ML20216B566

Comment Supporting NRC Draft RG DG-1071, Std Format & Content for Post-Shutdown Decommissioning Activities Rept

ML20216B566
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/31/1998
From:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR1877, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 63FR1877-00005, 63FR1877-5, NUDOCS 9804130517
Download: ML20216B566 (3)

Text

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.6 DiR. BPANCH HADDAM NECK PLANT 3'HggLgROAD e EAST HAMPTON, CT 06424-3099 March 31,1998 Docket No. 50-213 CY-98-040 Re: DG-1071 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rules and Directives Branch Office of Administration Comments on NRC Draft Regulatory Guide DG-1071, " Standard Format and Content for Post-Shutdown Decommissionine Activities Penort."(63FR1877)

Enclosed are Connecticut Yankee Atomic Power Company's (CYAPCO's) comments on the NRC Draft Regulatory Guide DG-1071, " Standard Format and Content for Post-Shutdown Decommissioning Activities Report." In general, CYAPCO supports the development of a regulatory guide to assist licensees in developing or modifying this report. CYAPCO's specific comments are directed to the appropriate section in the draft regulatory guide.

If the NRC Staff should have any questions regarding the enclosed comments, please contact Mr. G. P. van Noordennen at (860) 267-3938.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY

' i R. A. Mellor \

Vice President - Operations and Decommissioning Enclosure f

9804130517 980406 PDR REGGD XX.XXX C PDR

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• U. S Nuclear Regulatory Commission

~ CY-98-040 / Page 2 ENCLOSURE Section Comment B. This section should describe the resolution process with regards to the comments received from the public meeting held to discuss the PSDAR. The h1C chould be required to respond to public comments within 90 days of the public meeting.

B While review and approval of the PSDAR is not required, the guidance should indicate that the staff review will ultimately result in a letter or memo being issued which concludes that the licensee conforms to the requirements of the regulation.

LC . The degree of specificity included in the PSDAR will be, in past, linked to the expected size of the document. As a result, this section should state the expected number of pages (12-15 maximum).

C.1 Description of activities should also include descriptions of the expected methods of removal or dismantlement 'a be employed such as the mechanical methods (i.e., cutting or sawing) or thermal methods.

"1 Soil remediation should be added to the list of activities which should be described for DECON.

C.2 This part of the guide states that the schedule allows the N1C to allot resources necessary

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for oversight activities._ In order to provide guidance for schedule detail development, the .

discussion should provide clear examples of what activities would qualify as requiring a higher degree of NRC oversight.

C.4 The guidance in this section is confusing. The discussion indicates that activities not considered in the GEIS are outside the bounds of the GEIS and therefore should be examined. This section also states that the licensee is prohibited from undertaking activities without first complying with 10CFR Part 51. Yet in section C.1 the guidance states that l activities which may be outside the bounds of the GEIS would need to be discussed in the l PSDAR in greater detail. A discussion should be provided to identify the approval process l if the PSDAR change results in an impact not bounded by the GEIS.The 90 day process for i the PSDAR is unclear with respect to how it would correlate to the regulatory process  ;

required for resolution of any activities which are beyond the bounds of the GEIS. )

i C.4 For plants that do not have an FES, it should be clear whether an environmental assessment is or is not applicable (delete "may be").~ This clarification should be consistent with the l update guidance in Section 6.

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' U. S$ Nuclear Regulatory Commission CY-98-040 / Page 3 C.6 The discussion associated with long term storage should use the term SAFSTOR. A statement should be included to the effect that an updated PSDAR is eventually necessary when a decision is made to go to DECON in order to provide the required decommissioning activity information.

t-C.6 Clarifying information should be added to indicate what is the threshold for a significant change in schedule versus a significant change in rnilestone. A signiGcant change should be defined as a minimum of six months or greater. Also, scheduling should be done to the extent known; factoring in decisions impacted by activities not within the control of the licensee cannot be accurately determined to the nearest month and year. Clarification l should also be provided as to whether notifications of schedule changes must be formalized via letter or whether a simple phone call to the appropriate NRC Project Manager would be sufficient.

C.6 The discussion regarding Decommissioning Plans that were submitted to the NRC, but not l yet approved, prior to the August 28,1996 final rule should say something with regards to the public meeting process. For this special category of decommissioning plants, a statement should be added that a public meeting will be appropriately scheduled as soon as l practical.

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