ML20155H046
| ML20155H046 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/1998 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Larkins J NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW), Advisory Committee on Reactor Safeguards |
| References | |
| RTR-REGGD-XX.XXX NACNUCLE, NUDOCS 9811090315 | |
| Download: ML20155H046 (2) | |
Text
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- 1 November 5, 1998 l l
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j MEMORANDUM TO: John T. Larkins, Executive Director ACRS/ACNW ;
1 FROM: John W. N. Hickey, Chief [0RIGINALSIGNEDBY:] i Low-level Waste and Decommissioning ;
Projects Branch j Division of Waste Management, NMSS
SUBJECT:
REGULATORY GUIDE DG-1078, " STANDARD FORMAT AND ,
CONTENT OF LICENSE TERMINATION PLANS FOR POWER REACTORS" Because there were no public comments to reconcile, your October 27,1998, letter j i
stated that ACNW has no objection to the final publication of Regulatory Guide DG-1078,
" Standard Format and Content of License Termination Plans for Power Reactors." Recently, we received comments from Nuclear Energy Institute (NEI). The comments were editorialin !
nature and all the comments were addressed in the revised document. I have attached a copy of NEl's comments. Because of the editorial nature of the comments, unless we hear from you by November 15,1998, we are planning on issuing DG-1078 as scheduled.
Attachment:
As stated
Contact:
Larry Pittiglio, LLDP/DWM (301) 415-6702 TICKET NO.N/A DISTRIBUTION: Central File LLDP r/f NMSS r/f PUBLIC RJohnson j Path & File Name: S:\DWM\LLDP\CLP\LTR.ACN !
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OFC LLDP E LLDPj/ C LLD F N NAME LPifMv TJoh JNkey DATE h/8 V'
11/Yl98 11/I/98 OFFICIAL RECORD COPY ACNW: YES NO x Category: Proprietary _ or CF Only_ /
IG: YES NO x }/
LSS: YES NO x' Delete file after distribution: Yes_ No_x_ l
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4 . . . . . ,o November 5, 1998 MEMORANDUM TO: John T. Larkins, Executive Director ACRS/ACNW FROM: John W. N. Hickey, Chief Low-level Waste and Decommissioning { f ,
Projects Branch 4 '4 y/7'. e Division of Waste Management, NMSS Y
SUBJECT:
REGULATORY GUIDE DG-1078, " STANDARD FORMAT AND CONTENT OF LICENSE TERMINATION PLANS FOR POWER REACTORS" l l
Because there were no public comments to reconcile, your October 27,1998, letter stated that ACNW has no objection to the final publication of Regulatory Guide DG-1078,
" Standard Format and Content of License Termination Plans for Power Reactors." Recently, we received comments from Nuclear Energy Institute (NEI). The comments were editorialin 1
nature and all the comments were addressed in the revised document. I have attached a copy of NEl's comments. Because of the editorial nature of the comments, unless we hear from you l
by November 15,1998, we are planning on issuing DG-1078 as scheduled.
Attachment:
As stated i
Contact:
Larry Pittiglio, LLDP/DWM l
(301) 415-6702 l
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W Lynnette Hendricks NERATION OM$CN July 7,1998 Rules and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Draft Regulatory Guide DG 1078," Standard Format and Content of License Termination Plans for Nuclear Power Reactors" Issuance for Public Comment (63 Federal Register 24833 May 5,1998)
The Nuclear Energy Institute is providing these comments on the subject draft regulatory guide on behalf of the nuclear energy industry. These comments were developed from input by radiation protection staff from member utility companies who assisted in reviewing the subject document.
The subject draft regulatory guide does not utilize or make reference to two related draft regulatory guidest issued by the NRC over the past year. It is essential that NRC implement a process that assures the guides will be finalized in a coordinated manner that results in a coherent and consistent' set of guidance on the overall regulatory framework for decommissioning nuclear power reactors.
The discussion in the " Introduction" regarding possible hearings under either Subpart G or Subpart L of 10 CFR Part 2 should be revised to clarify the related status of spent fuel storage for the respective subparts. Suggested wording is:
" permanently removed from the Part 50 license, e.g., to storage authorized under Part 72" (Subpart L), and " spent fuel continues to be possessed under the Part 50 license" (Subpart G).
In the section on "Remediation Plans," the draft guide states that the license termination plan "should address any changes from the previously approved radiological control program." This wording is confusing because nuclear power reactor radiological control programs are described in the Final Safety Analysis i DG 1071. " Standard Format and Content for Post Shutdown Decommissioning Activities Report,"
and DG 4006, " Demonstrating Comphance with the Radiological Criteria for License Termination."
ATTACHMENT PPe ifettf *d W Su?t 4G0 <<
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Rules and Directives Branch r July 7,1998 i
Page 2 Report (FSAR) and defined in written procedures. Changes to the program are * '
evaluated against the description in the FSAR, When applicable, the changes are documented in periodic updates to the FSAR, and are therefore not necessary to be included in the license termination plan.
To improvo clarity and consistency, the section on "Remediation Plans" should be revised to include wording similar to what is in the draft regulatory guide on post-shutdown decommissioning activities reports (DG 1071):" details regarding the radiation protection plan ... are not required or expected in the post shutdown decommissioning activities report; however, this information may be required in periodic updates to the Final Safety Analysis Report."
The section on " Final Radiation Survey Plan" should be revised to reflect current applicable technical reports,2 References to superseded technical reports, for example, References 5 and 6, should be deleted.
We appreciate the opportunity to provide our comments on the draft regulatory guide, If you have any questions regarding our comments, please contact Ralph Andersen of our staff at 202-739-8111 or me at 202 739 8109.
Sincerely, ,
! Lynnette Hendricks l
RLA/tnb t
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- For example. NUREG 1575 "Multt. Agency Radiation Survey and Site Investigation Manual -
(MARSSIM," and draft NUREG.1549,"Using Decision Methods for Dose Assessment to Comply with Radiological Criteria for License Termination."
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