ML18221A475
| ML18221A475 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/2018 |
| From: | Charles Brown Advisory Committee on Reactor Safeguards |
| To: | |
| Brown C | |
| References | |
| NRC-3625 | |
| Download: ML18221A475 (195) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
ACRS Subcommittee on Radiation Protection and Nuclear Materials Docket Number: N/A Location: Rockville, Maryland Date: April 4, 2018 Work Order No.: NRC-3625 Pages 1-195 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 SUBCOMMITTEE ON RADIATION PROTECTION AND 8 NUCLEAR MATERIALS 9 + + + + +
10 WEDNESDAY 11 APRIL 4, 2018 12 + + + + +
13 ROCKVILLE, MARYLAND 14 + + + + +
15 The Subcommittee met at the Nuclear 16 Regulatory Commission, Two White Flint North, Room 17 T2B1, 11545 Rockville Pike, at 8:30 a.m., Matthew 18 Sunseri, Chairman, presiding.
19 COMMITTEE MEMBERS:
20 MATTHEW SUNSERI, Chairman 21 RONALD G. BALLINGER, Member 22 MARGARET SZE-TAI Y. CHU, Member 23 MICHAEL L. CORRADINI, Member 24 WALTER L. KIRCHNER, Member 25 JOSE MARCH-LEUBA, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 DANA A. POWERS, Member 2 HAROLD B. RAY, Member 3 JOY L. REMPE, Member 4 PETER RICCARDELLA, Member 5 JOHN W. STETKAR, Member 6
7 DESIGNATED FEDERAL OFFICIAL:
10 ALSO PRESENT:
11 JOSEPH ANDERSON, NSIR 12 JOE BOROWSKY, NMSS 13 MICHAEL CALL, NMSS 14 DONALD CHUNG, NMSS 15 SANABRIA YOIRA DIAZ, DSFM 16 STEVE EVERARD, NMSS 17 DONNA GILMORE*
18 HIPOLITO GONZALEZ, NMSS 19 BENJAMIN HOLTZMAN, NEI 20 TONY HSIA, NMSS 21 MICHAEL LAYTON, NMSS 22 BRET LESLIE, U.S. Nuclear Waste Technical 23 Review Board 24 MARVIN LEWIS*
25 ROD McCULLUM, NEI NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 JOHN MCKIRGAN, NMSS 2 MICHAEL NORRIS, NSIR 3 MERAJ RAHIMI, NMSS 4 JEREMY SMITH, NMSS 5 JORGE SOLIS, NMSS 6 TRAVIS TATE, NMSS 7 RICARDO TORRES, NMSS 8 BERNARD WHITE, NMSS 9 JOHN WISE, NMSS 10 JON WOODFIELD, NMSS 11 12 *Present via telephone 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 T-A-B-L-E O-F C-O-N-T-E-N-T-S 2 PAGE 3 Opening Remarks and Objectives 4 by Matthew Sunseri, ACRS 5 5 Staff Opening Remarks 6 by Michael Layton, NMSS/DSFM 8 7 Background and Overview of Comments 8 by Jeremy Smith, NMSS/DSFM 9 9 Panel Technical Presentation 10 by NMSS/DSFM SRP Team 56 11 Industry Presentation 12 by Rod McCullum, Senior Director 117 13 Public Comments 146 14 Committee Discussion 150 15 Adjourn 167 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 P R O C E E D I N G S 2 8:30 a.m.
3 CHAIR SUNSERI: Good morning. This 4 meeting will now come to order. This is a meeting of 5 the Radiation Protection and Nuclear Materials 6 Subcommittee, the Advisory Committee on Reactor 7 Safeguards.
8 I am Matt Sunseri, Chairman for this 9 Subcommittee. ACRS members in attendance are Ron 10 Ballinger, Margaret Chu, Harold Ray, Dana Powers, Peter 11 Riccardella, John Stetkar, Jose March-Leuba, Walt 12 Kirchner, and Joy Rempe.
13 Christopher Brown is the Designated 14 Federal Official for this meeting. The purpose of 15 today's meeting is for the subcommittee to receive an 16 informational briefing from the Division of Spent Fuel 17 Management regarding draft NUREG-2215, Standard Review 18 Plan for Spent Fuel Dry Storage Systems and Facilities.
19 Additionally, NEI will provide perspective and 20 comments from the industry on the draft NUREG.
21 The ACRS was established by statute and 22 is governed by the Federal Advisory Committee Act.
23 That means that the committee can only speak through 24 its published letter reports. We hold meetings to 25 gather information to support our deliberations. As NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 this is a subcommittee meeting and not a full committee 2 meeting, any comments that are made today are from 3 individual committee members and not representative 4 of ACRS' position.
