ML18313A187
| ML18313A187 | |
| Person / Time | |
|---|---|
| Issue date: | 11/09/2018 |
| From: | Anton S Holtec |
| To: | May Ma Office of Administration |
| References | |
| 83FR39475 00019, NRC-2018-0066, NUREG-2224 | |
| Download: ML18313A187 (3) | |
Text
Holtec Technology Campus, 1 Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID 5014857 Page 1 of 2 November 9, 2018 Ms. May Ma Office of Administration US Nuclear Regulatory Commission Docket ID: NRC-2018-0066
Subject:
Holtec International Comments on Draft NUREG-2224
Dear Ms. Ma:
We fully agree with and support the comment letter on the NUREG submitted by NEI on September 21, 2018. Furthermore, given the importance of this NUREG, we feel the need to reinforce, and supplement those comments:
Further interaction between NRC and the industry is considered crucial for a successful implementation. The examples in Chapter 3 and 4 of the NUREG allow a wide range of options in licensing of HBF, however, many of those will need additional justification, and there appears to be no clear guidance what level of justification would be needed and what the acceptance criteria would be. Resolving this on a case-by-case (i.e. application by application) basis does not appear to be an efficient regulatory process. Developing a broad consensus in that respect would help both applicants and NRC.
The examples in Chapter 3 and 4 make extensive reference to the approaches developed in NUREG/CR-7203. NUREG/CR-7203 clearly and repeatedly states that the configurations considered are studies beyond the design basis, many of those excessively conservative if not physical impossible, and that the purpose of the report is to show the sensitivity to those assumed conditions. However, the way they are referenced in NUREG-2224 does not appear to fully recognize this. And while NUREG-2224 states in numerous places that other approaches may be acceptable, statements such as In an approach acceptable to the Staff. may, for all practical purposes, essentially elevate those approaches or conditions to design basis conditions. We recommend adding an introductory section to those chapters that clearly clarifies the nature of the studies performed in NUREG/CR-7203 and its relevance for NUREG-2224. This would be valuable for both applicants and reviewers.
Holtec Technology Campus, 1 Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID 5014857 Page 2 of 2 Sincerely, Stefan Anton Vice President of Engineering Holtec International
PUBLIC SUBMISSION As of: 11/9/18 1:04 PM Received: November 09, 2018 Status: Pending_Post Tracking No. 1k2-96gf-go8x Comments Due: November 09, 2018 Submission Type: Web Docket: NRC-2018-0066 NUREG-2224, Dry Storage and Transportation of High Burnup Spent Nuclear Fuel, Draft Report for Comment.
Comment On: NRC-2018-0066-0016 Dry Storage and Transportation of High Burnup Spent Nuclear Fuel Document: NRC-2018-0066-DRAFT-0020 Comment on FR Doc # 2018-21974 Submitter Information Name: Stefan Anton General Comment See attached file(s)
Attachments 5014857 - Holtec Comments on NUREG-2224 Page 1 of 1 11/09/2018 https://www.fdms.gov/fdms/getcontent?objectId=09000064838bd30b&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD= Wendy Reed, Ricardo Torres COMMENT (19)
PUBLICATION DATE:
8/9/2018 CITATION: 83 FR 39475