ML17249A094
| ML17249A094 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 09/05/2017 |
| From: | Cummings K Nuclear Energy Institute |
| To: | Patricia Silva Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML17249A093 | List: |
| References | |
| Download: ML17249A094 (3) | |
Text
KRISTOPHER W. CUMMINGS Senior Project Manager Fuel and Decommissioning 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8031 kwc@nei.org nei.org September 5, 2017 Ms. Patricia Silva Chief, Inspections and Operations Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission
Subject:
Transmittal of NEI 12-04, Revision 1, Draft A, Guidelines for 10 CFR 72.48 Implementation Project Number: 689
Dear Ms. Silva:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 is transmitting to the U.S.
Nuclear Regulatory Commission (NRC) an updated revision to NEI 12-04, Guidelines for 10 CFR 72.48 Implementation. This revision addresses the 11 fundamental issues identified during a series of public meetings conducted between NRC and NEI in 2016 and 2017 (reference [1 through 4]).
We recommend that the NRC endorse the revised NEI 12-04 through a revision to Regulatory Guide 3.72.
Upon endorsement by the NRC, NEI 12-04 would replace NEI 96-07, Appendix B. We would then remove Appendix B from NEI 96-07; however, no changes to the guidance in NEI 96-07 or its other appendices pertaining to 10 CFR 50.59 would be necessary. Until NEI 12-04 is endorsed by the NRC, NEI 96-07 Appendix B continues to remain an acceptable approach to meet 10 CFR 72.48.
The industry believes that this revision is reflective of the progress made to achieve alignment on a common understanding of the 72.48 process over the past five years. Therefore, industry is requesting a meeting with NRC to discuss detailed wording, reflecting this alignment, and finalize the text contained in NEI 12-04 to support the endorsement process. To support the completion of this document, we request NRC comments and/or markup of the enclosed document no later than October 20, 2017 so that this meeting can be held during the week of November 6, 2017. The details of the schedule have been discussed previously with Mr. Raynard Wharton of the NRC.
1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
Ms. Patricia Silva September 5, 2017 Page 2 Please contact me at your earliest convenience regarding the scheduling of proposed meeting or if you have any additional questions regarding industrys plans to complete NEI 12-04 for your endorsement.
References:
- 1. Summary of July 11, 2017, Meeting with Nuclear Energy Institute to Discuss Nuclear Energy Institutes Proposed Language on Method of Evaluation to be Included in NEI 12-04, Guidelines for 10 CFR 72.48 Implementation, Revision 0, ML17226A010
- 2. Summary of May 11, 2017, Meeting with Nuclear Energy Institute to Discuss NRC Responses Nuclear Energy Institute Industry Summary Issues Related to NEI 12-04, Guidelines for 10 CFR 72.48 Implementation, Revision 0, ML17164A056
- 3. U.S. Nuclear Regulatory Commission letter U.S. Nuclear Regulatory Commission Response to Industry Summary Meeting Conducted to Discuss Fundamental Issues Regarding Nuclear Energy Institute Submittal: Guidelines for Title 10 of the Code of Federal Regulations 72.48 Implementation, Revision 0, Patricia A. Silva to Rod McCullum, dated March 3, 2017, ML17065A186, ML17065A188
- 4. Nuclear Energy Institute letter Industry Summary of Meeting with the NRC Pertaining to NEI 12-04, Guidelines for 10 CFR 72.48 Implementation, Revision 0, Dated August, 2012, Rod McCullum to Patricia Silva, dated August 8, 2016, ML16251A025, ML16251A028
- 5. U.S. Nuclear Regulatory Commission letter Final Response to the September 10, 2012 Guidelines for 10 CFR 72.48 Implementation, Revision 0, Patricia A. Silva to Rod McCullum, dated April 24, 2015, ML15110A197.
- 6. U.S. Nuclear Regulatory Commission letter 2nd Interim Response to September 10, 2012 Guidelines for 10 CFR 72.48 Implementation, Revision 0, Patricia A. Silva to Rod McCullum, dated December 11, 2014, ML14349A402.
- 7. U.S. Nuclear Regulatory Commission letter Interim Response to September 10, 2012 Guidelines for 10 CFR 72.48 Implementation, Revision 0, Eric Benner to Rod McCullum, dated September 26, 2013, ML13260A030, ML13260A056, and ML13260A064.
Ms. Patricia Silva September 5, 2017 Page 3 Sincerely, Kristopher Cummings
Enclosure:
NEI 12-04, Guidelines for 10 CFR 72.48 Implementation, Revision 1, Draft A c:
Mr. Raynard Wharton, NMSS/DSFM/IOB, NRC Mr. Anthony Hsia, NMSS/DSFM, NRC Mr. Michael Layton, NMSS/DSFM, NRC Mr. Marc Dapas, NMSS, NRC NRC Document Control Desk