View source for NRC-2015-0120, Comment (4) of J. Brown on Behalf of Maine Yankee on Proposed Draft Regulatory Guide DG-5057, Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities, Proposed Revision 3 of Regulatory Guide 5.29

{{Adams
| number = ML15167A039
| issue date = 06/03/2015
| title = Comment (4) of J. Brown on Behalf of Maine Yankee on Proposed Draft Regulatory Guide DG-5057, Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities, Proposed Revision 3 of Regulatory Guide 5.29
| author name = Brown J
| author affiliation = Maine Yankee Atomic Power Co
| addressee name = Bladey C
| addressee affiliation = NRC/ADM/DAS/RADB
| docket = 05000309, 07200030
| license number = DPR-036, SFGL-0014
| contact person = SECY RAS
| case reference number = 80FR27709 00004, NRC-2015-0120, OMY-15-026
| document type = General FR Notice Comment Letter type:NRC
| page count = 2
}}

=Text=
{{#Wiki_filter:MAINE YANKEE 321 Old Ferry Road, Wiscasset, Maine 04578 June 3, 2015 OMY- 15-026 In -Ms. Cindy Bladey, Office of Administration, ,,,-720,9 Mail Stop: OWFN-12-H08, -U.S. Nuclear Regulatory Commission, --Washington, DC 20555 7Thi Maine Yankee Atomic Power Company -.Maine Yankee Independent Spent Fuel Storage Installation NRC License Nos. DPR-36 and SFGL-14 (NRC Docket Nos. 50-309 and 72-30)

==Subject:==
Comments on Proposed Draft Regulatory Guide DG-5057, "Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities," Proposed Revision 3 of Regulatory Guide 5.29, dated June 2013 [Docket ID NRC-2015-0120]
Maine Yankee Atomic Power Company (Maine Yankee) appreciates the opportunity to provide comments on the proposed Draft Regulatory Guide DG-5057, "Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities." Maine Yankee is a 10 CFR Part 50 Licensee that operated a single unit nuclear power plant that is now permanently shut down and decommissioned.
All that remains at the site is an Independent Spent Fuel Storage Installation (ISFSI) that utilizes a 10 CFR Part 72 licensed dual-purpose dry cask storage system. All Special Nuclear Material (SNM) is stored within the dry cask storage system and is in a static storage condition.
Maine Yankee is concerned that the NRC did not address or include guidance specific to stand-alone ISFSI sites that have completed decommissioning within the proposed Draft Regulatory Guide DG-5057, "Special Nuclear Material Control and Accounting System for Non-Fuel Cycle Facilities." Maine Yankee believes that the guidance should be enhanced to acknowledge the existence of stand-alone ISFSIs that have completed decommissioning of the nuclear plant, and define compliance options specific to those licensees.
In addition, Maine Yankee previously supplied comments regarding the proposed rulemaking on March 10, 2014. Maine Yankee does not believe the NRC provided a sufficient safety basis, data or analysis to justify the fundamental restructuring of the current Material Control and Accounting practices for a stand-alone ISFSI. Given the low risks associated with spent fuel stored in dry canisters at stand-alone ISFSI sites, Maine Yankee believes that the NRC should utilize a risk-informed approach regarding stand-alone ISFSIs in the revised rule and the associated.
guidance document.SUNSI Review Complete Template = ADM -013 E-RIDS= ADM -03 A d d Maine Yankee Atomic Power Company OMY-15-026/June 3, 2015/Page 2 of 2 If you have any questions regarding this submittal, please contact me at (207) 882-1303.Respectfully, J. Brown, P.E.ISFSI Manager cc: D. Dorman, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager}}