5 The ACRS section of U.S. NRC public website 6 provides our charter, bylaws, letter reports, and full 7 transcripts of all full and subcommittee meetings, 8 including the slides presented at the meeting.
9 The rules for participation in today's 10 meeting were announced in the Federal Register on 11 Tuesday, April 3rd, 2018. The meeting was announced 12 as an open-to-public meeting. We have received no 13 requests for making a statement to the subcommittee 14 from the public.
15 A transcript of the meeting is being kept 16 and will be made available as stated in the Federal 17 Register notice. Therefore, I would request that 18 participants in this meeting use the microphones 19 located throughout the meeting room when addressing 20 the subcommittee.
21 Participants should first identify 22 themselves and speak with sufficient clarity and volume 23 so that they can be readily heard. We have a bridge 24 line established for interested members of the public 25 to listen in.
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7 1 To minimize disturbance, the public line 2 will be kept in a listen-in-only mode. The public will 3 have an opportunity to make a statement or provide 4 comments at the designated time towards the end of the 5 meeting. I would now request that meeting attendees 6 and participants silence their cell phones and other 7 electronic devices.
8 The ACRS has routinely provided the 9 opportunity to review guidance documents such as the 10 proposed or revised NUREGs. These documents are often 11 assigned to individual members to make a recommendation 12 on the scope of review to be performed by the full 13 committee. And this review could range from no review 14 to a formal document review.
15 In this particular case and due to the high 16 level of stakeholder interest, we have decided to have 17 a subcommittee determine whether the full committee 18 will get involved with the draft of this NUREG.
19 I realize there is much more interest in 20 spent fuel than just the consolidation of two standard 21 review plans and associated interim staff guidance into 22 one NUREG. However, today's focus will only be on the 23 consolidation aspects of draft NUREG-2215 and any 24 matters safety related to the consolidation.
25 At this time, I now invite Michael Layton, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 Director of the Division of Spent Fuel Management, to 2 introduce the presenters and start the briefing.
3 MR. LAYTON: Thank you, Matt. Good 4 morning, everyone. I'm Michael Layton. And as Matt 5 said, I'm the Director for the Division of Spent Fuel 6 Management at NMSS. And we appreciate the opportunity 7 to meet with the subcommittee to talk about our efforts 8 on consolidating the spent fuel storage guidance in 9 NUREG-2215.
10 I'd also like to point out that this was 11 a commitment that staff made to the Commission under 12 Project Aim as an effort to increase efficiency in our 13 licensing review programs. And since the issuance of 14 the draft NUREG, the staff has actively engaged and 15 received feedback and comments from stakeholders and 16 interested parties.
17 And as Matt said, we focused our efforts 18 on consolidating existing guidance rather than 19 including new guidance from ongoing efforts.
20 Principally, many of the efforts that we have in process 21 now are still moving toward completion. And once we 22 have finalized those efforts, those will be put out 23 for public comment and eventually rolled into inclusion 24 into this guidance.
25 The presentations that you'll receive this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 morning will focus on the more significant areas of 2 the consolidation effort, but we're happy to address 3 any questions that any members may have on any others 4 areas of the document.
5 And with that, I'll turn the presentation 6 over to Jeremy Smith to being the staff's efforts.
7 Thank you.
8 MR. SMITH: Thank you, Mike. My name is 9 Jeremy Smith. I am Senior Criticality Safety Reviewer 10 in the Division of Spent Fuel Management, and I am the 11 team leader for the consolidation effort for both the 12 storage and the transportation NUREGs.
13 I'm going to give a quick outline here.
14 We're going to discuss the background on why we decided 15 to consolidate the SRPs, the expectations from the 16 update and consolidation that we expect, the approach 17 that we used for the consolidated SRP, the public 18 comments that we received on the draft SRP, and then 19 we will have technical staff discussions on 20 enhancements and changes to the SRP.
21 We recognize that there was a need to update 22 both the storage and transportation standard review 23 plans or SRPs that used throughout this presentation.
24 Storage SRPs were issued in 2000 and 2010 and they 25 were NUREG-1536 and NUREG-1567.
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10 1 CHAIR SUNSERI: Jeremy -- good ahead.
2 MR. SMITH: No, you go ahead.
3 MEMBER REMPE: Well, okay. I thought you 4 were going to go through this in a little more detail.
5 MR. SMITH: I am. I'm going --
6 MEMBER REMPE: Okay. If you are, I'll 7 wait till you finish. That's fine. But I do have some 8 questions on this slide.
