ML20137J148

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Discusses Comsecy 96-058 Strategic Assessment Issue Paper Re Decommissioning of Non Reactor Facilities
ML20137J148
Person / Time
Issue date: 01/28/1997
From: Diaz N
NRC COMMISSION (OCM)
To: Dicus G, Shirley Ann Jackson, Mcgaffigan E, Rogers K, The Chairman
NRC COMMISSION (OCM)
Shared Package
ML20137J085 List:
References
COMSECY-96-058, COMSECY-96-58, DSI-9, SECY-96-058-C, SECY-96-58, SECY-96-58-C, NUDOCS 9704030230
Download: ML20137J148 (2)


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COMMISSIONER January 28,1997 l

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MEMORANDUM TO:

Chairman Jackson Commissioner Rogers Commissioner Dicus i

Commissioner McGaffigan Commissioner Diaz,/

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SUBJECT:

COMSECY-96-058 STRATEGIC ASSESSMENT ISSUE PAPER: DECOMMISSIONING OF NON-REACTOR FACILITIES (DSI-9)

The issue posed in this DSI is "What should be NRC's strategy to take advantage of new and different approaches to optimize site remediation of the Site Decommissioning Management Plan (SDMP) and other problem sites?" One possible answer is to evaluate any new and different approaches as they are presented. Not only is this option not offered but the issue presented has little to do with decommissioning the tens of thousands of non-reactor facilities nationwide.

I agree that the decommissioning review process should be as simple for staff and liceneees as possible, while supporting reasonable assurance + hat cleanup standards have been met. I disagree with simplification for simplification sake, such as the elimination of decommissioning plans. If the preparation and review of these plans is more resource intensive than can be justified, they should be simplified commensurate with the complexity and risk associated with the site to be decommissioned. The simpler the decommissioning activity, the simpler the plan. To eliminate the plan is false economy. It would reduce resource consumption initially, but in the long run, I believe these plans conserve resources. The review should be used to efficiently focus licensee and staff attention and resources on the highest risks.

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l I agree with the establishment of a performance goal. The ongoing rulemaking to l

establish radiological criteria for decommissioning will establish that goal. The highest priority should be given by the staff to the development of comprehensive l

and clear guidance on implementation of this rule. This step is critical to ensuring that decommissioning efforts protect public health and safety while conserving national resources. I believe that the risk to members of the public and the environment should not be permitted to exceed that specified in the final rule, even for difficult sites such as those on the'SDMP.

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