ML21280A363

Watermarked for ACRS - Response to Public Comments on Proposed RG 1.244 -10-7

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Issue date:	10/26/2021
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Response to Public Comments on Draft Regulatory Guide (DG)-1381 Control of Heavy Loads at Nuclear Facilities Proposed Regulatory Guide (RG) 1.244 On May 4, 2021 the NRC published a notice in the Federal Register (86 FR 23750) that Draft Regulatory Guide, DG-1381, a proposed new Regulatory Guide (RG) was available for public comment. The Public Comment period ended on July 5, 2021, after an extension of the initial public comment period published in the Federal Register (86 FR 28158).

The NRC received comments from the individuals or organizations listed below. The NRC has combined the comments and NRC staff responses in the following table.

Comments were received from the following:

Timothy Riti for Nuclear Energy Institute (NEI) ADAMS Accession No. ML21196A254 1201 F Street, NW, Suite 1100 Washington, DC 20004 David Duerr, P.E.

2DM Associates, Inc. ADAMS Accession No. ML21168A094 Houston, TX 77024 Greg DElia for Slingmax Rigging Solutions ADAMS Accession No. ML21196A172 205 Bridgewater Road Aston, PA 19014 Comment Section of Specific Comments NRC Resolution No. DG-1381 NEI-1 Background, With the planned endorsement of applicable ASME Standards NOG-1, The NRC staff disagrees with the comment.

Page 6 NML-1, and parts of BTH-1, the document does not emphasize the need to The staff considers the information in the ASME B30 series of include requirements of related standards of the ASME B30 series (e.g.,

standards and other standards related to handling system design B30.1 through B30.33). NEI Recommendation: Include related standards and use as secondary references, as discussed in the subsection as references to the regulatory guide.

entitled Documents Discussed in Staff Regulatory Guidance.

Although the information contained in these standards may have applicability to handling system design and use, the application of these standards is limited or modified by the standards endorsed

by this proposed regulatory guide in order to satisfy specific regulatory requirements under Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Domestic Licensing of Production and Utilization Facilities; 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants; and Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste.

The staff made no change to the final RG as a result of this comment.

NEI-2 Background, As stated in the draft guidance, Compared to NUREG-0612 guidelines, the The NRC staff disagrees with the comment.

Page 6 standard covers a broader scope in terms of the types of overhead Understanding of the materials used and fabrication methods is handling systems and the safety significance of the load handling important in defining appropriate test methods and acceptance activities. It is unclear how additional devices that are considered special criteria for handling system components. The proposed RG may use load tests/inspections in lieu of meeting material requirements. endorses standards for design, fabrication, and testing of major NEI Recommendation: Clarify how load tests/inspections may be used. handling system components (i.e., ASME Std. NOG-1 and ASME Std. BTH-1) and the endorsed ASME Std. NML-1 identifies secondary references for specific handling system components (e.g., ASME Std. B30.9, Slings). These standards and secondary references generally specify material requirements and post-fabrication testing. Therefore, clarification of how load test/inspections may be used for qualification of handling system components is not necessary.

The staff made no change to the final RG as a result of this comment.

NEI-3 Background, Some licensees may not wish to fully adopt ASME NML-1 due to the effort The NRC staff disagrees with the comment.

Page 6 required to fully update Heavy Load Handling program procedures, general Changes to the design and licensing basis of components is heavy load handling procedures, general lifting and rigging procedures, governed by the requirements of 10 CFR 50.59, Changes, tests, crane procedures, and specific component lift procedures to name a few. and experiments. When a highly reliable handling system is However, there are isolated aspects of the ASME NML-1 standard that selected as the means of providing appropriate protection against could be of great benefit to the licensees. For example, a utility may wish to internal missiles, each component may be designed, fabricated, utilize only the requirements of ASME NML-1 for designing, fabricating, and tested to any approved method of evaluation approved by the testing, maintaining, and operating a special lifting device to ASME BTH-1, NRC for the specified application. Therefore, an existing approved as amended by the Draft Guidance. For example, an existing crane may special lifting device may be replaced by another special lifting perform the lift that falls under the existing NUREG-0612 Heavy Loads device using a method of evaluation approved for the specified 2

program; however, the special lifting device would be designed to the full application, such as ASME BTH-1 as modified by the proposed extent of ASME NML-1 and ASME BTH-1, as amended by the Draft regulatory position C.3 for special lifting devices.

