last sentence: fuel that is transferred “Spent clar GER2 7 1.14 The intended use is decisive for the X to destined for reprocessing facilities is not classification of spent fuel (either considered radioactive waste.” radioactive waste or a future energy resource), not the physical act of a transfer to a reprocessing facility. edit GER3 6 1.14 2nd sentence: “These are dealt with in the To be consistent within this list X Safety Guides WS-G-6.1, Storage of (citation of the relevant Safety Radioactive Waste [10] and SSG-15, Storage Guides either with or without their of Spent Nuclear Fuel [11].” titles). IRQ 3 1.167 This paragraph is better to be omitted. Because this draft is not concern X Text was agreed with with physical protection of NSCGC materials. 2nd sentence: and “Recommendations edit GER3 8 1.17 Simplify wording. X guidelines on nuclear security arrangements at nuclear facilities and of radioactive material are provided in publications in … the IAEA Nuclear Security Series, such as IAEA Nuclear Security Series No. 14 [14].” IRQ 6 2 General exemption criteria for predisposal Identify the need for optimization X waste management practices should be of radiation protection and safety included. measures. 2.02 Safety Requirements, GS-R-3, The The “The UK’s non-prescriptive UK 15 “The Safety X DS456, Leadership and Management System for Facilities and regulatory regime implies that Requirements, GS-R-3, Management for Safety Activities, requires establishment of the management both the regulatory body The Management (revision of GS-R-3), is the operator to establish a management systems that ensure safety is purely and System for Facilities and applicable to the the responsibility of operators. The system….” Activities, requires both operation as well as the independent regulatory body is the regulatory body and regulation of facilities. responsible for setting out the goals the operator to the that such management systems establishment of a should achieve, without being management system….” proactively involved in the establishment of those systems.
clar GER2 7 1.14 last sentence: “Spent fuel that is transferred to destined for reprocessing facilities is not considered radioactive waste.” The intended use is decisive for the classification of spent fuel (either radioactive waste or a future energy resource), not the physical act of a transfer to a reprocessing facility. X edit GER3 6 1.14 2nd sentence: “These are dealt with in the Safety Guides WS-G-6.1, Storage of Radioactive Waste [10] and SSG-15, Storage of Spent Nuclear Fuel [11].” To be consistent within this list (citation of the relevant Safety Guides either with or without their titles). X IRQ 3 1.167 This paragraph is better to be omitted. Because this draft is not concern with physical protection of materials. X Text was agreed with NSCGC edit GER3 8 1.17 2nd sentence: “Recommendations and guidelines on nuclear security arrangements at nuclear facilities and of radioactive material are provided … in publications in the IAEA Nuclear Security Series, such as IAEA Nuclear Security Series No. 14 [14].” Simplify wording. X IRQ 6 2 General exemption criteria for predisposal waste management practices should be included. Identify the need for optimization of radiation protection and safety measures. X UK 15 2.02 “The Safety Requirements, GS-R-3, The Management System for Facilities and Activities, requires both the regulatory body and the operator to establish a management system….” The UK’s non-prescriptive regulatory regime implies that establishment of the management systems that ensure safety is purely the responsibility of operators. The independent regulatory body is responsible for setting out the goals that such management systems should achieve, without being proactively involved in the establishment of those systems. “The Safety Requirements, GS-R-3, The Management System for Facilities and Activities, requires both the regulatory body and the operator to the establishment of a management system….” X DS456, Leadership and Management for Safety (revision of GS-R-3), is applicable to the operation as well as the regulation of facilities.
a%20Consolidated%20MS%20Comments%20DS447.docx