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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20211N5231999-09-10010 September 1999 Memorandum & Order (CLI-99-24).* Grants Util Motion to Withdraw Without Prejudice Pending Appeal of ASLB Memorandum & Order LBP-99-14 & Vacates LBP-99-14 & LBP-99-17.With Certificate of Svc.Served on 990910 ML20211J8041999-09-0303 September 1999 Order.* Time within Which Commission May Take Sua Sponte Review Pursuant to 10CFR2.786(a) of Board Order (LBP-99-27) Hereby Extended to 990910.With Certificate of Svc.Served on 990903 ML20216D6571999-07-28028 July 1999 Memorandum & Order (Termination of Proceeding).* Orders That Intervenor 990517 Contentions Be Dismissed as Moot & Licensee Motion to Terminate Proceeding Be Granted.With Certificate of Svc.Served on 990729 ML20196K5271999-07-0606 July 1999 NRC Staff Response to Yankee Atomic Electric Co Motion to Terminate Proceeding.* for Listed Reasons,Licensing Board Should Grant Motion to Withdraw Application & Terminate Proceedings.With Certificate of Svc ML20212J5661999-07-0101 July 1999 Notice of Withdrawal.* Notice Given That Effective 990701 ML Zobler Withdraws Appearance in Yankee Atomic Electric Co Proceeding.All Mail & Service Lists Should Be Amended to Delete Name After That Date.With Certificate of Svc ML20212J6251999-06-29029 June 1999 Motion for Leave to Reply (Intervenor 990623 & 24 Filings).* Board Should Enter Order Terminating Proceeding,Without Prejudice & Without Conditions.With Certificate of Svc ML20196F1321999-06-24024 June 1999 Necnp Reply to LBP-99-22.* Recommends That Panel Should Grant Relief That Intervenors Requested for Reasons Stated. with Certificate of Svc ML20196F3801999-06-23023 June 1999 CAN Reply to Board Order of 990614.* Board Should Find Way to Satisfy Public Right to Know Answers to Questions CAN & Others Raised Re Yankee Rowe Site Contamination.Fees,Costs & Expenses Justified.With Certificate of Svc ML20196F1651999-06-22022 June 1999 Response to Board Request for Answers to Questions & Other Matters.* Contends That Intervenors & Public Interest Have Been Severely Prejudiced by Failure of Proceeding to Adjudicate Matters at Issue.With Certificate of Svc ML20196B1621999-06-17017 June 1999 Response of Yankee Atomic Electric Company to LBP-99-22.* Informs That Board Should Enter an Order Terminating Proceeding,Without Prejudice & Without Conditions. with Certificate of Svc ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20195H3941999-06-15015 June 1999 NRC Staff Response Re Yaec Board Notification (Withdrawal of Application) & Motion to Terminate Proceeding & Dismiss Appeal.* Commission Should Hold Abeyance Any Action on Yaec Motion to Dismiss Appeal.With Certificate of Svc ML20195F5551999-06-14014 June 1999 Memorandum & Order (Requesting Replies to Necnp Response to Termination Motion).* Parties Invited to Reply to Necnp 990607 Response No Later than 10 Days Following Svc of This Memorandum & Order.With Certificate of Svc.Served on 990614 ML20207H5791999-06-14014 June 1999 Motion of Yankee Atomic Electric Co for Leave to Respond to Intervenor Opposition To...Motion to Terminate (Etc).* Board Should Enter Order Terminating Proceeding,Without Prejudice & Without Conditions.With Certificate of Svc ML20207G2021999-06-0707 June 1999 Yankee Response to Intervenors Motion in Support of Yankee Motion for Dismissal of Appeal.* Recommends That Appeal Should Be Dismissed as Moot for Reasons Stated.With Certificate of Svc ML20195D7081999-06-0707 June 1999 Intervenor Opposition to Yankee Atomic Electric Co Motion to Terminate & Proposed Form of Order for Expenses,Fees & Responses to Discovery.* Panel Requested to Grant Motion to Withdraw by Imposing Conditions ML20195D7871999-06-0707 June 1999 Declaration of Jm Block,Attorney,New England Coalition on Nuclear Pollution,Inc.* Informs That Necnp Has Incurred Listed Expenses & Generated Listed Attorney Hours in Course of Proceeding.With Certificate of Svc ML20195D7281999-06-0606 June 1999 Declaration of F Katz,President,Citizens Awareness Network, Inc.