Implementation of 10 CFR 20.1406 Through Life Cycle Planning for Decommissioning

The focus of this paper is on a regulatory guide (draft guide DG-4012) being developed by the Office of Nuclear Regulatory Research for the implementation of 10 CFR 20.1406. The draft guide was published in the Federal Register on July 31, 2007 for a 90 day public comment period. Besides being available in the Federal Register, it is also available electronically in NRC's agency data management system (ADAMS). The accession number is ML0712100110. 10 CFR 20.1406 requires license applicants, other than renewals, after August 20, 1997, '..to describe in the application how facility design and procedures for operation will minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual decommissioning, and minimize to the extent practicable, the generation of radioactive waste'. The intent of the regulation is to diminish the occurrence and severity of 'legacy sites' by taking measures that will reduce and control contamination and facilitate eventual decommissioning. 10 CFR 20.1406 is significant because it applies to all new facilities and in the very near future (perhaps as soon as the fall of 2007), the U.S. Nuclear Regulatory Commission (NRC) anticipates receiving one or more license applications for new nuclear power plants. The regulatory guidemore » is intended to facilitate that licensing by providing suggestions of things an applicant can do to minimize contamination of the facility and the environment, minimize generation of waste, and to facilitate decommissioning. Over 100 different kinds of activities are covered by license applications submitted to the NRC. They do not all reflect the same potential for contamination of a facility and the environment, or for the generation of radioactive waste. Therefore, an applicant should use sound judgment to evaluate the potential for contamination and the consequences of such contamination in deciding on the extent to which this guide applies to any given facility or activity. Factors which may enter into this decision include form (e.g., dry solids, liquids, gases), inventory, and environmental mobility of unintended releases. The bulk of the guidance presented in the guide will consist of specific design considerations drawn from nuclear industry experience and lessons learned from decommissioning. These design suggestions provide examples of measures which can be combined to support a contaminant management philosophy for a new facility. The principles embodied in this philosophy are threefold: (1) prevention of unintended release, (2) early detection if there is unintended release of radioactive contamination, and (3) prompt and aggressive clean-up should there be an unintended release of radioactive contamination. If the guiding principles are followed through the use of 'good' engineering and science, as well as careful attention to operational practices, it should result in meeting the requirements of 10 CFR 20.1406. All this should be considered in the context of the life cycle of the facility from the early planning stages through the final plans for decommissioning and waste disposal. Some of the mechanisms which can be employed for life cycle planning are described further in the Discussion section. In summary: The principles of the guide are threefold: prevention, early detection, and prompt response. If these guiding principles are followed through the use of 'good' engineering and science, as well as careful attention to operational practices, it should result in meeting the requirements of 10 CFR 20 In summary, the thrust of this guide is for an applicant to use technically sound engineering judgment and a practical risk-informed approach to achieve the objectives of 10 CFR 20.1406. This approach should consider the materials and processes involved (e.g., solids, liquids, gases) and focus on: (1) the relative significance of potential contamination; (2) areas most susceptible to leaks; and (3) the appropriate level of consideration to prevention and control of contamination that should be incorporated in facility design. Since the applicability of the guidance is a facility-by-facility decision, early consultation with the NRC is strongly suggested.« less