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| {{#Wiki_filter:February 4, 2016 Rod McCullum, Director Used Fuel Programs Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 | | {{#Wiki_filter:February 4, 2016 Rod McCullum, Director Used Fuel Programs Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| REQUEST FOR ADDITIONAL INFORMATION RELATED TO "BENCHMARKS FOR QUANTIFYING FUEL REACTIVITY DEPLETION UNCERTAINTY" AND "UTILIZATION OF THE EPRI DEPLETION BENCHMARKS FOR BURNUP CREDIT VALIDATION" | | REQUEST FOR ADDITIONAL INFORMATION RELATED TO "BENCHMARKS FOR QUANTIFYING FUEL REACTIVITY DEPLETION UNCERTAINTY" AND "UTILIZATION OF THE EPRI DEPLETION BENCHMARKS FOR BURNUP CREDIT VALIDATION" |
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| ==Dear Mr. McCullum:== | | ==Dear Mr. McCullum:== |
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| By letter dated June 6, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12165A455), the Electric Power Research Institute (EPRI) submitted two reports, "Benchmarks for Quantifying Fuel Reactivity Depletion Uncertainty" and "Utilization of the EPRI Depletion Benchmarks for Burnup Credit Validation" to the U.S. Nuclear Regulatory Commission (NRC). Both of these reports support the ongoing revision of NEI 1216, "Guidance for Performing Criticality Analyses of Fuel Storage at LightWater Reactor Power Plants." Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. | | By letter dated June 6, 2012 (Agencywide Documents Access and Management System (ADAMS) |
| | | Accession No. ML12165A455), the Electric Power Research Institute (EPRI) submitted two reports, "Benchmarks for Quantifying Fuel Reactivity Depletion Uncertainty" and "Utilization of the EPRI Depletion Benchmarks for Burnup Credit Validation" to the U.S. Nuclear Regulatory Commission (NRC). Both of these reports support the ongoing revision of NEI 1216, Guidance for Performing Criticality Analyses of Fuel Storage at LightWater Reactor Power Plants. Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. |
| In an email dated January 6, 2016, Mr. Kristopher Cummings, representing the Nuclear Energy Institute, and I agreed that the NRC staff will receive your response to the enclosed request for additional information (RAI) questions by March 31, 2016. | | In an email dated January 6, 2016, Mr. Kristopher Cummings, representing the Nuclear Energy Institute, and I agreed that the NRC staff will receive your response to the enclosed request for additional information (RAI) questions by March 31, 2016. |
| If you have any questions regarding the enclosed RAI questions, please contact me at (301) 415-7297. | | If you have any questions regarding the enclosed RAI questions, please contact me at (301) 415-7297. |
| Sincerely, /RA/ | | Sincerely, |
| Joseph J. Holonich, Sr. Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689 | | /RA/ |
| | Joseph J. Holonich, Sr. Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689 |
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| ==Enclosure:== | | ==Enclosure:== |
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| RAI questions | | RAI questions |
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| ML16007A034; *concurred via e-mail NRR-106 OFFICE DPR/PLPB DPR/PLPB* DSS/SRXB DPR/PLPB DPR/PLPB NAME WMacFee DHarrison EOesterleKHsuehJHolonich DATE 01/07/2016 01/22/2016 02/02/2016 02/02/2016 02/04/2016 REQUEST FOR ADDITIONAL INFORMATION (RAI) QUESTIONS REGARDING EPRI REPORT 1025203, "UTILIZATION OF THE EPRI DEPLETION BENCHAMRKS FOR BURNUP CREDIT VALIDATION," AND EPRI REPORT 1022909, "BENCHMARKS FOR QUANTIFYING FUEL REACTIVITY DEPLETION UNCERTAINY" | | ML16007A034; *concurred via e-mail NRR-106 OFFICE DPR/PLPB DPR/PLPB* DSS/SRXB DPR/PLPB DPR/PLPB NAME WMacFee DHarrison EOesterle KHsueh JHolonich DATE 01/07/2016 01/22/2016 02/02/2016 02/02/2016 02/04/2016 REQUEST FOR ADDITIONAL INFORMATION (RAI) QUESTIONS REGARDING EPRI REPORT 1025203, UTILIZATION OF THE EPRI DEPLETION BENCHAMRKS FOR BURNUP CREDIT VALIDATION, AND EPRI REPORT 1022909, BENCHMARKS FOR QUANTIFYING FUEL REACTIVITY DEPLETION UNCERTAINY |
| : 1) For the resulting benchmark model to be applicable, the uncertainty of the benchmark must be established such that a 95/95 confidence assessment can be established on the subsequent criticality calculations. As such the uncertainty in the reactivity of a specific assembly at a specific burnup needs to be determined. The variance of the average of multiple assemblies will be smaller than the variance of a single assembly. | | : 1) For the resulting benchmark model to be applicable, the uncertainty of the benchmark must be established such that a 95/95 confidence assessment can be established on the subsequent criticality calculations. As such the uncertainty in the reactivity of a specific assembly at a specific burnup needs to be determined. The variance of the average of multiple assemblies will be smaller than the variance of a single assembly. |
