ML20141A097

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Forwards Draft Regulatory Guide, Std Format & Content of License Termination Plan for Evaluating 10CFR50.82(a)(9), for Review
ML20141A097
Person / Time
Issue date: 06/15/1997
From: Greeves J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Blough A, Mallett B, Pederson C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
REF-WM-3 NUDOCS 9706200084
Download: ML20141A097 (15)


Text

. l June 15, 1997 MEMORANDUM TO: A. Randolph Blough. Director Division of Nuclear Materials Safety. R-I I Bruce A. Mallett. Director Division of Nuclear Materials Safety. R-II Cynthia D. Pederson Director Division of Nuclear Materials Safety. R-III Ross A. Scarano. Director Division of Nuclear Materials Safety. R-IV Thomas T. Martili. Director Division of Reactor Program Management. NRR William M. Morris. Director Division of Regulatory Applications. RES FROM: John T. Greeves. Director [0RIGINAL SIGNED BY:]

Division of Waste Management. NMSS SUBJEC'- REVIEW OF THE DRAFT STANDARD FORMAT AND CONTENT GUIDE FOR EVALUATING PART 50 LICENSE TERMINATION PLANS (10 CFR PART 50.82(a)(9))

I have attached a copy of the ** Standard Format and Content of !.icense Termination Plan for Evaluating Part 50 Requirements (10 CFR Part 50.82(a)(9))" for your review and comment. The staff has developed the draft , ,

guide to ensure that the license termination plan adequately addresses the /

requirements in 10 CFR 50.82(a)(9). I am requesting your comments be provide by July 15, 1997. Note that we incorporated your comments on our draf t Standard Review plan dated April 4, 1997, where applicable into our draft /

Standard Format and Content Guide for a License Termination Plan.

Attachment:

As stated

Contact:

Larry Pittiglio. LLDP/DWM n g j ,

hvl 'i i TICKET:N/A (301) 415-6702 %A [

DISTRIBUTION: sCentralsFile LLDP r/f DWM r/f NMSS r/f PUBLIC PSobel MFederline o SEE PREVIOUS CONCURRENCE E' L;>' u m n q 7 6 M g, 72 Path & File Name: J:\DWM\LLDP\CLP\SFC.LTR S:\DWM\CLP\SFC 0FC R$1/P) LLDP LLDP LLDP& A/ JM N NAME [Iihg[io* EK* TJohnson* JHibey k(deees DATE Y /97 5////97 [/b97 [#9/97 b//697 0FFICTAL RECORD COPY g ACNW: YES N0 x Category- Proprietary or CF Only 1G  : YES NO x LSS : YES N0 x Delete file after distribution: Yes No x

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.. *' '* '[" 4* UNITED STATES - ,

NUCLEAR REGULATORY COMMISSION o I f- WASHINGTON, D.C. 20556-0001 i s*****/ June 15, 1997 t

i MEMORANDUM.TO: A. Randolph Blough, Dir actor '

Division of Nuclear Mcterials Safety. R-I Bruce A. Mallett Director Division of Nuclear Materials Safety R-II Cynthia D. Pederson, Director  !

Division of Reactor Safety. R-III  !

Ross A. Scarano Director  !

Division of Nuclear Materials Safety. R-IV Thomas T. Martin. Director Division of Reactor Program Management, NRR l

J Bill M. Morris Director Division of Regulatory Applicati ns. RES )

FROM: John T Greeves, Director Division of Waste Manageme , NM5S 1

SUBJECT:

REVIEW OF THE DRAFT STAND FORMAT AND CONTENT GUIDE FOR EVALUATING PART 50 LICENSE TERMINATION PLANS (10 CFR PART 50.82(a)(9)) 7 I have attached a copy of the " Standard Format and Content cf a License Termination Plan for Evaluating Part 50 Requirements (10 CFR Part 50.82(a)(9))" for your review and comment. The staff has developed the draft guide to ensure that the license termination plan adequately addresses the requirements in 10 CFR 50.82(a)(9). I am requesting your comments be provided by July 15. 1997. Note that we incorporated your comments on our Draft Standard Review Plan dated April 4.1997, where applicable, into our Standard  ;

Format and Content Guide for a License Termination Plan.

