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Review of Performance Assessment for Decommissioning Plans

Licensees that are decommissioning their facilities are required to demonstrate to the U.S. Nuclear Regulatory Commission (NRC) that their proposed methods will ensure that the decommissioning can be conducted safely, and that the facility will comply (at the completion of decommissioning activities) with the NRC’s radiological criteria for license termination, as set forth in Subpart E of Title 10, Part 20, of the Code of Federal Regulations (10 CFR Part 20). Toward that end, licensees typically submit dose modeling information as part of a performance assessment, which accompanies the licensee's decommissioning plan (DP). NRC staff guidance for reviewing the performance assessment is outlined in NUREG-1757, Vol. 2, “Consolidated Decommissioning Guidance: Characterization, Survey, and Determination of Radiological Criteria.”

The NRC staff is currently reviewing performance assessment information for the following complex materials sites undergoing decommissioning, as described on this page:

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Shieldalloy Metallurgical Corporation

The NRC's technical staff is reviewing the dose assessment portions of the licensee's DP for the Shieldalloy Metallurgical Corporation (SMC) site in Newfield, New Jersey. Accumulated materials at the site consist of slag and baghouse dust containing natural uranium and natural thorium, which the facility generated in the course of its metal and alloy processing activities. These materials are present in a storage yard located in the eastern segment of the property. To demonstrate compliance with the NRC's regulations, SMC’s dose assessment is divided into two separate areas, of which the licensee proposes to release one for unrestricted use, while the other would be released with restrictions to control access to the area.

SMC submitted Revision 1 of its DP on October 24, 2005. However, in a letter dated January 26, 2006, the NRC refused to docket that DP and submit it for technical review. In doing so, the agency cited technical deficiencies that could significantly impact the progress of the detailed technical review. As a result, SMC submitted a supplement (Rev. 1a) to its DP, on June 30, 2006. The NRC's performance assessment staff subsequently contributed to the requests for additional information (RAIs) regarding the safety review (RAI 11-16) and environmental review (RAI 7-14) pertaining to the DP. Those RAIs related to the assumed source term for the dose assessment involving the restricted release area of the site, treatment of parameter uncertainty within the dose assessment, justification for excluding groundwater as a potential exposure pathway, assumptions regarding the movement of radioisotopes through the soil, and other issues. The NRC's technical staff is engaged in frequent followup discussions with the licensee on these topics.

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West Valley

The West Valley site is located on the Western New York Nuclear Service Center, and comprises 3,300 acres of land established for siting a former reprocessing facility. Within that area, the West Valley Demonstration Project (WVDP) Act gives the U.S. Department of Energy (DOE) exclusive possession of the 200-acre portion of the Western New York Nuclear Service Center, which includes the former reprocessing facility, the NRC-licensed disposal area (NDA), high-level waste (HLW) tanks, waste lagoons, and above-ground waste storage areas.

The NRC's performance assessment staff participates in the DOE-sponsored core team process (CTP) for the WVDP and Western New York Nuclear Service Center.  The CTP is designed to be a collaborative process, through which State and Federal agencies resolve technical issues associated with developing the draft environmental impact statement (EIS) for decommissioning and/or long-term stewardship at the site. DOE issued a Revised Draft Environmental Impact Statement for the Decommissioning and/or Long-Term Stewardship for public comment, and submitted Proposed Phase 1 Decommissioning Plan to the NRC for review in December 2008.

The preferred alternative recommended by the core team would complete the decommissioning of the WVDP in two phases. Phase 1 would include the following actions:

  • Relocate 275 canisters of HLW stored in the main plant to a new onsite storage facility.
  • Remove the main plant, including below-grade sections and the source area of the North Plateau Ground Water Plume (NPP).
  • Remove the liquid low-level waste water treatment facility, lagoons, and all facilities that are not needed to maintain the waste tank farm (WTF), NPP, and NDA, and conduct general site monitoring and maintenance.
  • Further characterize and evaluate site surface soils to identify and remove areas of higher contamination.
  • Identify a management strategy for the State-licensed disposal area (SDA).

In addition, Phase 1 would include the following assessments, which would support future decisions (in Phase 2) regarding exhumation or in-place closure of the WTF, NDA, and the remaining portion of the NPP:

  • Collect site erosion data for further evaluation of landscape evolution modeling and erosion barriers.
  • Monitor and evaluate evolving exhumation technologies and waste disposal options.
  • Review site status every 5 years.

The decommissioning decision for the WTF, NDA, and remaining portion of the NPP would be made no later than 30 years after the Phase 1 Record of Decision.

The NRC met with DOE in public meetings on May 19, 2008 and July 24, 2008, to discuss the scope and content of the DP and dose modeling approaches for Phase 1 decommissioning. Some of the complex performance assessment issues that the staff is evaluating include erosion modeling, complex site hydrology, and integration of Phase 1 and Phase 2 sources. The NRC remains actively engaged with DOE on these and other performance assessment issues in preparation for its review of DOE’s EIS and DP, including whether or not certain wastes at the site can be determined to be waste incidental to reprocessing.

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Wednesday, February 11, 2009