ML20236S177
| ML20236S177 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/1996 |
| From: | Delligatti M, Kakajko L, Willie Lee NRC |
| To: | Leeds E, Sturz F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20236S154 | List: |
| References | |
| NUDOCS 9807240178 | |
| Download: ML20236S177 (7) | |
Text
.%
ATTACHMENT B(1) p c secoq f
k UNITED STATES 3
S NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20046 4001
\\*.../
April 16, 1996 MEMORANDUM TO:
Eric J. Leeds and Fritz C. Sturz, Section Leaders Spent Fuel Project Office, NMSS FRON:
RAI Task Group:
Mark S. De111gatti Lawrence E. Kokajko Henry W. Lee Carl J. Withee
SUBJECT:
STYLE AND FORMAT FOR REQUEST FOR ADDITIONAL INFORMATION (RAI)
In accordance with your request, we have completed the primary portion of the task assigned to us. Attached you will find our approach to the style and format for RAls, including appropriate action verbs, RAI preamble, and examples for both 10 CFR Parts 71 and 72. We believe that this represents a reasonable format for the technical reviewers to submit RAls to the project.
manager, who will then prepare a correspondence package for concurrence by the section leaders.
The next portion of this project will be to develop the general applica'bility statements for each major section of review for both 10 CFR Parts 71 and 72.
This work is currently in progress and will be provided to you on or before April 26, 1996.
We would like to meet with you to discuss our results.
If you have any questions prior to our meeting, we would be pleased to respond to them.
Q
{Q i
Mark S. De111gatti Lawrence E. Kokajko Henry W. Lee Carl
. Wi ee 1
r l
l l
9807240178 980714 5
I l
GED ELudSXE@_ _ _
9
STYLE AND FORMAT FOR
(
REQUESTS FOR ADDITIONAL INFORMATION l
The SFP0 staff reviews and evaluates the analysis and design of spent fuel storage and transportation packages to determine the package's technical adequacy and corpliance witt. regulatory requirements.
Requests for additional informati e. (RAI) to any licensee or applicant should follow the style and format as outlined below in order to ensure proper communications as outlined in NRC policy requirements.
l Requests for additional information related to the technical adequacy of the document under review should state all the relevant problems and issues to be resolved prior to approval in a manner that is clear, concise, and consistent with the regulations and good engineering practice. This is considered primarily an exchange of technical information through which the staff elicits the information necessary for it to determine if the applicant has demonstrated compliance with the regulations. The statf may provide further supporting information depending upon the complexity of the request.
During the technical review, some RAls may be related to an apparent failure to meet the regulatory requirements, which must be satisfied prior to reaching a licensing decision.
In this case, the RAI should identify the specific section of the regulations, and other supporting documents (Reg. Guides, SRP, NUREGs, ASME/ ASTM codes) that relate to good engineering in support of meeting the regulations.
In this type of item, it is expected that supporting information will be provided, as necessary, both from a technical perspective and a regulatory one.
Requests for additional information will be delineated by chapter and section, with a general regulatory applicability statement for each topical area. The general applicability statement will apply to all items in that area and will reference the regulatory requirements applicable to that topic.
Each request will have an action verb and an object which will clearly and concisely identify the information requested.
If necessary, further technical information will be provided in a separate paragraph for that item.
If an item requires further regulatory citations, it will be provided in the
'4 additional information paragraph.
Examples of action ;erbs that elicit knowledge, comprehension, application, analysis, syn,%esis, evaluation, and skills are:
analyze,
assess attach choose clartfy classify combine compare conclude -
contragt construct defend define demonstrate determine describe 1
differentiate discuss distinguish establish l
evaluate explain find identify l
illustrate indicate justify label 1
1 list measure name perform plan position provide rate reproduce resolve revise select specify surmarize support show state turn translate use I
l 1
(RAI COVER PAGE AND PREAMBLE]
REQUEST FOR ADDITIONAL INFORMATION This document, titled Request for Additional Information (RAI), contains a compilation of additional information requirements, identified to-date by the U.S. Nuclear Regulatory Commission staff, during its review of the applicant's application and Safety Analysis Report (SAR). This RAI follows the same format of the applicant's SAR. NUREG 1536, " Standard Review Plan for Dry Cask Storage Systems," was used in the review of the application and the SAR.
Each individual RAI describes information needed by the staff for it to complete its review of the application and/or the SAR and to determine whether the applicant has demonstrated compliance with the regulatory requirements.