9 MR. SMITH: Okay. No problem.
10 CHAIR SUNSERI: Let me --
11 MR. SMITH: I had a last-minute slide 12 added, but unfortunately, it's not in this 13 presentation. But I can speak from it. And so 14 NUREG-1536 --
15 CHAIR SUNSERI: Well, can I add something 16 here?
17 MR. SMITH: Sure.
18 CHAIR SUNSERI: And maybe you're going to 19 do this and I may be getting ahead of you. But the 20 two REG guides, so you have a standard review plan for 21 dry storage systems generalized and the other one is 22 for spent fuel dry storage facilities which is a 23 specific license. Are you going to kind of explain 24 how those are applied and what the differences between 25 the two are?
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11 1 MR. SMITH: Yes.
2 CHAIR SUNSERI: Okay. Thank you.
3 MR. SMITH: That was what I was going to 4 go into. And you should have the slide that's not being 5 currently presented up on the screen here. It says, 6 site specific versus general license. It's the next 7 slide.
8 A site specific license, which is what 9 NUREG-1567 covers, this is available to Part 50 reactor 10 licensees and all other applicants. This was how we 11 originally did Part 72 license applications back when 12 we first started back in the 1980s.
13 It is required for away-from-reactor 14 sites. One of the main issues on this is this gets 15 to have an opportunity for a hearing. This is covered 16 under 10 CFR Part 72 Subparts A through J which leads 17 me into the general license which is what 1536 covered.
18 This general license is only granted to 19 either Part 50 or 52 licenses and it requires the use 20 of a certified cask design. A certificate application 21 is submitted to the NRC by a cask vendor and it requires 22 site evaluation for compatibility with cask assignment 23 such as a decommissioning plan or physical security 24 of the plant site.
25 The general license is covered under 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 CFR 72 Subparts A through L and it came into being around 2 1990 and essentially allowed the NRC to evaluate cask 3 designs in lieu of doing a full site review. These 4 are all codified in 72.212 -- 236. And so every cask 5 design that is approved is codified under Part 214.
6 Thank you. Too many numbers in my head.
7 That's essentially what the difference is.
8 The reason we thought that these would be good 9 candidates for consolidation is from a technical 10 perspective. We are reviewing essentially the exact 11 same things. So we are looking at the cask design.
12 We're looking at how it is loaded, how it is stored, 13 what materials. We look at the criticality, the 14 shielding. All of those items are common throughout 15 both of these SRPs.
16 And the thought was it would be worthwhile 17 to combine all of this along with the new interim staff 18 guidance that we've developed to make one consolidated 19 SRP so that you can find all the information in one 20 location.
21 MEMBER REMPE: Okay. So now, I'll ask my 22 question.
23 MR. SMITH: Sure. Go right ahead.
24 MEMBER REMPE: When I was looking through 25 the draft report, I expected up front somewhere to see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 these are all the types of fuels that are considered, 2 these are all the types of cladding that were 3 considered. And I did find it in later sections. You 4 talked about Zircaloy-based ones. You had stainless 5 steel.
6 I don't know if accident tolerant fuels 7 were considered. I saw you had MOX. Do you have gas 8 reactor fuel -- I mean, like for the Fort St. Vrain 9 fuel? What all is covered by this and not covered if 10 I were going to apply this document?
11 MR. SMITH: This covers all nuclear spent 12 fuel.
13 MEMBER REMPE: Okay.
14 MR. SMITH: And so regardless of design 15 or configuration.
16 MEMBER REMPE: Okay. So does it say that 17 clearly somewhere in there in the beginning?
18 MR. SMITH: I hope so. I think it might 19 be mentioned in the abstract possibly. Maybe in the 20 introduction?
21 MEMBER REMPE: I think it should. And 22 again, I didn't see it in the abstract. But again, 23 it's 600 pages, so I could've --
24 MR. SMITH: It's --
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14 1 I just that that's something that would be nice to know 2 because --
3 MR. SMITH: Okay.
4 MEMBER REMPE: -- again, some places in 5 some chapters -- and I'll bring it up later today --
6 it only talks about Zircaloy and things like that.
7 Again, have you really thought about accident tolerant 8 fuel and some of the special considerations that you 9 may need for that?
10 MR. SMITH: Right. The SRP is intended 11 to tell a reviewer -- give them guidance on how to 12 interpret the regulations that are in 10 CFR Part 72.
13 What the SRP does is it kind of provides lessons learned 14 in staff experience in that description. And so most 15 of our experience is in the Zircaloy fuel range which 16 was probably why it stuck out. But the intent of the 17 SRP is not to limit any type of fuel design that gets 18 submitted to the NRC. Anyone can submit any kind of 19 fuel design and we will evaluate, using the SRP as kind 20 of overall guidance but looking at the special 21 parameters of any given type of fuel.
22 MEMBER REMPE: That kind of discussion 23 might be nice to have up front.
24 MR. SMITH: Okay.
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15 1 questions on site specific versus general license?