Attachment:

As stated

Contact:

Larry Pittiglio. LLDP/DWM i (301) 415-6702 l

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l REGULATORY GUIDE l (Task 97-XX)

STANDARD FORMAT AND CONTENT OF '

A LICENSE TERMINATION PLAN FOR I EVALUATING PART 50 REQUIREMENTS i

i. (10 CFR 50.82(a)(9))

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U.S. Nuclear Regulatory Commission l Office of Nuclear Material Safety and Safeguards

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TABLE OF CONTENTS h

A . I NT RO D U CTI O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I

1. G e ne ral . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

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2. Format ............. ............................... 2 2.1 Graphical Presentations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.2 Physical Specifications ................................. 2 l

' 2.3 Procedures for Updating or Revising Pages . . . . . . . . . . . . . . . . . . . . . 3  ;

B. CONTENT OF LICENSE TERMINATION PLAN .................... 4

1. General Information ..................................... 4
2. S ite Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3. Identification of Remaining Dismantlement .ictivities ................. 5 3.1 S c hed u l es . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ,
4. Re med iation Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
5. Final Radiation Survey Plan ................................ 7
6. Site End-Use Description (fe- Restricted Release) ................... 8
7. Update Site-Specific Decommissioning Cost . . . . . . . . . . . . . . . . . . . . . . . 8  ;
8. Supplemental Environmental Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 C. I M P L EM ENTATI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 D . R E F E R E N C ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 i

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A. INTRODUCTION

1. General On July 29, 1996, the Commission published amendments to its regulations in 10 CFR Parts 2,50, and 51 (61 FR 39278) (Ref 1), prescribing specific criteria for decommissioning nuclear power reactors, effective August 28,1996. Additional guidance on meeting the revised decommissioning criteria is contained in DG-1067,

" Decommissioning of Nuclear Power Reactors," dated May 1997 (Ref. 2). The amendments specify that a licensee would no longer be required to submit a decommissioning plan for approval before undertaking decommissioning activities.

Under the new rules, a licensee would be able to begin decommissioning after certain actions occur. First, the licensee would need to make two certifications to the U.S.

Nuclear Reguletory Commission: 1) that the reactor was permanently shut down; and

2) all spent fuel was removed from the reactor. After these certifications were submitted to NRC, the licensee would no longer be permitted to operate the facility, and a number of 10 CFR Part 50 technical requirement modifications would become effective to reflect the changed status of a mactor facility undergoing decommissioning. Next, th' licensee would need to submit a Post-Shutdown Decommissioning Activities Report (PSDAR), to NRC, which describes the activities to be undertaken, along with a schedule for these activities, an estimate of the expected costs, and a discussion of whether the environmental impacts of the proposed actions are bounded by existing environmen:al impact statements.

Additional guidance for meeting the informational requirements in the PSDAR is contained in DG-1071, " Standard Format and Content for Post-Shutdown Decommissioning Activities Report," dated May 1997 (Ref. 3). In addition, a mandatory hold for ninety (90) &j was included in the proposed rule, to allow time for the staff to review the licensee's submittal and to hold a public information meeting in the site vicinity.

Furthermore, the rule also specifies that an application for license termination must be accompanied or preceded by a License Termination Plan (LTP), which is reviewed and approved by NRC. The process outlined in the new rule for the LTP approval processes is similar to the process occurring under the previous 10 CFR 50.82 rule j when a decommissioning plan was submitted. A public meeting would be scheduled j near the site and any hearing held in relation to this plan (LTP) would fall under l Subpart L of 10 CFR Part 2 because, with fuel removed from the reactor, the reactor licensee would be more like a materials licensee where a less formal hearing process is involved.

The LTP can take the form of either of the following requests:

  • Release of facility and site for unrestricted use; or i l

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  • Release of the facility and site under restricted use conditions (residual radioactivity above release guidelines). Restricted release of a site is not envisioned by the rule nor by the " Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for Decommissioning of NRC-Licensed Facilities" (NUREG-1496) (Ref. 4), and would constitute an environmental impact not previously discussed in the licensee's environmental statement nor bounded by any previous generic environmental impact statements.

