ML23095A037
| ML23095A037 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 04/04/2023 |
| From: | Richter M Nuclear Energy Institute |
| To: | NRC/SECY/RAS |
| References | |
| NRC-2018-0291, 88FR13717 00001, DG-1406, PR-50 | |
| Download: ML23095A037 (1) | |
Text
4/4/23, 1:34 PM blob:https://www.fdms.gov/7c03c464-7b51-4dc6-a0b5-4a1ddc9f3571 blob:https://www.fdms.gov/7c03c464-7b51-4dc6-a0b5-4a1ddc9f3571 1/1 PUBLIC SUBMISSION As of: 4/4/23, 1:34 PM Received: April 04, 2023 Status: Pending_Post Tracking No. lg2-eb77-c5tg Comments Due: May 05, 2023 Submission Type: Web Docket: NRC-2018-0291 Approval of American Society of Mechanical Engineers Code Cases, Revison 40 Comment On: NRC-2018-0291-0002 American Society of Mechanical Engineers Code Cases and Update Frequency Document: NRC-2018-0291-DRAFT-0010 Comment on FR Doc # 2023-03742 Submitter Information Email:atb@nei.org Organization:Nuclear Energy Institute General Comment See attached file(s)
Attachments 04-04-23_NRC_DG-1406
MARK A. RICHTER, PH.D.
Technical Advisor, Decommissioning & Used Fuel 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8106 mar@nei.org nei.org April 4, 2023 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Rulemakings and Adjudication Staff Submitted on Regulations.gov
Subject:
NEI Comments Regarding NRC Draft Regulatory Guide DG-1406 Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1 (Docket ID NRC-2018-0291)
Project Number: 689
Dear Rulemakings and Adjudication Staff:
On behalf of the Nuclear Energy Institutes (NEI)1 members (hereinafter referred to as industry), we are grateful for the opportunity to review and offer comments regarding NRC Draft Regulatory Guide DG-1406, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, (Docket ID NRC-2018-0291.)
This regulatory guide lists the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components Code Cases, that the US Nuclear Regulatory Commission (NRC) has approved for use as voluntary alternatives to the mandatory ASME BPV Code provisions that are incorporated by reference into Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities.
Specifically, the proposed revision to Regulatory Guide 1.147 includes N-860 as an approved code case.
As noted in Table 1 of DG-1406, Code Case N-860 is fully accepted as written. Also, Regulatory Guide 1.147, written for reactor licenses, has not been revised to incorporate applicability to ISFSI licenses.
Under applicability it states that the RG applies to reactor licensees and applicants subject to 10 CFR Part 50, Section 50.55a, Codes and Standards.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Rulemaking and Adjudications Staff April 4, 2023 Page 2 NEI offers one specific comment on DG-1406, suggesting that clarification be included that addresses applicability of Code Case N-860 to 10 CFR Part 72, Independent Spent Fuel Storage Installations.
Thank you for your time and consideration of the suggested clarification. If you have any questions, please contact me.
Sincerely, Mark A. Richter Attachment
Rulemaking and Adjudications Staff April 4, 2023 Page 3 Attachment Clarification 3.h indicates that the applicant should supply a summary of proposed FSAR change related to aging management. The staff clarification requests specific proposed FSAR changes. This clarification is unnecessarily constraining for the following reasons:
The applicant may modify those FSAR changes under 72.48 any time after the renewal is approved.
Therefore, NRC approval of FSAR changes is not required.
The potential exists that FSAR information could be incorporated by reference into the renewed license or CoC, thus removing it from the 72.48 scope.
The regulations do not require specific FSAR markups as part of the submittal. We recognize that regulations for ISFSI license renewals and CoC renewals are somewhat different.
The potential for unnecessary administrative burden is not driven by safety issues. An applicant can inform the NRC where the information required by regulations will reside in the FSAR. The RAI process may be used to clarify the FSAR changes.
Specific references in the regulations follow:
ISFSI license (72.42):
CoC (72.240):