ML23353A136
| ML23353A136 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 12/19/2023 |
| From: | Montgomery B Nuclear Energy Institute |
| To: | Leslie Fields Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EPID L-2022-NTR-0002 | |
| Download: ML23353A136 (1) | |
Text
Bruce Montgomery Director, Decommissioning and Used Fuel Phone: 202.406.0054 Email: bsm@nei.org December 19, 2023 Ms. Leslie C. Fields Senior Project Manager U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
NEI Comments on Draft Safety Evaluation for NEI 16-03, Revision 1, Guidance For Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools (Docket no. 99902028; EPID L-2022-NTR-0002)
Project Number: 689
Dear Ms. Fields:
On behalf of the nuclear industry, NEI is pleased to offer comments on NRCs Draft Safety Evaluation for NEI 16-03, Revision 1, Guidance For Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools, which was provided to NEI for review on November 13, 2023 and discussed in a public meeting on December
- 14. Our comments are included in the attachment to this letter.
If you have any questions, please do not hesitate to contact me at bsm@nei.org.
Sincerely, Bruce Montgomery, Director, Decommissioning and Used Fuel Attachment CC:
Gerond A. George, NRR/DORL/LLPB Matthew G. Yoder, NRR/DNRL/NCSG Steven D. Bloom, NRR/DNRL/NCSG
NEI 16-03, REVISION 1 COMMENT RESOLUTION TABLE Comment Number Text Location in the DSE Comment Type (Clarification, Editorial,
- Accuracy, Proprietary)
NEI Suggested Revision NRC Response Page Line 1
7 31 Editorial Draft SE text:
The core of i-LAMP is an SFP coupon database.
Suggested edit:
The key components of i-LAMP are the SFP coupon database, water chemistry database, and additional analysis. Analysis not only includes data analysis for coupons and water chemistry but also impact on reactivity.
2 3
13 14 14 20-25 15-16 9-14 17-21 Editorial/
Clarification Draft SE text:
Section 1.0: the NRC staff has determined that NEI 16-03, Rev. 1 is acceptable, with the limitation described below, for referencing in a license amendment request (LAR) that includes the information described below in Section 4.0 of this SE.
Suggested edit:
the NRC staff has determined that NEI 16-03, Rev. 1 is acceptable, with the limitation described below, for referencing in a licensees regulatory change control process (e.g., 10 CFR 50.59 review, license amendment request (LAR), etc.) that includes the information described below in Section 4.0 of this SE.
Section 3.6:
Based on the foregoing, the NRC staff has determined that NEI 16-03, Rev.1 is acceptable for referencing in a LAR requesting approval of a NAM monitoring program.
Suggested edit:
Based on the foregoing, the NRC staff has determined that NEI
NEI 16-03, REVISION 1 COMMENT RESOLUTION TABLE Comment Number Text Location in the DSE Comment Type (Clarification, Editorial,
- Accuracy, Proprietary)
NEI Suggested Revision NRC Response Page Line 16-03, Rev.1 is acceptable for referencing in a licensees regulatory change control process to implement a NAM monitoring program.
Section 5.0 (paragraph 2): The NRC staff finds that the requirements would be satisfied with respect to NAMs and the NAM monitoring program if referenced in an LAR requesting use of the program Suggested edit:
The NRC staff finds that the requirements would be satisfied with respect to NAMs and the NAM monitoring program if referenced in a licensees regulatory change control process to implement LAR requesting use of the program Section 5.0 (paragraph 3): Each licensee adopting NEI 16-03, Rev. 1 will need to implement it in accordance with its plant-specific processes and licensing basis. This will involve review under the plant commitment control process and 10 CFR 50.59.
Either of these processes could result in the need for a plant-specific license amendment request. Each licensee will need to make its own evaluation in this regard under its site-specific change control program.
Suggested edit:
Each licensee adopting NEI 16-03, Rev. 1 will need to implement it in accordance with its plant-specific processes and licensing basis. This will involve review under the plant commitment control process, procedure revision process, and/or 10 CFR 50.59. Either of tThese processes could result in
NEI 16-03, REVISION 1 COMMENT RESOLUTION TABLE Comment Number Text Location in the DSE Comment Type (Clarification, Editorial,
- Accuracy, Proprietary)
NEI Suggested Revision NRC Response Page Line the need for a plant-specific license amendment request. Each licensee will need to make its own evaluation in this regard under its site-specific change control program.
Note If the suggested edits are untenable, please confirm that the existing SE language does not require licensees to adopt i-LAMP/NEI 16-03 Rev 1 via a license amendment request exclusively.
3 9
25-26 Editorial Draft SE text:
With respect to the concept of a 2 bin approach, the staff finds that NEI 16-03 Rev. 1 represents an overly simplistic approach.