| The statistics in the proposed approach appears to only derive the uncertainty of the CASMO/SIMULATE code that is applicable to the reactor core average decrement. | | The statistics in the proposed approach appears to only derive the uncertainty of the CASMO/SIMULATE code that is applicable to the reactor core average decrement. |
| Clarify how the variance in the reactivity decrement for a specific assembly and burnup can be established to support subsequent criticality benchmark analyses. | | Clarify how the variance in the reactivity decrement for a specific assembly and burnup can be established to support subsequent criticality benchmark analyses. |
| : 2) Benchmarks have historically been "measurements" with some minor calculation adjustments for clarity or simplification. The approach, as presented in the reviewed documents and revised statistical approach, presents a case to assess the uncertainty of the code methodology based indirectly on core measurements with adjustments to minimize the code difference (error). The "benchmark" is then manufactured from the code using the code's relative uncertainty. Thus, the benchmark is based on the code, not on the measurement. To be based on the measurement, only those measurements (i.e., directly from flux map data) applicable to a benchmark case would be used with the establishment of case-specific absolute variances or errors. Explain why EPRI's reactivity decrement error deduction approach is appropriate given that the benchmark is based on the code rather than direct measurement. | | : 2) Benchmarks have historically been measurements with some minor calculation adjustments for clarity or simplification. The approach, as presented in the reviewed documents and revised statistical approach, presents a case to assess the uncertainty of the code methodology based indirectly on core measurements with adjustments to minimize the code difference (error). The benchmark is then manufactured from the code using the codes relative uncertainty. Thus, the benchmark is based on the code, not on the measurement. To be based on the measurement, only those measurements (i.e., directly from flux map data) applicable to a benchmark case would be used with the establishment of case-specific absolute variances or errors. Explain why EPRIs reactivity decrement error deduction approach is appropriate given that the benchmark is based on the code rather than direct measurement. |
| : 3) Discuss how extrapolation of the EPRI work will be extrapolated to other fuel designs given that the benchmarks contain a limited subset of fuel designs. | | : 3) Discuss how extrapolation of the EPRI work will be extrapolated to other fuel designs given that the benchmarks contain a limited subset of fuel designs. |
| : 4) Discuss the range of method applicability with respect to the use of different depletion codes and clarify the general validation procedure outlined in EPRI report 1025203. | | : 4) Discuss the range of method applicability with respect to the use of different depletion codes and clarify the general validation procedure outlined in EPRI report 1025203. |
| Specifically, the procedure described in EPRI report 1025203 describes how depletion code validation is to be performed, but does not discuss any of the procedure limitations. For example, the implications of excessive depletion code bias is not addressed. Additionally, how are the 11 calculational benchmarks robust to consideration of different fuel designs that have different physical characteristics? That is, why isn't it necessary to define application-specific calculational benchmarks? The EPRI report 1025203 procedure is also vague with respect to expectations regarding incorporation of biases and uncertainties from EPRI report 1022909 into a user's depletion code validation analysis as part of an overall criticality safety analysis. | | Specifically, the procedure described in EPRI report 1025203 describes how depletion code validation is to be performed, but does not discuss any of the procedure limitations. For example, the implications of excessive depletion code bias is not addressed. Additionally, how are the 11 calculational benchmarks robust to consideration of different fuel designs that have different physical characteristics? That is, why isnt it necessary to define application-specific calculational benchmarks? The EPRI report 1025203 procedure is also vague with respect to expectations regarding incorporation of biases and uncertainties from EPRI report 1022909 into a users depletion code validation analysis as part of an overall criticality safety analysis. |
