ML20211J195

Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Requests Extension Until 990915,to Fully Comment on Draft RG

ML20211J195
Person / Time
Site:	Maine Yankee
Issue date:	08/30/1999
From:	Haines P MAINE, STATE OF
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR41604, RTR-REGGD-XX.XXX 64FR41604-00002, NUDOCS 9909030080
Download: ML20211J195 (2)

Text

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RULES & DR BRANCH US NRC 9

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Dear Gentlemen:

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The State of Maine is a major stakeholder in the license termination as it pestains to the decommissioning of the Meine Yankee facility. As public servants entrusted to protect the public interest we are very interested in this process. 1

- 1 As you may well be aware Maine Yankee has embarked on a very aggressive l schedule to dismantle its power plant. The State has limited resources and it is  ;

very diffloult to stay abreast of developments at the plant and at the same time I comment on all NRC documents in a timely fashion. However, since we are involved in this process, we do wish to comment on your Draft Regulatory Guide DG-4006, " Demonstrating Compliance with the Radiological Criteria for License l Termination". l We note that the comment deadline is August 31, 1999. We request an extension untN September 15,1999, to fully comment on your Draft Guide, DG-4006.

At this time we are only prepared to make three general comments on the AL. ARA portion of the Guide:

1. We are concemed that a potential bias may exist with the ALARA cost \D.

benefit evaluation. -

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2. We are wondering if the ALARA program, as outlined in DG-4006, is comparable to Al. ARA programs in nuclear power operational facilities. The decommissioning version appears to envision a less aggresolve ALARA Program than operational facilities. -

3. We are wondering if there is a provision within DG-4006 to measure the effootiveness of the ALARA Program. On the surface it is not readily apparent that such a provision exists. -

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, TEL: Aug 30'99 15:15 No.007 P.02  !

i Unfortunately, we will not have time to further develop these comments in this letter, The State's Omeo of _ Nuclear Safety and Radiation Control Program would appreciate the opportunity to provide some insights on these general comments.  !

' By the time you receive this submittal the dead!)ne will have passed. We realize j that a timely response to our request is unreasonable. However, we will proceed '

with the presumption that en extension may be granted and will submit our full comments by September 15. If an extension is not granted, wa recognize that any inclusion of our September 15 comments would be exclusively at NRC's discretion. .

9 Sincerely, i

Philip W. Haines, Dr. P.H.

Deputy Director Bureau of Health 3 i 1

. r c: i Mr. Clough Toppan, Dir., Div of Heenth Engineering -

Mr. Jay Hyland, Mgr., Radiation Control Program Mr Patrick Dostie, State Nuclear Safety 1,nspector G

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