ML20217Q732
| ML20217Q732 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/26/1998 |
| From: | Zinke G Maine Yankee |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-63FR1877, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 63FR1877-00004, 63FR1877-4, GAZ-98-18, MN-98-20, NUDOCS 9804130128 | |
| Download: ML20217Q732 (2) | |
Text
l 6soq MaineYankee
- '"W' 2 9 P.O. BOX 408 + WISCASSET, MAINE 04578 * (207) 882-6321 RECEIVED
- C i
3 N4OphU l
l l
I?93 l.FR -6 PM 1: 34 RULES & DS. ERWCH US NnC March 26,1998 MN-98-20 GAZ-98-18
- Rules and Directives Branch OfTice of Administration United States Nuclear Regulatory Commission Washington, DC 20555-0001 j
Reference:
(a) License No. DPR-36 (Docket No. 50-309) 1
Subject:
Comments on Draft Regulatory Guide DG-1071 " Standard Fonnat and Content for Post-Shutdown Decommissioning Activities Report" We appreciate the opportunity to offer comments on the subject draft regulatory guide. Overall, the draft regulatory guide appears to be consistent with the intent of the decommissioning rule and j
provides adequate and appropriate additional guidance without imposing unnecessary complexities over and above the decommissioning rule.
Attached are a few comments on certain aspects of the draft regulatory guide. If you have any questions, please contact us.
Very truly yours, George A. Zinke, Dir r
Nuclear Safety & Regulatory Affairs Attachment I
c:
Mr. Hubeit Miller l
t Mr. Michael Masnik -
Mr. Ron Bellamy Mr. R. A. Rasmussen Mr. Clough Toppan Mr. Patrick J. Dostie Mr. Uldis Vanags Document Control Desk 9804130128 980326 PDR REGGD XX.XXX C PDR MpL
I, l
'o ATTACHMENT l
l SPECIFIC COMMENTS ON DRAFT REGULATORY GUIDE DG-1071
" STANDARD FORMAT AND CONTENT FOR POST-SIIUTDOWN DECOMMISSIONING ACTIVITIES REPORT" Section C FORMAT AND CONTENT OF THE POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT Subsection 6 PSDAR UPDATES Pg. I1,2nd para.,2nd sentence:
j
" Changes to the milestone schedule will be used by the NRC staff to schedule NRC inspections of the licensee's activities and to provide assurance that decommissioning is being conducted safely and in accordance with regulatory requirements" Comments:
Although there is no reference to the amount ofI :ad time licensees should give the NRC for PSDAR activity and schedule changes, it is clear from the type of examples provided that they should be made with sufficient notice and detail appropriate for the type of NRC or state actions involved. This flexibility allows the licensees to exercisejudgement with due consideration to the impact of activity and schedule changes on regulatory agency inspection and review resources. This is especially appropriate in view of the licensees' l
own interest in facilitating timely and successful review and inspection of their activities.
Pg. I1,2nd para.,5th sentence:
" Examples of significant increr,es in cost associated with decommissioning the facility would included a new estimexed cost greater than 20 percent above the site-specific cost estimate or the PSDAR cost estimate, or a 20 percent increase in cost above a major milestone estimate."
l Comments:
Insert the parenthetical phrase: "(whichever applies)" after the words: "PSDAR cost l
l estimate" to indicate that once the site-specific cost estimate is submitted it supersedes the PSDAR cost estimate previously submitted.
l In Draft Regulatory Guide DG-1067 " Decommissioning of Nuclear Power Reactors",
page 19, last paragraph,4th sentence, a similar statement is made with the exception that the cost of major milestone estimate increases are proposed as 25 percent instead of 20 percent as proposed by DG-1071. We believe it is appropriate to maintain the 25 percent as previously proposed. This is appropriate since the impact of cost changes on the decommissioning fund from even the major milestones will be less significant that the impact of cost changes in the total estimated costs.
i