ML16180A023

Encl. 1: Comments on NEI 14-03 Revision1 (Ltr to R. J. Mccullum Response to Sept. 2015, Nuclear Energy Institute Submittal: NEI-14-03, Format, Content and Implementation Guidance for Dry Cask Storage Operations-Based Aging Management, Rev.

ML16180A023
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Issue date:	08/18/2016
From:	Mark Lombard Division of Spent Fuel Management
To:	Mccullum R Nuclear Energy Institute
Audrain M
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ML16180A018	List: ML16180A021 ML16180A023
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Comments on NEI 14-03 Revision 1 Comment Location Type Comment Action PRM 72-7 has been accepted for rulemaking consideration, but has not Page i,

1. Substantive yet gone through the rulemaking Reword Paragraph 3 process and been added to 10 CFR 72.

Page 1, Change to As Low as Reasonably

2. ALARA Editorial --

Achievable.

Acronym Page 2, Consider harmonization with Harmonize with Baseline NUREG-1927, as the lead

3. Substantive NUREG-1927 Rev 1 Inspection terminology was removed in the final for consistency Definition NUREG-1927, Revision 1.

The definition should be broader, Page 3, Dry consistent with the definition in Reword/Harmonize Storage

4. Substantive NUREG-1927. Use of terms with NUREG-1927 System canister vs. cask introduces some Rev 1 for consistency Definition inconsistencies.

Page 4, Lead Harmonize with

5. Component Substantive See comment #3 NUREG-1927 Rev 1 Definition for consistency Page 5, Change to Pertaining the storage Period of time frame, up to 40 years, after the

6. Extended Substantive initial specific license or CoC term Reword Operation that has been authorized in the Definition renewal.

Page 8, Reword, as statement may imply that Paragraph 2, remediation, repair, and replacement

7. first sentence Substantive Reword/Delete has never had to be done on any and second to SSC.

last sentence Change 3rd sentence to The licensing and design bases for a Page 9,

8. Editorial specific ISFSI license address the Delete only Paragraph 2 facility, location, storage system design Update NUREG Page 10, NUREG-1536 and NUREG-1567 will

9. Editorial number when Section 1.3 change when they are combined combined Statement is misleading, in that Page 11, inaccessibility is not a criteria for Reword/Harmonize

10. Paragraph 1, Substantive determining whether an SSC must be with NUREG-1927 last sentence addressed with an aging Rev 1 for consistency management activity.

Consider adding a statement that Page 11,

11. Substantive these components are inside the Reword Paragraph 2 storage cask/canister and maintained Enclosure 1

in a controlled environment and are not subject to atmospheric environmental effects, however aging effects at relevant exposure temperatures may occur.

Role of ANL Report in MAPS is Page 11, overstated. Only portions of ANL

12. Substantive Reword/Delete Paragraph 3 system descriptions is ultimately being incorporated.

As of this writing, four 40-year Part Page 12,

13. Editorial 72 specific license renewals will Update Paragraph 1 need to be updated.

First two sentences will need to be Page 14,

14. Editorial updated, as the status of renewal Update Paragraph 1 applications changes.

Suggestion to make a reference to Page 16,

15. Substantive Appendix A of NUREG-1927, Add reference Paragraph 2 Nonquantifiable Terms.

Page 16,

16. Editorial Change Appendix C to Appendix B --

Paragraph 3 Would be helpful to list applicable Page 16, ISGs, RGs, or other guidance, along

17. Paragraph 3, Substantive Add reference with their potential use in renewal last sentence applications.

Keep design basis Page 16, design basis documentation. Is and design bases

18. Paragraph 4, Editorial inconsistent with glossary and Part consistent throughout first sentence 72, which states design bases.

document Page 16, Some detailed Paragraph 4, procedures/calculations may need to

19. Substantive Reword second be referenced, to avoid potential sentence RAIs.

Clarify that components that have moving parts typically are covered by Page 17, a maintenance (and testing) program.

20. Section Substantive Reword This would be a basis for not 2.2.2.3 (a) proposing additional aging management activities.

It is not clear whether guidance on active components is appropriate.

Consider reframing to state that the

21. Substantive Reword degradation of active components Page 17, may already be managed in the Section current license.

2.2.2.3 (a)

Add qualifier to last sentence of first Harmonize with paragraph, as long as the SSCs do

22. Substantive NUREG-1927 Rev 1 not meet either of the scoping criteria for consistency in NUREG-1927, Section 2.4.2.

Identified environments definition does not account for off-normal Page 18, Reword/ Harmonize conditions. Consider making

23. Paragraph 1, Substantive with NUREG-1927 consistent with NUREG-1927, first sentence Rev 1 for consistency regarding the range of operating and service conditions.