Guidance.. NEI Recommendation: Clarify in the guidance that this is an The staff made no change to the final RG as a result of this acceptable approach to implementation. comment.

NEI-4 Background, We recommend adding language to the draft guidance that is similar to that The NRC staff partially agrees with the comment.

Page 7 found in NRC RIS 2008-28. The applicable language from the RIS is In Section B. of the RG, the NRC staff included a statement copied below with amended text provided in brackets [ ].

identifying the guidance that constitutes a complete method of

• RIS 2008-28, Pg. 2 - licensees may consider the guidelines of NEI-08-05 evaluation to demonstrate that regulations would be met and that

[change to ASME NML-1] as providing methods approved by the NRC for guidance that merely provide an acceptable approach to the specified applications when implementing the requirements of 10 CFR developing a method of evaluation. To conform with other changes 50.59. With NRC staff clarifications and conditions noted in the safety described in this table, the staff changed the statement to indicate evaluation [change in the safety evaluation to herein], licensees may that the use of a handling system controlled range of motion (i.e.,

use these guidelines to voluntarily establish a revised licensing basis for conforming with Section 2-6.1(c)(1) of ASME Std. NML-1, including handling of [delete this phrase reactor vessel heads and other] heavy clarifications provided in proposed regulatory position C.1.a), and loads consistent with the provisions of 10 CFR 50.59.

the use of an enhanced reliability handling system (i.e., conforming RIS 2008-28 Pg. 3, Backfit Discussion - Licensees may choose to retain with Section 2-6.1(c)(2) of ASME Std. NML-1 and using ASME Std.

the facilitys current licensing basis with respect to handling of heavy loads.

NOG-1, Type I), provide a complete NRC approved method for However, licensees that choose to clarify the facilitys licensing basis with evaluating the response of handling system structures and respect to handling of heavy loads consistent with the industry initiative components to equipment failures and the effects of natural may find that NRC acceptance of the guidelines in NEI 08-05 [change to phenomena. Thus, use of these methods of evaluation would not ASME NML-1] facilitates the associated changes to the safety analysis constitute a departure from a method of evaluation described in report. Pursuant to Paragraph (a)(2)(ii) of 10 CFR 50.59, a change from a the safety analysis report, as defined in 10 CFR 50.59. However, method described in the safety analysis report to another method approved the use of a highly reliable handling system based on regulatory by the NRC for the intended application does not constitute a departure position C.1.b.(2) or engineering controls based on load drop from a method of evaluation described in the safety analysis report. NEI consequence analyses conforming with Section 2-6.1(c)(3) of Recommendation: Clarify that a licensee incorporating ASME NML-1 into ASME Std. NML-1 do not constitute a complete calculational their Heavy Load program can do so within the 10 CFR 50.59 process and framework and, therefore, regulatory positions C.1.b.(2) and C.1.c that this change is considered a change in methodology that is approved do not establish an NRC approved method of evaluation. Rather, by the NRC and is not a departure from a method of evaluation described these regulatory positions provide guidance to applicants and in the safety analysis report.

licensees when alternative highly reliable crane designs or load drop analyses are relied upon to demonstrate that safety functions would not be challenged by postulated handling system component failures or natural phenomena.

The staff made clarifying changes to Section B of the RG as a result of this comment.

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NEI-5 Background, Using the License Amendment Request process to adopt NML-1 to a The NRC staff partially agrees with the comment.

Page 7 currently licensed facility will not be efficient. The draft guidance alludes to As documented in the response to Comment NEI-4, the staff the use of the 10 CFR 50.59 process as a means to adopt the new described those regulatory positions that are considered NRC standard. NEI Recommendation: Considering reinforcing that using the 10 approved methods of evaluation to simplify voluntary adoption CFR 50.59 process is an acceptable means to modify a stations licensing through the 10 CFR 50.59 change process in Section B of the RG.

basis from NUREG-0612 to NML-1 as provided by NML-1 Nonmandatory The staff made clarifying changes to Section B of the RG as a Appendices A and B. result of this comment.

