ML20100P139
| ML20100P139 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Point Beach, Arkansas Nuclear, 07201007  |
| Issue date: | 03/05/1996 |
| From: | Travers W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Shillinglaw F AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20100B818 | List: |
| References | |
| NUDOCS 9603110060 | |
| Download: ML20100P139 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION e
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March 5, 1996
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4 Ms. Fawn Shillinglaw 1952 Palisades Drive Appleton, Wisconsin 54915
SUBJECT:
RESPONSE TO LETTERS OF DECEMBER 9, 1995, AND DECEMBER 29, 1995, REGARDING THE CONTROL AND USE OF SAFETY ANALYSIS REPORTS FOR SPENT FUEL DRY STORAGE CASKS LICENSED UNDER 10 CFR PART 72
Dear Ms. Shillinglaw:
In your letters of December 9,1995, and December 29, 1995, you raise several issues concerning the use and control of safety analysis reports (SARs) for spent fuel dry storage casks licensed under Part 72 of Title 10 of the Code of Federal Regulations (10 CFR).
In the December 9,1995 letter, you recommend that the Nuclear Regulatory Commission require that the SAR for a cask design certified under the provisions of 10 CFR Part 72, Subpart L, fully conform with the associated NRC safety evaluation report (SER) and certificate of compliance (C0C) before NRC certification of the cask design. Current practice permits cask vendors to confom their SARs subsequent to NRC staff issuance of the SER and C0C.
Further, you request that whenever the SAR is referenced in documents, the revision date and number be specified.
You note that this has not been done in the past and cite the VSC-24 cask as an example. You believe that, as a result, there is confusion among various parties concerning the appropriate SAR revision to be followed and, hence, a possibility that ' iconsees and/or their agents will fail to adhere to all of l
the requirements contained in NRC's SER and C0C. You also ask about the procedures to be followed for vendor-initiated changes to the SAR for a particular cask design and suggest that clarification is needed regarding the effect of such changes on general licensees either already using or seeking to use that design.
In the December 29, 1995 letter, which you ask be considered along with the December 9,1995 letter, you repeat the above concerns and describe (and question) changes which you believe were made to the VSC-24 cask by the vendor, Sierra Nuclear Corporation. As a separate matter, you express concern regarding the unavailability of plant-specific cask unloading procedures.
Insofar as your comments request that NRC impose requirements on the contents of SARs, they are being considered by the staff as a request for rulemaking as provided for in the Commission's regulations at 10 CFR 2.802. NRC intends to use the provisions and procedures of Section 2.802 to further evaluate your request and the need for NRC to propose revisions to 10 CFR Part 72.
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l F. Shillinglaw.
i Regarding your question about the requirements for making changes to the SAR
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following issuance of the COC, certain specified changes involving the SAR are allowed under the provisions of 10 CFR 72.48, " Changes tests, and experiments," or similar provisions that may be contained in the applicable 00C. Changes made under 10 CFR 72.48 (or the applicable C00) that do not require prior NRC review and approval may subsequently be inspected by NRC staff.
As for your questions about the " Summary of WEPC0 Changes to VSC-24," the staff has reviewed the contents of the table and found that it lists changes to cask fabrication details.
In this regard, NRC considers Wisconsin Electric Power Corporation's review and approval of the changes proposed by Sierra i
Nuclear to be consistent with the requirements of 10 CFR 72.48. Therefore, 3
the changes are not required to be submitted to the NRC for review; however, they are subject to inspection by NRC staff at any time.
4 l
In answer to your concern regarding access to cask unloading procedures, plant specific procedures often expand upon the generic procedures described in the SAR and include site-specific information. These site-specific cask unloading procedures are written, evaluated, and retained by, the licensee. Although subject to NRC inspection, the procedures are not generally submitted to the Agency. As such, they are not available to the public through the NRC.
i Sincerely, I
William D. Travers, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Docket Nos.:
50-255, 50-266/301, 50-313/368, 72-5, 72-7, 72-13, & 72-1007 i
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Chairman Jackson iFOR' SIGNATURE OF :
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ROUTING:
CONCERNING STORAGE CASKS Taylor Milhoan 1
Thompson Blaha Paperiello I
DATE: 12/13/95 ASSIGNED TO:
CONTACT:
d.I d NRR Russell 4
SPECIAL INSTRUCTIONS OR REMARKS:
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' PAPER NUMBER:
CRC-95-1093 LOGGING DATE: Dec 13 95 ACTION OFFICE:
EDO AUTHOR:
FAWH SHILLINGLAW AFFILIATION:
WYOMING ADDRESSEE:
CHAIRMAN JACKSON LETTER DATE:
Dec 9 95 FILE CODE:
SUBJECT:
.THE NEED FOR. COMPLETED SAR, UPDATED TO NRC SER REQUIREMENTS ACTION:
Direct Reply DISTRIBUTION:
CHAIRMAN, COMR ROGERS SPECIAL HANDLING: SECY TO ACK CONSTITUENT:
NOTES:
i DATE DUE:
Dec 28 95 SIGNATURE:
DATE SIGNED:
-AFFILIATION:
EDO --- 000880