Page 18, (for prolonged periods of time) is a

24. Paragraph 1, Substantive Reword/Clarify nonquantifiable term.

first sentence Page 18, Rather than saying no aging Paragraph 3, management is required, consider

25. Substantive Reword second adding that a TLAA or technical basis sentence could be provided.

Statement is not entirely accurate.

Page 18, 1927 Rev 1, Appendix B has example Reword/Harmonize Paragraph 4,

26. Substantive AMPs and NUREG -1927 Rev 0 had with NUREG-1927 second Appendix C and Appendix D that Rev 1 for consistency sentence addressed aging effects.

Consider referencing NUREG-1927, Page 19, first Section 3.5 on Time-Limited Aging

27. Substantive Add reference paragraph Analysis Evaluation as last sentence of this paragraph.

Page 19, last

28. Editorial Change Appendix C to Appendix B --

paragraph for 3 SSCs, would more accurately Page 19, last

29. Editorial be stated as 3 groups of SSCs Reword/Clarify paragraph (canisters, concrete, fuel assemblies)

Page 20, first Could reference Section 3.6.1 of

30. Editorial Edit reference sentence 1927, rather than Section 3.6 The phrase summary description of the programs, should be better Page 21, defined to clarify what exactly Section summary description includes. It

31. Substantive Define/Clarify 2.2.2.8 3rd should include the scope, parameters bullet monitored and inspected, detection of aging effects, and acceptance criteria.

Include in the list of bullets, information from NUREG-1927, Rev.

1, Section 1.4.4, regarding any Page 21, differences in the scoping evaluation, Harmonize with

32. Section Editorial aging management review, TLAAs, or NUREG-1927 Rev 1 2.2.2.9 bullets AMPs for each CoC amendment. for consistency This information is reflected in the last sentence of Section 3.2 of NEI 14-03, Rev. 1.

Biennial 10 CFR 72.48 reports that Page 22, are already docketed may be

33. second Substantive Reword referenced in application and do not paragraph need to be submitted with application.

Page 23, The term summary of each AMP

34. Section Substantive should be defined to clarify what that Define/Clarify 2.2.5.2 includes. See Comment 32.

Implies NRC will approve an AMP Page 23, with vague acceptance criteria.

35. Section Substantive Clarify that actionable acceptance Reword 2.2.5.3 criteria should be provided in the application.

Page 25,

36. Editorial Management is misspelled. --

Chapter 3 title Page 25, Suggested edit is to change #1 to number 1 in

37. Editorial identification of materials and --

Section 3.1.1 environments.

list Avoid the word commitment, as this may have an unintended meaning.

Page 25, The staff does not rely on

38. Substantive Edit for clarity Section 3.1.2 commitments (which are not enforceable) to reach reasonable assurance.

Page 28, Keep spelling of Design Basis vs.

39. Section 3.3 Editorial --

Design Bases consistent title This section should note that CoC holders should consider different environments or site conditions, in Page 32, first terms of AMP applicability to the Reword/Harmonize

40. and second Substantive general licensees, in the development with NUREG-1927 paragraph of the CoC renewal application and Rev 1 for consistency the proposed generic AMPs. May reference NUREG-1927 Rev 1, Appendix E.

Page 32, Inaccessibility does not factor into Reword/Harmonize Section whether an SSC must be addressed

41. Substantive with NUREG-1927 3.6.1.1, first with an aging management activity.

Rev 1 for consistency paragraph See comment 11.

Discussion regarding surrogate inspections is contrary to the position in NUREG-1927, in which such Page 34, General inspections are acceptable only when Harmonize with

42. Section Comment on the technical basis is supported by NUREG-1927 Rev 1 3.6.2.2 Section substantial OpE. Presently, there is for consistency not enough OpE to use surrogate inspections. Suggestion to reference 1927s position.

continual, frequent Inspections is Page 35, not an accurate description.