NEI-6 Background, For stations whose licensing bases reference NUREG-0612, Phase I, The staff partially agrees with the comment.

Page 7 please clarify that any Phase I commitments that are NOT requirements The requirements of 10 CFR 50.59 define the process to change a under ASME NML-1 can be removed from the stations licensing basis as facilities licensing basis. Guidance on implementing changes to a provided by NML-1 Nonmandatory Appendix B, Paragraph B-2. NEI facility licensing basis pursuant to 10 CFR 50.59 are provided in Recommendation: Provide clarity as described.

RG 1.187. This guidance applies to licensees, and NRC approved methods of evaluation expand the scope of changes that may be implemented without prior NRC approval. Consistent with the response to NEI-4, the staff revised Section B of the RG to indicate those regulatory positions that are considered NRC approved methods of evaluation to simplify voluntary adoption through the 10 CFR 50.59 change process.

The staff made no change to the final RG as a result of this comment.

NEI-7 Background, For stations whose licensing bases reference NUREG-0612, Phase II, The NRC staff partially agrees with the comment.

Page 7 please clarify that any Phase II commitments that are NOT requirements The requirements of 10 CFR 50.59 define the process to change a under ASME NML-1 can be removed from the stations licensing basis as provided by NML-1 Nonmandatory Appendix B, Paragraph B-2. NEI facilities licensing basis. Guidance on implementing changes to a Recommendation: Provide clarity as described. facility licensing basis pursuant to 10 CFR 50.59 are provided in RG 1.187.

The staff made no change to the final RG as a result of this comment.

NEI-8 C.1, Page 10 Hydraulic gantry cranes per ASME B30.1 are commonly used for rigging The staff partially agrees with the comment.

and lifting activities at NPPs (e.g., turbine rotor replacements, generator Section 1-2, Scope, of ASME Std. NML-1 lists telescopic stator replacements, upending transformers in haul paths, etc.). ASME hydraulic gantry systems and strand jack systems as types of B30.1 has very similar requirements to ASME B30.2, and both ASME overhead handling systems covered by ASME Std. B30.1 as standards require testing certification. ASME B30.1 is not discussed or handling systems within the scope of the standard. However, the referenced in the NML-1 list. NEI Recommendation: Add related staff considers the level of detail in the ASME B30 series of standards as references to the proposed regulatory guide. standards with respect to design is generally insufficient to serve 4

as an NRC approved method of evaluation for the design of a highly reliable handling system. The NRC staff provided guidance in Regulatory Position C.1.b.(2) supporting an NRC staff review of this type of handling system when the associated lift is a nuclear safety critical lift. Lifts other than nuclear safety critical lifts do not require a highly reliable handling system and may be performed with appropriate consideration of risk management and seismic qualification requirements applicable to lifts in the specific plant area.

The staff modified the RG to clarify that standards cited in Section 2.1 of ASME Std. NML-1 may be referenced in developing proposed handling systems for nuclear safety critical lifts under Regulatory Position C.1.b.(2).

NEI-9 C.1.a (1) There are no safety factors described to the margin for tipping including if The staff partially agrees with the comment.

1st bullet, the tip over is due to a seismic event. NEI Recommendation: Add Margin is inherent in the criterion for consideration of tipping. The Page 10 clarification on how safety factors are considered.

intent of the criterion is to consider the effect of a tipping load when tipping of less than 45 degrees on average from its lifted orientation would result in the load being unstable. The staff does not consider the risk of seismic action on a suspended load to be significant relative to tipping. However, the staff noted a need to clarify that the crane used for nuclear safety critical lifts under the provisions of ASME Std. NML, Section 2-6.1(c)(1) must meet the design criterion for a Type II crane specified in ASME Std. NOG-1 or otherwise be seismically qualified under load.

The staff modified the RG to clarify the need for a seismically qualified overhead crane to preclude loss of support for the crane during a seismic event.

NEI-10 C.1.a(1) It is not clear how redundancy and separation can be considered for the The staff disagrees with the comment.

