ML23181A032
| ML23181A032 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 06/28/2023 |
| From: | Laing D Maine Yankee Atomic Power Co |
| To: | Office of Administration |
| References | |
| NRC-2023-0107, 88FR36514 00005, OMY-23-014 | |
| Download: ML23181A032 (1) | |
Text
6/30/23, 7:38 AM blob:https://www.fdms.gov/3fed6160-3448-4a9d-9b1e-018fb91bb408 SUNSI Review Complete Template=ADM-013 As of: 6/30/23, 7:38 AM E-RIDS=ADM-03 Received: June 29, 2023 PUBLIC SUBMISSION ADD: John -Chau Nguyen, Harriet Karagiannis, Bridget Status: Pending_Post Tracking No. ljh-utzf-9xbx Curran, Mary Neely Comments Due: July 05, 2023 Comment (5)
Publication Date: 6/5/2023 Submission Type: Web Citation: 88 FR 36514 Docket: NRC-2023-0107 Draft Regulatory Guide: Weather-Related Administrative Controls at Independent Spent Fuel Storage Installations Comment On: NRC-2023-0107-0001 Draft Regulatory Guide: Weather-Related Administrative Controls at Independent Spent Fuel Storage Installations Document: NRC-2023-0107-DRAFT-0007 Comment on FR Doc # 2023-11895 Submitter Information Email: sday@3yankees.com Organization: Maine Yankee Atomic Power Company General Comment See attached file(s)
Attachments OMY-23-014 - Comments on DG-3057 blob:https://www.fdms.gov/3fed6160-3448-4a9d-9b1e-018fb91bb408 1/1
Maine Yankee Atomic Power Company OMY-23-014/June 28, 2023/Page 2 represent the weather at the site. In these cases, the user would enter the site's zip-code and the NWS usually provides a forecast based on data from the closest airport, not from NWS data. Does the utilization of this data provided through the NWS meet the intent of the NRC's clarification?
Exception #8 is too open ended and could be subject to differing opinions on how well a site has addressed contingencies. What a licensee develops as a sufficient contingency policy for a site may not seem sufficient to an inspector/auditor. Consideration should also be given to Independent Spent Fuel Storage Installation (ISFSI) only sites that do not have access to plant equipment like single failure proof cranes. Aging management inspections performed to date have proved to have sufficient contingencies. Examples that have been used in typical planning activities include; using mobile cranes with double the capacity for the heaviest lift and documented in the crane certifications; using single failure proof rigging; identifying sources for a suitable backup crane with an acceptable response time to the site; maintaining redundant torque wrenches on site for torquing requirements; obtaining tooling to address stuck bolts; utilizing personnel with multiple qualifications to address personnel absences; limiting load lift height when removing/reinstalling components over casks; requiring load transit paths that avoid other casks and safety related hardware; and obtaining multiple spare parts for inspection robots and cameras.
Typically, malfunctions and delays are addressed in technical support documents. As a result of these considerations, limitations are included in the work order controlling the work that include contingency steps for malfunctions and delays. All such events would also be documented in the site's corrective action program. This is standard practice for licensees using existing programs and processes which ;:ilre;:iciy occur without reliance on the NEI guidance or the NRC exception.
We think the NEI guidance adequately highlights the consideration to licensees engaged in these activities.
If you have any questions regarding this submittal, please contact me at (207) 882-1303.