ML20203J158

Submits Comments on Maine Yankee Post Shutdown Decommissioning Activities Rept & Urges Increased Scrutiny of Decommissioning & Encourage NRC Cooperation W/Involved State Agencies,Oversight Groups & Public

ML20203J158
Person / Time
Site:	Maine Yankee
Issue date:	11/06/1997
From:	Dostie P MAINE, STATE OF
To:	Michael Webb NRC (Affiliation Not Assigned)
References
NUDOCS 9712190138
Download: ML20203J158 (3)

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- STATT!OF MAINE

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DEPARTMENT OF liUMAN SERVICES AUGUSTA MAINE 04333 November 6,1997 Mr. Michael K. Webb, Project Manager Non-power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Comments on Maino Yankoe's Post Shutdown Decommissioning Activities Report (PSDAP'

Dear Mr. Webb:

The State has recolved Maino Yankee's Post Shutdown Decommissioning Activities Report (PSDAR), which was submitted to the NRC on August 27,1997.

The Department of Human Services has several initial impressions that it would like to share with your agency.

Maine Yankee is amcng the first plants to be decommissioned ur' der the new 155-agency rules promulgated by the NRC on July 29, 1996. These newly M-implemented regulations place greater control of the process with the licensee, E-requiring limited NRC approval prior to undertaking various decommissioning activi9es. Hence, Maine Yankee's decommissioning can be a test case for the h

l industry. As Maine Yankee's decommissioning proceeds, it could set precedents, and it is evido,',t upon review of the PSDAR that Maine Yankee E-desires to be o model for the industry. G-While we do not wish for any involved government entity to impede the spoed, nor increase the costs, of a safe and orderly decommissioning of Maine Yankee, we are concerned that haste will make waste. Wo feel the strak.s imposed by

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an aggressive schedule could load to work being repeated and/or important issues being ovedooked. The risk of this occurring is increased should the NRC 4 not allocate the necessary tesvurces for appropriate oversight in the process. /hl 9712190138 971106 .

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The need for federal-state cooperation in this process can hardly be overstated.

While the NRC regulates Maine Yankee's reactor, including the decommissioning of the reactor site, it is the State's responsibility to protect its citizens from radiological hazards existing outside Maine Yankee's protected area, and within it upon NRC's license termination.

For all of these reasons we urge increased scrutiny of the decommicsioning of the Maine Yankee plant, and encourage NRC's cooperation with involved State agencies, oversight groups, and the public, to ensure that Maine Yankee undertakes its plant decommissioning in a safe and methodical manner.

Our initial comments are attached. Should we have any additional comments on the PSDAR, we will forward them within the week.

Sincerely,.

Patrick J. Do le State Nuclear Safety inspector Office of Nuclear Safety Attachment c:

Uldis Vanags, Nuclear Safety Advisor, Governor's Office Dr. Phil Haines, Dep. Dir., Bureau of Health W. Clough Toppan, Dir., Div, of Health Eng.

Jay Hyland, Acting Radiation Control Program Mgr.

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i STATE OF MAINE COMMENTS ON MAINE YANKEE'E PSDAR

1) The State is trying to keep up with all the plant chLnges. However, due to our limited resources and the aggressive schedule, we are finding it increasingly difficult to keep up with the pace, impairing our ability to review decommissioning documents in a timely manner.

2) We note that in the table summarizing the 1993 and 1997 decommissioning costs that in the 'Other Costs' category approximately $5 million in 1997 dolicrs has been allocated to such items as property taxes, insurance, energy, NRC and State fees, etc. We view this as being seriously deficient. If the Stato is to mainte!n its current oversight functions, the State fees incurred by Maine Yankee over its projected seven year period will itself amount to over $4 million.

3) We need more assurance that the fine balance between safety and cost effectiveness will be maintained. Our concern is that economic considerations couid resurrect sume historical shortcomings as identified in the ISAT report.

Preferably, the emphasis should l'e on quality, by doing the job right the first tirne.

4) We believe Maine Yankee's decommissioning could extend well beyond the Wiscasset plant. By increasing the understanding within the industry of the decommissioning process, Maine Yankee may set new standards as to what is deemed acceptable practice under NRC's regulation. As Maine Yankee decommissluns, tho industry will incorporate lessons learned and improve future decommissioning strategies. Examples of this phenomenon have already impacted other areas of NRC regulation. Witncus the industry wide reduction in refueling outage times; a process that once took 8 nr 12 weeks is now being completad in less than three weeks in some instances. Indeed, Maine Yankee may have already set one such precedent relevant to decommissioning; Maine Yankee filed the PSDAR itself in a record breaking 20 days. In light of this, the NRC may want to consider revisiting the allocation of its resources to ensure that appropriate oversight is achieved.