ML14276A013

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RAIs for NEI 12-16
ML14276A013
Person / Time
Site: Nuclear Energy Institute
Issue date: 10/14/2014
From: Joseph Holonich
Licensing Processes Branch (DPR)
To: Mccullum R
Nuclear Energy Institute
Holonich, J 301-415-7297
References
NEI 12-16
Download: ML14276A013 (4)


Text

October 14, 2014 Rod McCullum, Director Used Fuel Programs Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO NEI 12-16, GUIDANCE FOR PERFORMING CRITICALITY ANALYSES OF FUEL STORAGE AT LIGHTWATER REACTOR POWER PLANTS

Dear Mr. McCullum:

By letter dated April 18, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14112A517), the Nuclear Energy Institute (NEI) submitted NEI 12-16, Guidance for Performing Criticality Analyses of Fuel Storage at LightWater Reactor Power Plants for review. Upon review of the information provided, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete the review.

In an email dated October 2, 2014, Mr. Kristopher Cummings, representing the NEI, and I agreed that the NRC staff will receive your response to the enclosed Request for Additional Information (RAI) questions within 45 days of the date of this letter.

If you have any questions regarding the enclosed RAI questions, please contact me at (301) 415-7297.

Sincerely,

/RA/

Joseph J. Holonich, Sr. Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689

Enclosure:

RAI questions

ML14276A013

  • concurred via email NRC-088 OFFICE DPR/PLPB DPR/PLPB*

DSS/SRXB DPR/PLPB DPR/PLPB NAME JHolonich DHarrison UShoop AMendiola JHolonich DATE 10/9/2014 10/9/2014 10/9/2014 10/14/2014 10/14/2014

Letter to Rod McCullum from Joseph J. Holonich dated October 14, 2014

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO NEI 12-16, GUIDANCE FOR PERFORMING CRITICALITY ANALYSES OF FUEL STORAGE AT LIGHTWATER REACTOR POWER PLANTS DISTRIBUTION:

PUBLIC RidsNrrOd RidsOpaMail RidsNrrDss RidsOgcMailCenter KWood AMendiola JHolonich RidsNrrDprPlpb RidsAcrsAcnwMailCenter UShoop APatel PLPB R/F RidsNrrDeEicb RidsNrrDprDHarrison EXTERNAL DISTRIBUTION:

CUMMINGS, Kristopher kwc@nei.org

Enclosure REQUEST FOR ADDITIONAL INFORMATION REGARDING NEI 12-16, GUIDANCE FOR PERFORMING CRITICALITY ANALYSES OF FUEL STORAGE AT LIGHTWATER REACTOR POWER PLANTS

1. On page 36, Section 9.5.1.b of its letter dated April 18, 2014, the guidance document states that basic testing is appropriate when previous testing and operating experience of the material indicates that no degradation mechanism would result in loss of Boron-10. The U.S. Nuclear Regulatory Commission (NRC) staff understands this to mean that tests for neutron-absorbing capacity may be discontinued in the program because basic testing does not include testing for neutron attenuation. Please discuss whether neutron attenuation testing will be performed in addition to basic testing and whether it will be performed at intervals not exceeding 10 years.
2. On page 36, Section 9.5.2, first bullet, of its letter dated April 18, 2014, the guidance document states that in-situ measurement of Boron-10 areal density should be performed on an appropriate statistical sample. Please discuss the methodology used in determining an appropriate/acceptable statistical sample.
3. The NRC guidance (i.e., Generic Aging Lessons Learned Report 1801) recommends basing the frequency for inspection and testing of neutron-absorbing material capacity on the condition of the material and operating experience, not to exceed 10 years. In the Nuclear Energy Institute letter dated April 18, 2014, the guidance document provides little guidance for maximum test intervals for materials that are known to degrade and the rate of degradation is not fully understood. Please discuss whether guidance will be provided on maximum test intervals for materials that are known to experience significant degradation and rate of degradation is not fully understood.