View source for CY-13-027, Comment (4) of Brantley Buerger on the Draft Regulatory Basis Document to Support Potential Amendment to Regulations Concerning Nuclear Power Plant Licenses' Station Blackout Mitigation Strategies (10 CFR Part 50 and 52), (NRC-2011-0299)

{{Adams
| number = ML13136A213
| issue date = 05/02/2013
| title = Comment (4) of Brantley Buerger on the Draft Regulatory Basis Document to Support Potential Amendment to Regulations Concerning Nuclear Power Plant Licenses' Station Blackout Mitigation Strategies (10 CFR Part 50 and 52), (NRC-2011-0299)
| author name = Buerger B
| author affiliation = Connecticut Yankee Atomic Power Co
| addressee name = 
| addressee affiliation = NRC/SECY
| docket = 05000213, 07200039
| license number = DPR-061
| contact person = 
| case reference number = 78FR21275 00004, CY-13-027, NRC-2011-0299, PR 10 CFR 50 &amp; 52
| document type = Rulemaking-Comment
| page count = 2
}}

=Text=
{{#Wiki_filter:PR 10 CFR 50 AND 52                                                                                            4 (78FR21275) c~:         CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD' EAST HAMPTON, CT 06424-3099 May 2, 2013 CY-13-027 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License No. DPR-61 (NRC Docket Nos. 50-213 and 72-39)

==Subject:==
Comments on Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52) Draft Regulatory Basis and Rule Concepts Document -- Docket ID NRC-2011-0299 Connecticut Yankee Atomic Power Company (Connecticut Yankee) appreciates the opportunity to comment on the subject Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52)
Draft Regulatory Basis and Draft Rule Concepts document (Reference 1) associated with the potential amendment of Nuclear Regulatory Commission regulations concerning nuclear power plant licensees' Station Blackout Mitigation Strategies.
The draft document does not address stand-alone 10 CFR 50 licensees that have permanently ceased operations, fully decommissioned and dismantled the former operating plant, and are storing spent nuclear fuel and Greater than Class C (GTCC) waste in a dry cask Independent Spent Fuel Storage Installation (ISFSI) ..ConneCticut Yankee's position isthattheDraft Regulatory Basis document arid subsequent~emaidng arb not applicable tol'(j "CFR50 licensees where"the operating rea.ctor arid th~ power plant have been coinpletelydecommissioned and the licensee only operates a dry storage ISFSI at the former reactor site.
Accordingly, Connecticut Yankee requests that the final regulatory basis document and future development of the Station Blackout Mitigation Strategies rulemaking clearly delineate that it applies to holders of, of applicants for,an operating license under 10 CFR 50,except those;
: 1) 10 CFR 50 license<es 'o/ho p.ave ptirmanently ceasedoperations,'2) certified that fuel has been permanently removt~d from the reaCtor vessel, and 3) removed all fuel from the spent fuel pool.
This letter contains no regulatory commitments.

Connecticut Yankee Atomic Power Company CY-13-027IMay 2, 2013IPage 2 If you have any questions regarding this submittal, please do not hesitate to contact me at (860) 267-6426 ext. 303, or at bbuerger@3yankees.com.
Respectfully,
~r,p.E.
ISFSIM ager

==Reference:==
: 1.      NRC request for comments on Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52) Draft Regulatory Basis and Rule Concepts (Federal Register Notice 21275 21276) cc:     NRC Document Control Desk W. M. Dean, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region 1 J. Goshen, NRC Project Manager, Haddam Neck}}