ML21098A024
| ML21098A024 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/2021 |
| From: | Kristina Banovac Storage and Transportation Licensing Branch |
| To: | |
| Karagiannis H | |
| Shared Package | |
| ML21098A001 | List: |
| References | |
| DG 3055 (RG 3.76 Rev 0) Resp to Pub Comm | |
| Download: ML21098A024 (2) | |
Text
Response to Public Comments on Draft Regulatory Guide DG-3055, Implementation of Aging Management Requirements for Spent Fuel Storage Renewals, Proposed new Regulatory Guide 3.76 On December 11, 2020, the U.S. Nuclear Regulatory Commission (NRC) published a notice in the Federal Register (85 FR 80193) announcing the availability for public comment of Draft Regulatory Guide (DG)-3055, Implementation of Aging Management Requirements for Spent Fuel Storage Renewals, proposed new Regulatory Guide (RG) 3.76. The public comment period ended on January 25, 2021. The NRC received comments from the following organization:
Mr. Rod McCullum Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 rxm@nei.org Dated: January 25, 2021 Agencywide Documents Access and Management System Accession No. ML21025A364 The table below shows the public comments and the NRC staffs responses.
Commenter Specific Comments NRC Resolution Mr. Rod McCullum We agree with NRCs decision, in draft regulatory guide (DG)
DG-3055, Implementation of Aging Management Requirements for Spent Fuel Storage Renewals, not to endorse the use of surrogate inspections at this time. With regard to the clarification on surrogate inspections, NUREG-1927, Revision 1, notes that surrogate inspections may be acceptable only when substantial operating experience provides a basis for their use. To date, there is currently insufficient operating experience from canister examinations to apply susceptibility assessments and use surrogate data across the ISFSI [independent spent fuel storage installation] fleet, as had originally been proposed in NEI 14-03, Revision 2. In the future, when industry has gained additional experience applying operations-based aging management, it may be appropriate to The NRC staff agrees with the comment, including the industrys encouragement of the use of AMID. The NRC staff will reengage with stakeholders on the topic of surrogate inspections in the future, as appropriate.
2 Commenter Specific Comments NRC Resolution re-engage in the dialogue relative to the use of surrogate inspection results. To that end, NEI strongly advocates and encourages industry use of the Aging Management Information Database (AMID) to inform the basis for potential future application of surrogate inspection results.
Mr. Rod McCullum Clarification 3.h indicates that the applicant should supply a summary of proposed FSAR [final safety analysis report]
change related to aging management. The staff clarification requests specific proposed FSAR changes. This clarification is unnecessarily constraining for the following reasons:
The applicant may modify those FSAR changes under
[10 CFR] 72.48 any time after the renewal is approved.
Therefore, NRC approval of FSAR changes is not required.
The potential exists that FSAR information could be incorporated by reference into the renewed license or CoC [certificate of compliance], thus removing it from the 72.48 scope.
The regulations do not require specific FSAR markups as part of the submittal. We recognize that regulations for ISFSI license renewals and CoC renewals are somewhat different.
The potential for unnecessary administrative burden is not driven by safety issues. An applicant can inform the NRC where the information required by regulations will reside in the FSAR. The RAI [request for additional information] process may be used to clarify the FSAR changes.
The NRC staff agrees with the comment in part. The staff notes that the clarification was not intended to restrict a licensee or CoC holder from making changes to the aging management information in the final safety analysis report (FSAR) (as updated), after the renewal.
The regulations do not explicitly require FSAR changes to be submitted as part of the license or CoC renewal application.
The NRC staff notes that the FSAR supplement in the renewal application should provide sufficient information on aging management programs (AMPs) in the period of extended operation (e.g., scope, parameters monitored and inspected, detection of aging effects, and acceptance criteria) to be auditable by the NRC. This FSAR supplement may include, but is not limited to, specific FSAR proposed changes, or a summary of the time-limited aging analyses (TLAAs) and AMPs with enough details for the NRC staff to understand how the FSAR will include the aging management information that forms the basis for NRCs approval of the renewal.
The NRC staff made changes to the clarification 3.h in the final RG to reflect this comment response.