Suggested edit:
Suggest deleting the sentence. Licensees will identify sibling(s) for analysis per Limitations and Conditions in the SE. Two bin approach is still discussed elsewhere in NEI 16-03 Rev 1 and this sentence appears to be unnecessary to support the overall regulatory determination made in the SE.
4 13 29-36 Clarification Draft SE text:
The NRC staff approves the NEI 16-03, Rev. 1, methodology for employing i-LAMP as an alternative monitoring strategy only if the i-LAMP program provides for the licensee to perform a detailed analysis of its SFP and BORAL material considering the parameters described in NEI 16-03 Rev 1. The i-LAMP alternative strategy is unacceptable unless a plant-specific analysis verifies that SFP conditions and BORAL parameters are
NEI 16-03, REVISION 1 COMMENT RESOLUTION TABLE Comment Number Text Location in the DSE Comment Type (Clarification, Editorial,
- Accuracy, Proprietary)
NEI Suggested Revision NRC Response Page Line consistent with those of a sibling SFP or are bounded by those of an older SFPs BORAL. This limitation is imposed to address the discussion in NEI 16-03 Rev.1 of a 2-bin system in which plants without coupons are assumed to be bounded by those with coupons.
Suggested edit:
The NRC staff approves the NEI 16-03, Rev. 1, methodology for employing i-LAMP as an alternative monitoring strategy only if the i-LAMP program provides for the licensee to perform a detailed analysis of its SFP and BORAL material considering the parameters described in NEI 16-03 Rev 1. The i-LAMP alternative strategy is unacceptable unless a plant-specific analysis verifies that SFP conditions and BORAL parameters are consistent with those of a sibling SFP. or are bounded by those of an older SFPs BORAL. This limitation is imposed to address the discussion in NEI 16-03 Rev.1 of a 2-bin system in which plants without coupons are assumed to be bounded by those with coupons.
Note: licensees will identify sibling to perform requisite analysis per the SE, but there is no need to retain language specifically diminishing the 2 bin approach. Industry understands the 2 bin approach will still effectively be part of the industrywide and learning aspects of i-LAMP after initial implementation of the program.
5 9
27 Clarification Draft SE text:
While it may be true that the data collected in i-LAMP to date anecdotally bounds all operating SFPs in the United States
NEI 16-03, REVISION 1 COMMENT RESOLUTION TABLE Comment Number Text Location in the DSE Comment Type (Clarification, Editorial,
- Accuracy, Proprietary)
NEI Suggested Revision NRC Response Page Line A large body of data has been collected from coupon measurements, actual panels, and EPRI projects such as the Zion comparative analysis project that have shown no parameters with adverse trends in the performance of BORAL.
Suggested edit:
Replace anecdotally bounds with is representative of 6
8 21 Editorial Draft SE text:
The essential parameters needed to identify an appropriate sibling plant is listed below:
Suggested edit:
Replace the word is with the word are in this line.
7 13 3
Editorial Draft SE text:
described in NEI 16-03 are consistent Suggested edit:
Add Rev. 1 after NEI 16-03 8
9 12 14-15 39 Editorial/
Clarification Draft SE text:
Section 3.3.2: and its SFP environment including chemistry should be consistent with or bounded by the characteristics of the BORAL Suggested edit:
Remove or bounded by in this sentence.
Section 3.6: SFP and NAM conditions and parameters bound those of the licensees plant.
NEI 16-03, REVISION 1 COMMENT RESOLUTION TABLE Comment Number Text Location in the DSE Comment Type (Clarification, Editorial,
- Accuracy, Proprietary)
NEI Suggested Revision NRC Response Page Line Suggested edit:
Replace bound with are consistent with 9
3 7
7 7
12 13 13 38 3
5 10 17 10 11 Editorial Suggested edit:
Draft SE uses presume/presumption and assume/assumption seemingly interchangeably.
Revise document to be consistent, using assume/assumption throughout, as analyses use assumptions rather than presumptions 10 9
33-36 Clarification Draft SE text:
Failure to perform plant-specific analysis to verify that parameters are consistent with a sibling SFP, or bounded by an older SFPs BORAL, constitutes inappropriate application of i-LAMP as an alternative monitoring strategy. This will be addressed in Section 4.0, Limitations and Conditions of this safety evaluation.
Suggested edit:
Failure to perform plant-specific analysis to verify that parameters are consistent with a sibling SFP, or bounded by an older SFPs BORAL, constitutes inappropriate application of i-LAMP as an alternative monitoring strategy. This will be addressed in Section 4.0, Limitations and Conditions of this safety evaluation.
Note: Age is one of the applicable parameters of interest from NEI 16-03 Rev 1 to be considered in determining a sibling SFP.