ML18346A529
| ML18346A529 | |
| Person / Time | |
|---|---|
| Issue date: | 12/11/2018 |
| From: | Kristina Banovac Office of Nuclear Material Safety and Safeguards |
| To: | Haile Lindsay NRC/NMSS/DSFM/IOB |
| Lindsay H | |
| Shared Package | |
| ML18338A059 | List: |
| References | |
| Download: ML18346A529 (12) | |
Text
Update on NEI 14-03 Guidance and 10 CFR Part 71 Rulemaking Kristina Banovac NMSS/DSFM/RMB REG CON 2018 December 11, 2018
- NEI developed NEI 14-03, Format, Content and Implementation Guidance for Dry Cask Storage Operations-Based Aging Management
- Guidance for industry to compliment the guidance in NUREG-1927, Revision 1, Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel (ML16179A148)
Dec 11, 2018 DSFM REG CON 2018 2
NEI 14-03 History
- NEI 14-03, Rev. 0, 9/23/2014 (ML14266A224)
- NRC comment on Rev. 0, 1/21/2015 (ML15013A201)
- NEI 14-03, Rev. 1, 9/24/2015 (ML15272A329)
- NRC comment on Rev. 1, 8/18/16 (ML16180A018)
- NEI 14-03, Rev. 2, 12/21/16 (ML16356A204)
- NRC review put on hold until mid-2018 to work on competing casework and guidance Dec 11, 2018 DSFM REG CON 2018 3
NRC staff preliminary findings on NEI 14-03, Rev. 2
- NEI 14-03, Rev. 2 mostly addresses NRC comments on Rev. 1
- One exception to the position on the use of surrogate inspections
- Several clarifications, some of which are a result of recent renewal application reviews
- Recommend partial endorsement Dec 11, 2018 DSFM REG CON 2018 4
NEI 14-03 Path Forward
- NRC staff to pursue partial endorsement of NEI 14-03, Rev. 2 through development of a draft guidance document for public comment
- Update to NUREG-1927
- New Regulatory Guide
- Guidance document would include updated references and other information
- Schedule depends on staff resources and completion of other guidance (NUREGs-2214,
-2215, -2216, -2224)
Dec 11, 2018 DSFM REG CON 2018 5
10 CFR Part 71 Rulemaking Dec 11, 2018 DSFM REG CON 2018 6
10 CFR Part 71 Rulemaking:
Authority and Scope
- SRM-SECY-16-0093 approved the rulemaking plan to harmonize 10 CFR Part 71 with the IAEAs Specific Safety Requirements No. 6 (SSR-6), 2012 and 2018 editions.
- The rulemaking action includes administrative, editorial, and clarification changes to improve 10 CR Part 71 implementation.
- The rulemaking action includes conforming revisions to NUREG-1608, NUREG-2216, and Regulatory Guide 7.9 Dec 11, 2018 DSFM REG CON 2018 7
10 CFR Part 71 Rulemaking:
Purpose
- Harmonize and align transportation regulations with the IAEA safety requirements in SSR-6, 2012 and 2018 editions.
- Ensure continued compatibility of 10 Part 71 with the DOT regulations (DOT is also harmonizing its regulations in 49 CFR with IAEA safety requirements).
- Improve implementation of 10 Part 71 regulations.
Dec 11, 2018 DSFM REG CON 2018 8
10 CFR Part 71 Rulemaking:
History
- In 2015 NRC and DOT updated their respective regulations in response to the IAEAs safety standards series in TS-R-1, 2009 edition.
- The IAEA requirements in SSR-6, 2012 edition were not addressed in the 2015 10 CFR Part 71 rulemaking.
- In 2016 the IAEA issued an update to its SSR-6 requirements titled Draft SSR-6, 20XX edition. The final version of these IAEA requirements was issued in June 2018.
Dec 11, 2018 DSFM REG CON 2018 9
10 CFR Part 71 Rulemaking:
Status
- Draft regulatory basis concurrence package (draft regulatory basis, FRN, and CA note) has been completed and is currently under management review.
- Rulemaking schedule has been delayed mainly because of the delayed publication of the final version of SSR-6 requirements, 2018 edition by the IAEA.
- NRC staff plans to submit a schedule extension request to the Commission Dec 11, 2018 DSFM REG CON 2018 10
10 CFR Part 71 Rulemaking:
Regulatory Issues -Backup Slide
- 1. Fissile Materials
- 2. Consideration for Adopting a Change to the Reduced External Pressure Design Requirement for Transportation Packages
- 3. Type C Package
- 4. Solar Insolation
- 5. Replace Radiation Level with Dose Equivalent Rate
- 6. Deletion of the Low Specific Activity-III Leaching Test
- 7. Introduction of the Provisions for Large Solid Contaminated Objects (Surface Contaminated Object (SCO-III))
- 8. Evaluation of Uranium Hexafluoride Cylinder Plugs
- 10. Transitional Arrangements Dec 11, 2018 DSFM REG CON 2018 11
10 CFR Part 71 Rulemaking:
Regulatory Issues -Backup Slide Continued
- 11. Head Space for Liquid Expansion Clarification
- 12. Quality Assurance Program Clarification
- 13. Clarification of Type A Package Requirements in § 71.22 -
General License: Fissile Material, and § 71.23 - General License:
Plutonium-Beryllium Special Form Material
- 14. Clarification of 233U Restriction in § 71.22 - General License:
Fissile Material
- 15. Other Proposed Changes to Part 71 Dec 11, 2018 DSFM REG CON 2018 12