ML21050A285
| ML21050A285 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/08/2021 |
| From: | Lane H Nuclear Energy Institute |
| To: | Borges J Office of Administration |
| References | |
| 85FR76489 00002, NRC-2020-0253 | |
| Download: ML21050A285 (5) | |
Text
2/19/2021 blob:https://www.fdms.gov/3b83eabd-aabc-4348-86b6-0e36a8b25021 SUNI Review Complete As of: 2/19/21 1:13 PM Template=ADM-013 Received: February 08, 2021 PUBLIC SUBMISSION E-RIDS=ADM-03 ADD: Hipo Status: Pending_Post Tracking No. 1k5-9loi-31a3 Gonzalez, Isaac Lopaz Anchondo, Comments Due: February 08, 2021 Mary Neely Submission Type: Web Comment (2)
Publication Date:
Docket: NRC-2020-0253 11/23/2020 Advanced Manufacturing Technologies Subtask 2A CITATION: 85 FR 76489 Comment On: NRC-2020-0253-0003 Advanced Manufacturing Technologies Subtask 2A Document: NRC-2020-0253-DRAFT-0004 Comment on FR Doc # 2020-26845 Submitter Information Name: Hilary Lane General Comment See attached file(s)
Attachments 02-08-21_NRC_NEI Comments on Draft Regulatory Basis blob:https://www.fdms.gov/3b83eabd-aabc-4348-86b6-0e36a8b25021 1/1
HILARY LANE Director, Fuel and Radiation Safety 1201 F Street NW, Suite 1100 Washington, DC 20004 P: 202.341.7951 hml@nei.org nei.org February 8, 2021 Jennifer Borges Office of Administration ATTN: Program Management, Announcements and Editing Staff Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Industry Comments on Draft Regulatory Basis Document, Implementation of Quality Assurance Criteria and 10 CFR 50.59 for Nuclear Power Plant Components Produced Using Advanced Manufacturing Technologies, Docket ID NRC-2020-0253 Submitted via regulations.gov Project Number: 689
Dear Ms. Borges:
The Nuclear Energy Institute (NEI) 1, on behalf of its members, submits the following comments on the draft Regulatory Basis document, Implementation of Quality Assurance Criteria and 10 CFR 50.59 for Nuclear Power Plant Components Produced Using Advanced Manufacturing Technologies, which represents Sub-task 2A on the NRCs Advanced Manufacturing Technologies (AMT) Action Plan. We appreciated the opportunity to discuss this draft with NRC staff at the recent January 14, 2021 public meeting. Furthermore, the issuance of a revised Federal Register Notice (FRN) on December 10, 2020, was most welcomed, as it extended the comment period from 45 days to 60 days, and allowed the industry a greater timeframe for review.
AMT applications are of significant interest to both the current operating fleet and advanced reactor developers. There are numerous AMTs that are technologically mature for use in the nuclear industry, and in fact many are already being used in other industries. Testing and qualification efforts by suppliers, the Electric Power Research Institute (EPRI), DOE National Laboratories, universities, and others are well 1
The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Ms. Jennifer Borges February 8, 2021 Page 2 underway to further expand AMT use in safety-related applications for the nuclear industry. Many of these activities were discussed at length at the NRCs recent AMT Workshop, on December 7-10, 2020, which we found to be very productive and informative.
We recognize that the intent of this draft document is not to create new regulatory requirements or establish new regulatory positions. We also understand that this draft document may be subject to future revision, and support the notion that such future revisions would factor in additional industry operating experience and insights. We feel this is one of several components in creating a risk-informed regulatory framework for AMTs. We also believe that AMT experiences and insights from other industries can play a role in regulatory decision making.
The nuclear industrys first AMT deployment using the § 50.59 pathway occurred in Spring 2020. We expect to see many other applications of AMT pursue a § 50.59 pathway, with additional deployments in the pipeline, continuing as early as Spring 2021. Provided the provisions of § 50.59 are satisfied, this well-defined, pre-existing regulatory approach allows the industry a straightforward and efficient method to deploy AMT components, without the need for a license amendment or prior approval. As such, we want to emphasize that there is considerable and continuing interest in utilizing the § 50.59 regulatory pathway for future applications. We support the NRCs conclusion that the current QA criteria and § 50.59 regulations are sufficient for AMT applications.
