Groundwater Protection Initiative

And Other Issues Of Interest

George OliverRETS/REMP Conference

Charlotte, NCJune 23, 2008

2

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)

3

NEI Groundwater Protection Initiative

Applies To All Nuclear Generating Plants Technical Groundwater Protection

Requirements– Hydrogeology And Geology– Risk Assessment–Monitoring– Remediation And Records

Communication Of Leaks/Spills And Monitoring Program Oversight

4

NEI Groundwater Protection Initiative

What Has Happened In The Last Year?– NEI 07-07 Guidance Document Issued

7-31-2007• One Year Period For Implementation

• NRC Public Meeting 9-27-2007

– EPRI Groundwater Protection Guidelines Issued 11-2007• NRC Public Meeting 2-5-2008

– NRC RIS 2008-03 Return & Reuse of Previously Discharged Radioactive Effluents

5

NEI Groundwater Protection Initiative

What Has Happened In The Last Year?– NRC Issues TI 2515/173

“GWPI Implementation Assessment Issued” 5-29-2008

Coming Attractions– NRC Begins Assessment 9-1-2008 – GWPI Self Assessments (One Year After

Implementation)– NEI Sponsored Peer Assessments– EPRI/NEI Groundwater Protection Workshop

September 23-25, 2008 - Augusta GA

6

Additional Issues of Interest Decommissioning Planning Rules

Decommissioning Planning Rulemaking– Federal Register Notice 1-22-2008– Very Extensive Rulemaking

•10 CFR Parts 20, 30, 50, 70, 72•Financial And Monitoring Guidance

– Comments Submitted 5-8-2006•NEI & 12 Nuclear Utilities•32 Sets of Comments 21 From Industry

– NEI Decommissioning Taskforce

7

Additional Issues of Interest 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

The Nuclear Industry Is Prepared To Work With NRC To Improve The Regulatory Process Related To Decommissioning

8

Additional Issues of Interest Decommissioning Planning Rules

Rules Provide For Adjustment of Financial Assurances Based On Soil Or Groundwater Contamination

Rules Provide For Subsurface Evaluations That May Generate Extensive Operational Characterization & Remediation Based On Decommissioning Criteria

9

Additional Issues of Interest Decommissioning Planning Rules

MARSSIM Is Being Established For Operational Monitoring Preformed Under This Proposed Rule

New Requirements For Leak Detection And Containment

May Require Extensive Groundwater Modeling Even With No Subsurface Contamination

10

Additional Issues of Interest Decommissioning Planning Rules

Use Of The GWPI Communication Thresholds (100 Gal Spill) To Define Significant For Decommissioning Records

Future Activity– NRC Is Reviewing The Comments From

The Public Comment Period

– A NRC Stakeholder Workshop Is Anticipated Later This Year

11

Additional Issues of InterestRegulatory Guide 4.21

NEC Issues Regulatory Guide 4.21

June 6, 2008 “Minimization of Contamination and Radioactive Waste Generation: Life Cycle Planning”

AKA 20.1406 & DG 4012 Industry Contributions To

Regulatory Guide Template To Be Developed