ML20093G454

Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors

ML20093G454
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/18/1995
From:	Kumar S External (Affiliation Not Assigned)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR37374, RULE-PR-2, RULE-PR-50, RULE-PR-51 60FR37374-00009, 60FR37374-9, NUDOCS 9510190083
Download: ML20093G454 (3)

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I FROrt .: KtJ1RR PHONE NO. : 2126847177 Oct. 181995 07:53V1 P2 00CKF.TED CCCNET NUMBER usHRc ra0msE0RU!.EElla p s, (LDFR'M SM) '95 OCT 18 A1002 ,

TTX ASSOCIATES, INC. OFFICf. ..gr:mC gTA$y.

PROJECT MAN AGERS & ENGINBBRS 00CKti. 6NkROAD MEDPIBLD.5SXCHUSETTS dI. ; y, sNy02052

, TEI.BPHONE(508) 359-2066

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FAX (508) 359 2259 October 18,1995 The Secretary of the Commission U. S. Nuclear Regulatory Commission l

Washington, DC 20555 l ATTENTION: Docketing and Service Bronch

REFERENCE:

Proposed Rule Decommissioning of Nuclear Power Reactors Federal Register, July 20,1995 (60 FR 37374)

TTX Associates, Inc.(TTX) is pleased to comment on the proposed amendments tc the NRC regulations on the decommissioning procedures for nucleer power ,

reactors. -

TTX evolved from the very successful Shoreham decommissioning pro}ect.

Shoteham was the first large, NRC-licensed, commercial nuclest power plant to complete decommissioning and have its license terminated. Under these circumstances, Shoreham became a test case for the decommissioning regulations promulgated in June 1988. The Shoreham experience exposed the shortcomings of the current regulations, especirJiy as they applied to prem&turely shutdown plants. TTX principals' involvement in the Shoreham decommissioning project included licensing and regulatory compliance, feasibility studies, environmental impact analyses, safety evaluations and cost estimates pertaining to the sallent aspects of the project.

Based on our knowledge of the decommissioning processes and our experience with Shoreham, we believe that the proposed rule represents a substantial l 9510190083 951018 PDR PR 2 60FR37374 PDR 36@

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Improvement. It contains many welcome provisions and goes a long way towards  ;

eliminating gaps and ambigultles in the current regulations. We wish to command l the NRC Staff for making constructive use (with strong encouragement from the 3 Commissioners) of the lessons learned from Shoreham and other ongoing decommissioning projects.

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j Our review of the proposed rule identified certain potential problems and opportunities for further improvement. These are outlined below:

l 6 The proposed rule requires that a post shutdown activities report l

(PSDAR) be submitted within two years after the ' permanent -

cessation of operation.The PSDAR would provide e description of the 4

licensee's planned decommissioning activities, along with a schedule j

for their accomplishment, and an estimate of expected costs. It is l i

assumed that the degree of detall required by the PSDAR is l l significantly less than that required by the Decommissioning Plan l

specified in the current regulations. We hope that further regulatory {

2 l guidance would be developed concerning the format and content of l l

d the PSDAR. l 1  !

e The proposed rule contains a provision for a pub'ic meeting to be organized by the NRC after the receipt of the PSDAR to inform the j - pubic about the licensee's plans. Public information meetings served an important purpose and proved beneficial to the Shoreham decommissioning proJoct although they were conducted only at the -

' end of tbo project. However, we did recognize that it is essential that -

adequate mechanisms be developed for addrensing issues and #

concerns rc: sed by members of the public. In the absence of such a '

t closura mechanism, public meetings could compound the frustrations L

felt by the Interested public and further complicate the -

decommissioning process.  ;

i e The proposed rule would entitle the licenses to a fee reduction after the submittal of two certifications (the certification of permanent cessation of operations and the certification of permanent removal of fuel). We recommend that the fee reduction be made effective i immediately after the first notification certifying that the plant has been permanently shutdown.

e The proposed rule would allow a total of 23 parcent (3 percent initially for planning and 20 percent after submittal of PSDAR) of the docommissioning trust funds to be used for legitimate decommissioning activules without prior approval from the NRC. We

• recommend that this fraction be increased to one-third of the decommissioning funds (about 33 percent). Such an increase would permit additional flexibility without jeopardizing the Integrity of the

' decommissioning process. .

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FFOt

• KUMfW PHONE NO. : 2126847177 Oct. 18 1995 07:544M P4 l e l

• As in the case of the PSDAR, we hope that additional regulatory I guidance would be forthcoming with respect to the format and  !

content of the license termination plan.  :

Thank you for the opportunity to submit our comments on this important matter.

If you have any questions concerntr.g our comments, please fee: free to contact us.

Very truly yours, i

y- .

M. Siva Kumar Vice President i

cc: R. F. Thibault C. W. Adey

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