ML18346A511
| ML18346A511 | |
| Person / Time | |
|---|---|
| Issue date: | 12/19/2018 |
| From: | Marlone Davis Division of Spent Fuel Management |
| To: | |
| Lindsay H | |
| Shared Package | |
| ML18338A059 | List: |
| References | |
| Download: ML18346A511 (19) | |
Text
Session: Inspection Oversight Inspection Oversight and Regulatory Experience Related to the Review of 10 CFR 72.48 Evaluations Division of Spent Fuel Management Regulatory Conference 2018 December 11 - 12, 2018 Marlone Davis, Sr. Storage and Transportation Safety Inspector U.S. NRC Office of Nuclear Material Safety and Safeguards Division of Spent Fuel Management
Content
- Introduction
- Background
- Overview of Regulatory Experience and Practices
- Summary
- Questions 12/12/2018 2
Introduction
- The purpose of this presentation is to provide a brief overview of the U.S. Nuclear Regulatory Commission (NRC) regulatory experience related to the inspection oversight of the review of 10 CFR 72.48 evaluations and provide information on the endorsement of the new guidance document.
- Success for this presentation is to ensure that all interested parties have a general awareness of recent NRC regulatory experience and provide the status on the new guidance document.
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Background
U.S. NRC Regulatory Experience 12/12/2018 4
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Background===
Certificate Holders: with NRC-Approved Designs for Use NAC Holtec Orano Energy International International Transnuclear Solutions (TN) Americas 12/12/2018 5
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Background===
Dry Cask Storage Safety Inspections NRC Inspection Manual Chapters (IMC)s
- IMC 2690 - Inspection Program Guidance for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations (ISFSI)s
- IMC 2515, Appendix C - Special and Infrequently Performed Inspections NRC Inspection Procedure (IP)
- IP 60856 - Review of 10 CFR 72.212(b) Evaluations
- IP 60857 - Review of 10 CFR 72.48 Evaluations 12/12/2018 6
Background
IP 60857 Inspection Requirements Inspection Sample Selection
- Review a list of evaluations performed and select a representative sample based on a judgment of risk significance
- Select a sample that were screened out as not requiring a performance of the 10 CFR 72.48 evaluation Review of Evaluations
- Review the selected sample evaluations to verify that the licensee or certificate holder has appropriately considered the conditions under which the change was made
- Review the selected screen to determine that an evaluation was not required and verify that the conclusions were correct and consistent with the licensees 10 CFR 72.48 procedure 12/12/2018 7
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Background===
Inspection Guidance Regulatory Guide 3.72, Guidance for Implementation of 10 CFR 72.48, Changes, Test, and Experiments, Revision 0 Nuclear Energy Institute (NEI) 96-07, Appendix B dated March 5, 2001 12/12/2018 8
Overview - Applicability Process
- Applicability Determination is to determine the correct regulatory change control process, if any for all or part of a proposed activity Applicability
- Generally three to four questions to determine if the Determination proposed activity is applicable 9
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Overview - Screening Process
- Screening is the process for determining whether a proposed activity requires a 10 CFR 72.48 evaluation to be performed Screening for
- Generally three to four questions to determine if the Adverse Effects proposed activity is adversely impacted
- Determine if an activity involves a method of evaluation (MOE)
Screening for
- Distinguishing between input parameters and Methods of elements Evaluation 10 12/12/2018
Overview - 72.48(c)(2) Criteria - Evaluation
- Does the proposed activity result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the FSAR 10 CFR 72.48 Criterion (c)(2)i (as updated)?
- Does the proposed activity result in more than a minimal increase in the likelihood of occurrence of a malfunction of a system, structure, or 10 CFR 72.48 component (SSC) important to safety previously Criterion (c)(2)ii evaluated in the FSAR (as updated)?
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Overview - 72.48(c)(2) Criteria - Evaluation
- Does the proposed activity result in more than a minimal increase in the consequences 10 CFR 72.48 of an accident previously evaluated in the Criterion (c)(2)iii FSAR (as updated)?
- Does the proposed activity result in more than a minimal increase in the consequences 10 CFR 72.48 of a malfunction of an SSC important to Criterion (c)(2)iv safety previously evaluated in the FSAR?
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Overview - 72.48(c)(2) Criteria - Evaluation
- Does the proposed activity create a possibility for an accident of a different type than any 10 CFR 72.48 previously evaluated in the FSAR (as updated)?
Criterion (c)(2)v
- Does the proposed activity create a possibility for a malfunction of an SSC important to safety with a different result than any previously 10 CFR 72.48 Criterion (c)(2)vi evaluated in the FSAR (as updated)?
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Overview - 72.48(c)(2) Criteria - Evaluation
- Does the proposed activity result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being 10 CFR 72.48 Criterion (c)(2)vii exceeded or altered?
- Does the proposed activity result in a departure from a method of evaluation described in the 10 CFR 72.48 FSAR (as updated) used in establishing the Criterion design bases or in the safety analyses?
(c)(2)viii 14 12/12/2018
Overview Regulatory Experience Method of Evaluation Screenings vs. Meeting the Nonconforming or (MOE) Evaluations applicable criteria of Degraded Conditions 10 CFR 72.48(c)(2) 10/30/2018 15
Overview Regulatory Guide 3.72 Update
- The staff developed a Draft Regulatory Guide (DG) for a revision to Regulatory Guide 3.72, Guidance For Implementation of 10 CFR 72.48, Changes, Test, and Experiments
- The staff expects the DG to be out for public comment within the next six months.
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Summary Method of Evaluation Review of Meeting the applicable criteria of 10 CFR 72.48 10 CFR 72.48(c)(2)
Evaluations Screenings vs.
Evaluations Nonconforming or Degraded Conditions 12/12/2018 17
12/12/2018 18 References Code of Federal Regulations (CFR), Title 10, Part 72 - Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste.
Inspection Manual Chapter (IMC) 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 Transportation Packaging Regulatory Guide 3.72, Guidance for Implementation of 10 CFR 72.48, Changes, Tests, and Experiments 12/12/2018 19