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NEI Issues & Current Events. George Oliver June 22, 2009 19th Annual RETS – REMP Workshop South Bend, Indiana. NEI Issues & Current Events. NEI Groundwater Protection Initiative NEI Technical Report 08-08 DG-1186 & DG-4013 (aka RG 1.21 & 4.1) Decommissioning Planning
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NEI Issues & Current Events George Oliver June 22, 2009 19th Annual RETS – REMP Workshop South Bend, Indiana
NEI Issues & Current Events • NEI Groundwater Protection Initiative • NEI Technical Report 08-08 • DG-1186 & DG-4013 (aka RG 1.21 & 4.1) • Decommissioning Planning • SECY 08-0197 Radiation Protection Standards
NEI Groundwater Protection Initiative • Nuclear Generating Unit Issues 2005-2006 • Indian Point, Braidwood….. • NRC Also Formed “The Liquid Radioactive Release Lesson Learned Task Force • Report September 1, 2006 • 26 Recommendations • Not A Health And Safety Issue • It Was An Issue About Communications And Public Perception (Transparency) • NEI 07-07 Issued 8-31-2007
NEI Groundwater Protection Initiative • What's Happening? • NRC Began Assessment Summer-2008 • GWPI Self Assessments (One Year After Implementation) • NEI Sponsored Peer Assessments • EPRI/NEI Groundwater Protection Workshop September 15-16, 2009 – Charleston, SC
NEI Groundwater Protection Initiative • NEI Peer Review Issue Areas • SSC’s Risk Assessments (Objective 1.2) • Remediation Protocol (Objective 1.4) • NEI Notification (Objective 2.2.e) • Note: These Are Detailed Assessments
NEI Technical Report 08-08(New Plants) • Meeting The Operational Requirements Of 10 CFR 20.1406 & Regulatory Guide 4.21 • NEI 08-08 Minimizing Facility Contamination • MINIMIZATION OF LEAKS AND SPILLS • PROMPT DETECTION OF LEAKAGE • MINIMIZE THE POTENTIAL OF THE RELEASE OF CONTAMINATION FROM UNDETECTED LEAKS • REDUCING THE NEED FOR DECONTAMINATION OF EQUIPMENT AND STRUCTURES • REVIEW OF OPERATIONAL PRACTICES
NEI Technical Report 08-08(New Plants) • NEI 08-08 MINIMIZING CONTAMINATION OF THE ENVIRONMENT • SITE CONCEPTUAL MODEL DEVELOPMENT • EARLY DETECTION OF LEAKAGE AND CONTAMINANT MIGRATION • FINAL SITE CONFIGURATION • NEI 08-08 FACILITATION OF DECOMMISSIONING • DESIGN AND OPERATIONAL FEATURES • DECOMMISSIONING RECORDS
NEI Technical Report 08-08(New Plants) • NEI 08-08 MINIMIZING THE GENERATION OF WASTE • WASTE MANAGEMENT • ONSITE STORAGE OF RADIOACTIVE WASTE • Based Largely On NEI 07-07 Objective 1 • NEI 08-08 Is Part Of The Licensing Basis • As The Licensing Basis It Is Not Voluntary
Decommissioning Planning Rules • Federal Register Notice 1-22-2008 • Financial And Monitoring Guidance • Comments Submitted 5-8-2008 • NEI Decommissioning Taskforce
Decommissioning Planning Rules • The Nuclear Industry Shares The NRC Goal Of Preventing Legacy Sites • We Do Not Believe The Proposed Rules Are Required To Prevent Future Legacy Sites • Any Health And Safety Benefits Do Not Justify The Burden Created By The Rules • We Also Believe The Proposed Rules Are A Backfit
Decommissioning Planning Rules • Rules Provide For Adjustment of Financial Assurances Based On Soil Or Groundwater Contamination • Rules Provide For Subsurface Evaluations Based On Decommissioning Criteria
Additional Issues of Interest Decommissioning Planning Rules • NRC Is Reviewing Proposed Final Rules • DG-4014 To Be Issued For Public Comment • A NRC Stakeholder Workshop Is Anticipated Later This Year
DG-1186 & DG-4013 IssuesIndustry & Staff Efforts • Industry Contribution From 30+ Individuals • Many Detailed Technical Comments • Professional & Productive Relationship With Staff • January 15, 2009 Workshop Productive • Emergence Of SECY 08-0197 • 40 Guidance Documents Impacted • An Integrated Approach Is Needed
DG-1186 & DG-4013 IssuesNeed For Integrated Approach • DG-1186 & DG-4013 Duplicate & Inconsistent With Other Guidance • Several Guidance Documents Related To Groundwater • SECY 08-0197 Offers A Real Opportunity • Benefits Of Consolidated Guidance
DG-1186 & DG-4013 Opportunities • The Existing Guidance Should Remain Applicable • The Licensing Basis Is Not Impacted • Clarification Of Solid Radioactive Waste Reporting • Elimination of On Site Radiological Monitoring Programs From DG-4014 • Additional Flexibility • Calculate C-14 Effluents
SECY 08-0197Need For Integrated Approach • Emergence Of SECY 08-0197 • NEI/Industry Supports The Approach Taken By The Commission • Approximately 40 Guidance Documents Impacted • An Integrated Approach Is Needed • Supports Efficient Resource Utilization • Gather Stakeholder Input • Several Year Effort
We Need Your Support! • Completion Of GWPI Peer Reviews • Review Of DG-4014 “Decommissioning Planning” Monitoring • SECY 08-0197 “10 CFR 20, 10 CFR 50, …”