ML20212J563
| ML20212J563 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 06/15/1999 |
| From: | Whitney M Maine Yankee |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-64FR3140, RTR-NUREG-1700 64FR3140-00002, 64FR3140-2, MAW-99-04, MAW-99-4, MN-99-16, NUDOCS 9907060061 | |
| Download: ML20212J563 (3) | |
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RULES & D!R. BRANCH June 15,1999 US NRC MN-99-16 MAW-99-04 l
Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, D.C. 20555-0001
Subject:
Maine Yankee Comments on Draft NUREG-1700 " Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans" dated December 1998 The purpose of this letter is to provide Maine Yankee's comments on Draft NUREG-1700
" Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans" dated December 1998. We request that the NRC hold open the comment period beyond the specified June 15,1999 date. The reason for the request is because of the evolving nature oflicensees experience with the License Termination Rule and associated guidance. Some of this guidance is not yet published for licensees use, so it is difficult to appreciate all of the implications of the statements made in NUREG-1700. The recent rejection of two License Termination Plans has highlighted the difference in interpretation of the guidance, especially with regard to level of l
detail expected.
l As stated in section A, pg. 2 of NUREG-1700, "the principal purpose of the SRP is to ensure the l
quality and uniformity of staff reviews and to present a well-defined base from which to evaluate j
the requirements. It is also the purpose of the SRP to make the information about regulatory matters widely available to improve the understanding of the staff's review process by interested members of the public and the nuclear industry." Our comments are aimed at clarifying the
. O expectations of the NRC as documented in the SRP so that understanding is improved and the staff's evaluation basis is well-defined.
In general, Maine Yankee believes that whenever the SRP specifies an informational element for I
LTP acceptability, the SRP should provide an explanation of why the NRC needs that informational element and, in particular, what conclusion the NRC is looking to make by the use of that informational element. This general comment specifically applies to the informational elements associated with the survey units and the reference coordinate system. Section B.5, pg.
5, states: "The LTP is acceptable if the licensee has appropriately divided the survey area into survey units." AND "The LTP final survey plan is acceptable if the licensee establishes... a reference coordinate system for the survey areas." The SRP does not explain why the NRC YYk N G H
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i U.S. Nuclear Regulatory Commission MN-99-16 Chief, Rules Review and Directives Branch Page Two l
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needs this level of detail, nor does it describe the conclusion NRC is looking to make by the use ofit. Iflicensees knew why and for what purpose the NRC needs this infonnation, it might assist licensees in the format and content of the information or might allow licensees to provide alternative information to enable the NRC to make the same conclusion.
As stated in section A, pg.2 of NUREG 1700: "The LTP must be sufficiently detailed to permit the staff to independently verify that the facility can be decommissioned safely, and the license can be terminated." Maine Yankee does not believe that the NRC needs the specification and division of each survey unit or the establishment of the reference coordinate system in order to make a determination that the LTP will result in the facility being safely decommissioned, and that the license can be terminated. We believe that a description of the methodology for dividing the survey areas into survey units and a description of the methodology for the establishment a reference coordinate system for the survey area is sufficient level of detail to permit the NRC to make the determination discussed above. Depending upon the extent of dismantlement, decontamination and/or remediation activities, the division of the survey area into survey units may not be possible and therefore, the establishment of a reference coordinate system may not be readily useful. We recommend that the NRC revise the SRP to prescribe a description of the methodologies involved rather than the results ofimplementing these methodologies.
Section B.1, pg. 3, la paragraph under Acceptance Criteria states: "The LTP is submitted in the fomi of a supplement to the FSAR and is accompanied or preceded by an application for license termination." This statement contradicts 10 CFR 50.82 (a)(9). It should read "... accompanies or followed by...
Section B.3, pg. 4, la paragraph under Acceptance Criteria includes the phrase: " estimates of the quantity of radioactive material to be released to unrestricted areas." It is not at all clear what the SRP is referring to by this phrase. One might conclude that an estimate of the quantity of radioactive material being shipped for processing / disposal is what is desired. Another might conclude that the SRP is calling for an estimate of the quantity of radioactive material to be free released or cleared for unrestricted use, reuse, recycling or disposal. Still another might conclude that it means an estimate of the quantity of residual activity to be left on-site after license termination. In the first case, this information request would be consistent with commitments made in the PSDAR regarding estimated radioactive waste volumes. In the second case, one could argue that the answer should be zero under the current "no detectibility" standard for
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power reactor licensees. We recommend that the NRC clarify the meaning of this phrase and I
that the NRC explain why they need this information and for what purpose.
Section B.5, pg. 5,4th bullet under the 1" item under Acceptance Criteria states: " verification surveys and evaluations used to support delineation of radiologically affected (contaminated) areas and unaffected (noncontaminated) areas." This element appears to be out of place in the final survey plan and would be more appropriate in the site characterization section of the LTP.
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U.S. Nuclear Regulatory Commission MN-99-16 Chief, Rules Review and Directives Branch Page Three l
We appreciate this opportunity to comment on the draft standard review plan. If you have any questions, please contact us.
Very truly yours, Michael A. Whitney Senior Licensing Engineer c:
Document Control Desk -
Mr. Hubert Miller Mr. Michael Webb Mr. Michael Masnik l