ML21159A112

DG-3055 (Rg 3.76 Rev 0) Responses to Public Comments Final

ML21159A112
Person / Time
Issue date:	01/25/2021
From:	Kristina Banovac Storage and Transportation Licensing Branch
To:	Mccullum R Nuclear Energy Institute
Karagiannis H
Shared Package
ML21098A001	List: ML21098A022 ML21098A024 ML21118A001 ML21158A061 ML21159A112
References
DG-3055 RG-3.076, Rev 0
Download: ML21159A112 (2)

Text

Response to Public Comments on Draft Regulatory Guide DG-3055, Implementation of Aging Management Requirements for Spent Fuel Storage Renewals, Proposed new Regulatory Guide 3.76 On December 11, 2020, the U.S. Nuclear Regulatory Commission (NRC) published a notice in the Federal Register (85 FR 80193) announcing the availability for public comment of Draft Regulatory Guide (DG)-3055, Implementation of Aging Management Requirements for Spent Fuel Storage Renewals, proposed new Regulatory Guide (RG) 3.76. The public comment period ended on January 25, 2021. The NRC received comments from the following organization:

Mr. Rod McCullum Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 rxm@nei.org Dated: January 25, 2021 Agencywide Documents Access and Management System Accession No. ML21025A364 The table below shows the public comments and the NRC staffs responses.

Commenter Specific Comments NRC Resolution Mr. Rod We agree with NRCs decision, in draft regulatory guide (DG) The NRC staff agrees with the comment, including the industrys McCullum DG-3055, Implementation of Aging Management encouragement of the use of AMID. The NRC staff will Requirements for Spent Fuel Storage Renewals, not to reengage with stakeholders on the topic of surrogate endorse the use of surrogate inspections at this time. With inspections in the future, as appropriate.

regard to the clarification on surrogate inspections, NUREG-1927, Revision 1, notes that surrogate inspections may be acceptable only when substantial operating experience provides a basis for their use. To date, there is currently insufficient operating experience from canister examinations to apply susceptibility assessments and use surrogate data across the ISFSI [independent spent fuel storage installation] fleet, as had originally been proposed in NEI 14-03, Revision 2. In the future, when industry has gained additional experience applying operations-based aging management, it may be appropriate to

Commenter Specific Comments NRC Resolution re-engage in the dialogue relative to the use of surrogate inspection results. To that end, NEI strongly advocates and encourages industry use of the Aging Management Information Database (AMID) to inform the basis for potential future application of surrogate inspection results.

Mr. Rod Clarification 3.h indicates that the applicant should supply a The NRC staff agrees with the comment in part. The staff notes McCullum summary of proposed FSAR [final safety analysis report] that the clarification was not intended to restrict a licensee or change related to aging management. The staff clarification CoC holder from making changes to the aging management requests specific proposed FSAR changes. This clarification is information in the final safety analysis report (FSAR) (as unnecessarily constraining for the following reasons: updated), after the renewal.

• The applicant may modify those FSAR changes under

[10 CFR] 72.48 any time after the renewal is approved. The regulations do not explicitly require FSAR changes to be Therefore, NRC approval of FSAR changes is not submitted as part of the license or CoC renewal application.

required. The NRC staff notes that the FSAR supplement in the renewal

• The potential exists that FSAR information could be application should provide sufficient information on aging incorporated by reference into the renewed license or management programs (AMPs) in the period of extended CoC [certificate of compliance], thus removing it from the operation (e.g., scope, parameters monitored and inspected, 72.48 scope. detection of aging effects, and acceptance criteria) to be

• The regulations do not require specific FSAR markups auditable by the NRC. This FSAR supplement may include, but as part of the submittal. We recognize that regulations is not limited to, specific FSAR proposed changes, or a for ISFSI license renewals and CoC renewals are summary of the time-limited aging analyses (TLAAs) and AMPs somewhat different. with enough details for the NRC staff to understand how the

• The potential for unnecessary administrative burden is FSAR will include the aging management information that forms not driven by safety issues. An applicant can inform the the basis for NRCs approval of the renewal.

NRC where the information required by regulations will reside in the FSAR. The RAI [request for additional The NRC staff made changes to the clarification 3.h in the final information] process may be used to clarify the FSAR RG to reflect this comment response.

changes.

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