproach resulted in several advantages to the NRC staff and the licensee:

Advantages to the NRC staff:• Reports were concise, technically accurate, and easy to read.• Reports were administratively correct, meaning: i. reviews and approvals were complete, signed, and dated; ii. survey equipment records were complete; and iii. training and qualification records were complete.Advantages to the licensee:• On the average, NRC staff was able to review supporting documentation for final status surveys in 30 minu• NRC staff reviewed and approved final status survey report in 16 months; and• Less staff time required by the NRC staff translated into lower costs to the licensee.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-14 Facility Type: Reactors, Material Facilities Stage: Decommissioning Planning, Decommissioning Benefits: Facilitates Decommissioning WorkSubject: Benefits of implementing a good quality control (QC)/quality assurance (QA) program throughout a decommissionDiscussion: Licensees that implement a good QC/QA program throughout the entire decommissioning of their facilities ca

benefits that can truncate the schedule and reduce costs. An effective QC/QA program can help to:• Self-identify problems or deficiencies during decommissioning and implement corrective actions before rouare conducted;• Avoid significant delays whenever technical or regulatory issues are identified;• Ensure that calculations and assumptions are accurate and justifiable;• Ensure quality submittals, thus reducing requests for additional information (RAIs) and delays; and• Provide confidence that the final status survey reports are accurate.These benefits could result in significant savings for licensees. Advantages to the NRC Staff:• Report reviews are facilitated due to completeness, conciseness, regulatory compliance, technical accurac

submittals.

Advantages to the licensee:• Routine QA/QC audits and surveillance can provide independent feedback to senior management on the psafety, work integration, schedule, field performance and documentation, during the deactivation, dismantling

final survey phases of the decommissioning project.

• QA/QC audits and surveillance can assist licensees self-identify deficiencies and implement corrective bef

occur.

• QA/QC audits and surveillance of radiological surveys during decontamination and remediation activities eradioactivity levels and compliance with decommissioning plan/license termination plan (DP/LTP) requiremen• QC surveillance that includes independent random sampling and measurements ensure that final status su
with DP/LTP requirements, are well documented, and that confirmatory surveys performed by the NRC will de

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-15 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning WorkSubject: Benefits of using realistic scenarios to demonstrate compliance with unrestricted release requirements under the 

Rule.

Discussion: Two good examples of the use of realistic scenarios are the Nuclear Fuel Services (NFS) site in Erwin, TN an

(Fansteel) site in Muskogee, OK. The staff from the NFS site used a combination of two realistic scenarios to 

specific DCGLs. The licensee demonstrated that the shallow, contaminated groundwater would not be used asource in any case. The licensee then demonstrated that the most likely use of the site at license termination 

site. It also acknowledged that there was considerable suburban development in the area. The licensee perfofor the facility using an industrial scenario, as well as a suburban resident scenario. The licensee then chose conservative) DCGL value of the two scenarios for each specific radionuclide identified on the site. These valthan the calculated DCGLs for the default residential farmer scenario.

At the Fansteel site, the licensee proposed an industrial land use scenario for dose estimation purposes. The 

north by the Port of Muskogee and industrial operations on the east by the Arkansas River, on the south by Uthe west by the Muskogee Turnpike. In addition, there is a coal-fired power plant across the Arkansas River. Tconfirmed future development plans in the areas surrounding the site, including planned expansion of the Po

land currently owned by FMRI, and reviewed the proposed scenario and dose analysis. The NRC staff concluland use scenario was appropriate for dose calculations. 

These cases studies are examples of the application of NRC's realistic scenario approach to analyze reasonauses for the property and still demonstrate compliance with the unrestricted release requirements in 10 CFR 

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-16 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning LicensingSubject: Eliminating exposure pathways during the use of realistic scenarios in a dose assessment at a site requires a tec

justification.

Discussion: Many times, the use of a realistic scenario in a dose calculation involves eliminating one or more exposure pa

reasonably expected to receive the greatest dose from radiation. As part of this approach, the licensee should 

and adequate justification with enough details to allow the NRC staff to conduct an independent review and cjustification. Licensees should meet with NRC staff to discuss the scenario and the justification before develo

will be acceptable. Failure to provide an adequate justification with strong supporting information can result in 

assessment, ultimately leading to extensive RAIs, or even rejection of the submittal. This will result in delays activities, more staff time necessary to review the dose assessment, and more time being charged to the lice

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-17 Facility Type: Reactors, Material Facilities Stage: Design, OperationsBenefits: Facilitates Decommissioning WorkSubject: Adequate characterization of the subsurface of the site during the design and construction phase of a nuclear fac

during the operation and decommissioning of the facility.

