ML20217F536

Comment Opposing Draft Regulatory Guide DG-1071, Std Format & Content for Post-Shutdown Decommissioning Activities Rept

ML20217F536
Person / Time
Site:	Davis Besse
Issue date:	03/25/1998
From:	Donnellon R CENTERIOR ENERGY
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR1877, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 2526, 63FR1877-00002, 63FR1877-2, NUDOCS 9804010042
Download: ML20217F536 (3)

Text

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US NRC March 25, 1998 O Rules and Directives Branch Office of Administration U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001

Subject:

Comments on Draft Regulatory Guide DG-1071," Standard Format And Content For Post-Shutdown Decommissioning Activities Report" Ladies and Gentlemen:

The Toledo Edison Company is the operator and a licensee of the Davis-Besse Nuclear Power Station. As such,it has a vested interest in the promulgation of formal regulatory guidance such as the subject draft Regulatory Guide. Toledo Edison (TE) has reviewed the subject draft Regulatory Guide and is providing the comments contained in the attachment to this letter.

Should you have any questions or require additional information, please contact Mr.

James L. Freels, Manager - Regulatory Affairs, at (419) 321-8466.

Very truly yours, f

7wt E.W  !

Robert E. Donnellon Director- Engineering & Services Davis-Besse Nuclear Power Station KAS/laj Attachment Gus fnC.w-rd2 cc: A. B. Beach, Regional Administrator, NRC Region III S. J. Campbell, NRC Region III, DB - 1 Senior Resident Inspector A. G. Hansen, NRC/NRR Project Manager USNRC Document Control Desk 9804010042 900325 PDR REGGD XX.XXX C PDR ,

Attachment Page1 COMMENTS ON DRAFT REGULATORY GUIDE DG-1071:

STANDARD FORMAT AND CONTENT FOR POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT (PSDAR)

1) Standard Fermat and Content Guidance:

Page 3 of DG-1071 at [18], states,"...if the NRC determines during the review that the information provided by the licensee in the PSDAR does not comply with the requirements provided in 10 CFR 50.82(a)(4)(i), the NRC will inform the licensee in writing of the additional information required by the regulation before the NRC staff holds the PSDAR public meeting and major decommissioning are begun".

Greater consistency in the format and content of PSDARs would be achieved by adding a general table of contents for a typical PSDAR to the Regulatory Guide (RG). This table of contents should outline the order and type of information to be presented in the PSDAR. This would better describe the information to be presented in the PSDARs from licensees. Without such a general table of contents," quasi-regulatory guidance" outside of the RG is likely to evolve for the content of PSDARs based on precedents;i.e.,it will become incumbent upon licensees preparing a PSDAR to review other licensees' PSDARs and associated NRC questions in order to better determine the order and typc of information expected by the NRC staff to be provided in the PSDAR.

2) NRC Determination of Adeauacy of PSDAR:

Page 3 at [20): Since major decommissioning activities can commence 90 days after the NRC receives the PSDAR, a timeframe of no later than 60 days after receipt of the PSDAR should be set for the NRC staff to determine if the PSDAR is adequate. This would assist in minimizing licensee decommissioning mobilization costs that would be affected should the PSDAR be determined to be inadequate by the NRC staff, thus i delaying commencement of major decommissioning activities.

3) Description of Licensee's Planned Decommissionine Activities: l Page 5 at [4], change "The level of detail of the description provided for each of the activities will depend, in part, on the nature of the activity, although normally it would be approximately a paragraph." by deleting "although normally it would be approximately a paragraph" and clarifying the words " specific and unique" in the next sentence.

This section lacks specific direction as to what would require additional NRC staff oversight and what would be " unique" or plant specific. This could result in considerable time spent by the licensee and the NRC staff resolving these issues.

l

Attachment Page 2 Page 6 at [8]: If activities and tasks for maintaining the facility and site in safe storage should be mentioned, then this should be a more specific requirement of the PSDAR.

Page 6 at [28], change the sentence, "The description of the licensee's planned decommissioning activities is meant to be broad, but specific to the facility; however, it should be completed ......" by deleting "is meant to be broad, but specific to the facility; however, it" since this wording seems to be confusing as to the type of description being requested by the NRC staff.

4) Schedule of Planned Decommissionine Activities:

Page 7 at [8]: This sentence references the " degree of oversight required by the NRC" is vague and should define what items will require NRC staff oversight.

5) Generic Cost Estimates:

Page 8 at [10), change "For generic cost estimate..." to "For generic cost estimate methods, . .".

This paragraph describes NUREG/CRs that were published in 1978 and 1980. These cost estimates are outdated, however, the cost estimate methods may still be used. This is consistent with the next paragraph that refers to cost estimate methods.