ML20212H623

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Submits Response to Request for Comments on Rulemaking Plan for Preoperational Testing Notification,In Response to 970902 Memo
ML20212H623
Person / Time
Issue date: 09/15/1997
From: Paperiello C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Knapp M
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20212H254 List:
References
FRN-64FR17510, RULE-PR-72 AG02-2-037, NUDOCS 9910010272
Download: ML20212H623 (1)


Text

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September 15, 1997 N42-2 ff)A 4

MEMORANDUM TO: Malcolm R. Knapp, Acting Director Office of Nuclear Regulatory Retaarch FROM: Carl J. Paperiello, Director (Original signed by W. Kane for)

Office of Nuclear Material Safety I and Safeguards

SUBJECT:

RESPONSE TO REQUEST FOR COMMENTS ON RULEMAKING PLAN FOR PREOPERATIONAL TESTING NOTIFICATION As requested in your September 2,1997, memorandurn, -NMSS has reviewed the proposed Commission paper and rulemaking plan to revise 10 CFR 72.82(e). NMSS concurs in the proposed rulemaking plan to eliminate the requirement for a licensee to submit a report on completed preoperational testing 30 days before the loading of spent fuel into an ISFSI or MRS; and to replace the report with two 5-day notificaticn requirements.

Based on our recent discussions, the basis for the 5-day notification periods are to make NRC aware of licensee preoperational testing; and afford NRC the opportunity to stop a j licensee from loading spent fuelif concerns are identified. However, NMSS now believes I the present program safeguards, which are in place (e.g., inspection Manual Chapter 2690, inspection Procedure 60854, and NRC awareness at least 90 days in advance of the licensee's intent to conduct these activities), support the elimination of the 5-day  !

notifications. Consequently, NMSS believes that an additional option should be added to l the rulemaking plan to eliminate 72.82(e) entirely.  !

CONTACT: Phil Brochman, NMSS/SFPO/TSIB _

301-415-8592 DISTRIBUTION: NMSS 9700386 NRC f/c SFPO r/f NMSS r/f NMSS Dir/r/f SBahadur, RES GGonderson, RES PNorian, RES LGilbert, SFPO CPoland , PMDA NJensen, OGC CAnderson, RI WGloerson, Ril

  • RLandsman, Rlli VEverett, RIV WKane, NMSS CHaughney, SFPO WReckley, NRR 9910010272 990924 PDR PR 72 64FR17510 PDR EDS PROOFED 9/12/97 Proofed By:Img Division: sfpo Date: Sept. 11,1997

'SEE PREVIOUS CONCURRENCE OPC SFPO:TSSS' C SFPO:TSSS* C SFPO: ADD

  • C NMSS:@[ C NAME P8rochman EEaston SShankman CP k DATE 09/12/97 09/12/97 09/12/97 09/ /97 / /97 ,

C = COVER E = COVER Ei ENCLOSURE N = NO COPY OPPICIAL RECORD COPY G:\brochman\ rules \72.82\ plan 7282.mem 9 9/60/0e7?L w