* Informs That CAN Has Incurred Listed Expenses in Course of Entire Proceeding to Date ML20195C9301999-06-0505 June 1999 Motion in Support of Yankee Atomic Electric Co Motion for Dismissal of Appeal.* Commission Should Immediately Grant Yankee Atomic Electric Co Motion to Dismiss Pending Appeal & Dismiss Appeal with Prejudice.With Certificate of Svc ML20207D7031999-05-26026 May 1999 Board Notification (Withdrawal of Application) & Motion to Terminate Proceeding & Dismiss Appeal.* Commission Suggests That Pending Appeal by Licensee from LBP-99-14,should Be Dismissed.With Certificate of Svc ML20206Q2051999-05-17017 May 1999 Necnp Request for Permission to File Contentions & Contentions on Inadequacy of NRC Staff 990412 Environ Assessment & Finding of No Significant Impact of Approval of Yankee Nuclear Power Co License Termination Plan.* ML20206Q2391999-05-14014 May 1999 Declaration of Rj Ross,Cgwp,Hydrogeologist.* Declaration of Rj Ross Re NRC Staff Environ Assessment & Finding of No Significant Impact on License Termination Plan for Yankee Nuclear Power Station ML20206P1481999-05-13013 May 1999 Board Notification.* Informs That Yankee Determined to Modify Plan for Final Status Survey of Ynps Site So as to Employ so-called Marssim Survey Methodology Instead of 5849 Survey Methodology.With Certificate of Svc ML20206Q2261999-05-13013 May 1999 Second Declaration of M Resnikoff.* Declaration of M Resnikoff Re NRC Staff Environmental Assessment on Yankee License Termination Plan ML20206D1931999-04-30030 April 1999 CAN First Set of Interrogatories & Requests to Produce Served Upon Yaec.* Incorporates & Republishes General Instructions in Necnp First Set of Interrogatories & Requests.With Certificate of Svc.Related Correspondence ML20206B7131999-04-27027 April 1999 NRC Staff Response to Letter from Necnp.* Recommends That Jm Block 990424 Request That Board Take Action Re EA Prepared in Connection with Staff Review of LTP Filed by Yaec Be Denied for Reasons Stated.With Certificate of Svc ML20205R4631999-04-22022 April 1999 Memorandum & Order (Denying Motion for Reconsideration of Contention 4).* Yaec Motion for Reconsideration of Portion of LBP-99-14 That Admitted Necnp/Can Contention 4 Denied. with Certificate of Svc.Served on 990422 ML20205Q6921999-04-19019 April 1999 Erratum to Reply Brief of Intervenor Citizens Awareness Network,Inc to Yaec Appeal of Prehearhing Conference Order of ASLB (LBP-99-14) on 990317.* Reply Included Draft Front Page.With Certificate of Svc ML20205S0181999-04-19019 April 1999 Erratum,Reply Brief of Intervenor Citizens Awareness Network Inc to Yaec Appeal of Prehearing Conference Order of ASLB (LBP-99-14) on 990317.* Draft Front Page Was Inadvertently Included in Reply Brief.With Certificate of Svc ML20205S0251999-04-17017 April 1999 Necnp First Set of Interrogatories & Requests to Produce Served Upon Yaec.* Answers & Documents Should Be Provided to Listed Persons,At Each Round of Discovery Re License Termination Plan ML20205Q9151999-04-16016 April 1999 on Appeal from Prehearing Conference Order of ASLB Issued 990317 (LBP-99-14).Reply Brief of Intervenor Necnp.* LBP-99-14 Should Be Upheld.Preceeding Should Go Forward. with Certificate of Svc ML20205Q0661999-04-16016 April 1999 Citizens Awareness Network,Inc Reply to Yaec Appeal of Prehearing Conference Order.* Requests That Yaec Appeal of ASLB Prehearing Conference Order Be Denied for Foregoing Reasons of Law,Regulations & Fact.With Certificate of Svc ML20205P8821999-04-16016 April 1999 NRC Staff Response in Support of Yankee Atomic Electric Co Appeal of LBP-99-14.* Commission Should Grant Licensee Appeal & Reverse ASLB Decision in LBP-99-14.With Certificate of Svc ML20205P9161999-04-15015 April 1999 Opposition to Appeal from Prehearing Conference Order of Atomic Safety & Licensing Board Filed by Yae Issued 990317 (LBP-99-14).* Petitioner Requests That Commission Deny Appeal & Uphold LBP-99-14.With Certificate of Svc ML20205P8851999-04-14014 April 1999 Erratum (Reconsideration of Portion of Prehearing Conference Order).* Licensee Learned That Yae Incorrect in Stating That Decommissioning Plan Had Been Approved on Basis of TEDE Analysis.With Certificate of Svc ML20205P1851999-04-12012 April 1999 Motion for Leave to Reply (Reconsideration of Portion of Prehearing Conference Order).