ML20220A183
| ML20220A183 | |
| Person / Time | |
|---|---|
| Issue date: | 09/21/2020 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Shared Package | |
| ML20211L879 | List: |
| References | |
| RG-3.72, Rev 1 | |
| Download: ML20220A183 (5) | |
Text
Response to Public Comments on Draft Regulatory Guide (DG)-3054, Guidance for Implementation of 10 CFR 72.48, Changes, Tests, and Experiments Proposed Revision 1 of Regulatory Guide 3.72 On June 2, 2020, the U.S. Nuclear Regulatory Commission (NRC) published a notice in the Federal Register (85 FR 33582) announcing that Draft Regulatory Guide (DG)-3054 (proposed Revision 1 of Regulatory Guide 3.72) was available for public comment. The public comment period closed on August 3, 2020 and the NRC staff received the following comments:
Commenter Name ADAMS Accession Number Commenter Affiliation Ms. Leonore Cicconettii ML20156A041 No Known Affiliation Mr. Vittorio Blankley ML20156A042 No Known Affiliation Mr. Leonore Cicconettii ML201564043 No Known Affiliation Anonymous ML20191A393 No Known Affiliation Anonymous ML20219A818 No Known Affiliation Rod McCullum ML20219A820 Nuclear Energy Institute, 1201 F Street, NW, Suite 1100 Washington, DC 20004 Telephone: (202) 739-8098 Email: rxm@nei.org
Response to Public Comments on Draft Regulatory Guide (DG)-3054, Proposed Revision 1 of Regulatory Guide 3.72 No. Commenter Comment NRC Resolution 1 Mr. Leonore Agree The NRC accepted the comment, but no Cicconettii changes were made to the DG-3054 in response to this comment.
There was no change made to the final regulatory guide in response to the comment.
2 Mr. Vittorio Agree The NRC accepted the comment, but no Blankley changes were made to the DG-3054 in response to this comment.
There was no change made to the final regulatory guide in response to the comment.
3 Mr. Leonore Agree The NRC accepted the comment, but no Cicconettii changes were made to the DG-3054 in response to this comment.
There was no change made to the final regulatory guide in response to the comment.
4 Anonymous NEI 12-04 Section 3.1.5.2, Reporting of Defects and NEI 12-04, Rev. 2 at Section 3.1.5.2 did not Deficiencies - First Sentence - Need to add 72.242(d) to include all applicable reporting requirements for this section for reporting a design or fabrication CoC holders in the NRCs regulations at 10 CFR deficiency. 72.242(d). The NRC staff agrees with the commenter that 10 CFR 72.242(d) was omitted from Section 3.1.5.2 of NEI 12-04, Reporting of Defects and Deficiencies. 10 CFR 72.242(d) applies to Certificate of Compliance (CoC)
Holders.
NEI 12-04, Revision 2, Section 3.1.5.2, Reporting of Defects and Deficiencies incorrectly states:
Licensees and CoC holders are required to report certain defects or deficiencies in any spent fuel storage structure, system, or component to 2
Response to Public Comments on Draft Regulatory Guide (DG)-3054, Proposed Revision 1 of Regulatory Guide 3.72 No. Commenter Comment NRC Resolution the NRC in accordance with the reporting requirements in 10 CFR 72.75, and 10 CFR 21.
The NRC staff addressed the omission by including the requirement of 10 CFR 72.242(d) in a clarification in Section C. Staff Regulatory Guidance of the revised Regulatory Guide 3.72.
The proposed clarification is as follows:
Clarification - NEI 12-04, Rev. 2 in Section 3.1.5.2 does not include all applicable reporting requirements for CoC holders. The NRCs regulations at 10 CFR 72.242(d) also require that CoC holders submit a written report to the NRC within 30 days of the discovery of a design or fabrication deficiency in any spent fuel storage cask that has been delivered to a licensee and where the design or fabrication deficiency affects the ability of structures, systems and components important to safety to perform their intended safety function.