2nd bullet, exclusion of components from within the range of motion. NEI The regulatory position applies to nuclear safety critical lifts, which Page 10 Recommendation: Clarify how redundancy and separation can be used.

are defined in ASME Std. NML-1 as lifts where uncontrolled motion of the load can result in the loss of an essential safety function.

With respect to credit of controlled ranges of motion, the method of protection for essential safety functions may credit redundancy and separation when two or more trains of equipment can each independently perform or support performance of an essential 5

safety function. The criterion for determining a redundant train has adequate separation is when essential components of that train are outside the range of potential direct impacts from uncontrolled load motion following a single lifting system component, impact from credible tipping of the load, and either outside the range of or not affected by the indirect consequences of the failure of other components that are within the zone of direct impact due to uncontrolled load motion. Thus, the staff considers the definition of a nuclear safety critical lift combined with the cited regulatory guidance provides sufficient information regarding how redundancy and separation may be considered.

The staff made no change to the final RG as a result of this comment.

NEI-11 C.1.b (2), For lifts using an alternative lifting scheme, reference is made to ASME The staff partially agrees with the comment.

Page 10 NML-1, Section 4-1.1. It is unclear how the use of Mobile Cranes meets The staff considers the use of mobile cranes and engineered ASME NML-1, Section 4-1.2. Also, it is unclear how the use of an temporary lift assemblies (ELTAs) as necessary for infrequent Engineering Temporary Lift Assembly meets ASME NML-1, Section 4-1.3.

major component replacement (e.g., steam generator NEI Recommendation: Add clarification on the use of mobile cranes and replacements) or useful for operations outside of nuclear power engineering temporary lift assemblies.

plant structures for more frequent maintenance operations (e.g.,

operations supporting removal and reinstallation of service water pumps through intake structure roofs). However, these types of lifting devices do not include standards that ensure an inherently stable structure is present to support an overhead lift and prevent toppling. Therefore, ASME Std. NML-1 restricts the use of mobile cranes and ELTAs to standard and special lifts unless the potential consequences of component and structural failures are shown to not impair essential safety functions. The cited regulatory position applies to nuclear safety critical lifts using lifting system designs that conform with the critical lift guidelines of Section 4-1.1 of ASME Std. NML-1, which permits only crane designs considered single-failure-proof. The staff believes the definition of a nuclear safety critical lift combined with the cited regulatory guidance provides sufficient information regarding the use of mobile cranes and ETLAs.

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The staff made no change to the final RG as a result of this comment.

NEI-12 C.1.b (2) Please provide examples for the second bullet, like examples provided in the The staff agrees with the comment.

2nd bullet, first bullet:

Infrequent major component replacement refers to large Page 10

• outside of nuclear power plant structures (e.g., operations related to an components whose handling is not described in the facility safety independent spent fuel storage facility),

analysis report section addressing refueling activities.

• involves an infrequent major component replacement (please provide examples here), or NEI Recommendation: Similar to the first bullet, The staff added the above description to the final RG as a result of consider adding examples for the second bullet. this comment.

NEI-13 C.1.b (2) (a), Currently NML-1 is the only consensus standard that addresses The NRC partially agrees with the comment.

Page 11 Engineered Temporary Lift Assemblies (ETLA). It is not clear if the use of As discussed for Comment No. NEI-11, regulatory position an ETLA is permitted if the remaining items b through g are met.

C.1.b(2) applies to nuclear safety critical lifts using lifting system It is not clear if the term applicable national consensus standard(s) designs that conform with the critical lift guidelines of Section 4-1.1 includes all such standards or only the ones endorsed by the NRC. NEI of ASME Std. NML-1, which permits only lifting system designs Recommendation: Add clarify on the use of ETLA and national consensus considered single-failure-proof (i.e., a highly reliable handling standards.

system). ETLAs, in general, have not been accepted as single-failure-proof or highly reliable.

The staff made no change to the final RG as a result of this comment.

NEI-14 C.1.b (2) (b) It is unclear if quality assurance means meeting either ASME NQA-1 or 10 The NRC staff partially agrees with the comment.

