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{{#Wiki_filter:Session: Inspection Oversight Inspection Oversight and Regulatory Experience Related to the Review of 10 CFR 72.48 EvaluationsDivision of Spent Fuel ManagementRegulatory Conference 2018December 11  
{{#Wiki_filter: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
-12, 2018Marlone Davis, Sr. Storage and Transportation Safety InspectorU.S. NRC Office of Nuclear Material Safety and SafeguardsDivision of Spent Fuel Management 12/12/2018 2Content*Introduction
 
*Background
Content
*Overview of Regulatory Experience and Practices
* Introduction
*Summary*Questions 12/12/2018 3Introduction
* Background
*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.
* Overview of Regulatory Experience and Practices
12/12/2018 4BackgroundU.S. NRC RegulatoryExperience 12/12/2018BackgroundCertificate Holders: with NRC
* Summary
-Approved Designs for UseNAC InternationalHoltec InternationalOranoTransnuclear(TN) AmericasEnergy Solutions 5 12/12/2018 6BackgroundDry Cask Storage Safety InspectionsNRC Inspection Manual Chapters (IMC)s
* Questions 12/12/2018                         2
*IMC 2690 -Inspection Program Guidance for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations (ISFSI)s
 
*IMC 2515, Appendix C  
Introduction
-Special and Infrequently Performed InspectionsNRC Inspection Procedure (IP)
* 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.
*IP 60851 -Design Control of ISFSI Components
* 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.
*IP 60853 -Onsite Fabrication of Components and Construction of an ISFSI
12/12/2018                                                       3
*IP 60854 -Preoperational Testing of an ISFSI
 
*IP 60855 -Operation of an ISFSI
===Background===
*IP 60856 -Review of 10 CFR 72.212(b) Evaluations
U.S. NRC Regulatory Experience 12/12/2018 4
*IP 60857 -Review of 10 CFR 72.48 Evaluations 12/12/2018 7BackgroundIP 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 evaluationReview of Evaluations
Background===
*Review the selected sample evaluations to verify that the licensee or certificate holder has appropriately considered the conditions under which the change was made
Certificate Holders: with NRC-Approved Designs for Use NAC            Holtec        Orano      Energy International    International  Transnuclear  Solutions (TN) Americas 12/12/2018                                                         5
*Review the selected screen to determine that an evaluation was not required and verify that the conclusions were correct and consistent with the licensee's 10 CFR 72.48 procedure 12/12/2018 8BackgroundInspection GuidanceRegulatory Guide 3.72, "Guidance for Implementation of 10 CFR 72.48, Changes, Test, and Experiments," Revision 0Nuclear Energy Institute (NEI) 96
 
-07, Appendix B dated March 5, 2001 12/12/2018 9Overview -Applicability ProcessApplicability Determination
===
*Applicability Determination is to determine the correct regulatory change control process, if any for all or part of a proposed activity  
Background===
*Generally three to four questions to determine if the proposed activity is applicable 12/12/2018 10Overview -Screening ProcessScreening for Adverse Effects
Dry Cask Storage Safety Inspections NRC Inspection Manual Chapters (IMC)s
*Screening is the process for determining whether a proposed activity requires a 10 CFR 72.48 evaluation to be performed
* IMC 2690 - Inspection Program Guidance for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations (ISFSI)s
*Generally three to four questions to determine if the proposed activity is adversely impactedScreening for Methods of Evaluation
* IMC 2515, Appendix C - Special and Infrequently Performed Inspections NRC Inspection Procedure (IP)
*Determine if an activity involves a method of evaluation (MOE)
* IP 60851 - Design Control of ISFSI Components
*Distinguishing between input parameters and elements 12/12/2018 11Overview -72.48(c)(2) Criteria  
* IP 60853 - Onsite Fabrication of Components and Construction of an ISFSI
-Evaluation10 CFR 72.48 Criterion (c)(2) i*Does the proposed activity result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the FSAR (as updated)?10 CFR 72.48 Criterion (c)(2)ii
* IP 60854 - Preoperational Testing of an ISFSI
*Does the proposed activity result in more than a minimal increase in the likelihood of occurrence of a malfunction of a system, structure, or component (SSC) important to safety previously evaluated in the FSAR (as updated)?
* IP 60855 - Operation of an ISFSI
12/12/2018 12Overview -72.48(c)(2) Criteria -Evaluation10 CFR 72.48 Criterion (c)(2)iii
* IP 60856 - Review of 10 CFR 72.212(b) Evaluations
*Does the proposed activity result in more than a minimal increase in the consequences of an accident previously evaluated in the FSAR (as updated)?10 CFR 72.48 Criterion (c)(2)iv
* IP 60857 - Review of 10 CFR 72.48 Evaluations 12/12/2018 6
*Does the proposed activity result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the FSAR?
 
12/12/2018 13Overview -72.48(c)(2) Criteria -Evaluation10 CFR 72.48 Criterion (c)(2)v
===Background===
*Does the proposed activity create a possibility for an accident of a different type than any previously evaluated in the FSAR (as updated)?10 CFR 72.48 Criterion (c)(2)vi
IP 60857 Inspection Requirements Inspection Sample Selection
*Does the proposed activity create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the FSAR (as updated)?
* Review a list of evaluations performed and select a representative sample based on a judgment of risk significance
12/12/2018 14Overview -72.48(c)(2) Criteria -Evaluation10 CFR 72.48 Criterion (c)(2)vii
* Select a sample that were screened out as not requiring a performance of the 10 CFR 72.48 evaluation Review of Evaluations
*Does the proposed activity result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered?10 CFR 72.48 Criterion (c)(2)viii
* Review the selected sample evaluations to verify that the licensee or certificate holder has appropriately considered the conditions under which the change was made
*Does the proposed activity result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses?
* 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
10/30/2018 15OverviewRegulatory ExperienceMethod of Evaluation (MOE)Screenings vs. EvaluationsMeeting the applicable criteria of 10 CFR 72.48(c)(2)Nonconforming or Degraded Conditions 12/12/2018 16OverviewRegulatory 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.
Background===
12/12/2018 17SummaryReview of10 CFR 72.48 Evaluations Method of EvaluationMeeting the applicable criteria of 10 CFR 72.48(c)(2)Screenings vs. EvaluationsNonconforming or Degraded Conditions 12/12/2018 18 12/12/2018 19ReferencesCode of Federal Regulations(CFR), Title 10, Part 72  
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
-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}}
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
12/12/2018
 
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)?
11 12/12/2018
 
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?
12 12/12/2018
 
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)?
13 12/12/2018
 
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.
12/12/2018                                                         16
 
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}}

Revision as of 09:19, 20 October 2019

Presentation Slides: 10 CFR 72_48 Evaluations and Inspection
ML18346A511
Person / Time
Issue date: 12/19/2018
From: Marlone Davis
Division of Spent Fuel Management
To:
Lindsay H
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ML18338A059 List:
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Download: ML18346A511 (19)
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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.

12/12/2018 3

Background

U.S. NRC Regulatory Experience 12/12/2018 4

=

Background===

Certificate Holders: with NRC-Approved Designs for Use NAC Holtec Orano Energy International International Transnuclear Solutions (TN) Americas 12/12/2018 5

=

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
  • IP 60853 - Onsite Fabrication of Components and Construction of an ISFSI

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

=

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

12/12/2018

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)?

11 12/12/2018

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?

12 12/12/2018

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)?

13 12/12/2018

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 expects the DG to be out for public comment within the next six months.

12/12/2018 16

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

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