ML093350501
| ML093350501 | |
| Person / Time | |
|---|---|
| Issue date: | 01/04/2010 |
| From: | Vonna Ordaz NRC/NMSS/SFST |
| To: | Kraft S Nuclear Energy Institute |
| Longmire P, NMSS/SFST 301-492-3562 | |
| References | |
| TAC LA0119 | |
| Download: ML093350501 (4) | |
Text
January 4, 2010 Mr. Steven P. Kraft, Senior Director Used Fuel Management Nuclear Energy Institute (NEI) 1776 I Street, NW Suite 400 Washington, DC 20006-3708
SUBJECT:
REVIEW OF NEI 09-03, 10 CFR 72 LICENSE AMENDMENT REQUEST GUIDELINES, DRAFT REVISION 0
Dear Mr. Kraft:
I am responding to your letter dated April 30, 2009 (ADAMS Accession No. ML091310619), that transmitted the draft guidance document entitled, NEI 09-03, 10 CFR 72 License Amendment Request Guidelines, Draft Revision 0 (ML091310620). We reviewed draft NEI 09-03 and support many of the recommendations described in the document. For example, recognition of the importance and value of providing an updated Final Safety Analysis Report (FSAR) with every new amendment; reducing the chances of administrative requests for additional information (RAI) by enlisting the services of a technical editor; and, recommending that the certificate holder clearly identify references within the license amendment request (LAR). These measures, if implemented, have the potential to enhance the licensing process. However, in some areas, the document appears to focus more on defining NRC processes, rather than providing specific guidance to applicants regarding LAR content. As such, endorsement of NEI 09-03 would not be the appropriate mechanism for implementing change to our review process. The industry has multiple avenues to provide input on NRC processes, such as commenting on draft NRC review documents during the public comment period, and through feedback at public meetings with the dry storage task force.
The Standard Review Plans (SRPs) aid in standardizing the staffs review of applications. Each SRP articulates the regulatory requirements necessary for approval of an application and describes the process that the Spent Fuel Storage and Transportation (SFST) staff should use to determine that regulatory requirements have been satisfied. For 10 CFR Part 72 reviews, NRC staff use two SRPs (NUREG-15361 and NUREG-15672), of which NUREG-1536 is undergoing revision (ML090400676) to include guidance on the performance of risk-informed reviews. The SRPs are updated and revised periodically as regulations or practices change, and are supplemented, as needed, by issuing Interim Staff Guidance (ISG) documents, to identify emergent issues, and to develop staff positions in a timely manner. In addition to the technical review guidance provided by the SRP and ISG documents, SFST uses a set of guidelines to define the expectations for interactions between SFST and applicants during the licensing process, known as the rules of engagement3/4. These rules provide guidelines for the quality and completeness of applications; scheduling the review of an 1 Standard Review Plan for Dry Cask Storage Systems 2 Standard Review Plan for Spent Fuel Dry Storage Facilities 3 RIS-2004-20, NRC Regulatory Issue Summary 2004-20 Lessons Learned from Review of 10 CFR Parts 71 and 72 4 RIS-2005-27, NRC Regulatory Issue Summary 2005-27, Rev. 1, NRC Timeliness Goals, Prioritization of Incoming License Applications and Voluntary Submittal of Schedule for Future Actions for NRC Review Applications - Attachment 1 (ML043510074)
application; performing the acknowledgment and technical review; and, preparing RAIs, Safety Evaluation Reports (SERs), certificate of compliances (CoCs), and licenses. Additionally, SFST is currently engaged in the development of enhancements to the review process that would provide added flexibility and enhance efficiency while remaining consistent with the NRCs mission and goals.
If you have any questions regarding this matter, please contact me or Dr. Pamela Longmire, of my staff, at 301-492-3562.
Sincerely,
/RA/
Vonna L. Ordaz, Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards TAC No. LA0119 cc: See attached list
application; performing the acknowledgment and technical review; and, preparing RAIs, Safety Evaluation Reports (SERs), certificate of compliances (CoCs), and licenses. Additionally, SFST is currently engaged in the development of enhancements to the review process that would provide added flexibility and enhance efficiency while remaining consistent with the NRCs mission and goals.
If you have any questions regarding this matter, please contact me or Dr. Pamela Longmire, of my staff, at 301-492-3562.
Sincerely,
/RA/
Vonna L. Ordaz, Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards TAC No. LA0119 cc: See attached list DISTRIBUTION:
SFPO r/f NMSS r/f BWhite MWeber RLorson Filename: G:\\SFST\\Longmire\\NEI\\09-03_Letter.doc ML093350501 OFC:
SFST E SFST SFST SFST SFST NAME:
PLongmire EBenner RLorson RBoyer VOrdaz DATE:
10/02/2009 10/06/2009 12/01/2009 12/09/2009 12/24/09 1/4/10 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
Mr. Steven Sisley, P.E.
Licensing/Regulatory Compliance Manager EnergySolutions Spent Fuel Division 2105 S. Bascom Ave. Suite 316 Campbell, CA 95008 Ms. Tammy Morin, Acting Licensing Manager Holtec International 555 Lincoln Drive West Marlton, NJ 08053 Mr. Anthony Patko, Director Licensing NAC International, Inc.
3930 E. Jones Bridge Rd. Suite 200 Norcross, Georgia 30092 Mr. Don Shaw, Licensing Manager Transnuclear, Inc.
7135 Minstrel Way, Suite 300, Columbia, MD 21045