NRC-2015-0136, Comment (0001) of Damon Bryson on Information Collection: NRC Generic Letter 2015-XX, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools
| ML15211A544 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/08/2015 |
| From: | Bryson D - No Known Affiliation |
| To: | Office of Information Services |
| Donnell, Tremaine | |
| References | |
| NRC-2015-0136-0001 | |
| Download: ML15211A544 (3) | |
Text
As of: 7/30/15 9:48 AM Received: July 08, 2015 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1jz-8jv1-jtgx Comments Due: August 03, 2015 Submission Type: Web Docket: NRC-2015-0136 Request for Information Pursuant to 10 CFR 50.54(f): NRC Generic Letter 2015-XX, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools Comment On: NRC-2015-0136-0001 Information Collection: NRC Generic Letter 2015-XX, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools Document: NRC-2015-0136-DRAFT-0001 Comment on FR Doc # 2015-13631 Submitter Information Name: Damon Bryson Address:
451 Old Ruff Road Winnsboro, SC, 29180 Email: damonbryson@yahoo.com General Comment NRC-2015-0136 comments from South Carolina Electric & Gas VC Summer Nuclear Station
Contact:
Damon Bryson, Senior Reactor Engineer The NRC is seeking comments that address the following questions:
- 1. Is the proposed collection of information necessary for the NRC to properly perform its functions? Does the information have practical utility?
Some of the requested data is already available to the NRC in each plants FSAR and correspondence docket. The rest of the information is not needed for NRC to properly perform its safety oversight. Neutron absorbers in the US nuclear fleet are generally performing well. In a few instances, problems have been noted and are being addressed using the existing corrective action programs in place. NRC resident inspectors at each plant are aware of the situation at that
plant. NRC headquarters would receive their desired information more quickly and efficiently if they asked each resident inspector about the status of their plant.
Some of the proposed information will not be available for some plants. Licensee executives will not want to send a docketed letter to the NRC saying that information is not available, due to appearances. Licensees will spend limited engineering and licensing resources to assure that the information is not available, or to generate new information. This search will be expensive to perform, but will not provide a significant safety benefit.
- 2. Is the estimate of the burden of the information collection accurate?
No. The proposed generic letter estimates 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br /> of effort per reactor, in most cases. That number may be approximately correct for the responsible engineers to research the design and licensing history of each plant, assuming it only uses a single neutron absorber. However, the estimate completely ignores all the management and licensing reviews that will be necessary to submit the docketed response to the NRC. Most nuclear plants require a very detailed review of any docketed correspondence. Typically, there is much more supporting material generated.
Each statement of fact in the docketed letter needs references and justification. VC Summer will be a Category 4 plant, so 5 pages of information are requested. The response can be expected to be at least 5 times that amount. The supporting reference material can be expected to be at least 5 times the amount of the response material. At least 5 people are going to review the material.
Given the amount of material, reviews can be expected to take many hundreds, if not thousands of hours.
- 3. Is there a way to enhance the quality, utility, and clarity of the information to be collected?
Not without expending substantial engineering resources. It would be more beneficial to expend these limited resources on a topic which would result in a substantial safety benefit.
- 4. How can the burden of the information collection on respondents be minimized, including the use of automated collection techniques or other forms of information technology?
The NRC can gather most of the needed information by reviewing the FSAR for each plant. For many plants, this will be sufficient. If information is missing from the FSAR description, the information can be requested through the NRC resident inspectors. If the data is not forthcoming, a targeted NRC inspection can be performed.
Summary The proposed Generic Letter is overly detailed and unnecessary. Given the performance history of the US nuclear fleet, with no incidents of any safety significance that can be attributed to neutron absorbers, the issues presented in the proposed Generic Letter do not have a high safety significance. Generic Letters have traditionally been used to deal with new safety-significant issues. As such, the number of Generic Letters has dropped substantially over the years, as most issues have already been addressed in the US nuclear fleet (as would be expected in a mature industry). Only 1 Generic Letter has been issued since 2009. The issue of neutron absorber performance does not appear to meet the safety criteria to be a Generic Letter.
Specific comments on Appendix A:
Areas of Requested Information (1) Describe the neutron-absorbing material credited in the spent fuel pool (SFP) nuclear criticality safety (NCS) analysis of record (AOR) and its configuration in the SFP, including the following:
(a) manufacturers, dates of manufacture, and dates of material installation in the SFP What use is this information to the NRC? How is a particular date going to illuminate the issue?
Licensees who obtained neutron absorbers from certain manufacturers with performance problems already know these details, but most licensees with well-performing absorbers will require substantial research to determine them. Some of these manufacturers are no longer in business, so much of the information will no longer be relevant.
- Comments truncated due to web site limitations.
Attachments Neutron Absorber GL comments