ML23005A241
| ML23005A241 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 12/16/2022 |
| From: | Schlueter J Nuclear Energy Institute |
| To: | Office of Administration |
| References | |
| NRC-2022-0190, 87FR73345 00001 | |
| Download: ML23005A241 (1) | |
Text
1/5/23, 3:07 PM blob:https://www.fdms.gov/0f0339b8-9f91-427d-b04f-c0fb7444f148 blob:https://www.fdms.gov/0f0339b8-9f91-427d-b04f-c0fb7444f148 1/1 PUBLIC SUBMISSION As of: 1/5/23, 3:06 PM Received: December 16, 2022 Status: Pending_Post Tracking No. lbq-u6i9-wznn Comments Due: December 29, 2022 Submission Type: Web Docket: NRC-2022-0190 Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities Comment On: NRC-2022-0190-0001 Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities Document: NRC-2022-0190-DRAFT-0001 Comment on FR Doc # 2022-26018 Submitter Information Organization:Nuclear Energy Institute General Comment See attached file(s)
Attachments 12-16-22_NRC_Industry Comments on Draft NUREG-1307 Rev 19 on LLW Disposal Charges SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Emil Tabakov, Richard Turtil, Shawn Harwell, Patricia Cline-Thomas, Mary Neely Comment (1)
Publication Date:
11/29/2022 Citation: 87 FR 73345
JANET R. SCHLUETER Sr. Advisor, Fuel and Radiation Safety 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8098 jrs@nei.org nei.org December 16, 2022 Office of Administration U.S. Nuclear Regulatory Commission Mail Stop: TWFN-7-A60M Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff
Subject:
Industry Comments on Draft NUREG-1307, Revision 19, Report on Waste Burial Charges; Docket NRC-2022-0190; 87 FR 73345 Project Number: 689
Dear Office of Administration:
On behalf of the Nuclear Energy Institutes (NEI)1 members (hereinafter referred to as industry), we provide the following comments on Draft Revision 19 of NUREG-1307, Report on Waste Burial Charges, regarding costs associated with the disposal of radioactive waste generated at NRC-licensed facilities. It is important to recognize that the safe management and disposal of all radioactive waste generated as a result of licensed operations and activities is of the utmost import to the nuclear industry. It is in this context that we offer the comment below which is repeated from our December 20182 and December 20203 letters and remains highly if not even more relevant today. We would appreciate feedback on how this comment will be addressed by the staff.
While the concept of very low-level waste (VLLW) is briefly discussed in the draft NUREG, additional language is needed to accurately reflect currently allowed disposal practices thus reducing the calculated decommissioning funding amounts. Vast volumes of VLLW generated during the decommissioning of nuclear facilities (and other activities as well) are currently approved by NRC and individual Agreement States for alternate means of disposal at a significantly lower cost than burial as Class A waste in a licensed LLW disposal facility.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Office of Administration December 16, 2022 Page 2 As such, we disagree with the statement on page viii that VLLW is difficult to quantify and forecast. Licensed facilities often estimate and collect such data as part of a radioactive waste management and decommissioning program. In fact, one NRC-licensed facility estimates that approximately 72% of its bulk Class A waste generated during decommissioning could be disposed of at a Resource Conservation and Recovery Act hazardous waste facility. And, if that same waste was disposed of as Class A, the disposal cost would increase 250%. NRC should also consider reviewing EPRI report 1024844 (available at EPRI.com) which contains information related to the development of a basis for VLLW as well as tables that provide VLLW volume estimates (i.e., Tables 8-3, 9-2, 9-3).
Finally, NRC acknowledges that the calculated decommissioning funding for waste disposal continues to be grossly over estimated. See the statement on page viii Revision 19 does not consider the use of alternate disposal methods of their potential impact to minimum decommissioning fund formula calculations.
Therefore, we respectfully request that NRC correct its decommissioning fund formula calculations to reflect current NRC and Agreement State approvals that allow for VLLW disposals in permitted (non-LLW) facilities.
If this action requires that NRC collect additional data and information from a sample of its licensees or Agreement States, NRC should proceed to do so.
We appreciate the opportunity to present our views on this important matter. Please do not hesitate to contact me if you have any questions about our comments or if we can provide any additional information to further inform the final version of NUREG-1307. We look forward to hearing how NRC intends to address this important matter.
Sincerely, Janet R. Schlueter c:
Jane Marshall, NMSS/DUWP Bo Pham, NMSS/REFS Emil Tabakov, NMSS/REFS/FAB