ML15169A941

Comment (7) of Brian Smith on Behalf of Yankee Atomic Electric Company on Evaluation of a Proposed Risk Management Regulatory Framework; Request for Comment on Draft White Paper

ML15169A941
Person / Time
Site:	Yankee Rowe
Issue date:	06/10/2015
From:	Smith B E Yankee Atomic Electric Co
To:	Cindy Bladey Division of Administrative Services, Office of Nuclear Material Safety and Safeguards
References
80FR27191 00007, BYR 2015-020, NRC-2013-0254
Download: ML15169A941 (4)

Text

6/15/20"156/152015NRC-2013-0254-DRAFT-0031.htmlAs of: 6/15/15 3:43 PMReceived: June 10. 2015PUBLIC SUBMISSION Status: PendingPostTracking No. ljz-8jcb-rq8qComments Due: June 11, 20Submission Type: WebDocket: NRC-2013-0254Conceptual Example of a Proposed Risk Management Regulatory Framework Policy StatementComment On: NRC-2013-0254-0027Evaluation of a Proposed Risk Management Regulatory Framework; Request for Comment onDraft White PaperDocument: NRC-2013-0254-DRAFT-0031Comment on FR Doc # 2015-1145415Submitter InformationName: Stan Day .jGeneral CommentThe attached provide Yankee Atomic Electric Company's comments. i, mAttachmentsYAEC Comments -NRC-20 13-0254SUNSI Review CompleteTemplate = ADM -013E-RIDS= ADM-03file:///C:/Users/CAG/DownloadslNRC-2013-0254-DRAFT-0031.html 11/1

, ANIKEE2 YANKEE ATOMIC ELECTRIC COMPANY49 Yankee Road, Rowe, Massachusetts 01367June 9, 2015BYR 2015-020Ms. Cindy Bladey, Office of Administration,Mail Stop: OWFN-12-H08,U.S. Nuclear Regulatory Commission,Washington, DC 20555Yankee Atomic Electric CompanyYankee Rowe Independent Spent Fuel Storage InstallationNRC License Nos. DPR-3 and SFGL-1 3 (NRC Docket Nos.50-029 and 72-31)

Subject:

Comments on the "NRC Staff White Paper on Options for Responding to the June14, 2012 Chairman's Tasking Memorandum on 'Evaluating Options Proposed fora More Holistic Risk-Informed, Performance-Based Regulatory"' [Docket IDNRC-2013-0254]Yankee Atomic Electric Company (YAEC) appreciates the opportunity to provide comments onthe draft document published in the Federal Register on May 12, 2015: "NRC Staff White Paperon Options for Responding to the June 14, 2012 Chairman's Tasking Memorandum on'Evaluating Options Proposed for a More Holistic Risk-Informed, Performance-BasedRegulatory Approach'," (herein referred to as the NRC Staff White Paper).YAEC is a 10 CFR Part 50 licensee that operated a single unit nuclear power plant that is nowpermanently shut down and decommissioned. All that remains is an Independent Spent FuelStorage Installation (ISFSI) that utilizes a 10 CFR Part 72 licensed dual-purpose dry cask storagesystem.

Background:

The NRC staff working group formed to review NUREG-2150 "A Proposed Risk ManagementRegulatory Framework [RMRF]." The RMRF working group prepared a conceptual example ofa risk-informed, performance-based, defense-in-depth RMRF policy statement for Commissionconsideration. The RMRF working group drafted a white paper describing the conceptualexample of an RMRF policy statement and published a notice seeking public comments on thewhite paper in the Federal Register on November 25, 2013, (78 FR 70354). YAEC providedcomments on that white paper on February 25, 2014.As stated in Section III of the subject NRC Staff White Paper Working Draft, following reviewof the public comments provided in response to the 2013 Federal Register Notice, the staff hasdeveloped a revised example of an over-arching risk management policy statement. The statedpurpose of this example policy statement is to improve and make more consistent the regulatoryframework used for all program areas including reactors, industrial, medical uses of 'adioactivematerial, nuclear waste storage and disposal, fuel cycle facilities, and radioactive material Yankee Atomic Electric CompanyBYR 2015-020/June 9, 2015/Page 2 of 3transportation for both radiological safety and common defense and security. The NRC StaffWhite Paper states that such a policy statement could be written at a high level, therebypermitting each program office to implement the agency-wide policy tailored to the specificgoals of each regulated activity in a manner commensurate with the hazards and technology ofthe regulated program area.Comments:As YAEC stated in its February 2014 comment letter, a risk management regulatory frameworkshould be applied now, without the adoption of a RMRF policy statement, to the regulatoryframework associated with the interim storage and transportation of commercial spent nuclearfuel and high-level radioactive waste (SNF/HLW) -in particular, with regard to the regulation ofISFSIs at stand-alone decommissioned reactor sites.NUREG-2150 specifically encouraged the adoption of such a framework for regulatory activitiesassociated with spent fuel dry cask storage and acknowledged the need to expedite rule changesand regulatory guidance updates for such storage based on risk considerations. It providedseveral findings and recommendations along those lines and YAEC continues to urge the NRC totake immediate steps to implement a risk-informed framework associated with NRC's ongoingSNF/HLW storage, security, and transportation related regulatory initiatives associated withstand-alone ISFSI sites.Dry cask storage systems are robust passive systems that are designed to withstand the effects ofdesign basis events and "worst case" events while maintaining the capability to provide adequateshielding and confinement of the radioactive contents and prevent nuclear criticality. Thesesystems require minimal maintenance or repair and as noted in NUREG-2150, "Both the NRCand Electric Power Research Institute have conducted [Probabilistic Risk Assessments] PRAs ofdry cask storage systems and concluded that the risk associated with them is very low" (seeNUREG-2150 page xxvi). Numerous risk assessments already conducted on the safety oftransportation of SNF in NRC certified transportation casks include findings and conclusionsdocumenting the extremely low risk, such as NUREG-2125, "Spent Fuel Transportation RiskAssessment," (January 2014) and other SNF transportation related risk assessment documents.The stated purpose of the subject policy statement example is to improve and make moreconsistent the regulatory framework used for all program areas, including nuclear waste storageand radioactive material transportation, and YAEC believes that this can be accomplishedwithout the adoption of a RMRF policy statement. Accordingly, we continue to urge the NRC todevelop and apply risk-informed decision-making criteria and to implement a risk managementregulatory framework associated with the ongoing ISFSI security rulemaking, as well as with thecurrent staff evaluations of the extended SNF storage and transportation regulatory paradigmdirected by SRM-COMSECY- 10-0007 and the associated staff Licensing Program Improvementreview area that is focused on regulating ISFSIs at stand-alone decommissioned reactor sites.

Yhnkee Atomic Electric CompanyBYR 2015-020/June 9, 2015/Page 3 of 3If you have any questions regarding this submittal, please do not hesitate to contact me at(413) 424-5261 ext. 303.Respectfully,Brian SmithISFSI Managercc: D. Dorman, NRC Region I AdministratorM. Ferdas, Chief, Decommissioning Branch, NRC, Region IC. Haney, Director, Office NMSSM. Lombard, Director, Division of Spent Fuel Storage and Transportation, Office ofNMSSJ. Goshen, NRC Project Manager