instance. clar CAN 9 3.18 (b) change from “…its renewal after expiration” This would create an unlicensed to “its renewal at or prior to expiration…” waste facility if licence is permitted to expire Modify sentence to read: avoid any ….to USA 5 3.19, In some cases, when multiple omissions or unnecessary duplications and line 3 regulatory authorities are involved, to prevent conflicting requirements, as P. 9 requirements could be more practicable, on the operating organization. stringent by one authority than the other due to timing and/or overlap of regulations. CAN 10 3.20 Change to: “If a facility is shut down and no Add new text to include regulatory X last sent. longer to be used for its intended purpose, guidance for the review of the final a final decommissioning plan and decommissioning plan. supporting documents shall be submitted COMMENT: Section 3.20 provides to the regulatory body for approval within regulatory guidance on the level of two years of permanent shutdown, unless review on “initial decommissioning an alternative schedule is agreed by the plan” which is conceptual. regulatory body. The regulatory body However, the section does not should review the specific decommissioning provide any similar guidance for arrangements in accordance with DS450. the final decommissioning plan. Consistent wording with DS450 which is referenced. 3.20 Delete This paragraph is concerned with UK 29 the assessment of decommissioning plans and not the management of radioactive wastes. There is adequate relevant guidance on the topic of decommissioning plans in alternative Safety Guides. Modify last sentence to read: USA 6 3.20, Completeness to ensure If a facility is shot down and no longer to be Line 4 compliance with State
instance. clar CAN 9 3.18 (b) change from “…its renewal after expiration” to “its renewal at or prior to expiration…” This would create an unlicensed waste facility if licence is permitted to expire USA 5 3.19, line 3 P. 9 Modify sentence to read: ….to avoid any omissions or unnecessary duplications and to prevent conflicting requirements, as practicable, on the operating organization. In some cases, when multiple regulatory authorities are involved, requirements could be more stringent by one authority than the other due to timing and/or overlap of regulations. CAN 10 3.20 last sent. Change to: “If a facility is shut down and no longer to be used for its intended purpose, a final decommissioning plan and supporting documents shall be submitted to the regulatory body for approval within two years of permanent shutdown, unless an alternative schedule is agreed by the regulatory body. The regulatory body should review the specific decommissioning arrangements in accordance with DS450. Add new text to include regulatory guidance for the review of the final decommissioning plan. COMMENT: Section 3.20 provides regulatory guidance on the level of review on “initial decommissioning plan” which is conceptual. However, the section does not provide any similar guidance for the final decommissioning plan. Consistent wording with DS450 which is referenced. X UK 29 3.20 Delete This paragraph is concerned with the assessment of decommissioning plans and not the management of radioactive wastes. There is adequate relevant guidance on the topic of decommissioning plans in alternative Safety Guides. USA 6 3.20, Line 4 Modify last sentence to read: If a facility is shot down and no longer to be Completeness to ensure compliance with State
a%20Consolidated%20MS%20Comments%20DS447.docx