ML13129A395

Comment (2) of James Connell on the Draft Regulatory Basis Document to Support Potential Amendment to Regulations Concerning Nuclear Power Plant Licensees' Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52), (NRC-2011-0299)

ML13129A395
Person / Time
Site:	Maine Yankee
Issue date:	05/01/2013
From:	Connell J Maine Yankee Atomic Power Co
To:	Vietti-Cook A L NRC/SECY
SECY RAS
References
10 CFR Parts 50 and 52, 78FR21275 00002, NRC-2011-0299, OMY-13-042
Download: ML13129A395 (2)

Text

Maine 321 OLD FERRY RD

• WISCASSET, ME 04578-4922 May 01, 2013 OMY-13-042 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001, A TIN: Rulemakings and Adjudications Staff Maine Yankee Atomic Power Maine Yankee Independent Spent Fuel Storage NRC License No. DPR-36 (NRC Docket Nos. 50-309 and Comments on Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52) Draft Regulatory Basis and Rule Concepts Document --Docket ID NRC-2011-0299 Maine Yankee Atomic Power Company (Maine 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 dlY cask Independent Spent Fuei Storage Installation (ISFSI). Maine Yankee's position is that the Draft Regulatory Basis document and subsequent rulemaking are not applicable to 10 CFR 50 licensees where the operating reactor and the power plant have been completely decommissioned and the licensee only operates a dry storage ISFSI at the former reactor site. Accordingly, Maine 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, or applicants for, an operating license under 10 CFR 50, except tl1o,se; 1) 10 CFR 50 licensees who have" permanently ceased operations, 2) certified that fuel has been permanently removed from the reactor vessel, and 3) removed all fuel from the spent fuel pooL This letter contains no regulatory commitments.

Maine Yankee Atomic Power Company OMY-13-042IMay 01, 2013IPage 2 If you have any questions regarding this submittal, please contact me at (207) 882-1303 or jconnel1@3yankees.com. Respectfully, a James Connell Vice President

Reference:

NRC request for comments on Station Blackout Mitigation Strategies (10 CFR Parts 50 and 52) Draft Regulatory Basis and Rule Concepts (Federal Register Notice 21276) 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, Maine Yankee