* Util Requests That Board Reconsider LBP-99-14 & Upon Consideration, Contention 4 Be Excluded.With Certificate of Svc ML20205P1151999-04-12012 April 1999 Motion for Leave to Reply to Yaec Motion for Leave to Reply (Reconsideration of Portion of Prehearing Order) & Yaec Reply.* Moves for Leave to Submit Reply to Yaec Reply or to Supplement Necnp Orginal Reply.With Certificate of Svc ML20205K9541999-04-0909 April 1999 Necnp Opposition to Yaec Motion to Reconsider Part of Prehearing Conference Order.* Necnp Requests That Panel Either Deny Yaec Omr Outright or Reconsider & Modify Contention 4 Only in Ways Suggested.With Certificate of Svc ML20205J3421999-04-0909 April 1999 NRC Staff Response to Yae Objection to & Motion for Reconsideration of Portion of Prehearing Conference Order.* Staff Agrees with Yae Arguments Supporting Motion.Board Should Grant Motion.With Certificate of Svc ML20205K8691999-04-0909 April 1999 Citizens Awareness Network,Inc Reply to Yankee Atomic Electric Co Objection to & Motion for Reconsideration of Portion of Prehearing Conference Order.* Licensee Motion for Reconsideration Should Be Denied.With Certificate of Svc ML20205K9181999-04-0808 April 1999 Opposition to Objection to & Motion for Reconsideration of Portion of Prehearing Conference Order Filed by Yaec.* Franklin Regional Council of Governments Opposes Motion & Requests That Board Deny Motion.With Certificate of Svc ML20205G0961999-04-0606 April 1999 Notice of Hearing.* Hearing Will Be Conducted in Proceeding Re License Termination Plan.With Certificate of Svc.Served on 990406 ML20205G0791999-04-0101 April 1999 on Appeal from Prehearing Conference Order of Atomic Safety & Licensing Board Issued 990317 (LBP-99-14)Brief of Licensee.* LBP-99-14 Should Be Reversed & Proceeding Should Be Dismissed.With Certificate of Svc ML20205G0661999-04-0101 April 1999 Notice of Appeal.* Util Appeals Prehearing Conference Order of Slb Denominated LBP-99-14,issued on 990317 & Served on Util on 990317.With Certificate of Svc ML20205E2861999-04-0101 April 1999 Memorandum & Order (Telephone Conference on 990331).* Orders That Responses by Intervenors & NRC Staff to Reconsideration Motion Are to Be Filed with ASLB by COB 990409.With Certificate of Svc.Served on 990401 ML20205G1461999-03-31031 March 1999 Transcript of Util (Yankee Nuclear Power Station) Telcon.* Telcon Held on 990331 in Rockville,Md.Pp 283-329 ML20205E2071999-03-28028 March 1999 Objection to & Motion of Yaec for Reconsideration of Portion of Prehearing Conference Order.* as Listed,Yaec Requests That Board Reconsider as Listed & Requests That Contention 4 of LBP-96-18 Be Excluded.With Certificate of Svc ML20205A8111999-03-25025 March 1999 Notice of Change of Address.* D Curran Hereby Gives Notice That as of 990329,Curran Mailing & e-mail Address Will Change to Address Listed.With Certificate of Svc ML20207M3491999-03-17017 March 1999 Prehearing Conference Order (Ruling on Contentions).* Approves Four Contentions Advanced by Necnp & CAN & Grants Requests for Hearing & Petitions for Leave to Intervene of Petitioners.With Certificate of Svc.Served on 990318 ML20202E9891999-01-27027 January 1999 Transcript of 990127 Prehearing Conference in Greenfield,Ma Re Yankee Atomic Electric Co (Yankee Nuclear Power Station). Pp 176-282 1999-09-03
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20203J9751998-02-27027 February 1998 Comment on NRC Notice Re Objection to Use of NSHC to Approve Util License Termination Plan for Plant ML20203J7361998-02-27027 February 1998 Comment Opposing Approval of NSHC to Plant License Termination Plan ML20217Q3521998-02-27027 February 1998 Comment on Federal Register Notice Concerning Approval of License Termination Plan, & Revised on 971218 ML20203J7621998-02-26026 February 1998 Comment Opposing NSHC Approval of License Termination Plan & Request for 10CFR2,subpart G Hearing on Plan ML20197B1721998-02-24024 February 1998 Comment Opposing Process & Substance of Planned Approval of Yankee Atomic Electric Co