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| Enclosure}} | | Enclosure}} |
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Category:Letter
MONTHYEARML24304A3482024-10-29029 October 2024 10-29-24 NEI Letter to NRC Status and Way Forward on NEI 99-04 Revision 1 ML24274A3112024-09-30030 September 2024 Request for NRC Review and Endorsement of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML24255A0702024-09-0909 September 2024 09-09-24_NRC_Industry Timeliness Request Regarding Items Relied Upon for Safety ML24204A2082024-07-22022 July 2024 07-22-24_NRC_NEI Withdrawal of Fee Exemption Request for Wp Selection of Seismic Scenario for EPZ Determination ML24204A2162024-07-22022 July 2024 Withdrawal of Fee Exemption Request for Endorsement of NEI White Paper, Selection of a Seismic Scenario for an EPZ Boundary Determination ML24187A0552024-07-0303 July 2024 Fee Exemption Request for NEI White Paper Selection of Seismic Scenario for EPZ Determination ML24184C1212024-07-0202 July 2024 NEI - Request for NRC Endorsement of NEI 24-05 Revision 0, an Approach for Risk-Informed Performance-Based Emergency Planning ML24173A2712024-06-14014 June 2024 NEI - Proposed Changes to Inspection Procedure (IP) 71130.10, Cybersecurity ML24165A0852024-06-13013 June 2024 NEI White Paper - Impact of Higher Source Term Fractions on EQ Doses ML24165A0862024-06-13013 June 2024 NEI White Paper - Proposed Control Room Dose Acceptance Criteria Supporting RG 1.183 R2 ML24165A0872024-06-12012 June 2024 NEI White Papers Supporting NRC Workshop Discussions Regarding Nuclear Regulatory Commissions (NRC) Potential Changes to Regulatory Guide 1.183 ML24152A3242024-05-31031 May 2024 NEI Concept Paper: Regulation of Rapid High-Volume Deployable Reactors in Remote Locations ML24159A7312024-05-23023 May 2024 05-23-24 Nuclear Energy Institute Letter to the U.S. Nuclear Regulatory Commission Re Industry Comments on Buildings as Items Relied on for Safety ML24135A1982024-04-23023 April 2024 SFAQ No 2022-02, SAE Program Requirements - NEI Withdrawal Letter ML24078A2212024-03-15015 March 2024 3-15-24 NEI Letter Aveil from Juhle on Pur ML24061A0572024-02-29029 February 2024 Endorsement of NEI 08-09, Revision 7, Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors ML24023A0392024-01-22022 January 2024 NEI Comments on the Information Collection Renewal for Domestic Licensing of Special Nuclear Material, Docket Id NRC-2023-0118 ML23355A1972023-12-14014 December 2023 NEI, Comments on NRC Draft Resolution of SFAQ 2022-02, SAE Program Requirements ML23219A1672023-10-25025 October 2023 Response Letter to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23270B9002023-09-27027 September 2023 NEI Letter Request for an Extension of Comment Period on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses, Docket Id NRC 2023 0079 ML23268A0102023-09-22022 September 2023 NEI, Fee Exemption Request for Endorsement, Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors ML23241A8612023-08-25025 August 2023 Consolidated Industry Comments to NRC Regulatory Issue Summary 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels ML23236A4992023-08-24024 August 2023 Industry Feedback on Region II Fuel Cycle Facility Construction Oversight Workshop Held August 15, 2023, and Suggested Topics for Additional Public Meetings in Fall 2023 ML23256A1622023-08-0101 August 2023 Incoming NEI Letter Dated August 1, 2023 Regarding Increase in Fees 2023-2025 ML23206A0292023-07-24024 July 2023 Incoming Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23143A1232023-06-22022 June 2023 NRC Fee Waiver Request for Draft NEI 23-01 ML23200A1662023-05-30030 May 2023 NEI Proposed Metrics for a Performance-Based Emergency Preparedness Program ML23116A0732023-05-25025 May 2023 Letter to Hillary Lane in Response to a Request for a Fee Exemption for NEI 23-03 ML23135A7332023-05-0909 May 2023 NEI Comments on NRC Safety Culture Program Effectiveness Review ML23110A6762023-04-18018 April 2023 04-18-23_NRC_NEI 23-03 Review + Endorse ML23110A6752023-04-18018 April 2023 04-18-23_NRC_Fee Waiver for NEI 23-03 ML23110A6782023-04-18018 April 2023 Request for Review and Endorsement of NEI 23-03, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications at Non-Power Production or Utilization Facilities ML24120A2702023-04-0404 April 2023 Melody Rodridguez NEI Comment on Controlled Unclassified Information ML23107A2302023-03-31031 March 2023 NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking ML23083B4622023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23138A1662023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23060A3272023-03-0101 March 2023 NEI, Wireless Cyber Security Guidance ML23060A2142023-03-0101 March 2023 NEI, Request for NRC Endorsement of NEI White Paper, Enabling a Remote Response by Members of an Emergency Response Organization, Revision 0 ML23023A2752023-01-23023 January 2023 Request for Extension of Comment Period from the Nuclear Energy Institute on PRM-50-124 - Licensing Safety Analysis for Loss-of-Coolant Accidents ML22348A1122023-01-17017 January 2023 Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7 ML22353A6082023-01-11011 January 2023 U.S. Nuclear Regulatory Commission Report of the Regulatory Audit of the NEI-Proposed Aging Management Program Revision to Selective Leaching Program (XI.M33) ML22349A1012022-12-12012 December 2022 LTR-22-0343 Ellen Ginsberg, Sr. Vice President, General Counsel and Secretary, Nuclear Energy Institute, Expresses Concerns Related to Issuance of Regulatory Issue Summary 2022-02; Operational Leakage ML22336A0372022-11-16016 November 2022 Fee Exemption Request for NEI 08-09 Revision 7 - Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors ML22321A3152022-11-16016 November 2022 NEI Letter with Comments on Significance Determination Process Timeliness Review ML22298A2262022-10-25025 October 2022 Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated October 2022 ML22298A2302022-10-17017 October 2022 Submittal of NEI 22-03, Draft Revision 0, Nuclear Generation Quality Assurance Program Description ML22207B6512022-07-26026 July 2022 NEI, Full Fee Exemption Request for Industry Guidance Proposal - Weather Related Administrative Controls During Transient Outdoor Dry Cask Operations ML22195A1662022-07-14014 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22195A0672022-07-13013 July 2022 Fee Exemption Request for Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 21-05, Reporting Guidance for Licensees with Risk-Informed Licensing Bases ML22195A0202022-07-13013 July 2022 07-13-22 NRC Fee Exemption Request for NEI 21-05 Review 2024-09-09
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML16007A0342016-02-0404 February 2016 Request for Additional Information Related to Benchmarks for Quantifying Fuel Reactivity Depletion Uncertainty and Utilization of the EPRI Depletion Benchmarks for Burnup Credit Validation. ML14197A1712014-07-22022 July 2014 Request for Additional Information Regarding the Review of Nuclear Energy Institute 14-05, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 0 ML1207306592012-03-19019 March 2012 Request for Additional Information #2 for Nuclear Energy Institute TR 09-10, Rev 1, Gas Management ML1203702022012-02-0808 February 2012 Request for Additional Information Regarding the Review of NEI 11-04, Nuclear Generation Quality Assurance Program Description, Draft Revision 0 ML1121406172011-08-0404 August 2011 Request for Additional Information on Topical Report 09-10, Revision 1, Guidelines for Effective Prevention and Management of System Gas Accumulation ML1030101152011-02-0303 February 2011 Request for Additional Information, Related to NEI 10 01, Industry Guideline for Developing a Plant Parameter Envelope in Support of an Early Site Permit, Revision 0 (Project No. 689; TAC Q00341) ML0933405412009-12-0303 December 2009 Request for Additional Information Nuclear Energy Institute (NEI) Topical Report 94-01, Revision 2-A Supplement 1, Industry Guideline for Implementing the Performance-Based Option of 10 CFR Part 50, Appendix J. ML0923700952009-08-28028 August 2009 Request for Additional Information Nuclear Energy Institute Topical Report Material Reliability Program (Mrp): Technical Basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in Pressurized Water Reactors (MRP-169), (MRP-169) (TAC ML0912105492009-05-13013 May 2009 Request for Additional Information (RAI) Regarding Nuclear Energy Institute Topical Report Material Reliability Program (MRP) Technical Basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in Pressurized Water Reactors (MRP-169) ML0911404832009-04-30030 April 2009 Supplemental Request for Additional Information Regarding Nuclear Energy Institute Technical Report 06-14A, Quality Assurance Program Description, Revision 6 (Project No. 689; TAC Q00014) ML0827403822008-10-23023 October 2008 Request for Additional Information, Topical Report WCAP-16294-NP, Revision 0, Risk-Informed Evaluation of Changes to Technical Specification Required Endstates for Westinghouse NSSS PWRs ML0824607832008-09-17017 September 2008 Enclosure - Request for Additional Information Regarding the Nuclear Energy Institute Quality Assurance Program Description Topical Report No. NEI-06-14A, Revision 5 ML0811301332008-06-0303 June 2008 Request for Additional Information Nuclear Energy Institute (NEI) Topical Report (TR) - 103237, EPRI (EPRI Power Research Institute) MOV (Motor-operated Valve) Performance Prediction Program - Topical Report ML0814002052008-05-19019 May 2008 Request for Additional Information Regarding Nuclear Energy Institute Topical Report 07-03, Generic Final Safety Analysis Report Template Guidance for Radiation Protection Program Description, Revision 5 (Project No. 689; TAC MD5248) ML0809402502008-05-0606 May 2008 Request for Additional Information Regarding Nuclear Energy Institute Topical Report 07-10, Generic Final Safety Analysis Report Template Guidance for Process Control Program, Revision 2 (Project No. 689; TAC MD6860) ML0808701172008-04-28028 April 2008 Request for Additional Information Regarding Nuclear Energy Institute Topical Report Number 07-09, Generic Final Safety Analysis Report Template Guidance for Offsite Dose Calculation Manual Program Description, Revision 1 (Project No. 689; ML0809402802008-04-0707 April 2008 Request for Additional Information, Topical Report Material Reliability Program (Mrp): Technical Basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in Pressurized Water Reactors (MRP-169) ML0725505052007-09-21021 September 2007 NEI, Second Request for Additional Information Regarding Topical Report NEI 07-02, Generic FSAR Template Guidance for Maintenance Rule Program Description Guidance for Plants Licensed Under 10 CFR Part 52, Revision 1 ML0722201292007-08-27027 August 2007 Request for Additional Information (RAI) Regarding Nuclear Energy Institute Topical Report (TR) WCAP-16308-NP, Pressurized Water Reactor Owners Group 10 CFR 50.69 Pilot Program - Categorization Process - Wolf Creek Generating Station. ML0721504172007-08-23023 August 2007 Request for Additional Information Regarding Transmittal of NEI 07-02, Generic FSAR Template Guidance for Maintenance Rule Program Description for Plants Licensed Under 10CFR Part 52, Revision 1 ML0714504142007-07-0909 July 2007 Request for Additional Information (RAI) Regarding Topical Report No. NEI 07-03, Generic FSAR Template Guidance for Radiation Protection Program Description, Revision 0 (Project No. 689; TAC MD5248) ML0715501162007-06-13013 June 2007 Request for Additional Information (RAI) Regarding Nuclear Energy Institute Topical Report (TR) WCAP-16294-NP, Rev. 0, Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs.(MD51 ML0714504802007-05-25025 May 2007 Electronic Mail - Starefos, J L to Andersen R; 05/25/2007; RAI - NEI 07-03, Radiation Protection Program ML0710703702007-04-23023 April 2007 Request for Additional Information (RAI) Regarding Topical Report (TR) -103237, Electric Power Research Institute Motor-Operated Valve Performance Prediction Methodology Software ML0629102582007-02-21021 February 2007 Request for Additional Information (RAI) Regarding Nuclear Energy Institute (NEI) 94-01, Revision 1J, Industry Guideline for Implementing Performance-Based Option of 10 Code of Federal Regulations (CFR) Part 50, Appendix J & Electric Power ML0620503372006-08-0303 August 2006 Request for Additional Information Regarding Materials Reliability Program - 169 Technical Basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in Pwrs. ML0203100562002-01-31031 January 2002 Request for Additional Information on Sequal Topical Report Basis for Adoption of the Experience Based Seismic Equipment Qualification (Ebseq) Methodology by Non A-46 Nuclear Power Plants. 2016-02-04
[Table view] |
Text
February 4, 2016 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 "BENCHMARKS FOR QUANTIFYING FUEL REACTIVITY DEPLETION UNCERTAINTY" AND "UTILIZATION OF THE EPRI DEPLETION BENCHMARKS FOR BURNUP CREDIT VALIDATION"
Dear Mr. McCullum:
By letter dated June 6, 2012 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML12165A455), the Electric Power Research Institute (EPRI) submitted two reports, "Benchmarks for Quantifying Fuel Reactivity Depletion Uncertainty" and "Utilization of the EPRI Depletion Benchmarks for Burnup Credit Validation" to the U.S. Nuclear Regulatory Commission (NRC). Both of these reports support the ongoing revision of NEI 1216, Guidance for Performing Criticality Analyses of Fuel Storage at LightWater Reactor Power Plants. Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review.
In an email dated January 6, 2016, Mr. Kristopher Cummings, representing the Nuclear Energy Institute, and I agreed that the NRC staff will receive your response to the enclosed request for additional information (RAI) questions by March 31, 2016.
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
ML16007A034; *concurred via e-mail NRR-106 OFFICE DPR/PLPB DPR/PLPB* DSS/SRXB DPR/PLPB DPR/PLPB NAME WMacFee DHarrison EOesterle KHsueh JHolonich DATE 01/07/2016 01/22/2016 02/02/2016 02/02/2016 02/04/2016 REQUEST FOR ADDITIONAL INFORMATION (RAI) QUESTIONS REGARDING EPRI REPORT 1025203, UTILIZATION OF THE EPRI DEPLETION BENCHAMRKS FOR BURNUP CREDIT VALIDATION, AND EPRI REPORT 1022909, BENCHMARKS FOR QUANTIFYING FUEL REACTIVITY DEPLETION UNCERTAINY
- 1) For the resulting benchmark model to be applicable, the uncertainty of the benchmark must be established such that a 95/95 confidence assessment can be established on the subsequent criticality calculations. As such the uncertainty in the reactivity of a specific assembly at a specific burnup needs to be determined. The variance of the average of multiple assemblies will be smaller than the variance of a single assembly.
The statistics in the proposed approach appears to only derive the uncertainty of the CASMO/SIMULATE code that is applicable to the reactor core average decrement.
Clarify how the variance in the reactivity decrement for a specific assembly and burnup can be established to support subsequent criticality benchmark analyses.
- 2) Benchmarks have historically been measurements with some minor calculation adjustments for clarity or simplification. The approach, as presented in the reviewed documents and revised statistical approach, presents a case to assess the uncertainty of the code methodology based indirectly on core measurements with adjustments to minimize the code difference (error). The benchmark is then manufactured from the code using the codes relative uncertainty. Thus, the benchmark is based on the code, not on the measurement. To be based on the measurement, only those measurements (i.e., directly from flux map data) applicable to a benchmark case would be used with the establishment of case-specific absolute variances or errors. Explain why EPRIs reactivity decrement error deduction approach is appropriate given that the benchmark is based on the code rather than direct measurement.
- 3) Discuss how extrapolation of the EPRI work will be extrapolated to other fuel designs given that the benchmarks contain a limited subset of fuel designs.
- 4) Discuss the range of method applicability with respect to the use of different depletion codes and clarify the general validation procedure outlined in EPRI report 1025203.
Specifically, the procedure described in EPRI report 1025203 describes how depletion code validation is to be performed, but does not discuss any of the procedure limitations. For example, the implications of excessive depletion code bias is not addressed. Additionally, how are the 11 calculational benchmarks robust to consideration of different fuel designs that have different physical characteristics? That is, why isnt it necessary to define application-specific calculational benchmarks? The EPRI report 1025203 procedure is also vague with respect to expectations regarding incorporation of biases and uncertainties from EPRI report 1022909 into a users depletion code validation analysis as part of an overall criticality safety analysis.
Enclosure