ML16180A023
| ML16180A023 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/2016 |
| From: | Mark Lombard Division of Spent Fuel Management |
| To: | Mccullum R Nuclear Energy Institute |
| Audrain M | |
| Shared Package | |
| ML16180A018 | List: |
| References | |
| Download: ML16180A023 (8) | |
Text
Enclosure 1 Comments on NEI 14-03 Revision 1 Comment Location Type Comment Action
- 1.
Page i, Paragraph 3 Substantive PRM 72-7 has been accepted for rulemaking consideration, but has not yet gone through the rulemaking process and been added to 10 CFR
- 72.
Reword
- 2.
Page 1, ALARA Acronym Editorial Change to As Low as Reasonably Achievable.
- 3.
Page 2, Baseline Inspection Definition Substantive Consider harmonization with NUREG-1927, as the lead terminology was removed in the final NUREG-1927, Revision 1.
Harmonize with NUREG-1927 Rev 1 for consistency
- 4.
Page 3, Dry Storage System Definition Substantive The definition should be broader, consistent with the definition in NUREG-1927. Use of terms canister vs. cask introduces some inconsistencies.
Reword/Harmonize with NUREG-1927 Rev 1 for consistency
- 5.
Page 4, Lead Component Definition Substantive See comment #3 Harmonize with NUREG-1927 Rev 1 for consistency
- 6.
Page 5, Period of Extended Operation Definition Substantive Change to Pertaining the storage time frame, up to 40 years, after the initial specific license or CoC term that has been authorized in the renewal.
Reword
- 7.
Page 8, Paragraph 2, first sentence and second to last sentence Substantive Reword, as statement may imply that remediation, repair, and replacement has never had to be done on any SSC.
Reword/Delete
- 8.
Page 9, Paragraph 2 Editorial Change 3rd sentence to The licensing and design bases for a specific ISFSI license address the facility, location, storage system design Delete only
- 9.
Page 10, Section 1.3 Editorial NUREG-1536 and NUREG-1567 will change when they are combined Update NUREG number when combined
- 10.
Page 11, Paragraph 1, last sentence Substantive Statement is misleading, in that inaccessibility is not a criteria for determining whether an SSC must be addressed with an aging management activity.
Reword/Harmonize with NUREG-1927 Rev 1 for consistency
- 11.
Page 11, Paragraph 2 Substantive Consider adding a statement that these components are inside the storage cask/canister and maintained Reword
in a controlled environment and are not subject to atmospheric environmental effects, however aging effects at relevant exposure temperatures may occur.
- 12.
Page 11, Paragraph 3 Substantive Role of ANL Report in MAPS is overstated. Only portions of ANL system descriptions is ultimately being incorporated.
Reword/Delete
- 13.
Page 12, Paragraph 1 Editorial As of this writing, four 40-year Part 72 specific license renewals will need to be updated.
Update
- 14.
Page 14, Paragraph 1 Editorial First two sentences will need to be updated, as the status of renewal applications changes.
Update
- 15.
Page 16, Paragraph 2 Substantive Suggestion to make a reference to Appendix A of NUREG-1927, Nonquantifiable Terms.
Add reference
- 16.
Page 16, Paragraph 3 Editorial Change Appendix C to Appendix B
- 17.
Page 16, Paragraph 3, last sentence Substantive Would be helpful to list applicable ISGs, RGs, or other guidance, along with their potential use in renewal applications.
Add reference
- 18.
Page 16, Paragraph 4, first sentence Editorial design basis documentation. Is inconsistent with glossary and Part 72, which states design bases.
Keep design basis and design bases consistent throughout document
- 19.
Page 16, Paragraph 4, second sentence Substantive Some detailed procedures/calculations may need to be referenced, to avoid potential RAIs.
Reword
- 20.
Page 17, Section 2.2.2.3 (a)
Substantive Clarify that components that have moving parts typically are covered by a maintenance (and testing) program.
This would be a basis for not proposing additional aging management activities.
Reword
- 21.
Page 17, Section 2.2.2.3 (a)
Substantive It is not clear whether guidance on active components is appropriate.
Consider reframing to state that the degradation of active components may already be managed in the current license.
