ML18184A348

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Comment (2) of Janet Schlueter on Behalf of Nuclear Energy Institute on State of Wyoming: NRC Staff Assessment of a Proposed Agreement Between the NRC and the State of Wyoming
ML18184A348
Person / Time
Site: Nuclear Energy Institute
Issue date: 07/02/2018
From: Schlueter J
Nuclear Energy Institute
To: Andrea Kock
Rules, Announcements, and Directives Branch
References
83FR29828 00002, NRC-2018-0104
Download: ML18184A348 (3)


Text

SUNSI Review Complete Template= ADM-013 E-RIDS=ADM-03 PUBLJ C SUBMJSSJ ON ADD=Stephen Poy COMMENT (2)

PUBLICATION DATE:

6//26/2018 CITATION# 83 FR 29828 Docket: NRC-2018-0104 As of: 7/2/18.1 :26 PM Received: July 02, 2018 Status: Pending_Post Tracking No. lk2-941r-fdhv Comments Due: July 26, 2018 Submission Type: Web State of Wyoming: NRC Staff Assessment of a Proposed Agreement Between the Nuclear Regulatory Commission and the State of Wyoming Comment On: NRC-2018-0104-0001 State of Wyoming: NRC Staff Assessment of a Proposed Agreement Between the Nuclear Regulatory Commission and the State of Wyoming Document: NRC-2018-0104-DRAFT-0002 Comment on FR Doc # 2018-13626 Submitter Information Name: Janet Schlueter Submitter's Representative: Allison Borst Organization: Nuclear Energy Institute General Comment See attached file(s)

Attachments 07-02-18 _ NRC _NEI Comments on Proposed WY Agreement

JANET R. SCHLUETER Sr. Diredor, Radiation and Materials Safety 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8098 jrs@nei.org nei.org July 2, 2018 Ms. Andrea Kock, Acting Director Division of Materials Safety, Security, State and Tribal Programs U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Submitted via regulations.gov

~I NUCLEAR ENERGY INSTITUTE

Subject:

NEI Support for NRC Staff Assessment of Proposed Agreement between NRC and State of Wyoming [83FR29828; Docket ID NRC-2018-0104J Reference No: 689

Dear Ms. Kock:

This letter is sent on behalf of the Nuclear Energy Institute1 (NEI) and its uranium recovery members with regard to the subject Federal Register (FR) notice. Specifically, the U.S. Nuclear Regulatory Commission's (NRC) staff assessment of the proposed Agreement between the NRC and the state of Wyoming as authorized under Section 274b of the Atomic Energy Act (AEA) of 1954 as amended. Under the proposed agreement, the Commission would discontinue, and the state of Wyoming would assume, regulatory authority over the management and disposal of byproduct materials as defined in Section 11e.(2) of the AEA and a subcategory of sour,ce material associated with uranium or thorium milling within the state.

First, and most importantly, we are confident-based on the published staff assessment-that uranium recovery operations in Wyoming will continue to be regulated in a manner that adequately protects public health and safety and the environment. We congratulate state officials on establishing a comprehensive regulatory program with well-trained staff in a relatively short period of time.

Secondly, we commend the NRC staff on its expeditious review and processing of the state's formal request and agreement application. Both pa~ies have worked together in an effective and efficient manner to reach this important milestone in the agreement application process.

1 The Nuclear Energy Institute (NEI) is responsible for establishing unified poiicy on behalf of its members relating to matters affecting the nuclear energy ii;idustry, including the regulatory aspects of generic operational and technical issues. NEl's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees,

.and other organizations involved in the nuclear energy industry.

NUCLEAR. CLEAN AIR ENERGY

Ms. Andrea Kock July 2, 2018 Page 2 Finally, if the agreement is finalized, two important points worth noting are: 1) uranium recovery licensees transferring to Wyoming will pay reduced regulatory fees-which is a significant benefit during these economically stressed times; and 2) transferring almost all licensees in one fee category (i.e., uranium recovery) from NRC to an agreement state is unprecedented and raises significant budgetary concerns for those licensees remaining under NRC jurisdiction. NRC should be transpa~ent as it right sizes the budget to address this significant change in workload and minimize the financial burden to the remaining licensees as NRC promulgates the fiscal year 2019 fee rule.

Thank you for the opportunity to comment. I may be contacted at jrs@nei.org or 202-739-8098 with any comments or questions on the content of this letter.

Sincerely,

~~

-:Janet Schlueter c:

Mr. John Tappert, NMSS/DUWP Mr. Paul Michalak, NMSS/MSTR/ ASPB