License Termination Plan & to Request NRC Reconsider Process Formulated & Substitute Hearing Under 10CFR2,subpart G ML20058L4981993-11-29029 November 1993 Comment Supporting Proposed Rule 10CFR72 Re Notification of Events at ISFSI at MRS Installation.Offers Comments Re Apparent Dichotomy Between Discussion in Proposed Rule & Existing TSs ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20058E0641993-11-10010 November 1993 Comment Supporting Proposed Policy Statement on Staff Meetings Open to Public ML20059E9571993-10-28028 October 1993 Comment Supporting Proposed Rule 10CFR171 Re Restoration of Generic Exemption from Annual Fees for Nonprofit Educational Institutions ML20058F9561990-10-18018 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20059P0451990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20062B5331990-10-11011 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Changes Permit Use of Simplicity & Power Resident in Application of Current Licensing Basis Concept to Create Logical License Renewal Process ML20059P0571990-10-11011 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N4221990-10-0101 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N4241990-10-0101 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N4251990-09-25025 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N3751990-09-24024 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N3581990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.No Price Can Be Put on Health & Safety of People Living Near Yankee Rowe Nuclear Power Plant ML20059N4231990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N3701990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N3711990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N3541990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Commission Should Work Towards Closing Yankee Rowe Atomic Power Plant on Schedule ML20059N3731990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N3791990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N3831990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N4201990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N4211990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N8371990-09-22022 September 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20248B6201989-08-0202 August 1989 Comments on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. NRC Should Permit Use of Potential Tax Refund as Source of Decommissioning Funds ML20235T3581989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Util Endorses Comments Filed by NUMARC & Nuclear Util Backfitting & Reform Group.Rule Fails to Provide Basis for Determining Effective Maint Program ML20205N0321988-10-18018 October 1988 Comment Supporting Proposed Rule 10CFR150 Re Reassertation of NRC Authority for Approving Onsite Low Level Waste Disposal in Agreement States ML20196E9501988-06-22022 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20150E3871988-03-23023 March 1988 Comment Supporting Proposed Rule 10CFR50,App J Re Alternative Method for Leakage Rate Testing.Change Would Remove Util of Burden of Seeking Exemption to App J in Order to Employ More state-of-the-art Statistical Analyses ML20236U3931987-11-25025 November 1987 Comments Supporting Rev to 10CFR2 Re Statement of Policy on Enforcement.Urges Commission to Expeditiously Issue Revised Policy on Matl False Statements 1998-02-27
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an afx yos K Wehr h 29, //f8 K U""" PaulM. Blanch neceiveo y Energy Consultant l998 HAR -6 An 8: 59 RULES & DR. EECH February 27,1998 US NRC
% J Chief, Rules and Directives Branch Division of Administration Services Office of Administration US Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Comments on Federal Register: January 28,1998 (Volume 63, Number ,
- 18) Yankee Atomic Electric Company, Docket No.50-029, Yarkee ,
Nuclear Power Station, Franklin County, Massachusu+ts
Dear Chief:
. Please consider the following comments in response to the above Federal Register Notice. Many of these comments and questions were discussed a the i
NRC public meeting held in Rowe MA on January 13,1998.
