ML22301A179
| ML22301A179 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 12/02/2022 |
| From: | Siva Lingam Licensing Processes Branch |
| To: | Mccullum R Nuclear Energy Institute |
| References | |
| EPID L-2022-NTR-0002 | |
| Download: ML22301A179 (1) | |
Text
December 2, 2022 Mr. Rodney McCullum Senior Director, Decommissioning and Used Fuel Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
ACCEPTANCE REVIEW FOR NUCLEAR ENERGY INSITUTE DOCUMENT NEI 16-03, REVISION 1, GUIDANCE FOR MONITORING OF FIXED NEUTRON ABSORBERS IN SPENT FUEL POOLS (EPID L-2022-NTR-0002)
Dear Mr. McCullum:
By letter dated August 19,2022, as supplemented by letter dated October 12, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML22231B041 and ML22298A281, respectively), the Nuclear Energy Institute (NEI) submitted a Topical Report (TR) NEI 16-03, Revision 1, Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools, on behalf of its members for U.S. Nuclear Regulatory Commission (NRC) review and endorsement. NEI 16-03, Revision 1, includes Electric Power Research Institute (EPRI)
Technical Report 3002018497, Industrywide Learning Aging Management Program (i-LAMP):
Global Neutron Absorber Material Monitoring Program for Spent Fuel Pools, dated August 2022, as an alternative monitoring approach.
The purpose of this letter is to provide the results of the NRC staffs acceptance review of the NEI submittal. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review.
The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements in the TR.
The NRC staff has reviewed your TR and concluded that it did not provide technical information in sufficient detail to enable the staff to complete its detailed review and make an independent assessment regarding the acceptability of the proposed TR in terms of regulatory requirements for the protection of public health and safety and the environment. This informational need was conveyed to you via public meeting on November 21, 2022.
Because of the extensive nature of the information needed, the NRC staff finds the request for approval of the proposed action unacceptable for NRC review.
R. McCullum In accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-109, Acceptance Review Procedures for Licensing Basis Changes (ADAMS Accession No. ML20036C829), the NRC staff performed a review to determine whether the proposed NEI 16-03, Revision 1, Guidance for Monitoring Fixed Neutron Absorbers in Spent Fuel Pools, includes sufficient information to begin a detailed technical review. Using the guidance provided in Appendix B, Guide for Performing Acceptance Reviews, of LIC-109, the NRC staff determined that the proposed TR does not contain sufficient information to initiate its review, as described below:
- 1. As described in LIC-109, A licensees use of unapproved codes or TRs (or the use of codes and TRs outside the limitations imposed by the NRC staff) may be acceptable if the licensee has provided a full analysis to justify that the proposed use satisfies NRC regulations and is appropriately conservative. However, simply referencing an unapproved TR or code is not acceptable. Electric Power Research Institute (EPRI)
Report 3002018497, Industrywide Learning Aging Management Program (i-LAMP):
Global Neutron Absorber Material Monitoring Program for Spent Fuel Pools, is an unapproved TR that, until the submittal of NEI 16-03, Revision 1, the staff has not seen.
While its inclusion as a reference is not an immediate cause for non-acceptance, the lack of a full analysis to justify that the proposed use satisfies NRC regulations and is appropriately conservative cannot be verified.
- 2. The changes made in NEI 16-03, Revision 1, provide a high-level background on the i-LAMP program, but provide no programmatic details and no guidance on how licensees would use the program to manage neutron absorbers at their facility.
- 3. NEI 16-03, Revision 1, does not provide guidance on implementation of i-LAMP. Instead, it says that the i-LAMP report describes different implementation options. These are the details that should be included in the NEI guidance document.
- 4. NEI 16-03, Revision 1 contains no description of parameters that licensees are expected to follow if they choose to use i-LAMP (e.g., verification of bounding data for a specific plant, periodicity of formal i-LAMP data review to ensure the plant is bounded or new operating experience is available).
- 5. Programs that were approved by the NRC as part of NEI 16-03, Revision 0, include coupon testing, and in-situ measurement. For both programs the Revision 0 guidance provided program elements, sampling intervals, acceptance criteria, and guidance on evaluation of results. None of these programmatic details are provided for the newly proposed i-LAMP program. NEI 16-03, Revision 1, should contain the same level of detail for i-LAMP as the previously approved Revision 0 contained for coupon testing and in-situ measurement.
- 6. I-LAMP is only applicable to Boral in the current EPRI document. However, NEI 16-03, Revision 1, does not say that it should only be used for Boral. Although it says that the i-LAMP document has an initial focus on Boral, it does not rule out i-LAMP use for other neutron absorber materials. The NRC staff notes that the supplemental letter dated October 12, 2022, provides some clarification regarding the current programs focus on Boral plants without coupons. However, the same letter goes on to describe i-LAMPs applicability to newer materials. Given the current state of the i-LAMP program (only R. McCullum Boral data has been reported), the staff does not agree with the notion that i-LAMP should be treated as a non-material specific alternative monitoring approach as described in the NEI 16-03, Revision 1, under Forward section.
In order to make the application complete, the NRC staff requests that NEI supplement the application to address the above information within 13 working days from the date of this letter.
This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, Filing of application, and the NRC will cease its activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staffs detailed technical review by separate correspondence.
If you have any questions, please contact me at (301) 415-1564 or via e-mail at Siva.Lingam@nrc.gov.
Sincerely,
/RA/
Siva P. Lingam, Senior Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902028
ML22301A179 OFFICE NRR/DORL/LLPB/PM*
NRR/DORL/LLPB/LA*
NRR/DNRL/NCSG/BC*
NRR/DORL/LLPB/BC (A)*
NAME SLingam DHarrison SBloom LJames (A)
DATE 11/7/22 11/7/22 11/8/22 11/8/22 OFFICE NRR/DNRL/D*
NRR/NRR/DORL/D*
NRR/DORL/LLPB/PM NAME BSmith (BThomson for)
BPham (GSuber for)
SLingam DATE 11/21/22 11/28/22 12/2/22