View source for LR-N12-0376, Comment (10) of Jeffrie J. Keenan of Pseg Nuclear, LLC on Revision 15 of NUREG-1307, Report on Waste Burial Charges: Changes in-Decommissioning Waste Disposal Costs at Low-Level Waste-Burial Facilities.

{{Adams
| number = ML12340A144
| issue date = 11/15/2012
| title = Comment (10) of Jeffrie J. Keenan of Pseg Nuclear, LLC on Revision 15 of NUREG-1307, Report on Waste Burial Charges: Changes in-Decommissioning Waste Disposal Costs at Low-Level Waste-Burial Facilities.
| author name = Keenan J J
| author affiliation = PSEG Nuclear, LLC
| addressee name = Bladey C K
| addressee affiliation = NRC/ADM/DAS/RDEB, NRC/Document Control Desk
| docket = 05000272, 05000311, 05000354
| license number = 
| contact person = 
| case reference number = 77FR58591 00010, LR-N12-0376, NRC-2010-0362
| document type = General FR Notice Comment Letter
| page count = 3
}}

=Text=
{{#Wiki_filter:PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236-R"ULES AND DIRECTIVES BRANCH U, SNR(" 201? DEC -q AM 9-15 0 PSEG Nuclear LLC November 15, 2012 LR-N12-0376-RECE....VED R C , F-1 \ /E Ms. Cindy K. Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration Mail Stop: TWB-05-BOIM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 2~7' 7 ~ /

==Subject:==
PSEG Nuclear's Comments on Revision 15 of NUREG-1307, "Report on Waste Burial Charges: Changes in-Decommissioning Waste Disposal Costs at LowzLevel Waste-Burial Facilities" (Docket ID: NRC-2010-0362)

==Dear Ms. Bladey:==
PSEG Nuclear ('PSEG') as operators of the Salem and Hope Creek facilities fully support the comments supplied by the Nuclear Energy Institute 
('NEI') on Revision 15 to NUREG-1307.
In addition, PSEG is providing the comments in this letter to (1) ensure the Salem and Hope Creek data presented in Table A-4 is accurate, (2) comment on Greater than Class C Waste, and (3) supply insight into the business controls and philosophy we plan on-employing in addressing low level waste burial.PSEG Table A-4 Clarifications for Salem and Hope Creek For the Salem station we offer the following clarifications.
Salem is planning on employing the SAFSTOR method as supported by the NRC filing on March 31, 20091 and on September 15, 20012. Total process waste is approximately,73 Thousand ft 3/unit, total volume of waste generated for Unit 1 176 Thousand ft 3 and Unit 2 186 Thousand ft 3 , process waste disposal inclusive to shipment to Clive Utah is Unit 1 96 Thousand ft 3 and Unit 2 104 Thousand ft 3 , and Class A, B, C and GTCC inclusive to shipment to Barnwell South Carolina is Unit 1 81 Thousand ft 3 and Unit 2 82 Thousand ft 3.Based on the above information the percentage of direct disposal would be 46% for Unit 1 and 44% for Unit 2 and the percentage of processed waste would be 54% for Unit 1 and 56% for Unit 2.1 ADAMS ML110900521 2 ML11278A108
,/~/QF~
Ms. Cindy K. Bladey November 15, 2012 Page 2 For the Hope Creek station we offer the following clarifications.
The total Hope Creek capacity was uprated to 1275 MWe in 20093. The plant docket number 50-354 should be added to the Table. The total volume of waste generated should be 461 Thousand ft 3 , process waste disposal inclusive to Clive Utah should be 331 Thousand ft 3 , and Class A, B, C and GTCC inclusive to shipment to Barnwell is 130 Thousand ft 3.Based on this information the percentage of direct is 28% and the percentage of processed waste is 72%.., Importantly, the percentage of process waste will be driven by market based considerations.
The percentage cited above for processed waste will likely increase if it is more economical to process waste instead of direct disposal.
The percentage of Class A waste being processed will likely be far higher due to the current preferred pricing at the Clive Utah facility.Greater than tC--ass C Waste While Greater than Class C Waste represents less than one percent of the waste generated by volume, it does contribute materially to the costs considered in NUREG-1307 Appendix B.In the initial rulemaking for 10 CFR &sect;50.75 it was expressly stated that, "The Low-Level Radioactive Waste Policy Amendments Act of 1985 [Pub. L. 99-240, approved January 15, 1986, 99Stat. 1842] provides that disposal of waste exceeding Class C concentrations is the responsibility of the Federal government." 4 As mandated by the Act, PSEG Nuclear entered into conforming contracts with the Department of Energy.- As these costs have been 'acknowledged by the NRC as being the responsibility of the Federal government they should be excluded from the NUREG-1307 Appendix B cost estimate factor calculations.
PSEG Nuclear -Business Approach for Low Level Waste Disposal upon Decommissioning PSEG Nuclear supports the views expressed in the NEI comment letter regarding waste classification.
For Salem and Hope Creek, as a percentage of total volume of waste produced, Class a would be approximately 95% by molue. This percentage is congruent with the studies conducted by the NRC which specifically addressed classification of wastes from decommissioned large pressurized water reactors and boiling water reactors.5 As part of the commentaries in 10 CFR &sect;50.75 rulemaking the NRC 'summarized 
'that the great majority of the waste volume from decommissioning waste from power reactors as follows 6: ' ML081230540 4 53 Fed. Reg. 24040 5 See NUREG/CR-0130, Addendum 3 and NUREG/CR-0672, Addendum 2 6 See 53 Fed. Reg. 24040 1988 2 Ms. Cindy K. Bladey November 15, 2012 Page 3 Waste Class A B C Above C PWR (volume percent)98.0 1.2 0.1 0.7 BRW (volume percent)97.5 2.0 0.7 0.2 Consistent with our procurement practices, PSEG Nuclear will opt for the most cost effective means of waste disposal.
Based on current rates, use of process waste disposal would be maximized.
There are no regulatory, contractual or legal obligations which would otherwise restrict our ability to apply market based business decisions regarding low level waste disposal.Information in a March 2007 GAO Report provide evidence of the strong business preference toward disposing Class A waste at the Clive Utah facility.7 The manifest information management system data provide by DOE on waste disposal in 2005 demonstrates that 99.7%8 of Class A waste was disposed at Clive Utah. We respectfully request the Staff to consider this market based information in the NUREG revision.If you have any questions concerning these comments please feel free to contact me at 856-339-5429 or e-mail jeff.keenan@pseg.com Sincerely, A&#xfd;sciate General Nuclear Counsel PSEG Services LLC 7 GAO Report GAO-07-221, Appendix IV, Table 5.8 15,471,876 cubic feet of 15,516,893 cubic feet, GAO Report GAO-07-221, Appendix IV, Table 5.3}}