& (g), Page CFR 50 Appendix B. Also, it is unclear how NOG-1 Section 6170 or The staffs intent for regulatory position C.1.b(2) is to identify the 11 equivalent applies. NEI Recommendation: Add clarity on the use of qualify staff information needs for evaluation of new and previously control measures.

unapproved handling systems. Therefore, quality assurance means that information necessary to address the regulatory requirements in Appendix A to 10 CFR Part 50, GDC-1, Quality standards and records, (Part 50 and Part 52 licenses) or 10 CFR 72.24, Contents of application: Technical information, (Part 72 licenses). For both, the requirements relate to quality standards applied to the design, fabrication, construction, and testing of important to safety portions of heavy load handling systems. This is a reduction in scope relative to the requirements of 10 CFR Part 50, Appendix B and ASME NQA-1, but guidance developed for these requirements may assist in developing an appropriate program. The components important to safety are established based on the design function, so the staff cannot predetermine 7

those components that should be subject to these quality assurance measures.

The staff made no change to the final RG as a result of this comment.

NEI-15 C.1.b (2) (c) As described, it is unclear how conservative design criteria is applied. NEI The NRC staff agrees with the comment.

& (d), Page Recommendation: Add clarity on the use of conservative design criteria.

As stated in the response to Comment No. NEI-14, the staffs 11 intent for regulatory position C.1.b(2) is to identify the staff information needs for evaluation of new and previously unapproved handling systems. Therefore, conservative design criteria means that information necessary to address the regulatory requirements in Appendix A to 10 CFR Part 50, GDC-1, Quality standards and records, (Part 50 and Part 52 licenses) or 10 CFR 72.24, Contents of application: Technical information, (Part 72 licenses). For both requirements, the requirements relate to quality standards applied to the design of important to safety portions of heavy load handling systems. The staff identified national standards that may be used to establish design criteria.

The staff modified the RG to provide examples of acceptable design standards.

NEI-16 C.1.b (2) (e), Providing redundancy may prove to be difficult in some situations. The use The NRC staff partially agrees with the comment.

Page 11 of higher design margins or administrative controls (similar to those allowed The staff listed redundancy for mechanical components subject to for Single-Failure-Proof-Equivalency per NEI 08-05) would be beneficial.

fatigue or wear. As stated in Section A of the RG, the RG Higher safety factors should also be considered in lieu of redundancy.

positions are not regulations, and compliance with RG positions is Design criteria specified in the applicable national consensus standards not required. Design solutions that differ from those set forth in the should be referenced. NEI Recommendation: Add clarity on the use of RG are acceptable if supported by a suitable basis.

safety factors and applicable national consensus standards.

The staff made no change to the final RG as a result of this comment.

NEI-17 C.1.b (3), It is unclear if the attachment point referenced in this statement refers to a The NRC staff agrees with the comments.

Page 11 fixed attachment point on the load being lifted (such as a reactor head or The staff changed the term load attachment points to lifting steam generator) or the attachment points on the lifting device. ASME attachment as defined in ASME Std. BTH 1. The staff also BTH-1 does not address attachment points on the load. NEI clarified that the lifting attachment be designed to satisfy regulatory Recommendation: Add clarity.

position C.3.c. to meet Design Category B criteria for two Duerr-1 Discussion, ASME BTH-1-2020 defines the term lifting attachment as a load independent load paths and Design Category C for single load Page 5; supporting device, such as a lifting lug, padeye, trunnion or similar path configurations.

C.1.b (3), appurtenance that is attached to the lifted load, is designed for use with the 8

Page 11; and specific load to which it is attached, and either (a) remains attached to the The staff modified the RG to specify lifting attachment and C.3, Page 12 load, or (b) is removed and not reused. It is suggested that the term lifting referenced a definition of this term as a result of these comments.

attachment, as opposed to the present term load lifting attachment be used here and elsewhere throughout this guide to provide improved clarity and consistency with ASME BTH-1.

NEI-18 C.1.b (4), The use restrictions described in NML-1 Section 5-1.2.1 require a D/d ratio The NRC staff agrees with the comments.

