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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


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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


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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


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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




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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


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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


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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


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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


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Decommissioning Planning Rules

  • Federal Register Notice 1-22-2008

    • Financial And Monitoring Guidance

  • Comments Submitted 5-8-2008

  • NEI Decommissioning Taskforce


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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


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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


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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


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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


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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


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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


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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


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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, …”