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{{#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
{{#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


12/12/2018 2
Content
Content
* Introduction
* Introduction
Line 23: Line 24:
* Overview of Regulatory Experience and Practices
* Overview of Regulatory Experience and Practices
* Summary
* Summary
* Questions 12/12/2018                        2
* Questions


Introduction
12/12/2018 3
* 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.
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.
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
 
12/12/2018
 
===4 Background===
U.S. NRC Regulatory Experience
 
12/12/2018


===Background===
===Background===
U.S. NRC Regulatory Experience 12/12/2018 4
Certificate Holders: with NRC-Approved Designs for Use NAC International Holtec International Orano Transnuclear (TN) Americas Energy Solutions 5


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


===
===6 Background===
Background===
Dry Cask Storage Safety Inspections NRC Inspection Manual Chapters (IMC)s
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 2690 - Inspection Program Guidance for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations (ISFSI)s
Line 47: Line 51:
* IP 60855 - Operation of an ISFSI
* IP 60855 - Operation of an ISFSI
* IP 60856 - Review of 10 CFR 72.212(b) Evaluations
* IP 60856 - Review of 10 CFR 72.212(b) Evaluations
* IP 60857 - Review of 10 CFR 72.48 Evaluations 12/12/2018 6
* IP 60857 - Review of 10 CFR 72.48 Evaluations


===Background===
12/12/2018
 
===7 Background===
IP 60857 Inspection Requirements Inspection Sample Selection
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
* 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
* 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 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
* 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


===
===8 Background===
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
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
12/12/2018 9
* Applicability Determination is to determine the correct regulatory change control process, if any for all or part of a proposed activity Applicability
Overview - Applicability Process Applicability Determination
* Generally three to four questions to determine if the Determination        proposed activity is applicable 9
* Applicability Determination is to determine the correct regulatory change control process, if any for all or part of a proposed activity
12/12/2018
* Generally three to four questions to determine if the proposed activity is applicable  


Overview - Screening Process
12/12/2018 10 Overview - Screening Process Screening for Adverse Effects
* Screening is the process for determining whether a proposed activity requires a 10 CFR 72.48 evaluation to be performed Screening for
* Screening is the process for determining whether a proposed activity requires a 10 CFR 72.48 evaluation to be performed
* Generally three to four questions to determine if the Adverse Effects  proposed activity is adversely impacted
* Generally three to four questions to determine if the proposed activity is adversely impacted Screening for Methods of Evaluation
* Determine if an activity involves a method of evaluation (MOE)
* Determine if an activity involves a method of evaluation (MOE)
Screening for
* Distinguishing between input parameters and elements
* Distinguishing between input parameters and Methods of    elements Evaluation 10 12/12/2018


Overview - 72.48(c)(2) Criteria - Evaluation
12/12/2018 11 Overview - 72.48(c)(2) Criteria - Evaluation 10 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 10 CFR 72.48 Criterion (c)(2)i (as updated)?
* 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)?
* 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)?
10 CFR 72.48 Criterion (c)(2)ii
11 12/12/2018
* 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)?


Overview - 72.48(c)(2) Criteria - Evaluation
12/12/2018 12 Overview - 72.48(c)(2) Criteria - Evaluation 10 CFR 72.48 Criterion (c)(2)iii
* 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 of an accident previously evaluated in the 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?
10 CFR 72.48 Criterion (c)(2)iv
12 12/12/2018
* 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?


Overview - 72.48(c)(2) Criteria - Evaluation
12/12/2018 13 Overview - 72.48(c)(2) Criteria - Evaluation 10 CFR 72.48 Criterion (c)(2)v
* 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)?
* Does the proposed activity create a possibility for an accident of a different type than any previously evaluated in the FSAR (as updated)?
Criterion (c)(2)v
10 CFR 72.48 Criterion (c)(2)vi
* 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)?
* 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)?
13 12/12/2018


Overview - 72.48(c)(2) Criteria - Evaluation
12/12/2018 14 Overview - 72.48(c)(2) Criteria - Evaluation 10 CFR 72.48 Criterion (c)(2)vii
* 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 design basis limit for a fission product barrier as described in the FSAR (as updated) being 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?
10 CFR 72.48 Criterion (c)(2)viii
(c)(2)viii 14 12/12/2018
* 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?


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
10/30/2018 15 Overview Regulatory Experience Method of Evaluation (MOE)
Screenings vs.
Evaluations Meeting the applicable criteria of 10 CFR 72.48(c)(2)
Nonconforming or Degraded Conditions


Overview Regulatory Guide 3.72 Update
12/12/2018 16 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 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.
* 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)
12/12/2018 17 Summary Review of 10 CFR 72.48 Evaluations Method of Evaluation Meeting the applicable criteria of 10 CFR 72.48(c)(2)
Evaluations Screenings vs.
Screenings vs.
Evaluations Nonconforming or Degraded Conditions 12/12/2018                                     17
Evaluations Nonconforming or Degraded Conditions
 
12/12/2018 18


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.
12/12/2018 19 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}}
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}}

Latest revision as of 08:37, 5 January 2025

Presentation Slides: 10 CFR 72_48 Evaluations and Inspection
ML18346A511
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Issue date: 12/19/2018
From: Marlone Davis
Division of Spent Fuel Management
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ML18338A059 List:
References
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

12/12/2018 2

Content

  • Introduction
  • Background
  • Overview of Regulatory Experience and Practices
  • Summary
  • Questions

12/12/2018 3

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

4 Background

U.S. NRC Regulatory Experience

12/12/2018

Background

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

12/12/2018

6 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

12/12/2018

7 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

8 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 9

Overview - Applicability Process Applicability Determination

  • Applicability Determination is to determine the correct regulatory change control process, if any for all or part of a proposed activity
  • Generally three to four questions to determine if the proposed activity is applicable

12/12/2018 10 Overview - Screening Process Screening for Adverse Effects

  • Screening is the process for determining whether a proposed activity requires a 10 CFR 72.48 evaluation to be performed
  • Generally three to four questions to determine if the proposed activity is adversely impacted Screening for Methods of Evaluation
  • Determine if an activity involves a method of evaluation (MOE)
  • Distinguishing between input parameters and elements

12/12/2018 11 Overview - 72.48(c)(2) Criteria - Evaluation 10 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

  • 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)?

12/12/2018 12 Overview - 72.48(c)(2) Criteria - Evaluation 10 CFR 72.48 Criterion (c)(2)iii

  • 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

  • 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 13 Overview - 72.48(c)(2) Criteria - Evaluation 10 CFR 72.48 Criterion (c)(2)v

  • 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

  • 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)?

12/12/2018 14 Overview - 72.48(c)(2) Criteria - Evaluation 10 CFR 72.48 Criterion (c)(2)vii

  • 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

  • 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?

10/30/2018 15 Overview Regulatory Experience Method of Evaluation (MOE)

Screenings vs.

Evaluations Meeting the applicable criteria of 10 CFR 72.48(c)(2)

Nonconforming or Degraded Conditions

12/12/2018 16 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 17 Summary Review of 10 CFR 72.48 Evaluations Method of Evaluation Meeting the applicable criteria of 10 CFR 72.48(c)(2)

Screenings vs.

Evaluations Nonconforming or Degraded Conditions

12/12/2018 18

12/12/2018 19 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

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