As industry interest continues to grow, we underscore the importance of communication amongst multiple stakeholders, in furthering the development of these transformative technologies. We look forward to further engagement on AMT and working together throughout the progression of the NRCs AMT Action Plan.
Our more detailed comments can be found in the attachment to this letter. Please do not hesitate to contact me (hml@nei.org or 202.341.7951) should you have any questions.
Sincerely, Hilary Lane Attachment c: Mr. Hipolito Gonzalez, NRR Mr. Isaac Anchondo-Lopez, NRR
Attachment:
NEI Detailed Comments on Draft Regulatory Basis, Implementation of Quality Assurance Criteria and 10 CFR 50.59 for Nuclear Power Plant Components Produced Using Advanced Manufacturing Technologies Section Comment Proposed Resolution Pg. 8 The third paragraph has the following Clarification is requested on whether the sentence: word efforts should instead read effects.
However, for plant-specific applications, all relevant information related to specific AMT components and the component that will be replaced needs to be identified and analyzed for site-specific efforts.
Pg. 25 The following statement makes an There are several SDO activities currently assumption about the current state of AMT under review, including a code case Codes and Standards: submission to ASME Section III in August 2020, that would change the stated It is also assumed that the AMT assumption.
material/fabrication method has not yet been codified by the U.S. By the nature of the NRCs statement, it nuclear industry in a national begs the question as to whether the consensus standard that has been presence of an endorsed code case would formally endorsed by the NRC. change the outcome of applying the § 50.59 Screening (as outlined in Fig. 1 and in Section 4.2, Page 27). In fact, it seems reasonable that at this point in the process, the presence of an endorsed code case should automatically eliminate the need to perform a full § 50.59 Evaluation in conjunction with the 8 evaluation criteria. This is oftentimes referred to as screening out.
We recommend including a statement in Section 4.0 that would clarify and delineate how the presence of an endorsed code case would streamline the overall process for licensees, including any efficiencies through the § 50.59 process, including screening out.
Pg. 29-30 We noticed that certain terms in the Changing pre-defined terms may lead to document are italicized. We assume this is confusion with the reader and/or licensee, to mean that they are defined terms, but and should be avoided. Consider keeping that was not made clear. the terminology consistent with previously endorsed NEI 96-07 and related documents.
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NEI Detailed Comments on Draft Regulatory Basis, Furthermore, certain italicized terms do not explicitly match the terms in NRC- Further, terms or definitions should be endorsed NEI 96-07, Guidelines for 10 identified consistently throughout the CFR 50.59 Implementation. One specific document, whether it is determined to be example of this was the defined term quotation marks and/or italics.
Methods of Evaluation (Rev. 1, Sec. 3.10).
NRCs draft document uses a different italicized term, to the effect of element of an evaluation method.
There are also instances when the original defined term method(s) of evaluation are used (see Pages 25, 29, 30, 33), however it is not italicized in line with other key terms.
Pg. 31, The process conclusion on the bottom left N/A Figure 3 would be more accurate if it stated that the change may be documented and implemented per 10 CFR 50.59.
The difference being that in the other two process conclusions, a § 50.59 evaluation will be documented with an outcome of either 1) the licensee may implement per § 50.59, or 2) a license amendment request is necessary per § 50.90. Thus, all three flowchart end states could result in may be implemented per 10 CFR 50.59; the difference is in the point in the § 50.59 process where that conclusion is reached.
Pg. 33 Consider changing the following phrases Revised language could read as follows:
from as a departure to for a departure.
(1) Adverse changes to elements of a This avoids pre-judging the outcome of the methodology are treated for a departure evaluation and response to criterion (viii). from a method of evaluation.
(2) For AMT components, material properties or other component design parameters should be considered methodology elements if they meet either of the above criteria; adverse changes to these elements should be evaluated for a departure from the methods of evaluation in accordance with 10 CFR 50.59(c)(2)(viii).
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