The LTP can also be an integral part of the licensee's PSDAR and be submitted with it. In the case when the LTP is submitted as part of the PSDAR, the requirements for approval would apply to the PSDAR. For a PSDAR submittal only, pursuant to 10 CFR 50.82(a)(4), the staff is not required to approve the PSDAR, but need only notice receipt of the PSDAR and hold a public meeting on it.

For the most part the LTP will be a final site characterization, remediation, and survey plan, and similar in context to the material contained in a typical decommissioning plan for material licensees The LTP will be submitted as a supplement to the licensee's Final Safety Analysis Report (FSAR) or equivalent document.

2. Format 2.1 Graphical Presentations Graphical presentations such as drawings, maps, diagrams, sketches, and tables shoold be employed if the information may be presented more adequately or conveniently by such means. Due concern should be taken to ensure that all ,

information so presented is legible, that symbols are defined, and that scales are not reduced to the extent that visual aids are nyessary t3 interpret pertinent items of information. These graphical presentations should be located in the section where they are primarily discussed. i l

References used may appear either as footnotes to the page where discussed or at the j end of each chapter.

l 2.2 Physical Specifications

a. Paper size ]

(1) Text pages: 8-1/2 x 11 inches.  ;

(2) Drawings and graphics: 8-1/2 x 11 inches; however, a larger size is acceptable provided the finished copy, when folded, does not exceed 8-1/2 x 11 l inches.

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b. Paper stock and ink. Suitable quality in substance, paper color, and ink density for handling and reproduction by microfilming or image-copying equipment.
c. Page margins. A margin of no less than 1 inch should be maintained on the top, bottom, and binding side of all pages submitted.
d. Printing (1) Composition: text pages should be single-spaced.

(2) Typeface and style: should be suitable for microfilming or image-copying equipment.

(3) Reproduction: may be mechanically or photographically reproduced. All pages of text should be printed on both sides and the image printed F-ai to head.

e. Binding. Pages should be punched for standard three-hole loose-leaf binders.
f. Page numbering. Pages should be numbered witi. the digits corresponding to the chapter followed by a hyphen and a sequential number e.g., the third page of Section 4 should be numbered 4-3. Do not number the entire report sequentially,
g. Table of contents. A table of contents and an index of key items should be included.

2.3 Procedures for Updating or Revising Pages Data and text should be updated or revised by replacing pages. The changed or revised portion on each page should be highlighted by a " change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding margin.

The line should be of the same length .s the portion actually changed.

All pages submitted to update, revise, or add pages to the report should show the date of change and change or amendment number. A guide page listing the pages to be inserted and the pages to be removed should accompany the revised pages.

When major changes or additions are made, a revised table of contents should be provided. l I

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B. CONTENT OF LICENSE TERMINATION PLAN

1. General Information The LTP should be submitted in the form of a supplement to the FSAR and accompanied by an application for license termination.

The licensee's name and address, license number, and docket number should agree with the most recent license. The LTP table of contents should address each of the following 10 CFR 50.82(a)(9) criteria, with any supporting information required:

  • Site radiological characterization,
  • Remaining site dismantlement activities,
  • Remaining site remediation,
  • Plan for the final radiation / release sursey,
  • Description of the end use of the site if not for unrestricted release,
  • Site-specific estimate of remaining decommissioning costs, and
  • A supplement to the environmental report, pursuant to 10 CFR 51.53, describing any new information or environmental changes associated with the licensee's proposed termination activities.

1 Licensees may address locations of data in other documents such as FSARS, l PSDARs, environmental reports. environmental assessments, and environmental )

I impact statements.

2. Site Characterization The entire characterization survey package should be submitted. However, in the .

l LTP, the site characterization may be submitted in the form of a detailed summary that provides sufficient information ( ange! of contamination levels, specific locations, i area maps, etc.) for the reviewer to assess the radiological and non-radiological conditions at the site without having to review extensive survey data tables and extract the desired information. The licensee can docket the entire site characterization package separately and reference it in the LTP, or it can be submitted as an integral part of the LTP.

l The LTP should include an historical description--including dates and type of occurrences -of all locations in and outside of the facility where such events as neutron irradiation of components and structures, radiological spills, burials, or other radiological accidents / incidents that did or could have resulted in contamination of structures, equipment, laydown areas, or soils (stibfloor and outside area) have occurred.