Reword
- 22.
Substantive Add qualifier to last sentence of first paragraph, as long as the SSCs do not meet either of the scoping criteria in NUREG-1927, Section 2.4.2.
Harmonize with NUREG-1927 Rev 1 for consistency
- 23.
Page 18, Paragraph 1, first sentence Substantive Identified environments definition does not account for off-normal conditions. Consider making consistent with NUREG-1927, regarding the range of operating and service conditions.
Reword/ Harmonize with NUREG-1927 Rev 1 for consistency
- 24.
Page 18, Paragraph 1, first sentence Substantive (for prolonged periods of time) is a nonquantifiable term.
Reword/Clarify
- 25.
Page 18, Paragraph 3, second sentence Substantive Rather than saying no aging management is required, consider adding that a TLAA or technical basis could be provided.
Reword
- 26.
Page 18, Paragraph 4, second sentence Substantive Statement is not entirely accurate.
1927 Rev 1, Appendix B has example AMPs and NUREG -1927 Rev 0 had Appendix C and Appendix D that addressed aging effects.
Reword/Harmonize with NUREG-1927 Rev 1 for consistency
- 27.
Page 19, first paragraph Substantive Consider referencing NUREG-1927, Section 3.5 on Time-Limited Aging Analysis Evaluation as last sentence of this paragraph.
Add reference
- 28.
Page 19, last paragraph Editorial Change Appendix C to Appendix B
- 29.
Page 19, last paragraph Editorial for 3 SSCs, would more accurately be stated as 3 groups of SSCs (canisters, concrete, fuel assemblies)
Reword/Clarify
- 30.
Page 20, first sentence Editorial Could reference Section 3.6.1 of 1927, rather than Section 3.6 Edit reference
- 31.
Page 21, Section 2.2.2.8 3rd bullet Substantive The phrase summary description of the programs, should be better defined to clarify what exactly summary description includes. It should include the scope, parameters monitored and inspected, detection of aging effects, and acceptance criteria.
Define/Clarify
- 32.
Page 21, Section 2.2.2.9 bullets Editorial Include in the list of bullets, information from NUREG-1927, Rev.
1, Section 1.4.4, regarding any differences in the scoping evaluation, aging management review, TLAAs, or AMPs for each CoC amendment.
This information is reflected in the last sentence of Section 3.2 of NEI 14-03, Rev. 1.
Harmonize with NUREG-1927 Rev 1 for consistency
- 33.
Page 22, second paragraph Substantive Biennial 10 CFR 72.48 reports that are already docketed may be referenced in application and do not need to be submitted with application.
Reword
- 34.
Page 23, Section 2.2.5.2 Substantive The term summary of each AMP should be defined to clarify what that includes. See Comment 32.
Define/Clarify
- 35.
Page 23, Section 2.2.5.3 Substantive Implies NRC will approve an AMP with vague acceptance criteria.
Clarify that actionable acceptance criteria should be provided in the application.
Reword
- 36.
Page 25, Chapter 3 title Editorial Management is misspelled.
- 37.
Page 25, number 1 in Section 3.1.1 list Editorial Suggested edit is to change #1 to identification of materials and environments.
- 38.
Page 25, Section 3.1.2 Substantive Avoid the word commitment, as this may have an unintended meaning.
The staff does not rely on commitments (which are not enforceable) to reach reasonable assurance.
Edit for clarity
- 39.
Page 28, Section 3.3 title Editorial Keep spelling of Design Basis vs.
Design Bases consistent
- 40.
Page 32, first and second paragraph Substantive This section should note that CoC holders should consider different environments or site conditions, in terms of AMP applicability to the general licensees, in the development of the CoC renewal application and the proposed generic AMPs. May reference NUREG-1927 Rev 1, Appendix E.
Reword/Harmonize with NUREG-1927 Rev 1 for consistency
- 41.
Page 32, Section 3.6.1.1, first paragraph Substantive Inaccessibility does not factor into whether an SSC must be addressed with an aging management activity.
See comment 11.
Reword/Harmonize with NUREG-1927 Rev 1 for consistency
- 42.
