ML20216G032

Comment Re Draft RG DG-1071, Std Format & Content for Post- Shutdown Decommissioning Activities Rept. Recommends That Draft RG Be Revised to Accommodate Situations Similar to That Described for Unit 1

ML20216G032
Person / Time
Site:	Peach Bottom
Issue date:	03/04/1998
From:	Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR1877, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 63FR1877-00001, 63FR1877-1, NUDOCS 9803190179
Download: ML20216G032 (2)

Text

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l March 4,1998

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Mr. David L. Meyer, Chief Rules and Directives Branch Division of Administrative Services Office of Administration l i

U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comments Concerning Draft Regulatory Guide DG-1071,

" Standard Format ar'd Content for Post-Shutdown Decommissioning l Activities Report"

Dear Mr. Meyer:

This letter is being submitted in response to the NRC's request for comments conceming draft Regulatory Guide (RG) DG-1071, " Standard Format and Content for Post-Shutdown Decommissicaing Activities Report." The purpose of this draft RG is to identify the type of information to be contained in Post-Shutdown Decommissioning Activities Report (PSDAR) and establish a stardard format for the PSDAR that is acceptable to the NRC. The NRC is recommending that licensees use the guidance provided in this draft RG to facilitate the preparation of PSDARs.

l PECO Energy appreciates the opportunity to comment on this draft RG. PECO Energy offers the following comments for consideration by the NRC.

Comments Section B," Discussion," of the draft RG states that licensees with an approved decommissioning plan are required to submit an update to the PSDAR for activities that were not considered in their decommissioning plan. The discussion further states that because of the potential for a misunderstanding as to what must be updated, licensees are encouraged to replace their decommissioning plans with a PSDAR update that uses the format and content specified in this document.

Section 6,"PSDAR Updates," of the draft RG states that for facilities with approved <

decommissioning plans, updates would be required if the information required in a PSDAR 3 changes as described in the section. This section gives an example of a new estimated cost greater than 20 percent above the site-specific or PSDAR cost estimate.

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!' PECO Energy does not consider it necessary to update the PSDAR by replacing pages.

Compliance with 10CFR50.82(a)(7) can be achieved by submittal of a letter containing the pertinent information. The PSDAR for Peach Bottom Unit 1, is the decommissioning plan which

. was approved by Amendment No. 6 to Provisional Operating License DPR-12 dated July 14,

.1975. The approved decommissioning plan did not contain any estimate of expected decommissioning costs.' By letter dated July 26,1990, information was provided indicating how reasonable assurance will be provided that funds will be available to decommission our licensed facilities. Any changes that significantly (ncrease decommissioning costs for Unit 1 could be submitted by separate letter and meet the requirements of 10CFR50.82(a)(7). Notification of increased decommissioning costs should not be made simply because of higher estimated costs due to inflation. Notification should be made only if changes in the manner or timing nf decommissioning activities results in a significant increase in decommissioning costs. Therefore, PECO Energy recommends that the draft RG be revised to accommodate those situations similar j to that described for Peach Bottom Unit 1 above.

If you have any questions, please do not hesitate to contact us.

Very truly yours, j

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Garrett D. Edwards Director- Licensing i

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