Page 11 of 25:1. While appropriate for wire rope slings, this D/d ratio is very The staff intent in limiting the usage of slings is to avoid scenarios restrictive for synthetic slings. For example, using a shackle to connect a where the slings may be cut by a single rigging error, as indicated round sling to a load attachment point. It is unclear how to apply guidance by operating experience where large, non-cylindrical components of other ASME standards for standard lifting/rigging components. NEI cut slings used in a basket configuration when edge protection was Recommendation: Add clarification to allow for the use of other applicable not properly positioned. To address this concern as well as the standards in additional to NML-1.

intent of the comments, the staff will modify regulatory position C.1.b (4) to endorse Section 5-1.2.1 of ASME Std. NML-1 for all slings types and clarify that the intent is for slings to be used in a Slingmax C.1.b (4), This document intends to endorse the use of ASME standards NML-1, straight line between lifting attachment points, such as shackles Page 11 NOG-1, and BTH-1 by applicants and licensees for both nuclear power connected to a load attachment, or to be used in a basket plant operations as well as independent storage of spent nuclear fuel. Of configuration around large cylindrical portions of the load that particular concern with this change is the following section of NML-1: provide a D/d of 25:1 or greater to avoid the potential for sling (b) Synthetic slings may be used only if one of the damage. Note that this regulatory position is limited to applications following applies:

involving a nuclear safety critical lift and crediting a highly reliable (1) The tensioned slings remain in a straight line handling system to prevent a challenge to an essential safety between their end bearing points.

function through uncontrolled load motion.

(2) The tensioned legs wrap around a curved surface with a minimum D/d ratio of 25:1, where D is the diameter The staff clarified the use of slings as part of highly reliable of the curved surface and d is the nominal body diameter of handling systems.

the sling.

Synthetic slings have been safely and successfully used in critical lifts in the nuclear industry for decades. In fact, the nuclear industry has been the catalyst for many of the safety related innovations that Slingmax has introduced over the years, including:

• The independent load-bearing paths of a Twin-Path Sling

• Check-Fast inspection system

• Smart Sling Electronic monitoring system This change will severely restrict operations by requiring operators to revert back to heavy, inefficient steel rigging. We believe this is detrimental to the industry for several reasons:

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First, all slings are susceptible to cutting on edges and should be protected from cutting regardless of the sling material used. All riggers should be in the practice of protecting slings from cutting on edges at all times. In fact, we have performed testing where both synthetic and steel slings were rigged over an edge, and the steel wire slings failed at a similar load to the synthetic sling. Prohibiting synthetic slings from these types of lifts will not enhance safety and may in fact decrease safety because of the false sense of security when using steel rigging on edges. If there is an intention to reduce the possibility of slings cutting on edges, any prohibition should be universal, and engineered cut protection should be included in the consideration. Additionally, if there is an intention to avoid rigging around edges, a 25:1 D/d is far beyond what is needed to accomplish that goal.

NEI-19 C.2 (b), Page Unclear what should be done in cases where the NOG-1 load combinations The NRC staff disagrees with the comment.

12 are different than the facility design basis load combinations. NEI The staff considers the ASME Std. NOG-1 load combinations to be Recommendation: Add clarity.

flexible enough to accommodate the facility design basis load combinations for external events. The load combinations associated with the handling system itself are part of the change that the licensee must evaluate pursuant to the applicable change regulation. As stated in Section A of the RG, the RG positions are not regulations, and compliance with RG positions is not required.

Design solutions that differ from those set forth in the RG are acceptable if supported by a suitable basis.

The staff made no change to the final RG as a result of this comment.

NEI-20 C.3, Page 12 The draft regulatory guidance does not refer to ANSI N14.6. This ANSI The NRC staff agrees with the comment.

standard is embodied into NUREG-0612 5.1.1(4). NEI Recommendation:

The staff described in Section B of the RG that the endorsement, Confirm that by endorsing NML-1 and BTH-1, the intent of the draft in part, of ASME NML-1 and BTH-1 is intended to replace the regulatory guidance is to eliminate usage of ANSI N14.6 for stations that design, maintenance, and testing guidance for special lifting transition to NML-1 and BTH-1.

devices contained in ANSI/ANS N14.6.

The staff added the above description to Section B of the RG as a result of this comment.

NEI-21 C.3, Page 12 In Chapter 1 of ASME BTH-1, it states: Lifting devices designed to this The NRC staff partially agrees with the comment.