Page 34, Section 3.6.2.2 General Comment on Section Discussion regarding surrogate inspections is contrary to the position in NUREG-1927, in which such inspections are acceptable only when the technical basis is supported by substantial OpE. Presently, there is not enough OpE to use surrogate inspections. Suggestion to reference 1927s position.
Harmonize with NUREG-1927 Rev 1 for consistency
- 43.
Page 35, Section 3.6.2.2 Substantive continual, frequent Inspections is not an accurate description.
Inspection frequency should be determined by the possibility for CISCC and knowledge of the CISCC Reword
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)
- 44.
Page 35, Sections 3.6.2.2-3.6.3 General Comment Heavily geared toward CISCC example, consider expanding examples to provide general guidance.
Reword/provide other examples
- 45.
Page 35, Section 3.6.3 General Comment on Section Speaking 1.5 years into a 5-year ASME task group process. Suggest to speak to what has been previously used/accepted. Last two paragraphs will soon be outdated.
Reword/Update
- 46.
Page 35, Section 3.6.3 General Comment on Section Stating that American Society of Mechanical Engineers (ASME)
Section XI is one resource that the NRC has accepted for aging management activities at Part 50 power plants. is inaccurate. Consider 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.
Reword/Update
- 47.
Page 35, Section 3.6.3 General Comment on Section 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 approach in NUREG-1927 and the ASME Section XI dry storage system 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.
Reword/Update
- 48.
Page 36, Section 3.6.4 Editorial Change future knowledge is always captured to future knowledge will always be captured
- 49.
Page 37, second bullet under frequency Substantive Suggest some guidance for determining aging mechanism timing, in terms of initiation and rate of progression of the aging mechanism or effect.
Reword/Clarify
- 50.
Page 37 General Comment More guidance would give licensees a clear, consistent approach on establishing tollgates. (e.g. How to use information on aging mechanism timing to establish frequency)
Reword/Clarify
- 51.
Page 38, first paragraph, first sentence Editorial Change to No particular action other than performing an assessment and appropriate corrective actions if necessary is required to continue Add and appropriate corrective actions if necessary
- 52.
Page 41, third paragraph Substantive See comment 43. CoC holders should also consider different environments or site conditions, in terms of AMP applicability to the general licensees, in the development of the CoC renewal application and the proposed generic AMPs.
Reword/Clarify
- 53.
Page 41, third paragraph, last sentence Substantive When mentioning 10 CFR 72.212 report, suggest addressing timing of the update to the report. Specific guidance was added in NUREG-1927, Rev.1, Appendix E on this topic.
Harmonize with NUREG-1927 Rev 1 for consistency
- 54.
Page 42, Section 4.3, third bullet Substantive See comment 22 on passive vs.
active components.
Harmonize with NUREG-1927 Rev 1 for consistency
- 55.
Page 42, last bullet Editorial Suggested edit for clarification. It is unclear what is meant by inability to readily re-locate the radioactive source.
- 56.
Page 43, second bullet Substantive Suggested edit to convey that an inspection of internals may also involve breaching and reestablishing the confinement boundary, particularly for welded canisters.
Reword
- 57.
Page 45, Section 4.5.1, fourth bullet Substantive Consider clarifying how complete reporting of operating experience to the AMID will be verified.
Clarify
- 58.
Page 46, Section 4.5.3 General Comment Suggest adding guidance for how tollgates interface with the AMID database.
Clarify
- 59.
Page 47, first paragraph, last sentence Substantive Appears conflicting with Section 4.5.1, which states that only DSS-related OpE should be entered in AMID. Is AMID also for age-related degradation of any passive Clarify
component, irrespective of not being DSS-specific and from another industry? Unclear.
- 60.
Page 47, second paragraph General Comment Suggest avoiding the word commitment, as this may have an unintended meaning. The staff does not rely on Commitments (which are not enforceable) to reach reasonable assurance. See comment 39.
- 61.
Page 47, second paragraph Substantive 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 prescribed or recommended interval or trigger to review the ISFSI AMID 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.
Clarify
- 62.
Page A-2, #7, letter d.
Editorial Suggest addition preventive or corrective actions.
- 63.
Page C-1 Editorial Tollgate 1 row is cut off.
Extend row