ML20212H612
| ML20212H612 | |
| Person / Time | |
|---|---|
| Issue date: | 09/22/1997 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Knapp M NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20212H254 | List:
|
| References | |
| FRN-64FR17510, RULE-PR-72 AG02-2-036, NUDOCS 9910010265 | |
| Download: ML20212H612 (3) | |
Text
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~g NUCLEAR R'EGULATORY COMMISSION e
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R#sz-1 September 22,199L , /pg NG, UR.
-y MEMORANDUM TO: Malcom R. ,Knahp, Acting Director Office of Nuclear Regulatory Research e o ~ FROM: mkbor _ .
Offico of Nucient Reactor Regulation
SUBJECT:
RULEMAKING PLAN: REDUCTION OF 30-DAY, HOLD IN LOADlhG SPENT FUEL AFTER PREOPERATIONAL TESTING .
OF INDEPENDENT SPENT FUEL STORAGE CR MONITORED ,
RETRIEVABLE STORAGE INSTALLATIONS l l
My staff has reviewed the rulemaking plan related to the reduction or elimination of the 30-day hold in loading spent fuel after preoperational testing of independent spent fuel ,
storage or monitored retrievable storage installations. I am providing my concurrence with the following su22estions, it is our understanding that the Office of Nuclear Material Safety and Safeguards (NMSS) may propose the deletion of 10 CFR 7ld.82(e) as the preferred option. The basis for this approach is that neither the notice of iritent to perform preoperational testing nor the notice of intent to load fuel appear to be needed given the guidance in the NRC inspection program, notification requirements such as the 90-day notice for use of the ganerallicense, and other mechanisms for communicating dry-cat,k storage activities to the NRC staff and the public.
We believe that this would be the simplest and the preferable approach for revising 10 CFR 72.82(e).
As a second approach, we suggest that the Office of Nuclear Regulatory Researen and NMSS give further thought to the 5-day notice of intent for preoperational testing. This short a notice would not serve a useful purpose for NRC inspection planning. We would suggest
' that in order to make Option 1 more useful, the notice of intent to perform preoperational
. tests be extended to 60 days. Although a longer period would be preferable for inspection planning, the current requirements are for licensees opting to use the general license provisions of 10 CFR Part 72, Subpart K, to notify the NRC at least 90 days prior to first storage of spent fuel. The regulatory requirement for a notice of intent to perform
. preoperational testing could not reasons.bly precede the notification that a license selected and intends to use a particular NRC-certified cask. '
In addition, we believe that the proposed Commission paper should be revised regarding the impact that the rulemaking would have on the public's access to information pertaining to dry cask storage activities. In that regard, we suggest the following changes to the proposed Commission paper:
CONTACT: William Reckley,14DR 415-1314 9910010'265 990924 PDR PR
, ' 72 64FR17510 PDR L- . . . . .
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M. Knapp l l
Page 2,3rd paragraph: {
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As a result of this action, the general public will no longer be able to access the data l and information now available in the report on the preoperational test acceptance j criteria and test results which are submitted by licensees to the NRC and placed in the NRC Public Document Room and local public document room. Thi: : tien-win depfve the pub!! ef Mfermet!cr of :!grmeant n:= ::tivity er the :!t:. [Muchlof this informationTwill,[hoWeveff bs linbluded in~inspictidn[ reports lissesd lip the' NRC;sta#
]
j tegardinglits;;aasessment dlicensees' readiness l tofoperate 'an(ISFSI or .MRS.1 i H ::ver, under th!: Oden, the !!:en::: !: being required Thiiaction alsojequiress'
~ licensses to submit a written notice of intent to conduct preoperation testing at least 5 days prior to testing. In addition, this action will reduce the burden on licensees by eliminating the need to submit a report that is not used by the NRC staff.
Attachment:
Concurrence Package l
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Y' .:
RULEMAKING PLAN REDUCTION OF 30-DAY HOLD IN LOADING SPENT FUEL AFTER PREOPERATIONAL TESTING OF INDEPENDENT SPENT FUEL STORAGE OR MONITORED RETRIEVABLE STORAGE INSTALLATIONS -- 10 CFR PART 72 Lead Office: Office of Nuclear Regulatory Research Staff
Contact:
Gordon Gundersen, WMB/DRA/RES Concurrences:
M. R. Knapp, RES Date C. Paperiello, NMSS Date f,2 k m n 03 Q 1txr w _. Ahshi
({// 3 / . Collins) NRR S Date~
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J. Lieberman, OE Date B. J. Shelton, IRM Date J.Funches,CFO Date A. J. Galante, ClO Date W. J. Olmstead, OGC Date Approval:
L. Joseph Callan, EDO Date