43. Section Substantive Inspection frequency should be Reword 3.6.2.2 determined by the possibility for CISCC and knowledge of the CISCC

rate in a given environment. EPRI examined rates in EPRI report 3002002785 Flaw Growth and Flaw tolerance assessment for Dry Cask Storage Canisters. (Reference 29 of this report). A more accurate description would be periodic inspection based on the susceptibility assessment (Reference 28) and the range of possible crack growth rates (Reference 29)

Heavily geared toward CISCC Page 35, General example, consider expanding Reword/provide other

44. Sections Comment examples to provide general examples 3.6.2.2-3.6.3 guidance.

Speaking 1.5 years into a 5-year General ASME task group process. Suggest Page 35,

45. Comment on to speak to what has been previously Reword/Update Section 3.6.3 Section used/accepted. Last two paragraphs will soon be outdated.

Stating that American Society of Mechanical Engineers (ASME)

Section XI is one resource that the NRC has accepted for aging General management activities at Part 50 Page 35,

46. Comment on power plants. is inaccurate. Consider Reword/Update Section 3.6.3 Section inserting a caveat that the Section XI and the code cases that are developed in Section XI have not received a blanket endorsement by the NRC.

Other than the broad reference to ASME Section XI for power plants, there is nothing is this section that identifies specific codes or standards that may be appropriate. Instead, the section references a general General approach in NUREG-1927 and the Page 35,

47. Comment on ASME Section XI dry storage system Reword/Update Section 3.6.3 Section inspection code case (N-860) that is currently in development. There are many ASTM Standards for monitoring and inspection. In short, this section does not provide useful guidance to the licensee or certificate holders.

Change future knowledge is always Page 36,

48. Editorial captured to future knowledge will --

Section 3.6.4 always be captured

Suggest some guidance for Page 37, determining aging mechanism second bullet

49. Substantive timing, in terms of initiation and rate Reword/Clarify under of progression of the aging frequency mechanism or effect.

More guidance would give licensees a clear, consistent approach on General

50. Page 37 establishing tollgates. (e.g. How to Reword/Clarify Comment use information on aging mechanism timing to establish frequency)

Change to No particular action other Page 38, first Add and appropriate than performing an assessment and

51. paragraph, Editorial corrective actions if appropriate corrective actions if first sentence necessary necessary is required to continue See comment 43. CoC holders should also consider different environments or site conditions, in Page 41, third

52. Substantive terms of AMP applicability to the Reword/Clarify paragraph general licensees, in the development of the CoC renewal application and the proposed generic AMPs.

When mentioning 10 CFR 72.212 report, suggest addressing timing of Page 41, third Harmonize with the update to the report. Specific

53. paragraph, Substantive NUREG-1927 Rev 1 guidance was added in NUREG-last sentence for consistency 1927, Rev.1, Appendix E on this topic.

Page 42, Harmonize with See comment 22 on passive vs.

54. Section 4.3, Substantive NUREG-1927 Rev 1 active components.

third bullet for consistency Suggested edit for clarification. It is Page 42, last unclear what is meant by inability to

55. Editorial --

bullet readily re-locate the radioactive source.

Suggested edit to convey that an inspection of internals may also Page 43,

56. Substantive involve breaching and reestablishing Reword second bullet the confinement boundary, particularly for welded canisters.

Page 45, Consider clarifying how complete

57. Section 4.5.1, Substantive reporting of operating experience to Clarify fourth bullet the AMID will be verified.

Suggest adding guidance for how Page 46, General

58. tollgates interface with the AMID Clarify Section 4.5.3 Comment database.

Appears conflicting with Section Page 47, first 4.5.1, which states that only DSS-

59. paragraph, Substantive related OpE should be entered in Clarify last sentence AMID. Is AMID also for age-related degradation of any passive

component, irrespective of not being DSS-specific and from another industry? Unclear.

Suggest avoiding the word commitment, as this may have an Page 47, General unintended meaning. The staff does

60. second --

Comment not rely on Commitments (which are paragraph not enforceable) to reach reasonable assurance. See comment 39.

Reviewing the ISFSI AMID information prior to performing an AMP inspection seems to be the most logical way to incorporate the ISFSI AMID information into aging management. However, there is no Page 47, prescribed or recommended interval

61. second Substantive Clarify or trigger to review the ISFSI AMID paragraph information. Consider clarifying how this guidance addresses the use of ISFSI AMID so that the information will be reviewed and incorporated into aging management activities in a timely and consistent manner.

Page A-2, #7, Suggest addition preventive or

62. Editorial --

letter d. corrective actions.

63. Page C-1 Editorial Tollgate 1 row is cut off. Extend row