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The LTP should include a list of all locations in and outside the facility where any work with radioactive materials had been performed, what materials were involved, processes used in the work and the typical radiation and contamination levels existing during this work. Maps and drawings of the facility showing all modifications made to the radiological work areas in and outside of the facility during the Sie of the facility should be included. The LTP shall provide a quantitative site characterization (of radiological and non-radiological contaminants).

The licensee should describe in a summary form the current radiological and non-radiological status of the site. The detail of the characterization should allow NRC to determine the extent and range of radiological contamination of structures, residues, and environmental media. The survey should be sufficiently detailed to provide data for planning further remediation/ decommissioning activities, which include decontamination techniques, projected schedules, costs, waste volumes, and health ard safety considerations. A typical character 9ation should follow the guidance in NRC's " Draft Branch Technical Position on Site Characterization for Decommissioning," dated November 1994 (Ref. 5).

- 3. Identification of Remaining Dismantlement Activities The LTP should indicate the decommissioning objective and discuss how the proposed activities and tasks will achieve this objective and the reasoning used to select particular methods to be used in the dismantlement. The LTP should discuss tasks associated with the decontamination and dismantling methods, estimation of the quantity of radioactive material to be released to unrestricted areas, and the proposed control mechanisms, person-rem estimates, and radioactive waste characterization.

Those areas and equipment that need further remediation need to be described in sufficient radiological detail to allow the reviewer to estimate the radiological conditions that will be encountered during remediation of equipment, components, and structures Dismantlement techniques used should be thoroughly described. The details of mis section should be af sufficient detail for NRC to identify any inspection or technical resources needed during the dismantlement activities, i

The radiological status of each structure and component decontaminated or dismantled should be known. A remediation activity description that involves significant components, structures, contaminated soils, etc., that have not been identified in the facility descriptions or that have not been radiologically characterized is unacceptable.

Ilowever, a decommissioning activity that includes minor components or structures that have not been described is acceptable if the reviewer can reasonably estimate the component's or structure's relationship to other parts of the facility and can reasonably estimate the contamination level from the general information provided in  ;

the LTP.

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For major activities, such as waste tank removal, reactor internals removal, spent fuel pool decontamination. etc., the relationship between activities and tasks should be shown. Any significantly hazardous dismantlement method (use of divers in dismantlement, major component removal, blasting of facilities to rubble, etc.) should be discussed. The LTP should discuss worker and public safety for hazardous dismantlement activities.

3.1 Schedules For major dismantlement activities (as defined in 10 CFR 50.2), the relationship between those activities and supporting tasks should be shown. Schedules should clearly indicate the estimated time for completion of decommissioning.

4. Remediation Plans During remediation the release criteria in effect will be either that of Regulatory Guide 1.86 (Ref. 6) or the revised decommissioning criteria approved on May 21, 1997 (Ref. 7).

The LTP should address the radiological controls to be implemented for the control of non-radiological and radiological contamination associated with further decommissioning and remediation.

The LTP should discuss in detail how facility areas and site areas will be remediated to meet NRC release criteria. Discussions should focus on any unique techniques or procedures used to evaluate the effectiveness of remediation, including any computer modeling programs. If the end use of the site is not for unrestricted release the LTP should provide in detail dose modeling projections and institutional controls to be effected over the site. The LTP should clearly indicate the residual release criteria being applied to each area and justification for using a specific dose pathway analysis.

The LTP should explicitly describe the radiation and contamination leveis expected upon release of the facility for unrestricted use and provide a justification if they are different from existing or accepted guidance.

The LTP should address the waste handling procedures for minimizing the spread of contamination when transporting the waste from the point of generation to the area where it is to be processed, or packaged and shipped. A major area of review is the licensee's proposed methods for processing, packaging, and shipping radioactive waste. Radioactive waste can be characterized by volume, form, and classification.

The isotopic composition, activity, and construction material of the waste should also be described.

