ML20137S914
| ML20137S914 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1997 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Rogers K, The Chairman NRC COMMISSION (OCM) |
| References | |
| COMSECY-96-068, COMSECY-96-68, DSI-24, FACA, NUDOCS 9704150279 | |
| Download: ML20137S914 (1) | |
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OFFICE OF THE e,
comussioNEn January 29, 1997 MEMORANDUM T0:
Chairman Jackson i
Comissioner Rogers Commissioner Dicus Comissioner Diaz l
FROM:
Edward McGaffigan, Jr.
h Comissioner
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SUBJECT:
COMSECY-96-068 - DSI POWER REACTOR DECOMMISSIONING I support Option 2 on powar reactor decommissicning.
In an environment with economic deregulation of electric utili;ies accelerating and with utilities facing life extension decisions on existing fccilities. it is important that
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the necessary regulatory recuirements significantly affecting costs and i
i schedules be established anc finalized as soon as possible.
t I agree with Comissioner Rogers that the staff should consider the option of combining several rulemakings (other than the rulemaking on clean-up standards which will soon be before the Commission) into a single, integrated rulemaking, if that will speed the rulemaking process.
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.I further agree with Comissioner Rogers on the issues of entombment as a decommissioning option and the need to address site specific decommissioning 4
funding level estimates as well as onsite dry stcrage of greater-than-Class-C waste (an issue I also dealt with in my response to DSI-5).
4 Finally I am concerned about the compatibility of an accelerated rulemaking i
pace with the use of new and innovative regulatory approaches, as called for 3
in the preliminary views. The staff should not be overburdened with l
requirements to adopt novel rulemaking techniques and approaches at the same time the Commission is asking them to proceed ra)1dly to resolution of rulemakings.
I agree with Comissioner Rogers tlat the Agreement State option should only be pursued if it were deemed beneficial by both the licensee and the Agreement State, a remote possibility based on comments received.
If introducing this option slows the rulemakings. I am not sure it is worth pursuing.
I would not support use of resident site inspectors at all phases of decommissionings, and would have to be convinced of the value of resident inspectors at any specific phase given overall constraints on agency resources.
Finally. I would support a risk-informed performance-oriented approach to these rulemakings to the extent the staff is ready to proceed with such an approach now. As in other areas, we should not allow striving for C3 perfection in our rulemaking to prevent or delay the achievement of j
significant improvements in our regulations.
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