ML13129A402
| ML13129A402 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/01/2013 |
| From: | Mitchell R M Yankee Atomic Electric Co |
| To: | Vietti-Cook A L NRC/SECY |
| SECY RAS | |
| References | |
| 10 CFR Parts 50 and 52, 78FR21275 00003, BYR 2013-024, NRC-2011-0299 | |
| Download: ML13129A402 (2) | |
Text
Telephone (413) 424-5261 YANKEE ATOMIC ELECTRIC COMPANY 49 Yankee Road, Rowe, Massachusetts 01367JQO****
_e May 1, 2013 BYR 2013-024 Secretary U.S. Nuclear Regulatory Washington, DC ATTN: Rulemakings and Adjudications Staff Yankee Atomic Electric Yankee Nuclear Power Station Independent Spent Fuel Storage NRC License No. DPR-3 (NRC Docket Nos.50-029 and Comments on Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52) Draft Regulatory Basis and Rule Concepts Document --Docket ID NRC-2011-0299 Yankee Atomic Electric Company (Y ankee Atomic) appreciates the opportunity to comment on the subject Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52) Draft Regulatory Basis and Draft Rule Concepts document (Reference
- 1) associated with the potential amendment of Nuclear Regulatory Commission regulations concerning nuclear power plant licensees' Station Blackout Mitigation Strategies.
The draft document does not address stand-alone 10 CFR 50 licensees that have permanently ceased operations, fully decommissioned and dismantled the former operating plant, and are storing spent nuclear fuel and Greater than Class C (OTCC) waste in a dry cask Independent Spent Fuel Storage Installation (ISFSI). Yankee Atomic's position is that the Draft Regulatory Basis document and subsequent rulemaking are not applicable to 10 CFR 50 licensees where the operating reactor and the power plant have been completely decommissioned and the licensee only operates a dry storage ISFSI at the former reactor site. Accordingly, Yankee Atomic requests that the final regulatory basis document and future development of the Station Blackout Mitigation Strategies rulemaking clearly delineate that it applies to holders of, or applicants for, an operating license under 10 CFR 50, except those; 1) 10 CFR 50 licensees who have permanently ceased operations, 2) certified that fuel has been permanently removed from the reactor vessel, and 3) removed all fuel from the spent fuel pool. This letter contains no regulatory commitments.
Yankee Atomic Electric Company BYR 2013-024 May 1, 2013/Page 2 If you have any questions regarding this submittal, please do not hesitate to contact me at (413) 424-5261 ext. 303, or at rmitchell@3yankees.com.
Res p ec[2ful, _'/ _....' Robert M. Mitchell ISFSI Manager
Reference:
NRC request for comments on Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52) Draft Regulatory Basis and Rule Concepts (Federal Register Notice 21276) NRC Document Control Desk W. M. Dean, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region 1 1. Goshen, NRC Project Manager, Yankee Nuclear Power Station