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5. Final Radiation Survey Plan ,

t The final radiation survey is one of the most important aspects of the license i

termination since it is the primary document supporting the decision to release a facility for unrestricted use. The guidance in draft NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination," (Ref. 8) should j i

be closely followed. It is helpful if the LTP provides an outline of the proposed final survey report. The outline can be reviewed to ensure that all necessary information will be reported. Examples of survey data sheets to be used should also be provided. j The LTP should describe the final survey plan for demonstrating that the plant and site will meet criteria for release for unrestricted use. The licensee is required to address all the items identified in NUREG-5849, and to address any deviations from NUREG-5849. Some of the items identified in NUREG-5849 that should be included i in the final radiation survey plan are:

a) The proposed method for ensuring that all equipment, systems, structures, and the site are included in the survey (diagrams, plot plans, and facility layout draw.ings should be used to facilitate presentation) and that sufficient data are included for meaningful statistical survey; 1

b) A description of methods ,to evaluate data on background radiation (variances in l background radiation can be expected between structures constructed of different materials) (Ref. 9);

i c) The type, specifications, and operating conditions of instruments to be used; d) Methods to be used for reviewing, analyzing, and auditing data (Refs. 8 and 10),

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e) Data that define background radia
on levels; i.

l f) Verification surveys used to support delineation of affected and unaffected areas; g) Identification of major contaminants;

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h) Detailed description of remediation criteria; l t

- i) Survey procedures for conducting field / survey work; j) Quality Assurance Program to support Final Survey, addressing training l qualifications, instrument calibrations, custody of data, data verification, and survey records; j k) Methodology used for addressing hard to detect nuclide:

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1) Soil, water, and air sampling procedures; I

m) Reclassification methodology; and I n) Access control procedures.

6. Site End-Use Description (for Restricted Release)

The LTP should discuss in detail the controls to be put in place and maintenance of the controls over the lifetime of the facility, to protect health and safety of the public.

If a restricted release is desired by the licensee, then site-specific dose criteria will be developed for the site and meet the restriction imposed by the final rule on decommissioning criteria approved May 21,1997 (Ref. 7).

7. Update Site-Specific Decommissioning Cost The license termination plan must:

a) Provide an estimate of the accommissioning cost, and b) Compare the cost with the present funds set aside for decommissioning. If there is a deficit in present funding, the LTP must indicate the means for ensuring adequate funds to complete the decommissioning.

Regulatory Guide 1.159, " Assuring the Availability of Funds for Decommissioning Nuclear Reactors" (Ref,11) provides detailed explanation of methods for estimating decommissioning costs, as well as acceptet financial assurance mechanisms, if the LTP indicates that assurance of funding is to be provided by use of a surety method, insurance, or other guarantee, then the method must remain in effect until the Commission has terminated the license. The decommissioning cost estimates should include an evaluation of the following elements as related to cost:

Cost Elements

  • Cost assumptions used, including contingency factor
  • Major decommissioning activities / tasks
  • Unit cost factors
  • Estimated equipment / structural decontamination and removal cost
  • Estimated waste disposal cost, including applicable disposal site surcharges
  • Estimated final survey cost
  • Estimated total cost 8

The cost estimate should focus on detailed activity-by-activity cost estimates, for each measurable activity associated with the decommissioning-including the cost of labor, materials, equipment, energy, and services. No credit for the salvage value of equipment should be taken.

8. Supplemental Environmental Report If the licensee's proposed termination activities result in significant environmental changes not bounded by the site-specific decommissioning activities described in the PSDAR, previous issued environmental assessment or environmental impact statement, the licensee should submit a Supplemental Environmental Report describing the impacts associated with those site-specific termination activities.

Supplemental Environmental Report should-a) Describe in detail the impact of the site-specific termination activity, b) Compare the impact witF previously ana!yzed termination activities, and c) Analyze the environmental impact of the site-specific activity.

The Supplemental Environmental Report should include:

a) Description of the facility to be decommissioned, b) Description of the site and th: :::v!rons (climate, demography, socialeconomics, geology, hydrology, seismology, and meterology of the site),

c) Proposed decommissioning actions, d) Radiological and non-radiological impacts, e) Alternatives to the proposed action.