Discussion: Adequate characterization of the subsurface (i.e., geology and hydrology) of the area where a nuclear facility 

several advantages during the operation and decommissioning of the facility. Obtaining enough reliable chara

subsurface before building a facility:

• Will assist in determining how contamination resulting from daily operation of the facility will migrate throug

groundwater table, and how contamination could be contained.

• Will assist in decommissioning planning, thus reducing the possibility of dealing with unexpected contamindecommissioning activities have commenced.In the long run, these actions can reduce the likelihood of significant delays during decommissioning activities

money for licensees.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-18 Facility Type: Reactors, Material Facilities Stage: Decommissioning PlanningBenefits: Facilitates Decommissioning WorkSubject: Benefits from early coordination with the United States Fish and Wildlife Services (USFWS) and the State Historic 

(SHPO) during decommissioning planning.

Discussion: Early coordination with USFWS and SHPO during planning of decommissioning activities could be beneficial 

7 of the Endangered Species Act of 1973, and Section 106 of the National Historic Preservation Act of 1966 rto coordinate with USFWS and SHPO to determine if there are any endangered species or objects of archaeo

be affected by a decommissioning projects. Even though these consultations are not required for licensees, ecomments from these agencies is strongly recommended. Factoring their comments into the process will help species or objects of archaeological value before commencing actual decommissioning work, and planned deactivities accordingly, thus reducing decommissioning challenges at a later stage of the project. This could tracost savings for licensees in the long run.

References: Contact Us About Decommissioning of Nuclear Facilities

http://www.nrc.gov/about-nrc/regulatory/decommissioning/contactus.html

Lesson ID: 2006-19 Facility Type: Reactors, Material Facilities Stage: DesignBenefits: Facilitates Decommissioning Work, Minimizes ContaminationSubject: Examples of design features that licensees should incorporate to minimize contamination of the environment and 

decommissioning of a facility.

Discussion: Licensees should incorporate design features that ensure that exposures are As Low As Reasonably Achieva

maintenance, component replacement, surveillance, and remote sampling near areas that typically are high-rcontaminated areas. Examples that might apply to the reactor vessel or steam generator area could include: 

platforms prior to operations to help reduce the amount of time needed to reach high-radiation and/or highly cii) install shield walls. Other design features could include: i) planned removal pathways for tanks and vesse

walls, collapsible systems, etc.), ii) permanent coatings for porous materials isolation of radioactive waste sys

sensors for moisture, tank levels, etc., and iv) closed-circuit television.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-20 Facility Type: Reactors, Material Facilities Stage: DesignBenefits: Facilitates Decommissioning Work, Minimizes ContaminationSubject: The removal of large equipments should be consider when designing enclosures to place them in a nuclear facilitDiscussion: When designing enclosures for large pieces of equipment (e.g., steam generators, large piping, tanks, etc.), t

determine how these pieces will be removed for replacement or permanently removed at the time of decommshould evaluate: i) size/space clearances, ii) installation of removal roofs/walls, iii) installation of lifting lugs, iv

v) shearable nuts and bolts, vi) quick-disconnect components, etc.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Lesson ID: 2006-21 Facility Type: Reactors, Material Facilities Stage: Operations, Decommissioning PlanningBenefits: Facilitates Decommissioning Licensing, Facilitates Decommissioning WorkSubject: Benefits from using adequate onsite measurement capabilities during decommissioning planning.Discussion: During decommissioning planning, licensees should establish adequate measurement capabilities at the facil

radiological laboratories, mobile units, etc.). This approach could increase efficiency by ensuring early in the d

process that site characterization measurements to establish radiological conditions in the field or onsite are a

