1. NEI Issues & Current Events George Oliver June 22, 2009 19th Annual RETS – REMP Workshop South Bend, Indiana

2. 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. 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. 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

5. NEI Groundwater Protection Initiative 5

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7.  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

8. 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

9. 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

10. 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. 11 Decommissioning Planning Rules  Federal Register Notice 1-22-2008 Financial And Monitoring Guidance – Comments Submitted 5-8-2008 – NEI Decommissioning Taskforce

12. 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. 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. 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

15. DG-1186 & DG-4013 Issues Industry & 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

16. DG-1186 & DG-4013 Issues Need 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

17. 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

18. SECY 08-0197 Need 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 18

19. 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