CY-15-024, Comment (3) of Brantley Buerger on Behalf of Connecticut Yankee Atomic Power Co., Proposed Draft Regulatory Guide DG-5057, Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities, Proposed Rev. 3 of Regulatory.
| ML15163A025 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 06/03/2015 |
| From: | Buerger B Connecticut Yankee Atomic Power Co |
| To: | Cindy Bladey Division of Administrative Services |
| References | |
| 80FR27709 00003, CY-15-024, NRC-2015-0120 | |
| Download: ML15163A025 (2) | |
Text
CONNECTICUT YANKEE PAOLt.,1 7)1bWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW RD ,"EAS iA:TON, 1T CT 06424-3099
ý, ;7 7June 3,2015 RR \.-,'F _ CY-15-024 Ms. Cindy Bladey, Office of Administration, Mail Stop: OWFN-12-H08, U.S. Nuclear Regulatory Commission, Washington, DC 20555 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 Proposed Draft Regulatory Guide DG-5057, "Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities," Proposed Revision 3 of Regulatory Guide 5.29, dated June 2013 [Docket ID NRC-2015-0120]
Connecticut Yankee Atomic Power Company (CYAPCO) appreciates the opportunity to provide comments on the proposed Draft Regulatory Guide DG-5057, "Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities." CYAPCO is a 10 CFR Part 50 Licensee that operated a single unit nuclear power plant that is now permanently shut down and decommissioned. All that remains at the site is an Independent Spent Fuel Storage Installation (ISFSI) that utilizes a 10 CFR Part 72 licensed dual-purpose dry cask storage system. All Special Nuclear Material (SNM) is stored within the dry cask storage system and is in a static storage condition.
CYAPCO is concerned that the NRC did not address or include guidance specific to stand-alone ISFSI sites that have completed decommissioning within the proposed Draft Regulatory Guide DG-5057, "Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities." CYAPCO believes that the guidance should be enhanced to acknowledge the existence of stand-alone ISFSIs that have completed decommissioning of the nuclear plant, and define compliance options specific to those licensees.
In addition, CYAPCO previously supplied comments regarding the proposed rulemaking on March 10, 2014. CYAPCO does not believe the NRC provided a sufficient safety basis, data or analysis to justify the fundamental restructuring of the current Material Control and Accounting practices for a stand-alone ISFSI. Given the low risks associated with spent fuel stored in dry canisters at stand-alone ISFSI sites, CYAPCO believes that the NRC should utilize a risk-informed approach regarding stand-alone ISFSls in the revised rule and the associated guidance document.
SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03
Connecticut Yankee Atomic Power Company CY-15-024/June 3, 2015/Page 2 of 2 If you have any questions regarding this submittal, please do not hesitate to contact me at (860) 267-6426 ext. 303.
Respectfully, Brante rger, P.E.
ISFSI Manager cc: D. H. Dorman, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager