ML063480132
| ML063480132 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/22/2006 |
| From: | Gutherman B ACI Nuclear Energy Solutions |
| To: | Meraj Rahimi Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML063480132 (11) | |
Text
Page 1 of 1 Michelle DeBose - Updated Issues Matrix From:
"Brian Gutherman" <bgutherman@acines.com>
To:
"'Meraj Rahimi"' <MXR2@nrc.gov>
Date:
09/22/2006 1:50 PM
Subject:
Updated Issues Matrix
- Meraj, Attached is an issues matrix updated to include the 9th Circuit Court Diablo Canyon ISFSI issue.
Brian Gutherman, P.E.
President ACI Nuclear Energy Solutions P.O. Box 1725 Medford, NJ 08055 609-268-5527 (office) 609-268-5528 (fax) 609-273-7439 (cell) bguthermancacines.com This message is intended only for the clients, employees or associates of ACI Nuclear Energy Solutions and may contain confidential information. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone at (609) 268-5527 or notify us by e-mail at bgutherman@acines.com and delete the original message. Thank you.
file ://C :\\temp\\GW}00001.HTM 09/26/2006
10 CFR 71/72 DSTF ISSUES MATRIX I
SSE I
FI 1F AiO ISNO.
PRIORITY STATUS IS U E C I T O E AR SA T O S FL A
H Open Criticality Control (RIS 2005-05): Part 50 Meeting held 11/10/05 50.68 rulemaking Gutherman (Tracking) and Part 72 requirements apply during cask between NRC and in progress.
loading in pool. Requirements overlap and industry. Industry Presented to NRC (NRR and SFPO) burnup credit requested NRC to re-ACRS 9/7/06.
methods are not consistent. NRC requesting look at interim solutions Expect FR notice LARs from all affected plants as interim involving no TS or for direct-final compliance measure, enforcement discretion.
rule 4Q '06.
1 a M
Open Criticality Accident Requirements:
Appears rule change is Rule still appears Gutherman
§72.124(c): Regulations provide exemptions necessary to clarify. See to require a from monitoring when fuel is under water NRC letter to Holtec change to fix and in "storage configuration" During cask dated 8/1/00 for permanently.
preparation (out of pool but before in additional information.
Can this be "storage configuration"), no exemption NRC accepted Southern added to the
,applies and monitoring is required.
Co. approach to use area rulemaking gamma radiation approved under monitors. Refer to SRM SECY presentation material 0152 (Issue 36)?
from 3/14/06 meeting and Southern exemption response.
Page 1 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX Pj RIOR ITY STATUS ISSUE DESCRIPTION REMARKS ACTION DSTF LEAD 2
H Open Burnup Credit: ISG-8 does not allow Acquire and evaluate Revise ISG-8.
Quinn/Anton (Tracking) fission product credit, making BUC French data to expand methodology limited. SFPO method is ISG-8 guidance. In different than NRR. Except for geometry, parallel, evaluate Part methods should be the same.
50 and SFPO criticality analysis and BUC methods and assumptions for differences. Resolve differences and recommend single criticality/BUC analysis method where possible.
(EPRI input) 2a H
Open Burnup Measurements: ISG-8 recommends Evaluate safety benefit Industry to Nesbit/Franklin measuring burnup on a sampling basis to of BU measurements provide technical increase confidence in reactor records.
and recommend basis for no Industry does not believe this is necessary.
guidance change, as burnup appropriate (EPRI measurements.
input)
NRC to provide expectation for technology and what results are expected.
3 H
Open Damaged Fuel: Definition in ISG-I, Rev. I Determine damaged Revise ISG-I to Gutherman/Eyre is very broad and difficult to implement.
fuel criteria for storage agree with ANSI Need a definition generated with industry and transportation. Issue N14.33.
participation before implementation. RG may RG or add as defined be more appropriate than ISG. Need to term in the rules. CoCs ensure fuel previously loaded as intact for will need to be revised storage can be transported without re-to reflect new guidance packaging.
and/or rule. (EPRI input)
Page 2 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX DSSUE SES ION REMARKS I
ACTION DSTF LEAD J Control of Cask Licensing Basis: a) backfit Licensees, CoC holders, DSTF internal.
Sides of changes to ongoing TS (cask surveillance) and NRC may have FAQ issue to previously deployed casks. b) Backward different views on these and forward compatibility of hardware. c) issues. Need mutually Removal of information from SAR/CoC that agreeable position.
applies to previously deployed casks and/or site-specific licensee who incorporated the information by reference.
Regulatory Process: Certain issues are being addressed outside of recognized regulatory processes and should be addressed in a more structured process, such as a Regulatory Guide, rulemaking, or other formal generic communication (i.e., GL), to allow front-end industry participation and independent backfit evaluation by NRC (CRGR). Examples: ISGs, cask Technical Specifications, RIS 2005-05, fuel-air issue.
CoC( Noncom pliance-What process P crns*
Process feedback issue in 2/8/05 workshop.
Work with NRC as topics arise to determine appropriate process to use.
Discuss between NEI and NRC senior management Kraft Page 3 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX NO.
PRIORITY ISSUE DESCRIPTION
[
REMARKS
[]
ACTION DSTF LEAD 7
L Open Moderator Exclusion: 71.55(b) does not Work with NRC on Continue Gutherman permit moderator exclusion by design for regulatory issues discussion to normal conditions outside of limited associated with a rule determine path exceptions (i.e., entire cask designs cannot be change. Rule change forward. Need excepted from moderator intrusion).
may have broad (i.e.,
separate meeting Regulations (per ISG-19) permit moderator YM EIS) implications with NRC.
exclusion for accident conditions. Seems (EPRI input) contradictory. See EPRI Report 1011815.
