ML20245E095
| ML20245E095 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1988 |
| From: | Sakenas C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Jordan E NRC |
| References | |
| NUDOCS 8812160002 | |
| Download: ML20245E095 (3) | |
Text
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RELEASED TO THE POR.
,*e December.7,.1988-L 1
l MEHORANDUM FO'R:
Edward L'. Jordan, Chairman Robert M. Bernero, NMSS Jack R. Goldberg,;0GC j'
Carl J. Paperiello, RIII L
Denwood'F. Ross, RES James H. Sniezek, NRR THRU:
C. J. Heltemes, Jr., Deputy Director Office for. Analysis and Evaluation of Operational Data FROM:
Cheryl A. Sakenas Program Manager, CRGR Staff Office:for Analysis and Evaluation of Operational Data
SUBJECT:
SUMMARY
ANr TSSUE IDENTIFICATION FOR CRGR M 2lING N0. 152 Enclosed is an issue sheet for
- CRGR agenda item related to-follow-up review-of a Certificate of Compliance wl;ich will be incorporated into Part 72 rulemaking.and two implementing Reg. Guides.
- This item is scheduled for revia at CRGR Meeting No.152, December 14,-1988
'from.3:30-5 p.m.
31:
Cheryl A. Sakenas 1
Program Manager, CRGR Staff l
Office for Analysis and Evaluation of Operational Data j
Enclosure:
As stated
. Distribution:
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SUMMARY
AND ISSUE IDENTIFICATION FOR CRGR AGENDA ITEM - MEETING NO. 152 December 14, 1988 IDENTIFICATION - ITEM 1 Regulatory Guide 3.6.2, Standard Format and Content for the Safety Analysis Report for Onsite Storage of Spent Fuel Storage Casks.
DISCUSSION / ISSUES Although this Reg. Guide was written for preparing an F^R if the ISFSI is collocated with a civilian nuclear power reactor, the staff has stated that it does not apply for the general license provisions of sutspart K.
Part 72.212 requires only submittal of-a letter 90 days prior to use and again 30 days i
after.use.
The licensee is required to perform'and retain for three years.
written evaluations showing that the conditions in the Certificate of Compliance are met.
Part 72.212(a)(5) specifies that certain programs (QA, training, and radiation protection) must be maintained.
Since these programs ce addressed in this Reg. Guide, there may be some incentive for inspectors or reviewers to use the Reg. Guide as a means of determining acceptance.
It may be. beneficial to add some clarifying language to the rulemaking package to unambiguously explain the role of this Reg. Guide under the provisions of the general license.
IDENTIFICATION - ITEM 2 Regulatory Guide 3.6.1, Standard Format and Content for a Topical Safety Analysis Report for a Spent Fuel Dry Storage Cask DISCUSSION / ISSUES This Reg. Guide is to be used by vendors in preparing a topical safety I
analysis report for a spent fuel storage cask.
Subpart L of Part 72 describes I
the steps required to cbtain a Certificate of Compliance, which includes submittal of an SAR.
I did not find any major problems with this Reg. Guide although, in general, it seems far too detailed for its purpose.
For example, Section 9.1, Organization::1 Structure, specifies that detailed organizational descriptions be included.
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IDENTIFICATION - ISSUE 3 Draft Certificate of Compliance for General Nuclear Systems, Inc., Model No.
CASTOR V/21 Dry Spent Fuel Storage Cask DISCllSSION/ ISSUES
-This is the primary licenring document for onsite use of this dry spent fuel storage cask, and specifies the conditions for cask use.
The staff has approved several topical reports which 're the safety analysis for these casks.
You may wish to determine whether these topical reports should be considered for review by CRGR.
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