ML20147F784

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Comments on Proposed Decomm Plan,Incl Its Financing. Suggests Inclusion of Requirement for Providing Cost Estimates for Decomm Oper
ML20147F784
Person / Time
Issue date: 11/22/1978
From: Abriss A
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Stanford R
NRC OFFICE OF STANDARDS DEVELOPMENT
References
FRN-43FR46309, RULE-PR-72 NUDOCS 7812260013
Download: ML20147F784 (1)


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RROFOsto auufi,s -72h3FR 4tG30h MEMORANDUM FOR:

Russell Stanford ao m

Fuel Process Systems Standards Branch f

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FROM:

Arnold Abriss Low-Level Waste Brarch 7

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Office of Nuclear Material Safety (9

qM[L and Safeguards

SUBJECT:

PROPOSED 10 CFR PART 72 to to I would like to submit a comment on Proposed 10 CFR Part 72, Section 72.18 "Decomissioning Plan, including its Financing".

Proposed Section 72.18 of 10 CFR requests information to be included in the Decomissioning Plan for an ISFSI.

However, there is no requirement for providing cost estimates for the various decomissioning operations.

Estimated costs are necessary to properly select a funding mechanism to pay for decomissioning.

I would therefore, suggest the following j

changes:

f (a) Insert the following statement after the first Fontence, "The plan shall include cost estimates for implementing the decomissioning procedures, for decontaminating the site and for disposing of radioactive materials, including transportation and burial changes."

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(b) Add after " execution" based upon the cost estimates of cart (a) above.

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l Arnold Abriss Low-Level Waste Branch Office of Nuclear Material Safety l

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