8 M
Open High Burnup Fuel: ISG-I 1, Rev 3 does not Tracking item.
Revise ISG-I 1 provide guidance for transportation of HBU Determine criteria for fuel.
review of transport requirements for high burnup fuel. (EPRI input) 9 L
Open Cask Technical Specifications (NUREG-Work with NRC to Need separate Gutherman 1745): Level of detail in cask TS and CoCs make risk-based rule meeting with (e.g., fuel parameters) is not commensurate change to TS inclusion NRC to discuss with risk. Fuel paramete'r change process in criteria and revise criteria for TS NUREG-1745 is not consistent with NUREG-1745. Need similar to Part regulations.
cask loading PRA
.50. CoC contents issued.
should be risk-informed.
10 M
Open Risk Informed regulations and review Draft presented to Once issued, how Gutherman/EPRI guidance: Cask loading PRAs need to be ACNW 7/20/06. Final do we use the (Canavan)/NEI used to risk inform regulations and guidance.
issue expected by results?
(Bradley) 9/30/06. EPRI PRA issued Page 4 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX the conimitmnents in the program are not reduiced. There is no suIch provision in Part 71*and'drenewal is required evenr 5 (now 10) y~a~i~~s2lhels rules appear to conflict.
72.48 Guidance: Based on.experience since 4/01, NEI guidance on malfunctions, consequences, and methods of evaluation may need updating and more customizing for casks. For example, casks do not typically have single failure criteria requirements and often accidents have no offsite dose consequences.
Based on lessons learned, consider revising guidance to clarify implementation of 72.48.
DSTF internal.
NEI task force being assembled to address revision to 50.59 and 72.48 guidance in NEI 96-07 13 L
Open Licensee 72.48 Processing: a) What are GL FAQs and/or other DSTF internal.
Sides obligations (i.e., timing, actions) for communication vehicle FAQ issue.
processing CoC holder 72.48s? b) What's to establish industry required if GL does not adopt? c) What is consensus.
effective date for CoC holder-issued 72.48s on GLs (e.g., operating changes)? d) What is CoC holder 72.48 deletes or modifies information incorporated by reference by an SL and SL does not want to change?
Page 5 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX Open (Tracking)
SRP Updates: NRC needs to update SRPs to incorporate ISGs.
NRC action.
Industry to review and comment on proposed revisions 4
-l 4
-I I-18 L
Open (Tracking)
Reg Guide Updates: NRC needs to update RGs 3.48, 3.61 and 3.62 to match SRP format.
Need to discuss plan with NRC. Currently using SRPs where RGs are the correct guidance for industry No current plans to update these RGs.
Gutherman Page 6 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX ruei tiauaing integrity Anailysis: LaSK designers have not historically analyzed fuel cladding integrity. Fuel material data is limited. Guidance in ISG-12 only addresses buckling.
n~roaaen iicensing guidance in SRP.
25 L
Open DOE Standardized Canister: DOE Working with DOE to None.
Gutherman (Tracking) proposes to use a standard Transportation, develop performance Aging, and Disposal (TAD) fuel canister that spec.
will be compatible with the waste package at YM.
26 L
Open 10CFR72.13: Some sections may not be Review and make Industry to Sides appropriately listed.,
suggestions to NRC for consider petition.
rule change 27 M
Open Tornado Missiles: How do general licensees Develop industry DSTF internal.
compare site-specific missiles against generic consensus.
FAQ issue missiles? By spectrum or missile by missile comparison?
Page 7 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX
.1 29 Low Open RIS 2005-31, Security Sensitive Information: SFPO would like industry's input on developing procedures for the treatment of sensitive information in incomine documents..
No regulatory requirement for withholding SSI Need clarification of NRC expectations for implementation 30 Low Open Correcting CoC Errors: SFPO is NRC to engage considering how to correct errors in an stakeholders.
_ _existing CoC.
31 Medium Open Repetitive RAIs: Similar RAls issued by staff on applications submitted by different NRC to follow up Se(
Page 8 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX S
PRIORITY ISSUE DESCRIPTION REMARKS DSTF LEAD 33 TBD Open Neutron absorber material: The staff The staff is considering would like to engage industry on how to treat generic guidance in this neutron absorber material process controls area. The staff would (how the material is manufactured and like to engage industry tested) in dry storage cask applications. In on whether neutron recent applications these process controls absorber material have been captured in technical process control specifications.
guidance should be developed, and if it is to be developed, how that guidance should be captured. Need priority.
NRC believes it is "high."
34 TBD Open Canister leakage testing (ISG-18): The The NRC staff is Industry will NRC staff is considering revising ISG-18 to targeting issuing a draft comment on the capture lessons learned from recent reviews of the revised guidance draft ISG and to make the guidance more clear, in the Winter of 2006.
revision when (This date is subject to issued. Need change based on staff priority. NRC priorities.)
believes it is "high."
35 TBD Open Beyond Design Basis Threats: SFPO has After Commission Commission to made recommendations to the Commission action, need to meet rule on SFPO based on Sandia work that could result in with SFPO to determine recommendations new design standards for casks.
specific actions required, if any, and implementation plan.
36 TBD Open Part 72 Rulemaking: SECY-06-0152 Industry will provide NRC to create endorses rulemaking effort to address CoC input on proposed rule rule changes.
and GL terms and conditions changes.
Page 9 of 10 9/22/2006
10 CFR 71/72 DSTF ISSUES MATRIX II II ACTION II DSTF LEAD I ISSUE DESCRIPTION REMARKS I
I I
9th Circuit Decision: What are the generic implications of the 9h Circuit Court's decision on the Diablo Canyon ISFSI re:
NEPA and terrorist threats?
PG&E is appealing the decision to the Supreme Court. NRC is not appealing but may file amicus brief.
Grebel Page 10 of 10 9/22/2006