NEI Issues & Current Events

George OliverJune 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

2

3

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

4

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

5

NEI Groundwater Protection Initiative

6

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

7

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

8

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 9

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 10

11

Decommissioning Planning Rules

Federal Register Notice 1-22-2008•Financial And Monitoring Guidance

– Comments Submitted 5-8-2008– NEI Decommissioning Taskforce

12

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

13

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

14

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

15

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

16

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

17

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 Effort18

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, …”

19