ML17138A119
| ML17138A119 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/12/2017 |
| From: | Mccullum R Nuclear Energy Institute |
| To: | Michael Layton Division of Spent Fuel Management |
| Chung D | |
| References | |
| Download: ML17138A119 (11) | |
Text
~I RODNEY MCCULLUM Senior Director, Used Fuel and Decommissioning Programs 1201 F Street, NW, Suite 1100 Washington, DC 20004 NUCLEAR ENERGY INST ITUTE P: 202 .739.8082 rxm@ nei.org nei.org May 12, 2017 Mr. Michael Layton Director, Division of Spent Fuel Management Office of Nuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Regulatory Issue Resolution Protocol Screening Form and Resolution Plan for Improving the Part 72 Regulatory Framework (RIRP-1-16-01)
Project Number: 689
Dear Mr. Layton :
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) is transmitting the updated version of the draft Regulatory Issue Resolution Protocol (RIRP) Resolution Plan for Improving the Efficiency of the Regulatory Framework for Dry Storage of Spent Nuclear Fuel (RIRP-I-16-01) and two documents supporting the next steps in the plan. This update reflects the results of a recent NRC public meeting held on March 24, 2017. Along with the revised Resolution Plan, the attachments to this letter also include the License and Cask CoC Format, Content, and Selection Criteria document that will be used to guide a pilot Standardized NU HOMS Coe 1004 amendment request and a letter from TN Americas, LLC documenting their commitment to preparing and submitting the pilot application.
We thank the NRC for hosting the March 24th meeting. It accomplished its goal of defining the path forward for establishing a consistent approach to determining what information, related to an approved ISFSI license or cask design Coe, should be included in an ISFSI license or cask Coe (including technical specifications).
This approach will apply sound engineering judgment of safety significance to determine which Coe requirements will be retained and which will be relocated to other documents. The March 24 meeting provided valuable clarification as to how risk insights and expert knowledge would be used in making these judgements.
As part of this approach, a significant guiding principle was confirmed in the meeting - that the pilot Coe amendment request will not include any changes to the DSS design or operational requirements and the cask FSAR is part of the licensing basis. Therefore, information proposed to be relocated to the cask FSAR from the Coe retains the requirement for CoC holder and general license compliance, but would be subject to the NUCLEAR . CLEAN AIR ENERGY
Mr. Michael Layton May 12, 2017 Page 2 change controls of 10 CFR 72.48 rather than the Coe amendment process.
This effort, going forward, is expected to result in a significantly more efficient used fuel dry storage regulatory framework - consistent with NRC's Project AIM initiative and complimentary to the industry's "Delivering the Nuclear Promise" initiative.
As we discussed, the approach described in the attached RIRP is founded upon the NRC's 1993 Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors and the Industry's Petition for Rulemaking (PRM) 72-7 submitted in October 2012 (which itself is based upon the successful power reactor Improved Technical Specification (ITS) effort of the late 1980s and early 1990s in accordance with the Commission's policy). It is our expectation that this approach will result in the development of a complimentary component of the regulatory framework that, when complete, will be incorporated by the NRC via endorsement of NEI guidance.
Unless we hear otherwise from NRC by June 2, 2017, TN Americas, LLC will proceed with the application plans, including interactions with NRC, as described in their attached letter. If you have any questions, please do not hesitate to contact me or Dr. Mark Richter of my staff (mar@nei.org; 202-739-8106).
Sincerely, Rodney Mccullum Attachments c: Mr. John McKirgan, NMSS/DSFM, NRC Mr. Travis Tate, NMSS/DSFM, NRC Mr. Donald Chung, NMSS/DSFM, NRC NRC Document Control Desk Mr. Don Shaw, AR'EVA TN Americas LLC
USED FUEL STORAGE AND TRANSPORTATION ISSUE RESOLUTION PLAN Issue Number: 1-16-01 Rev . 5.11 .2017
Title:
Improving the efficiency of the regulatory framework for dry storage of used nuclear fuel I. Summary of Resolution Plan Industry and NRC will interact in public meetings and through letters to achieve the following :
- 1. Beginning with the Nuclear Regulatory Commission's 1993 Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors and the format, content, and selection criteria proposed in PRM 72-7, Industry and NRC agree on the preliminary format, content, and selection criteria for determining what information belongs in a dry storage system (DSS) CoC , including Technical Specifications (TS) .
- 2. Implement one or more pilot CoC amendments using the preliminary Coe form at, content, and selection criteria .
- 3. Using lessons learned from the pilot CoC amendment(s) , finalize the CoC format, content, and selection criteria.
