ML17165A330

Comment (25) from the Nuclear Energy Institute Regarding Regulatory Improvements for Power Reactors Transitioning to Decommissioning

ML17165A330
Person / Time
Site:	Nuclear Energy Institute
Issue date:	06/13/2017
From:	Mccullum R Nuclear Energy Institute
To:	Annette Vietti-Cook NRC/SECY/RAS
SECY/RAS
References
82FR13778 00025, NRC-2015-0070
Download: ML17165A330 (87)

Text

PUBLIC SUBMISSION As of: 6/14/17 8:53 AMReceived:

June 13, 2017Status: Pending_Post Tracking No.

1k1-8wxw-jeuxComments Due:

June 13, 2017 Submission Type:

Web Docket: NRC-2015-0070Regulatory Improvements for Power Reactors Transitioning to Decommissioning Comment On:

NRC-2015-0070-0178Regulatory Improvements for Power Reactors Transitioning to Decommissioning; Request for Comment on Draft Regulatory BasisDocument:

NRC-2015-0070-DRAFT-0216 Comment on FR Doc # 2017-05141 Submitter InformationName: Mark Richter General Comment See attached file(s)

Attachments 06-13-17_NRC_NEI Comments on Re gulatory Improvements for Power Reactors Transitioning to DecomissioningPage 1of 1 06/14/201 7 https://www.fdms.gov/fdms/g etcontent?objectId=09000064826d0e51&fo rmat=xml&showorig=fals e

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ATTACHMENT 1

2 Attachment 1 Federal Register Notice General Questions 1 through 5 Question 1 - Is the NRC considering appropriate options for each regulatory area described in the draft regulatory basis?

Question 2 -

Are there additional factors that the NRC should consider in each regulatory area? What are these factors?

3 Question 3 - Are there any additional options that the NRC should consider during the development of the proposed rule?

Question 4 - Is there additional information concerning regulatory impacts that NRC should include in its regulatory basis for rulemaking?

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5 Question 5 - Should the NRC address the exemption of 50.38 for licensees of facilities in decommissioning on a generic basis as a part of this rulemaking? If so, why, and how should the NRC address this issue?

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ATTACHMENT 2

10 Appendix A Emergency Preparedness Overview

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11 12 Spectrum of Accidents

Assessment of 10-hour Timeframe for Permanently Defueled Emergency Plans

13 14 Licensee Supporting Analyses and Commitments Timeframe for Taking Protective Actions Level 1: Post Shutdown Emergency Plan

15 Level 2: Permanently Defueled Emergency Plan

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Level 3: All Spent Fuel Transferred to an ISFSI

17 Notifications under 10 CFR 50.72

Additional Amendments for Emergency Planning

18 Plan Changes for the Next Level

Summary

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20 21 Appendix B Physical Security Overview

NRC-Conducted Force-on-Force Inspections

22 Suspension of Security Measures

Protection against Significant Core Damage

Training for Loss of the Ultimate Heat Sink Protection of the Control Room 23 Communications with the Control Room

Number of Armed Responders

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25 Safeguards Effectiveness

Transition to Physical Security Requirements Applicable to an ISFSI

26 Federal Register Notice Questions Related to Physical Protection of Quantities of Radioactive Materials (10 CFR 37)

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28 Category of Source Risk in being close to an individual source Risk in the event that the radioactive material in the source is dispersed by fire of explosion

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Federal Register Notice Questions Related to Physical Security 33 Appendix C - Cyber Security Overview NEI Response

34 Appendix D - Drug and Alcohol Testing Overview NEI Response

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38 Appendix E - Minimum Staffing and Training Requirements for Non-Licensed Operators, Including Certified Fuel Handlers Overview

39 Definition of Certified Fuel Handler

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50.120 Training and Qualification of Nuclear Power Plant Personnel 50.54(m) Minimum Requirements Per Shift for On-Site Staffing of Nuclear Power Units by Operators and Senior Operators

41 42 Appendix F - Decommissioning Trust Funds Overview

Use of the Decommissioning Trust Fund

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Triennial Reporting Requirement Miscellaneous Expense Allowance

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47 Correction of Shortfalls within Three Years

48 Site Specific Cost Estimates

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Additional Accompanying Administrative Changes 51 Miscellaneous Provisions and Comments

52 Appendix G - Offsite and Onsite Financial Protection Requirements and Indemnity Agreements Overview

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54 Offsite and Onsite Financial Protection Amounts

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Response to Federal Register Notice Question #11

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Application to Part 72 Specific ISFSI Licensees

57 Appendix H -Current Regulatory Approach to DecommissioningOverview

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58 Level of PSDAR Review and Approval by the NRC

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59 47

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The Appropriateness of Maintaining the Three Existing Options for Decommissioning 49

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50

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5253

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The 60 Year Timeframe Associated with Decommissioning

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64 57 The Role of State and Local Governments and Non-Government Stakeholders 58

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5960

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66 Clarifying the Spent Fuel Management Requirements of 10 CFR 72.218, 10 CFR 50.54(bb), 10 CFR 50.82 and 10 CFR 52.110 62

67 Clarifying the Environmental Requirements in 10 CFR Part 50 and 10 CFR Part 51 68 Appendix I - Application of Backfit Rule Overview

NEI Response

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70 Appendix J - Aging Management Overview NEI Response

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72 Appendix K - Fatigue Management Overview NEI Response

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74 ATTACHMENT 3

75 Preliminary Draft Regulatory Analysis for Regulatory Basis: Regulatory Improvements for Decommissioning

Summary Comments

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Specific Comments

Section 4.3 Physical Security

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Section 4.8 Decommissioning Trust Fund

79 Section 4.9 Offsite and Onsite Financial Protection Requirements and Indemnity Agreements Section 4.10 Application of Backfitting Protection

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