NUREG-0590, Comments on Draft NRC Paper Re Decommissioning,Per NUREG-0584 on Financial Assurance & NUREG-0590 on Regulatory Changes
| ML19254F553 | |
| Person / Time | |
|---|---|
| Issue date: | 10/24/1979 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bernero R NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| RTR-NUREG-0584, RTR-NUREG-0590, RTR-NUREG-584, RTR-NUREG-590, TASK-FP-902-1, TASK-OS NUDOCS 7911120020 | |
| Download: ML19254F553 (2) | |
Text
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OCT 2 41979 MEMORANDUM FOR: Robert M. Bernero, Assistant Director for Materials Safety Siandards Division of Engineering Standards Office of Standards Development FROM:
Richard E. Cunningham, Directo-Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguar'ds__
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SUBJECT:
REVIEW 0F PRELIMINARY DRAFT STAFF PAPERS ONsDECOMMISSIONING: '.
NUREG-0584 ON ?INANCIAL ASSURANCE AND NUREG-0590 h -
REGULATORY LHANGES Our comments on the subject draft documents are given below. We note that separate coments are being supplied by the Division of Waste Management, NMSS, with respect, particularly, to the implications of the documents on licensing of uranium mills and comercial low-level waste burial grounds.
NUREG-0584 - Assuring the Availability of Funds for Decommissioning Nuclear Facilities 1.
We believe that reference should be made in the first paragraph of page one to proposed 10 CFR Part 72, proposed licensing requirements for Storage of Spent Fuel in an Independent Spent Fuel Storage Installation (43 FR 46309) and proposed amendments to 10 CFR Part 40 pertaining to regulations on Uranium Mill Tailings Licensing (44 FR 50012). While it is true that " current Commission regulations are generally moo) on decommissioning non-reactor facilities and licensees," these regulations, which have been issued for public comment, would specifically require submission of decomissioning plans at the time of licensing and financial surety arrangements to assure that decomissioning funds will be available.
In this sense, these proposed regulations are precedent-setting and should be recognized in this document.
2.
It would be helpful if the document would indicate what provisions must be considered to determine acceptability of a proposed financial arrangement (particularly the prepayment or funded reserve methods) to assure that the funds are available for decommissioning only and not subject to demands of other creditors in event of bankruptcy.
1310 350 Q20 7911120 4
e Rober0 H. Bernero OCT 211979 s
3.
In past discussions concerning sinking funds or funded reserves as a means of establishing financial surety, it was indicated to us that certain SEC laws might also influence or restrict such' funding.
Has this aspect been considered in the development of this document?
NUREG-0590 - Thoughts on Regulation Changes for Decommissioning 1.
For the reason stated in the first comment above on draft NUREG-0585, we believe tha.t this document should recognize and reference the proposed regulations on spent fuel storage and uranium mill tailings.
Particularly in the case of mill tailings, the requirements specified in 44 FR 50012 provide more detail on the direction taken by NRC than indicated by draft NUREG-0590.
2.
Notwithstanding the parenthetical term in line 2 of Section 4.1, we request substitution of the word "decentamination" for the word
" dismantlement" throughout this section.
Decontamination to prescribed levels may involve total or partial dismantlement or perhaps no dismantlement, depending uoon the circumstances and the costs involved.
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Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards
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