Groundwater Protection Initiative And Other Issues Of Interest George Oliver RETS/REMP Conference Charlotte, NC June 23, 2008

2 NEI Groundwater Protection Initiative  Nuclear Generating Unit Issues – 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 Guidance Document Issued One Year Period For Implementation NRC Public Meeting – EPRI Groundwater Protection Guidelines Issued NRC Public Meeting – NRC RIS 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”  Coming Attractions – NRC Begins Assessment – GWPI Self Assessments (One Year After Implementation) – NEI Sponsored Peer Assessments – EPRI/NEI Groundwater Protection Workshop September 23-25, Augusta GA

6 Additional Issues of Interest Decommissioning Planning Rules  Decommissioning Planning Rulemaking – Federal Register Notice – Very Extensive Rulemaking 10 CFR Parts 20, 30, 50, 70, 72 Financial And Monitoring Guidance – Comments Submitted 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 Interest Regulatory Guide 4.21  NEC Issues Regulatory Guide 4.21 June 6, 2008 “Minimization of Contamination and Radioactive Waste Generation: Life Cycle Planning”  AKA & DG 4012  Industry Contributions To Regulatory Guide  Template To Be Developed