The proposed license amendment requests the approval of the License Termination Plan dated May 15,1997 and as revised December 18,1997.
Specific comments are as follows.
The Federal Register makes the following statement:
The proposed change willnot:
Create the possibility of a new or different kind of accident from any accident previously evaluated. Accident analyses are includedin the approved Decommissioning Plan and are incorporatedinto the FSAR. All )
y decommissioning and fuel storage activities described in the License Termination Plan are consistent with those in the approved Decommissioning Plan. The proposed change does not affect p%nt systems, structures, or components in any way not previously evaluated l in the approved Decommissioning Plan, and no new or different failure modes will be created. Therefore, the proposed change is administrative in nature and does not create the possibility of a new or different kind of yy accident from any pmviously evaluated.
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lt is unclear how the NRC Staff has arrived at this conclusion. Contained within I the proposed License Termination Plan is the request for approval for dry cask !
spent fuel storage. I am not aware of any site specific analysis' that considers -
such accMents as flooding, chemical explosions, sabctage. plane crashes, emergency planning for cask malfunctions and the potential removal of spent fuel from the dry cask in the event of cask or fuel prcblems. The use of dry cask j storage clearly creates "different kinds of accidents from any accident previously evaluated."
( 10 CFR 72.212(b)(5) requires that the spent fuel in the ISFS3 be protected L against the design basis threat for radiological sabotage. I am not aware of any ,
discussion.related to this requirement either in the License Termination or the
]
Decommissioning Plan. This comment applies to both wet and proposed dry fuel storage.
I
! My specific comments relaimi to the License Termination Plan are as foi!cws:
. Section 4.1 clearly sta'.es the site will be released for unrestricted use and l that the exposure " average member" of the of the critical population will be l
maintained at less than 15 mr/yr. Unrestricted usa allows one to inhabit the site for 365 days or 8740 hours0.101 days <br />2.428 hours <br />0.0145 weeks <br />0.00333 months <br /> per year. It is not clear what is rneant by the
" average member" of the of the critical population.
. Page A-7 clearly states that the maximum dose rate will be 10 micro R per hour. This would equate to an exposure of about 87 mr/yr. Please explain this apparent inconsistency in how a maximum exposure of 15 mr/yr wi'l be assured at a site with unrestricted use.
