ML20247L482

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Comments on Proposed Rulemaking Entitled Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Civilian Nuclear Power Reactor Sites. Provisions for IAEA to Implement Safeguards Program Not Clearly Defined
ML20247L482
Person / Time
Issue date: 03/29/1988
From: Stohr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Morris B
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20245D207 List:
References
FRN-54FR19379, RULE-PR-170, RULE-PR-50, RULE-PR-72 AC76-1-12, NUDOCS 8906020182
Download: ML20247L482 (1)


Text

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d7 REGloN 11 .i,fs . yE&N122g'[I j 101 MARIETTA STREET, N.W. th ,,, -- t ATLANTA, GEORGI A 30323 h l *%, **** *Of MAR 2 91988 MEMORANDUM FOR: Bill M. Morris,' Director. Division of Regulatory Applications, RES FROM: J. Philip Stohr, Director Division of Radiation Safety and Safeguards

SUBJECT:

COMMENT ON PROPOSE 0 RULEMAKING ENTITLED,

                               " STORAGE OF SPENT NUCLEAR FUEL IN NRC APPROVED STORAGE CASKS AT CIVILIAN NUCLEAR POWER REACTOR SITES" This is in response to your memorandum dated March I, 1988, requesting comment on the subject proposed rule. One point that is not clearly defined is how this proposed rule change would. address provisions for the IAEA' to implement their safeguards program at licensees with Facility Attachments. For example,-

the rule does not address the IAEA need to perform independent measurements of contained' SNM within stored casks. In addition, the mobility of the casks might also raise IAEA security concerns. We would recommend that the wording 72.4(e) be reworded to clarify the intent of this section. If you have any questions on the above, please do not hesitate to give me a call. b4 $' p J. ehi14p Stohr l 1 1

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