ML14070A180
| ML14070A180 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 02/25/2014 |
| From: | Mitchell R M Yankee Atomic Electric Co |
| To: | Bladey C K Rules, Announcements, and Directives Branch |
| References | |
| 78FR70354 00016, BYR 2014-012, NRC-2013-0254 | |
| Download: ML14070A180 (3) | |
Text
jr '~(YXAj~EE YANKEE ATOMIC ELECTRIC COMPANY 49 Yankee Road, Rowe, Massachusetts 01367///c~J ~February 25, 2014 BYR 2014-012 Cindy Bladey, Chief Rules, Announcements, and Directives Branch (RADB)Urlce O0 AC U.S. Nuclea Washington ministration, Mlail r Regulatory Commission ,DC 20555-0001 Yankee Atomic Electric Company Yankee Nuclear Power Station Independent Spent Fuel Storage Installation NRC License No. DPR-3 (NRC Docket Nos.50-029 and 72-3 i T1 C -N).. .C-..; .:".?. mr"
Subject:
Comments on the "White Paper on a Conceptual Example of a Proposed Risk Management Regulatory Framework Policy Statement" (ADAMS Accession No.ML13273A517)
[Docket ID NRC-2013-0254]
Dear Ms. Bladey:
The Yankee Atomic Electric Company (YAEC) appreciates the opportunity to provide comments on the document: "White Paper on a Conceptual Example of a Proposed Risk Management Regulatory Framework Policy Statement" (Federal Register Notice November 25, 2013) (White Paper).YAEC is a 10 CFR Part 50 licensee that operated a single unit nuclear power plant that is now permanently shut down and decommissioned.
All that remains at the site is an Independent Spent Fuel Storage Installation (ISFSI) that utilizes a 10 CFR Part 72 licensed dual-purpose dry cask storage system.Comments: Comments in Response to "Overall Questions" (1) and (5): The White Paper sets forth a possible Commission policy statement regarding the use of a structured decision-making model that results in risk-informed and performance-based defense-in-depth protections.
YAEC supports the adoption of a policy statement to establish a common risk management regulatory framework involving a more comprehensive and holistic risk-informed, performance-based regulatory approach that addresses the interim storage and transportation of spent nuclear fuel (SNF) and GTCC waste at stand-alone ISFSI sites. However, we also support the application of a risk management regulatory framework now, without the adoption of a policy statement, to the regulatory framework associated with interim storage and transportation of SNF and GTCC waste issues.SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= -, -r
- -. C Yankee Atomic Electric Company BYR 2014-012/February 25, 2014/Page 2 NUREG 2150, "A Proposed Risk Management Regulatory Framework" (April 2013), encouraged the adoption of such a framework for regulatory activities associated with spent fuel dry cask storage and acknowledged the need to expedite rule changes and regulatory guidance updates for such storage based on risk considerations.
It provided several findings and recommendations along these lines and we urge the Commission to take immediate steps to implement a risk-informed framework for the ongoing long term SNF storage, security, and transportation related regulatory initiatives associated with stand-alone ISFSI sites.As stated in NUREG 2150, to a certain extent 10 CFR Part 72 requirements are already informed by risk insights, as for example, Section 72.48 allows for some changes to be made without NRC review and approval (NUREG 2150 page 4.7-4). However, the Commission has directed the staff (SRM-COMSECY-10-0007) to revisit the paradigm for SNF storage and transportation and evaluate the dry storage of SNF, that includes a key Licensing Program Improvement review area focused on regulating ISFSIs at stand-alone decommissioned reactor sites in expectation of continued use of dry storage for extended periods of time. Accordingly, this licensing program is currently being reevaluated by NRC staff to determine if enhancements are needed to provide"adequate regulatory oversight" of extended SNF storage. We urge that the Commission and staff adopt a risk informed approach for this effort. This is particularly important relative to the ISFSI security related rulemaking underway given that, "The staff is currently engaging with stakeholders and gathering further information to support the regulatory basis for an ISFSI security rulemaking" (NUREG 2150 page 4.7-2).Comments in Response to "Section III.D, "Program Area Specific Policy Considerations" (Question (26)): The NUREG 2150 report addresses the specific actions needed in the next several years to ensure that the risk management regulatory framework is implemented.
Section III D, "Program Area Specific Policy Considerations," Subsection (c), of the White Paper addresses the development and application of decision-making criteria (e.g., risk, performance, defense in depth) specific to the regulated activities associated with storage of spent fuel and other high level waste -including their associated security measures.
It states that in developing and applying these decision-making criteria for this program area, the following factors should be taken into consideration: " Passive design features should be emphasized." Monitoring and oversight should be used to verify performance of passive design features as applicable.
- The failure of one level of defense should not lead to failure of other levels of defense." Capability to implement worker and public protection actions should be provided.YAEC notes that continued reliance on qualitative decision-decision making in this program area should be limited in recognition of the low risks associated with interim spent fuel storage. We urge that the following also be taken into consideration in developing and applying risk informed decision-making criteria and implementing the risk management regulatory framework for this program area:
4 -4.~Yankee Atomic Electric Company BYR 2014-012/February 25, 2014/Page 3* That it be applied to stand-alone ISFSI site security regulations, including the current ISFSI security rulemaking.
Dry cask storage systems are robust passive systems that are designed to withstand the effects of design basis events and "worst case" events while maintaining the capability to provide adequate shielding and confinement of the radioactive contents and prevent nuclear criticality.
These systems require minimal maintenance or repair and as noted in NUREG 2150, "Both the NRC and Electric Power Research Institute have conducted PRAs of dry cask storage systems and concluded that the risk associated with them is very low" (NUREG 2150 page xxvi)." That it be applied in the current staff evaluations of the extended SNF storage and transportation regulatory paradigm directed by SRM-COMSECY-10-0007 and the associated staff's Licensing Program Improvement review area that is focused on regulating ISFSIs at stand-alone decommissioned reactor sites." That it be applied to the regulatory assessment of the retrieval of the canisters from the stand-alone ISFSI storage casks and the subsequent transportation to a storage/disposal facility by the US DOE. Numerous risk assessments have already been conducted on the safety of transportation of SNF in NRC certified transport casks that include findings and conclusions documenting the extremely low risk, such as NUREG 2125 "Spent Fuel Transportation Risk Assessment" (January 2014) and other SNF transportation related risk assessment documents.
YAEC appreciates this opportunity to comment on the subject White Paper.Re ly, Robert M. Mitchell ISFSI Manager cc: W. M. Dean, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager, YAEC