. The Haddam Neck plant has considered the total loss of water inventory from the spent fuel pool and provided the analysis to demonstrate compliance with the off-site radiological requirements of 10 CF. , Part 100. I am not aware of a similar analysis being conducted for the Yankee Rowe high level waste facility. This analysis appears to be missing from the License Termination l- Plan.
l With this proposed license amendment, the licensee is proposing to establish a high level waste repository under a license for an operating nuclear power reactor. Power operation of the Yankee Rowe facility ceased in 1992 and with
, the removal of all structures except those to support spent fuel storage, the ,
i licensee is establishing a high level waste repository under power reactor l license in my opinion, this proposed license amendent is totally inconsistent with the intent of either 10 CFR 50 or 10 CFR 72. 4
' 10 CFR 72 Subpart E-Siting Evaluation Factors 2
l L
The intent of 10 CFR 72 is to establish the regulatory requirements for the independent Spent Fuel Storage Installations (ISFSI). With the removal of all structures related to power reactor operation, the facility is, by default, an ISFSI.
j lt is unclear as to why the licensee and the NRC are clearly avoiding the t
requirements and the safeguards provided by Part 72, except for the financial incentive associated with retaining the Part 50 license.
l The NRC has recently acknowledged that the annual license fee for a Part 72 license is $283,000 whereas the annual fee for a non operating power reactor (Yankee Rowe) is zero. This appears to be a significant financial incentive for the
! licensee to avoid applying for the appropriate license, increasing the risk to the general public and saving the . licensee more than a quarter million dollars per year.
1 l While there is no absolutely safe means of providing for the long term storage of
!~
high level radioactive waste,10 CFR 72 attempts to address the requirements that will minimize the risk to the general public. To ignore these requirements, not consider the impact on the environment and the safety of the public, is not consistent with the intended role of the Nuclear Regub'.ory Commission.
In Part 72 Statements of Considerations, page 72-SC-5 the NRC clearly states:
1
" Storage of spent fuel on a reactor site outside of an existing reactor basin is already regulated under the criteria of Part 72 and these criteria have been used in reviewing applications for additional fuel storage at reactor sites."
This statement infers that if spent fuel is stored outside the existing spent fuel l pool, then the criteria of part 72 would apply and also infers that the licensee
! would be required to apply for a Part 72 license. Please explain why a Part 72 L license is not required for the long term storage of spent fuel outside the existing reactor basin [ spent fuel pool] given the previous statement from the NRC.
When part 50 was promulgated it was implicitly assumed that the reactor site would have all attendant features (security, emergency planning, and the unique environmental requirements for a long term high level waste repository). The absence of these " guarantees" at a true ISFSI is the teason for the "added" l provisions in Part 72. If Yankee Rowe proceeds down its current path, it becomes, a de facto ISFSI.
But, its abbreviated Part 50 license does not have all of its original assurances nor does it contain the gap-bridging features of Part 72. Also, Part 72's regulations were designed with consideration for the site being " stand-alone" or independent. Since permanently closed plants (PCPs) get a free ride with little or 3
l-
! no NRC inspector presence, use of Part 50 seems further eroded. Again, Part 50 was implemented with consideration that NRC inspection / enforcement would l ensure compliance. Part 72 was implemented with realization that reduced /non-l existent NRC inspection / enforcement would be needed to ensure compliance.
l The licensee proposes to continue its license under the provisions of 10 CFR Part 50 titled " Domestic Licensing of Production and Utilization Facilities.
) Reviewing the definitions of 10 CFR 50.2 it is unclear how a high level nuclear waste facility could be classified as either a " Production2" or a " Utilization "
l facility.
Please explain the intent of 10 CFR Part 72 if the NRC is not going to apply this regulation to the more than 70 nuclear plant sites about to be converted to long term high level waste facilities.
I appreciate this opportunity to comment on this Federal Register Notice and look i forward to your response.
l l l l
l Sincerely, foul #1/O Paul M. Blanch !
135 Hyde Rd.
West Hartford CT. 06117 l
l 1 i
- Production facility means:
(1) Any nuclear reactor designed or used primarily for the formation of plutonium or uranium-233; or (2) Any facility designed or used for the separation of the isotopes of plutonium, except laboratory scale facilities designed or used for experimental or analytical purposes only; or (3) Any facility designed or used for the processing of irradiated materials containing special nuclear material. . .
- Utilization facility means any nuclear reactor other than one designed or used primarily for the formation of plutonium or U-233 4