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-22 Facility Type: Reactors, Material Facilities Stage: Operations, Decommissioning WorkBenefits: Minimizes Contamination, Minimizes Generation of WasteSubject: Not ApplicableDiscussion: Licensees should establish onsite decontamination facilities and/or waste segregation facilities in order to ma

radioactive material/waste.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Lesson ID: 2006-23 Facility Type: Reactors, Material Facilities Stage: OperationsBenefits: Facilitates Decommissioning WorkSubject: Benefits from establishing a program to ensure adequate and complete documentation of corporate knowledge aDiscussion: Licensees should establish a program to ensure adequate and complete documentation of corporate knowled

events, beyond those required by NRC in 10 CFR 50.75(g). This program can assist licensees in preparing a assessment of a nuclear facility. An adequate historical assessment can help to save time and effort during dplanning.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-24 Facility Type: Reactors, Material Facilities Stage: DesignBenefits: Facilitates Decommissioning WorkSubject: Benefits from minimizing the use of embedded piping in nuclear facilitiesDiscussion: Plant designs should minimize the use of embedded pipes, to the extent practicable, consistent with maintain

low as is reasonably achievable during operations and decommissioning. Embedded pipes, especially those diameter (less than 6 inches), could complicate decommissioning activities because they can be very difficult 

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Lesson ID: 2006-25 Facility Type: Reactors, Material Facilities Stage: Design, Operations, Decommissioning WorkBenefits: Minimizes Contamination, Facilitates Decommissioning WorkSubject: Licensees should make reasonable efforts to prevent, detect, and control minor leaks of radioactive materials ove

time.

Discussion: Minor leaks over long periods of time can contribute to significant contamination in soil and groundwater that 

costs for remediation. Tanks (e.g., radioactive waste storage tanks, chemical storage tanks, etc.), spent fuel p

process/transfer lines should be designed to resist corrosion and minimize leaks. They should be provided wimonitoring capabilities. For example, the detection system of a spent fuelpool should be capable of detecting pool. This system should have the ability to be flushed with clean water to remove small quantities of borated 

boric acid solids resulting from minor leaks from the spent fuel pool wall and floor welds, bellows to transfer cgates areas. In addition, an operational program should be implemented throughout the life of the facility to many leaks.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensing

http://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-26 Facility Type: Reactors, Material Facilities Stage: DesignBenefits: Minimizes ContaminationSubject: Benefits of having a quality assurance inspection program for grouted areas in a nuclear facility.Discussion: Licensees should develop a quality assurance inspection program that ensures that grouted areas have no c

allow fluids to bypass the floor drain and move into unmonitored areas beneath the floors and foundations. Cconnections for floor drains should be constructed such that leaks and spills on the floor will be collected in th

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Lesson ID: 2006-27 Facility Type: Reactors, Material Facilities Stage: Design, OperationsBenefits: Minimizes Contamination, Minimizes Generation of WasteSubject: Not ApplicableDiscussion: Licensees should develop a floor/wall expansion joint inspection procedure so that floor and wall joints are ins

ensure that spills and leaks on the floors do not enter unmonitored areas beneath the floors and foundations.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Monday, September 10, 2007 
Search Criteria: Year: 2006 Facility Type: All Facility Types

Stage: All Functional Areas Benefit: All Benefits

Lesson ID: 2006-28 Facility Type: Reactors, Material Facilities Stage: Design, OperationsBenefits: Minimizes ContaminationSubject: Licensees should ensure that concrete block walls are completely sealed to prevent the inadvertent intrusion of raDiscussion: Licensees should ensure that concrete block walls, constructed to allow removal for future maintenance, or re

components, are completely sealed to prevent intrusion of radioactive materials into the block interiors. Block connected to the ceiling are not always sealed on top, allowing contamination to enter the walls. In addition, hwalls that are sealed by concrete, paint, or other coatings, have been found with contamination inside the wabeen found with walls that are connected to ceilings and free-standing walls that are not physically connected On properly sealed walls, the ceilings are sealed or closed so that no contamination can enter.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Lesson ID: 2006-29 Facility Type: Reactors, Material Facilities Stage: Design, OperationsBenefits: Facilitates Decommissioning WorkSubject: Licensees should upgrade areas not designated for radiological activities when such are used for that type of worDiscussion: Licensees that conduct radiological work in onsite areas not designated for radiological work should upgrade 

example, this applies to the storage of radioactive waste in areas not designated for the storage of radioactive 

could include, for example, increased effluent monitoring for turbine building sumps, and temporary or permaareas. Surveillance programs for these areas should include the monitoring of liquid and airborne effluents. Icontamination will facilitate decommissioning planning. Licensees should collect radiological information from 

could be used later during decommissioning planning.

References: David Matthews Memo re: List of Decommissioning Lessons Learned in Support of the Development of a Sta

New Reactor Licensinghttp://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML062620355

Monday, September 10, 2007