ML18113A240
| ML18113A240 | |
| Person / Time | |
|---|---|
| Issue date: | 04/23/2018 |
| From: | Thomas Taylor Spent Fuel Licensing Branch |
| To: | |
| Taylor T | |
| References | |
| OIG-17-A-21 | |
| Download: ML18113A240 (20) | |
Text
Certificate of Compliance Expiration Term Torre Taylor Sr. Project Manager Division of Spent Fuel Management
Outline of Presentation
- OIG report and recommendation
- Staff response
- Process for development of expiration term
- General Discussion
- Next steps/schedule
- Contacts
- Questions 2
OIG Audit
- OIG report
- Audit of NRCs Oversight for Issuing Certificates of Compliance for Radioactive Material Packages (OIG-17-A-21), dated August 16, 2017
- Objective of audit
- Determine if NRCs processes for issuing certificates of compliance and reviewing 10 CFR Part 72.48 changes provide adequate protection for public health, safety, and the environment 3
OIG Recommendations
- 1. Conduct an analysis to develop the regulatory and technical bases for the part 71 certificates of compliance term
- 2. Document and communicate to stakeholders NRCs analysis results identifying the bases for an appropriate term for Part 71 certificates of compliance
- 3. Establish sufficient internal controls by updating NRC guidance related to Part 72.48 review procedures
- 4. Establish sufficient internal controls by developing and implementing training for part 72.48 review process 4
OIG Recommendation 1
- Recommendation 1
- Conduct an analysis to develop the regulatory and technical bases for the Part 71 Certificates of Compliance expiration term
- Purpose of this meeting is to discuss Recommendation 1 5
Staff Response
- The staff, in consultation with the U.S.
Department of Transportation, will conduct a technical and regulatory analysis to develop a basis for the duration of NRC-issued certificates of compliance for radioactive material packages
- Staff will consider risk insights from existing studies performed on transportation risk of spent fuel and solicit stakeholder input, including input from international counterparts 6
Staff Response (continued)
- Will develop technical and regulatory bases to establish an appropriate term for certificates of compliance for transportation packages
- Document the results
- Communicate results to stakeholders
- Post on the NRC public web site
- Communicate to stakeholders, such as the DSFM regulatory conference (REG CON) 7
Staff Response (continued)
- Existing Studies and Risk Estimates
- NUREG-0170, Final Environmental Statement on the Transportation of Radioactive Material by Air and Other Modes, September 1977
- Vol. 1: ML022590265
- Vol. 2: ML022590511 8
Staff Response (continued)
- Fischer, L.E., et al., Shipping Container Response to Severe Highway and Railway Accident Conditions, NUREG/CR-4829 (UCID-20733), Lawrence Livermore National Laboratory, Livermore, CA, February 1987 9
Staff Response (continued)
- NUREG/CR-6672, Reexamination of Spent Fuel Shipment Risk Estimates - Main Report, March 2000
- NUREG-2125, Spent Fuel Transportation Risk Assessment, January 2014 10
Process for Development of Appropriate Expiration Term
- Consulted with DOT
- Consult with stakeholders
- This public meeting
- Use information from risk studies to inform staff recommendations
- Develop a technical and regulatory bases for an appropriate expiration term 11
General Discussion
- What factors should NRC consider as it evaluates a regulatory and technical bases for expiration term?
- Stability of regulatory environment
- Institutional Stability
- Technological Stability
- Other?
12
General Discussion
- How should we factor in risk?
- How does human factors/error relate to the expiration term?
- Are there other risk contributors that correlate to the expiration term?
13
General Discussion
- What are the impacts if there were a change in the certificate expiration term?
- Domestic
- International
- Impact on international transportation
- IAEA requirements 14
Items for Discussion General Discussion
- What are the implementation challenges if the NRC were to change the expiration term?
- Costs
- Revisions to internal processes 15
Next Steps/Schedule
- Evaluate comments from this meeting and internal evaluations
- We welcome comments related to this public meeting
- Please provide comments no later than May 25, 2018 16
Next Steps/Schedule (continued)
- Develop a regulatory and technical bases for the expiration term for certificates of compliance
- Based on discussions in this meeting
- Our interactions with DOT
- Review of existing studies and risk estimates
- Response due to OIG September 2018 17
Contacts Project Manager for the OIG Audit Recommendations Torre Taylor, Sr. Project Manager Phone: 301-415-7900 Email: Torre.taylor@nrc.gov Senior Project Manager for Technical Questions Bernie White, Sr. Project Manager Phone: 301-415-6577 Email: Bernard.white@nrc.gov 18
Questions 19
- DOT - Department of Transportation
- DSFM - Division of Spent Fuel Management
- IAEA - International Atomic Energy Agency
- NRC - Nuclear Regulatory Commission
- OIG - Office of the Inspector General 20