ML22298A281
| ML22298A281 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute, 99902028 |
| Issue date: | 10/12/2022 |
| From: | Mccullum R Nuclear Energy Institute |
| To: | Joseph Donoghue Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NEI 16-03 | |
| Download: ML22298A281 (1) | |
Text
ROD MCCULLUM Sr. Director, Decommissioning and Used Fuel 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8082 rxm@nei.org nei.org October 12, 2022 Mr. Joseph E. Donoghue Director, Division of Reactor Safety Systems Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Supplement to NEIs Request for Review and Endorsement of NEI 16-03, Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools, Revision 1, Dated August 19, 2022 Project Number: 689
Dear Mr. Donoghue:
The Nuclear Energy Institute (NEI)0F1, on behalf of its members, has identified a need to supplement its recent request for review and endorsement of NEI 16-03 Revision 1, Guidance for Monitoring of Neutron Absorbers in Spent Fuel Pools. The original submittal was provided in my letter to you dated August 19, 2022
[ML22231B042]. This submittal was supported by the Electric Power Research Institutes Industrywide Learning Aging Management Program (i-LAMP): Global Neutron Absorber Material Monitoring Program for Spent Fuel Pools [attached to ML22231B042 as Reference 4].
This letter seeks to clarify the subject request for review and endorsement as follows:
The i-LAMP report describes a framework potentially applicable to numerous neutron absorber materials, with an initial focus on BORAL, in particular for pools that do not have coupons.
i-LAMP does not intend to replace the coupon monitoring program for SFPs with coupons.
i-LAMP can only be used as a surrogate to meet regulatory requirements at plants using BORAL that do not have coupons. Other plants are still expected to have installed coupons and continue testing.
For newer materials (for example, Metamic and Boralcan), i-LAMP enables industrywide data collection (coupon results and SFP water chemistry), analysis, and trending. In the event 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.
Joseph E. Donoghue October 12, 2022 Page 2 performance issues are identified in the future, it enables proactive testing, cause determination, extent of condition identification, material lifetime estimation, development of mitigation approaches, and timely dissemination of this information for the benefit of i-LAMP participants.
With this clarification, NEI is narrowing its request for NRC review and endorsement to NEI 16-03 itself and only those portions of the supporting EPRI i-LAMP document that pertain to use of surrogate data for spent fuel pools with BORAL neutron absorbers that do not have coupons. Use of i-LAMP for pools with other types of neutron absorbers is for industry experience sharing purposes only and may not be used as an alternative to meet NRC requirements with respect to coupons in those pools.
Sincerely, Rod McCullum c:
Mr. Steven Bloom, NRC/NRR Mr. Matthew Yoder, NRC/NRR Ms. Leslie Fields, NRC/NRR Ms. Lois James, NRC/NRR