Where an individual RAI relates to the applicant's apparent failure to meet one or more regulatory requirements, or where an RAI specifically focuses on compliance issues associated with one or more specific regulatory requirements (e.g.,' specific design criteria or accident conditions), such requirements will be specified in the individual RAI.
~*
l
[ EXAMPLE - 10 CFR PART 71]
Chapter 1 Introduction The foliowing regulatory requirements are applicable to the RAls in this chapter:
10 CFR Sections 71.0(a), 71.7(a), 71.35(a), and 71.39, and 10 l
CFR Part 71 Subparts E, F, and G.
It should be noted that other regulatory requirements may be applicable to this section.
1-1 Provide the construction detail at center of the impact limiter on drawing IL-001, sheets 1 and 2, revision 0.
1-2 Specify the torque applied to the impact limiter connector bars on drawing SPA-001, sheet 2, revision 0.
The necessary torque requirement should ensure that the impact limiter will not be loosened by vibrations during normal transportation.
i M
4 8
i l
[ EXAMPLE - 10 CFR PART 71]
Chapter 5 shielding The following regulatory requirements are applicable to the RAls in this chapter:
10 CFR Sections 71.7(a), 71.35(a), 71.39, 71.41, 71.43(f),
71.47, 71.51(a), 71.71(a) and 71,73(a), and 10 CFR Part 71 Subpart G.
It should be noted that other regulatory requirements may be applicable to this section.
5-1 Revise the normal conditions shielding analysis to include the dose rate at the actual package surface (i.e., neutron shield shell or cask wall).
The personnel barrier has not been shown to be an integral part of the transport package. The applicant should ensure that the requirements of 10 CFR Section 71.47 are met in response to this RAI.
4 f
4 e
4 8
- s
s i
[ EXAMPLE - 10 CFR PART 72)
Chapter 1 ral Description The following reg 61 story requirements are applicable to the RAls in this chapter:
10 CFR Sections 72.2(a)(1), 72.11, 72.24(b), 72.24(c)(3),
72.24(j), 72.28(a), 72.230(b), and 72.236(a).
It should be noted that other regulatory requirements may be applicable to this section.
1-1 Provide the technical qualifications of the applicant.
The application must contain the technical qualifications of the applicant to engage in the proposed activities as required by 10 CFR Section 72.24 and 10 CFR 72.28. The contents of the application were i
deficient in this regard. The application did not specify the training and experience of the applicant to engage in the proposed activity, did not provide information regarding the organization or its training
{
program, and did not state a comitment to he"e and maintain an adequate l
complement of trained and certified installation personnel prior to the j
receipt of spent fuel or high-level radioactive waste for storage.
j t
1-2 Provide a non-proprietary version of the proprietary engineering drawings for the cask.
4 As noted in a previous NRC letter, the staff agrees with the applicant that the engineering drawings should be withheld under 10 CFR 2.790.
However, in order to balance the.need to keep the public. informed and keep the applicant's material confidential, the staff requests that a non-proprietary version of the engineering drawings be developed suitable for placement in the Public Document Room in accordance with 10 CFR 2.790.
l l
[ EXAMPLE - 10 CFR PART 72)
Chapter 11 Accident Analyses i
The following regulatory requirements are applicable to the RAI's in this chapter:
10 CFR Sections 72.2(a)(1); 72.11; 72.24(d); 72.24(d)(2);
72.24(m); 72.104(a); 72.106(b); 72.122(b); 72.122(b)(2); 72.122(b)(3);
72.122(d); 72.122(g); 72.122(h); 72.122(1); 72.122(1); 72.124(a);
72.126(a); 72.236(c); 72.236(d); 72.236(1).
It should be noted that l
other regulatory requirements may be applicable to this section.
11-1 Update the TSAR with the lightning analysis and various compensatory measures that may be required to mitigate the effects of lightning.
Chapter 11 does not include an analysis for lightning effects; 10 CFR 72.122(b)(2) requires, in part, that structures, systems, and components important to safety must be designed to withstand the effects of natural phenomena, including _liahtning.
11-2 Discuss the ANSYS code verification and validation for in fire transient evaluation.
ANSYS was appropriately identified in accordance with 10 CFR 72.24. The response should include e. experimental tests performed in the ANSYS code development (e.g., furnace or fire, test conditions, instrumentation used,etc.).
11-3 Provide summary tables and figures similar to thost provided for Chapter 3 of the Part 71 Safety Analysis Report.
N w; ;
'i
,