- 4. NEI develops guidance on use of the format, content, and selection criteria for CoCs and use of the selection criteria for specific licenses to be submitted to the NRC for endorsement.
- 5. NRC endorses the NEI guidance.
II. Proposed Actions and Due Dates ACTION RESPONSIBLE PARTY DUE DATE
- 1. Public meeting kick-off RIRP for issue NRG/Industry Completed resolution (August 8, 2016)
- 2. Public meeting to discuss the proposed NRG/Industry Completed selection criteria , the graded approach , and (October 28, 2016) identify a pilot for graded approach
- 3. Workshop for NRC and Industry to discuss NRG/Industry Completed preliminary license/Coe selection criteria that (November 21, 2016) will define this portion of the graded approach for dry cask storage
- 4. NEI letter to NRC showing a template of how Industry Completed NRC's safety/risk table (Chung presentation (January 12, 2017) slide 14) will be used with the format, content, and selection criteria (as described in PRM 72-
- 7) to guide the pilot CoC amendment.
- 5. NRC Response regarding public meeting to NRC Completed clarify format, content, and selection criteria in (March 3, 2017) advance of a pilot exercise to test them
- 6. Public meeting to clarify CoC format, content, NRC Completed selection criteria, and risk insights (March 24, 2017)
- 7. NEI letter to NRC updating RIRP plan and pilot Industry Completed Coe amendment approach based on (May11 , 2017) discussions in 3/24 public meetina.
- 8. AREVA/NRG pre-application meeting to share Industry Week of June 12, the planned format/content of the application 2017 submittal, with a walk-though of a few examples to demonstrate format/content
- 9. AREVA submittal of a pilot CoC amendment Industry June 30, 2017 aoolication to NRC imolementina the Enclosure 2
preliminary format, content, and selection criteria proposed in PRM
- 10. Completion of a safety review of pilot CoC NRC 9 months after NRC amendment aoolication. submittal 11 . Hold public meeting to discuss lessons learned NRG/Industry May, 2018 from the pilot
- 12. Completion of rulemaking to make CoC NRC August, 2018 amendment effective
- 13. Modification of CoC format, content, and/or NEI August, 2018 selection criteria as required , and submit to NRC
- 14. Development and submittal of guidance Industry October, 2018 document based on final selection criteria and/or CoC format and content
- 15. Reviewed guidance, revised as needed , and NRG/Industry March , 2019 made decision on endorsement of NEI quidance
- 16. Endorsed guidance NRC Seotember, 2019 Enclosure 2
A AREVA April 13, 2017 E-48273 Nuclear Energy Institute Attn : Rodney McCullum Senior Director, Used Fuel and Decommission ing Programs 1201 F Street, NW, Suite 1100 Washington , DC 20004
Subject:
TN Americas LLC Anticipated Interactions with the U. S. Nuclear Regulatory Commission Regarding CoC 1004 Amendment 16 to Pilot RIRP-1-1 6-01 , Efficiency of the Regulatory Framework for Dry Storage of Spent Nuclear Fuel
References:
March 24, 2017 U. S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Public Meeting with the Nuclear Energy Institute to Discuss Topics Associated with Graded-Approach for Dry Cask Storage (ML17054C689)
As discussed in the public meeting referenced above, TN Americas LLC (TN) provides below our anticipated interactions with the U. S. Nuclear Regulatory Commission (NRC) regarding CoC 1004 Amendment 16 (Amendment 16) to pilot RIRP-1-16-01 , Efficiency of the Regulatory Framework for Dry Storage of Spent Nuclear Fuel (i.e., the graded approach pilot) , to inform NEl's forthcoming letter to NRC regarding this RIRP.
Based on the nature of the amendment, and the size and complexity of the associated technical specifications (TS) Microsoft Word file, TN feels that the initial application will best serve both NRC and th.e industry if the Amendment 15 proposed CoC conditions and TS are included for reference and the split-table represent the details and justifications for the proposed Amendment 16 changes.
As the request for additional information (RA!) phase takes place and the agreements between the NRC and the industry become known, the revised CoC and TS documents can be created and provided to NRC at that time .
Based on our planned June 30, 2017 initial application submittal for Amendment 16, and the RIRP schedule for Rulemaking to begin in January 2018, the following interactions are anticipated.
