ML14070A181

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Comment (17) of J. Stanley Brown on Behalf of Maine Yankee Atomic Power Company on White Paper on a Conceptual Example of a Proposed Risk Management Regulatory Framework Policy Statement.
ML14070A181
Person / Time
Site: Maine Yankee
Issue date: 02/26/2014
From: Brown J S
Maine Yankee Atomic Power Co
To: Bladey C K
Rules, Announcements, and Directives Branch
References
78FR70354 00017, NRC-2013-0254, OMY-14-005
Download: ML14070A181 (2)


Text

MAINE YANKEE 321 Old Ferry Road, Wiscasset, Maine 04578 February 26, 2014/ OMY-14-005 Cindy Bladey, Chief ( /7 ,-i Rules, Announcements, and Directives Branch (RADB) 13D _Office of Administration, Mail Stop: 3WFN-06-44M F7] -r-U.S. Nuclear Regulatory Commission

.., Washington, DC 20555-0001

-.Maine Yankee Atomic Power Company T1 Maine Yankee Independent Spent Fuel Storage Installation bo NRC License No. DPR-36 (NRC Docket Nos. 50-309 and 72-30)

Subject:

Comments on the "White Paper on a Conceptual Example of a Proposed Risk Management Regulatory Framework Policy Statement" (ADAMS Accession No.MLI3273A517)

[Docket ID NRC-2013-0254]

On February 25, 2014, the Yankee Atomic Electric Company (YAEC) provided comments on the document: "White Paper on a Conceptual Example of a Proposed.Risk Management

.Regulatory Framework Policy Statement" (Federal Register.Notice November 25, 2013.) (White Paper). Via this letter, Maine Yankee. Atomic Power Company (Maine Yankee) is endorsing the comments provided by YAEC.Like YAEC, Maine Yankee 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. Thus, Maine Yankee supports the: " Adoption of a policy statement to establish a common risk management regulatory framework involving a more comprehensive and holistic risk-informed, performance-based regulatory approach that addresses the interim storage and transportation of spent nuclear fuel (SNF) and Greater than Class C (GTCC) waste at stand-alone ISFSI sites." Application of a risk management regulatory framework now, without the adoption of a policy statement, to the regulatory framework associated with interim storage and transportation of SNF and GTCC waste issues.In addition, giventhe low risks associated with interim spent fuel storage, Maine Yankee utrges that risk informed decision-making be applied to rulemakings associated with:.stand-alone ISFSI (e.g., ISFSJ site security rulemaking, the extended SNF storage and transportation regulatory paradigm directed by SRM-COMSECY-10-0007 and the associated staff's Licensing Program SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 A dd= 72,), e--o a)

Maine Yankee Atomic Power Company OMY-14-005/February 26, 2014/Page 2 Improvement review area that is focused on regulating ISFSIs, and retrieval of the canisters from the stand-alone ISFSI).Maine Yankee appreciates this opportunity to comment on the subject White Paper.Respectfully, Sley Brown ISFSI Manager cc: W. M. Dean, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager, Maine Yankee