ML18250A256

Letter to P. Silva Transmittal of NEI 12-04, Revision 2, Guidelines for 10 CFR 72.48 Implementation.

ML18250A256
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/05/2018
From:	Mccullum R Nuclear Energy Institute
To:	Patricia Silva NRC/NMSS/DSFM/IOB
Marcano D
Shared Package
ML18250A254	List: ML18250A255 ML18250A256
References
Download: ML18250A256 (2)

Text

RODNEY MCCULLUM Senior Director, Fuel & Decommissioning 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8082 rxm@nei.org nei.org September 5, 2018 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 Washington, DC 20555-0001

Subject:

Transmittal of NEI 12-04, Revision 2, Guidelines for 10 CFR 72.48 Implementation Project Number: 689

References:

1. Nuclear Energy Institute letter Transmittal of NEI 12-04, Revision 1, Guidelines for 10 CFR 72.48 Implementation, Rodney McCullum to Patricia Silva, dated March 5, 2018, ML18068A607

2. Nuclear Regulatory Commission letter U.S. Nuclear Regulatory Commission Comments On Nuclear Energy Institute 12-04 Guidelines For Title 10 Of The Code Of Federal Regulations 72.48 Implementation, Revision 1, Patricia Silva to Rodney McCullum, dated August 22, 2018, ML18218A188

Dear Ms. Silva:

On behalf of our members, the Nuclear Energy Institute (NEI)1 is transmitting to the U.S. Nuclear Regulatory Commission (NRC) Revision 2 to NEI 12-04, Guidelines for 10 CFR 72.48 Implementation. Revision 2 addresses Issues 1 and 3 identified in Reference 2 and is otherwise identical to Revision 1. Accordingly, Revision 2 completely supersedes Revision 1 and should be used as the basis for the Draft Regulatory Guide endorsing NEI 12-04 that was described in Reference 2. We look forward to the opportunity to review NRCs regulatory position on Issue 2 during the public comment period on the Draft Regulatory Guide.

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 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, 2018 Page 2 We remain appreciative of NRCs engagement in the extensive, open and transparent dialogue which has informed this guidance - and resulted in a common understanding of how the 10 CFR 72.48 change control process can be most effectively implemented to provide an enforceable regulatory mechanism for the NRC to assure that industry appropriately evaluates the need for the NRC to review and approve certain proposed changes to the ISFSI or cask design or operation prior to implementation. The regulatory review performed pursuant to 10 CFR 72.48 is distinct from the activities performed under licensees and CoC holders quality assurance (QA) programs to ensure proposed changes to the ISFSI or cask design or operation are safe, effective and in compliance with all regulatory requirements. Hence, the 10 CFR 72.48 process is a vital element of an effective and efficient regulatory process - especially for an activity such as dry cask storage where there is a considerable amount of detailed design and operational information that does not affect public health and safety which should, most appropriately, be managed under licensee and CoC holder control.

Thank you for your time and continued attention on this important matter. If you have any questions, please contact me.

Sincerely, Rodney McCullum Enclosures c: Mr. Raynard Wharton, NMSS/DSFM/IOB, NRC Ms. Aida Rivera-Varona, NMSS/DSFM, NRC Mr. Michael Layton, NMSS/DSFM, NRC Mr. Marc Dapas, NMSS, NRC Mr. Scott Moore, NMSS, NRC NRC Document Control Desk