NEI 12-04, Revision 2, Section 3.1.5.2, Reporting of Defects and Deficiencies should state:
Licensees and CoC holders are required to report certain defects or deficiencies in any spent fuel storage structure, system, or component to the NRC in accordance with the reporting requirements in 10 CFR 72.75, 10 CFR 72.242(d), and 10 CFR 21.
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Response to Public Comments on Draft Regulatory Guide (DG)-3054, Proposed Revision 1 of Regulatory Guide 3.72 No. Commenter Comment NRC Resolution 5 Anonymous I have included Docket ID NRC-2020-0059 in my The subject and content of this comment does comment submission. But actually, my comment is a not pertain to DG-3054. There was no change message to President Trump. made to the final regulatory guide in response to the comment Mr. President, you may not be aware of this, but a group called The Lincoln Project is making very disrespectful videos about you. For example, their latest video "Nationalist Geographic" refers to you as the Small Pawed Trump, Impotus Americanus! And it makes fun of your complexion, which is referred to as Norvell (a brand of spray tan). Not only that they've added 100 pounds to your weight. And they deliberately chose the most unflattering clips, for example your understandably cautious walk down that incredibly steep and slippery ramp at West Point. Can't something be done about this?
I know that you are shutting down TikTok due to Sarah Cooper's disrespectful how to do President videos. Well these Lincoln Project videos are just as bad. Trust me, I watched Nationalist Geographic multiple times to make sure.
6 Nuclear Nuclear Energy Institute (NEI) recommends that This Comment addresses NEIs statement in Energy Exception Number 2 be re-characterized as a clarification Revision 2:
Institute and the following two paragraphs replace the second sentence of the exception (clarification) in DG-3054. Regarding the use of uncertainty in evaluation methods, NEI 12-04, Revision 2, Section 6.8.1, Uncertainty plays a role in a variety of manners in various provides language that addresses the use of stages of a design's development. As part of the design's uncertainty as an element of a method when development, uncertainty is omnipresent. For example, documenting a change under 10 CFR 72.48.
the uncertainty or tolerances associated with canister shell material manufacture plays a role in the final The NRC staff agrees in part with these selection of a specific steel thickness to ensure proper comments and revised exception number two (2) margins are maintained. Similarly, the uncertainty and to clarify the staffs position in the Section C, bias associated with the variables modeled in a criticality Staff Regulatory Guidance of Regulatory Guide analysis are inputs to that analysis. In both of these 3.72, Revision 2.
cases the final character of a safety analysis is influenced by these uncertainties. Such uncertainties are nominally 4
Response to Public Comments on Draft Regulatory Guide (DG)-3054, Proposed Revision 1 of Regulatory Guide 3.72 No. Commenter Comment NRC Resolution categorized as input parameters because they are part of The NRC staff accepts in part NEIs proposed the "physical characteristics of SSCs..."(NEI 12-04, clarifying paragraphs. The NRC staff revised the Definition 2.15). discussion of uncertainty of an element in a method of evaluation (MOE) to also account for As a proposed activity progresses to the phase requiring input parameters, as described in definitions 2.15 a 10 CFR 72.48 Evaluation, some of these uncertainties and 2.17 of NEI 12-04, Revision 2. The NRC are treated as being a formal part of the MOE, while the staffs clarification is as follows:
remainder continue through the 10 CFR 72.48 Evaluation with their categorization as an input parameter Clarification - The statement on uncertainty in unchanged. These remainders continue to play a role in Section 6.8.1 of NEI 12-04, Revision 2, could the evaluation, but, again, are treated as input limit the use of uncertainty in an MOE to be parameters. considered only as an element. The NRC staffs position is that uncertainty in an MOE could either be an element or an input parameter, depending on the circumstances of specified factors to account for uncertainty in measurements or data. The NRC staff also notes that in some situations, an input parameter in an MOE can be considered an element of an MOE, if it meets the criteria for an input parameter being an element of an MOE. Sections 2.15 and 2.17 of NEI 12-04, Revision 2, provide additional guidance on those particular circumstances.
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