C. IMPLEMENTATION This Standard Format and Content Guide (SF&C) will be used to provide information to licensees regarding the staff's plans for evaluating conformance of LTP submittals-- >

including submittals in acceptable alternative formats--with Commission regulations. The provisions of this SF&C apply to submittals made after the SF&C's date of issuance.

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! D. REFERENCES- l l

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1. - U.S. Code of Federal Regulations,10 CFR 50.82, " Termination of License"

} (61 FR 39278).

4 - 2 .- U.S. Nuclear Regulatory Commission, Draft Regulatory Guide DG-1067,

, " Decommissioning of Nuclear Power Reactors," May 1997.

1 l 3. U.S. Nuclear Regulatory Commission, Draft Regulatory Guide DG-1071,  ;

j " Standard Format and Content for Post-Shutdown Decommissioning Activities Report," May 1997.

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4. U.S. Nuclear Regulatory Commission, NUREG-1496, " Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for

[ Decommissioning of NRC-Licensed Facilities," August 1994.

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1 l 5. U.S. Nuclear Regulatory Commission, " Draft Branch Technical Position on Site i Characterization for Decommissioning, (NMSS/DWM), November 1994. [

! 6. U.S. Nuclear Regulatory Commission Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors."

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l 7. U.S. Nuclear Regulatory Commission, SECY-97-046, " Final Rule on Radiological' j Criteria for License Termination," February 1997.

4 8. U.S. Nuclear Regulatory Commission, NUREG/CR-5849, " Manual for I o Conducting Radiological Surveys in Support of License Termination,"  !

Draft, June 1992.

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. 9. U.S. Nuclear Regulatory Commission. NUREG 1501, " Background as a Residual i Radioactivity Criterion for Decommissioning," Draft, August 1994.

l 10. U.S. Nuclear Regulatory Commission, NUREG-1500, " Working Draft Regulatory Guide on Release Criteria for Decommissioning: NRC Staff's Draft for Comment," August 1994.

11. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, " Assuring the
Availability of Funds for Decommissioning Nuclear Reactors."

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. , ~ , ., _ _. __ _, _ , _ _ . . _ . . . .___ _ ____ __ _ _

MEMORANDUM TO: A. Randolph Blough. Director Division of Nuclear Materials Safety. R-I l l

Bruce A. Mallett. Director Division of Nuclear Materials Safety. R-II Cynthia D. Pederson. Director Division of Nuclear Materials Safety. R-III Ross A. Scarano. Director Division of Nuclear Materials Safety. R-IV Thomas T. Martin, Director Division of Reactor Program Managemen . NRR William M. Morris. Director Division of Regulatory Applicatio s, RES FROM: John T. Greeves. Director [0RI NAL SIGNED BY:] l Division of Waste Management NMSS l l

SUBJECT:

REVIEW OF THE DRAFT STAND D FORMAT AND l CONTENT GUIDE FOR EVALUA NG PART 50 LICENSE TERMINATION l PLANS (10 CFR PART 50.8 (a)(9)) l I have attached a copy of the " andard Format and Content of License Termination Plan for Evaluating Part 0 Requirements (10 CFR Part 50.82(a)(9))" for your review and mment. The staff has developed the draft guide to ensure that the license rmination plan adequately addresses the requirements in 10 CFR 50.82(a)( I am requesting your comments be provided by July 15, 1997. Note that we incorporated your comments on our draft Standard Review plan dated Apr 1 4. 1997, were applicable, into our draft l Standard Format and Content ide for a License Termination Plan.

Attachment:

As stated .

Contact:

Larry Pittiglio. LLDP/DWM l (301) 415-6702 l TICKET: )

DISTRIBUTION: Central File LLDP r/f DWM r/f NMSS r/f PUBLIC JSurmeier Path & File Name: S:\DWM\ DP\CLP\SFC.LTR S:\DWM\CLP\SFC l OFC LLDP[ [LLDP LLDP_/ LLDP DWM NAME LPidihs/c/ EK TJMcTi JHickey JGreeves DATE M97 [ 5//h97 [/6797 5/ /97 5/ /97 FICTAL RECORD COPY ACNW: YES 0 x Category: Proprietary or CF Only IG : YES N0 x LSS YES NO x Delete file after distribution: Yes No x l

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