Standard shall comply with ASME B30.20, Below-the-Hook Lifting Devices. Section 5-1.1 of ASME Std. NML-1 provides for compliance with ASME B30.20 includes provisions that apply to the marking, construction, ASME B30.20 for standard and special lifts. In addition, Section 5-installation, inspection, testing, maintenance, and operation of below-the- 1.2 of ASME Std. NML-1 provides for inspection of special lifting 10

hook lifting devices. Therefore, ASME BTH-1 is not a replacement for devices used for critical lifts under the provision of ASME B30.20, B30.20, but rather, ASME BTH-1 supplements the requirements of ANSI and establishes additional load test and continuing compliance B30.20. NEI Recommendation: Add this clarification to the RG to ensure testing guidelines beyond those specified in ASME B30.20.

compliance with the ASME B30.20 standard. The staff made no change to the final RG as a result of this comment.

NEI-22 General ASME NUM-1, Rules for Construction of Cranes, Monorails, and Hoists The NRC staff partially agrees with the comment.

Comment (With Bridge or Trolley or Hoist of the Underhung Type). NUM Type I The staff modified the RG to identify national consensus standards (Type 1A and 1B) lifting devices are allowed in NML-1 -2019. These identified within Section 1-2, Scope, of ASME Std. NML-1, which devices are regularly used at nuclear plants inside containment and other included ASME Std. NUM-1, as an acceptable consensus standard areas of the power block to perform heavy load lifts. NEI Recommendation:

cited under Regulatory Position C.1.b (2) for application to nuclear Consider including as part of this endorsement safety critical lifts. The staff finds ASME Std. NUM-1 not yet sufficiently clear to define an acceptable method of evaluation for an enhanced reliability handling system. In addition, the staff notes that ASME Std. NML-1 references application of NUM-1 to cranes used for other lift classifications.

The staff modified the RG to indicate national consensus standards identified within Section 1-2, Scope, of ASME Std.

NML-1 as acceptable consensus standard cited under Regulatory Position C.1.b (2) for application to nuclear safety critical lifts.

NEI-23 General The DG does not clearly describe how the guides, codes, and standards The NRC staff partially agrees with the comment.

Comment do, or do not, apply to lifts of spent fuel casks outside of the Part 50 facility.

For existing dry storage and multi-purpose cask systems, the This would include devices like cask crawlers, mobile cranes, and guidance of NUREG-0612 and NUREG-0554 is often specifically canister/cask transfer facilities. NEI Recommendation: Clarify how ISFSI identified in Technical Specifications included with the license.

license or CoC holders should consider how to apply the codes and The requirements of 10 CFR 72.48 apply to changes to the safety standards.

analysis report. Licensees are responsible for evaluating desired changes under those requirements. The intent of this RG is to endorse national consensus standards to replace NRC developed guidance. Implementation may require an amendment to the ISFSI license or the General License Certificate of Compliance.

The staff made no change to the final RG as a result of this comment.

NEI-24 General ASME-NML-1 Sect. 2-6.1(c)(1), (2), & (3) contains guidance crediting the The NRC staff disagrees with the comment.

Comment range of motion, specific requirements for enhanced handling system Administrative measures alone do not provide appropriate reliability, and postulated load drop requirements.

protection from the potential effects of handling system component 11

The draft RG should consider additional administrative measures, other failures. As stated in Section A of the RG, the RG positions are measures and controls for cases where range of motion cannot be not regulations, and compliance with RG positions is not required.

qualified, use of control of motion when enhance handling system reliability Design solutions that differ from those set forth in the RG are requirements cannot be met, or when postulated load drop analyses will be acceptable if supported by a suitable basis.

required. NEI Recommendation: Consider clarifying and including where The staff made no change to the final RG as a result of this administrative measures, other measures, and controls can be used to comment.

support the guidance.

Duerr-2 General The current edition of ASME BTH-1 is 2020, issued on June 11, 2021. The staff agrees with the comment.

Comment The staff retained the reference to ASME Std. BTH-1-2017 because it is referenced by ASME Std. NML-1-2019.

The staff made no change to the final RG as a result of this comment.

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