ML20046A810
| ML20046A810 | |
| Person / Time | |
|---|---|
| Issue date: | 05/27/1993 |
| From: | Remick F NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9307300085 | |
| Download: ML20046A810 (2) | |
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SAMUEL J.. CHILK, ; SECRETARY.i 0FiTHE Col 44ISSION-
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SUBJECT:
SECY-92-382 - DECOM4ISSIONING - LESSONS:
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p Commissioner Remick's Comments on SECY-92-382:
I commend OGC for a very thorough and thoughtful analysis of our decommissioning regulations and policies.
r I approve all of OGCs recommendations except part of the fourth: I would nct contmue the practice ofissuing confirmatory orders prohibiting resumed operation without prior NRC approval, though the practice might usefully be continued until the rest of OGCs Recommendation 4 is implemented. OGCs proposed approach to the POL would appear to render the use of confirmatory orders unnecessary. Moreover, continued use of them might detract from the visibility and easily understood character which OGC notes the POL already has (p. 41), and which will be greatly enhanced when OGCs recommendations are implemented.
I approve in particular OGCs recommendation that hearings on approvals of decommissioning plans be " post-effective", except when the stay criteria in i 2.788 are met.
I agree with my colleagues that public participation in any hearing on the decommissioning plans should not be rendered meaningless by actions taken before the hearings, but it would appear to me that OGCs recommendation to apply the stay criteria would accomplish our aim. I would also adopt OGCs alternative suggestion that the agency provide an informal process for earlier public input.
I would urge generally that the first four of OGCs Recommendations be implemented only on the basis of the best safety analyses we can do. In my vote approving the POL for Trojan (SECY-93-093), I expressed one aspect of my general concern that the licensee which has ceased operations not be permitted substantial additional flexibility until detailed reviews of the licensee's proposed post-shutdown activities are completed and the license amended if necessary. As the licensee's personnel and organization make the transition from operating to decommissioning, much care must be taken to assure that the decommissioning personnel learn what n. y need to know from the operating personnel.
3 I am particularly concerned that steps may be taken under i 50.59 without due regard for the unexpected form in which unreviewed safety questions may present themselves in the new environment of decommissioning.
Careful analyses and reviews by the staff in I
connection with the implementation particularly of Recommendations 1,2, and 4 will help assure continuity of knowledge in the licensee's organization, and due respect for the unexpected. Only thus wdl any unnecessary exposures to the public and workers be kept to a minimum. In the critical period before OGCs recommendations are implemented, the j
staff may sometimes have to exercise special care to assure that adequate reviews are done.}