2017 June Pre-application meeting with the main purpose to share the planned format and content of the application submittal, with a walk-though of a small number of examples to demonstrate that format and content 2017 Oct (potential) Post-RAl-issuance meeting or teleconference call to discuss any RAI items which need clarification 2017 Nov Pre-RAI response meeting or teleconference call to share anticipated changes and intended CoC/TS/UFSAR content TN AMERICAS LLC 7135 Minstrel Way. Suite 300. Columbia . Maryland 2 1045 Tel. : 410 910 6900 - Fax : 410 910 6902 - www.us.areva.com/TNAmerlcas
April 13, 2017 E-48273 Page 2 of 2 Based on the cost savings and other benefits Amendment 16 will provide to NRC and to the industry by the industry implementing these simplified technical specifications, due to reduction in the NRC reviewers' time in reviewing technical specification changes , TN requests that NEI include in your forthcoming letter to NRC a request that NRC review fees be waived for this particular licensing action as TN is already investing a significant amount of resources in the preparation of this amendment.
Should you require additional information, please do not hesitate to call me at 410-910-6878.
Sincerely, Don Shaw Licensing Manager cc: Mark Richter (NEI)
Brian Gutherman (Gutherman Technical Services, LLC)
ISFSI LICENSE AND CASK Coe FORMAT, CONTENT, AND SELECTION CRITERIA
Background
Guidance for the content of a specific ISFSJ license and a dry storage system (DSS) cask CoC must begin with, and not come into conflict with the applicable regulations. The 10 CFR 72 regulations contain requirements for the content of the technical specifications (TS) of a specific ISFSI license in I 0 CFR 72.44(c). The regulations also include requirements for specific information to be included in a DSS CoC in 10 CFR 72.236(a), but include no format and content requirements similar to those for a specific license. When issued, both specific ISFSI licenses and DSS CoCs include conditions in the body of the license/Coe and other information, including the TS, is included in one or more appendices to the license/Coe. Both the conditions of the license/Coe and any appendices are subject to the same requirement to seek NRC approval of any changes to the information contained therein . For this RIRP, the focus will start with the DSS CoC.
The 10 CFR 72.44(c) format and content criteria for specific ISFSI licenses do not apply to DSS CoC/TS, and there are no analogous criteria in the regulations for DSS CoCs. The format and content of CoCs have been determined via the NRC's review process and have evolved over the years. I 0 CFR 72.236(a) states:
"Specifications must be provided for the spent fuel to be stored in the spent fuel storage cask, such as, but not limited to, type of spentfuel (i.e., BWR, PWR, both), maximum allowable enrichment of the fuel prior to any irradiation, burn-up (i.e., megawatt-days/MTU), minimum acceptable cooling time of the spent fuel prior to storage in the spent fuel storage cask, maximum heat designed to be dissipated, maximum spent fuel loading limit, condition of the spent fuel (i.e.,
intact assembly or consolidated fuel rods), the inerting atmosphere requirements."
Given the lack of additional regulatory requirements for DSS CoC/TS content, the CoCs have become voluminous and difficult to implement, with compliance requirements for the CoC holder and the general licensee mixed together. Industry Petition for Rulemaking (PRM) 72-7 addressed the both the CoC format and content problem and the lack of selection criteria.
Industry proposes that the format, content, and selection criteria proposed in PRM 72-7, with certain modifications, be used in a pilot CoC amendment to make the contents of a DSS CoC more safety- and risk-focused and the level of detail more appropriate. In the pilot CoC amendment for the RIRP, the existing CoC condition, TS, administrative controls, authorized contents, and design features will be evaluated against the following guidance and selection criteria to determine if it is retained in whole or in part, deleted entirely, or relocated to another licensing basis document (e.g., the cask FSAR) as necessary:
CoC Body - Certified Design: Certified Design is implemented by the Certificate Holder and includes:
Section I, Technology. A concise description of the dry storage system for the purpose of identifying whether future modifications would be considered a significant deviation to the type of technology or included components, or fundamental manner in which the cask system operates, such that modification to these could not be performed through an amendment under 72.244.
Section II, Design Features. The design features that would have a significant effect on safety if altered or modified, such as materials of construction and geometric arrangement, would require an amendment under 72.244 in order to modify.
CoC Appendix A - Inspections, Tests, and Evaluations: Inspections, Tests, and Evaluations
(!TE), and acceptance criteria, that are necessary and sufficient to provide reasonable assurance that, if the ITE are performed and the acceptance criteria met, a cask has been manufactured and will operate in conformance with the certified design, and that the safety functions of confinement, sub-criticality and shielding will be performed. The entity responsible for implementing the !TE (i.e. , Certificate Holder or Licensee) will be identified.
Documentation that the ITE and acceptance criteria are satisfied is not submitted for NRC review or approval , but shall be documented (i.e., in the general licensee's I 0 CFR 72.212 Evaluation report) and made available for NRC inspection. In addition to inspections and tests, this section is where key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation (e.g., ambient temperature, seismic, wind, etc.), would be relocated, if retained. This information is currently generally included in the Design Features section of the CoC in a subsection entitled " Site-Specific Parameters and Analyses." A determination of which design criteria and required analyses to retain in the CoC would be based on safety significance, risk insights, and expert knowledge.
CoC Appendix B - Technical Specifications: Technical Specifications are implemented by the licensee and will include the following:
Section 1, Definitions, Use and Application. This section includes key definitions and the administrative rules for implementing the logic of the Limiting Conditions for Operation (LCOs) and Surveillance Requirements in the Technical Specifications. We anticipate this will be a verbatim transfer of information currently in Section 1 of the CoCs.
Section 2, Approved Contents. Approved contents are the minimum set of parameters defining the contents approved for storage in the certified design that would have a significant effect on safety if altered or modified. Information in the Approved Contents section of the technical specifications must meet one or more of the following criteria:
Criterion Al. The characteristic or parameter is identified in I 0 CFR 72.236(a);
Criterion A2. A characteristic or parameter for which verification is a necessary condition to provide reasonable assurance that the cask safety functions of confinement, sub-criticality, and shielding will be performed; Criterion A3. A characteristic or parameter that has a significant impact on public health and safety, based on risk insights and expert knowledge.
Section 3, Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs): Limiting conditions are the lowest functional capability or performance levels of equipment required for safe operation of the ISFSl facility and cask. Functional and operating limits for a cask are limits on fuel handling and storage conditions that are found to be necessary to protect the integrity of the stored fuel, to protect employees against occupational exposures and to guard against the uncontrolled release of radioactive materials.
Monitoring instruments and limiting control settings for casks are those related to fuel handling and storage conditions having significant safety functions.
Section 3.0 will include overarching requirements for the LCOs and SRs of the type currently included in Section 3.0 the CoC. Subsequent subsections will include LCOs for operation of the ISFSI facility or cask with appropriate SRs to ensure operability must be established for each item meeting one or more of the following criteria:
Criterion Ll. Installed instrumentation that is used to detect, and indicate a significant abnormal degradation of the cask confinement boundary; Criterion L2. An initial condition of a design basis accident that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; Criterion L3. A structure, system, or component that has a significant impact on public health and safety, based on risk insights and expert knowledge.
Section 4, Administrative Controls. Administrative controls include the organization and management of procedures, recordkeeping, review and audit, and reporting requirements necessary to assure that the operations involved in the storage of spent fuel and reactor-related GTCC waste in an ISFSI are performed in a safe manner. Programs descriptions included in this section are expected be at a high level and include only the essential elements of the programs required to assure safe cask or ISFSI operation, with additional supporting information relocated to the FSAR, as necessary. Implementation details would be included in general licensee procedures.
Each existing individual CoC requirement receives a written evaluation against the CoC format and content guidance and selection criteria previously described using rick insights and expert knowledge. The results of that evaluation are recorded in a "split document" comprised of the table below. This tab le records the decision-making process and justification for retaining a CoC requirement in the CoC or relocating it. Retained requirements may be moved to a different section of the CoC and/or partially retained. Removed or relocated requirements will defer to the regulations directly, be moved to the cask FSAR or other document, or deleted entirely, with appropriate justification. The basis for the determination on each CoC requirement is documented in the "Evaluation Summary" column.
CASK CoC FORMAT, CONTENT, AND SECTION CRITERIA EVALUATION CoC Body Appendix B, Technical Specifications Certified Desi2n Appendix A Coe Section 3, Limiting Conditions for Inspections, Requirement Section II. Section 1 Section 2, Approved Contents Operation (LCOs)* and Surveillance Section 4,Section I. Tests, and (Examp les) Design Definitions, Use (Selection Criteria) Requirements (SRs) Admin istrative Technology Evaluations Features ~nd Application <Selection C riteria) Controls Al A2 A3 Lt L2 L3 CoC Condition No.
x CoC Condition No.
y LCO No.
Administrative Control No.
Approved Contents No.
Desi1m Feature No.
CASK Coe FORMAT, CONTENT, AND SECTION CRITERIA EVALUATION (CONTINUED)
Rick lnsi2ht**: Will retainin2 or removine: this requirement from the CoC result in ...
Coe ... a significant increase in the . .. the possibility of a new or different ... a significant reduction in the Evaluation Summary Requirement probability or consequences of kind of accident being created margin of safety for ISFSI or cask (Examples) an accident previously compared to those previously operation evaluated in the cask FSAR? evaluated in the FSAR?
CoC Condition No.
x CoC Condition No.
y LCO No.
Adm in istra tive Control No.
Approved Contents No.
Desie:n Feature No.
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s) , and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- Jn performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question " what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction"?