2 MR. SMITH: I'm kind of speaking to it from 3 my perspective as a reviewer, but we have licensed folks 4 in the room with me that can help spell out exactly 5 what the differences are --
6 CHAIR SUNSERI: Right, right.
7 MR. SMITH: -- so there's no confusion.
8 CHAIR SUNSERI: So I think I get it. Now, 9 let me just ask one follow-up question. So if I were 10 thinking about an interim storage facility such as 11 something out in western Texas, would I be applying 12 for a site specific license in accordance?
13 MR. SMITH: That is the way it goes --
14 CHAIR SUNSERI: Okay, great.
15 MR. SMITH: -- because it's an 16 away-from-reactor site.
17 CHAIR SUNSERI: Thank you.
18 MEMBER MARCH-LEUBA: And if I read -- I'm 19 reading Chapter 3 of Section 342. And it says that 20 you must specify the type of fuel that you are going 21 to put in this facility.
22 MR. SMITH: That is correct.
23 MEMBER MARCH-LEUBA: So this facility will 24 get a license only for a ten by ten and nothing else 25 can go there?
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16 1 MR. SMITH: The way the licenses typically 2 work is that an applicant will come in and say, we want 3 to store this type of fuel. And then over time, they 4 say, oh, guess what? We think we can fill other types 5 of fuel in these canisters. And they will come to us 6 for an amendment that will specifically add that type 7 of fuel to that canister.
8 MEMBER MARCH-LEUBA: Because I think that 9 this grandfather thing when this happened in my own 10 plant where I only had one type of fuel.
11 MR. SMITH: Right.
12 MEMBER MARCH-LEUBA: Whereas if you have 13 a central facility somewhere in Texas, you're going 14 to have all types of fuel.
15 MR. SMITH: And it's my understanding that 16 there's going to be -- the application should contain 17 every type of fuel that is going to be stored at any 18 kind of interim site.
19 MEMBER MARCH-LEUBA: And you're expecting 20 to get a license amendment every time?
21 MR. SMITH: I'm personally not working on 22 the interim storage site. Was there anyone that could 23 speak to that?
24 MR. TATE: Well, the guidance -- I'm sorry.
25 This is Travis Tate. I'm chief of the Criticality, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 Shielding, and Risk Assessment Branch.
2 The guidance would cover all approved fuel 3 designs, so --
4 MEMBER MARCH-LEUBA: The guidance is 5 applicable to all fuel designs.
6 MR. TATE: Right.
7 MEMBER MARCH-LEUBA: But your license will 8 be only for the ones you ask for.
9 MR. TATE: Right.
10 MR. SMITH: That is correct.
11 MR. TATE: That's correct.
12 MEMBER MARCH-LEUBA: So if you --
13 MR. SMITH: So they may have ten different 14 fuel designs that they want to store at the get-go.
15 And those would be approved through the process.
16 MEMBER STETKAR: But the point is when 17 somebody comes in with a No. 11, you're going to have 18 to apply for a license amendment?
19 MR. SMITH: That is correct.
20 MEMBER REMPE: And so the intent was to 21 combine existing material, not new material that has 22 not been reviewed before in this process. And I was 23 looking at some of the exchanges. I guess NEI wrote 24 a letter saying that there was some lack of clarity 25 in the combination and some confusion. And you'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 discuss how you're going to or have addressed their 2 comments?
3 MR. SMITH: I will.
4 MEMBER REMPE: Okay.
5 MR. SMITH: That's a little bit later in 6 my presentation.
7 MEMBER MARCH-LEUBA: And then the 8 licensees will handle this, but there are flavors of 9 a particular type of fuel. And you change the spacer 10 and suddenly you have a different name. Do I need a 11 license amendment if I change a spacer?
12 MR. SMITH: If it considered a different 13 type of fuel, you do.
14 MEMBER MARCH-LEUBA: What is considered 15 a different type of fuel? If it has a different name?
16 MR. CALL: So this is Mike Call. It 17 depends on how those fuel specifications are put 18 together in the licensed application or in the 19 certificate application even. The various, for 20 example, vendors for the casks will put it out where 21 they don't put a very detailed or very specific type 22 of fuel but they'll have it set up where they have fuel, 23 simply types or classes, that are intended to envelope 24 a variety of parameters.
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19 1 of situation where you're talking about where a spacer 2 might've been slightly changed but it doesn't affect, 3 for example, what they've evaluated it for because they 4 come up with separate classes of fuel types which if 5 what somebody wants to store is within that class of 6 fuel type of the parameters that are specified, then 7 it's good to go in that --
8 (Simultaneous speaking.)
9 MEMBER MARCH-LEUBA: So that's the way it 10 really is then. So the SRP Section 342 doesn't say 11 that. So that makes sense and that's what I would 12 suspect.
13 CHAIR SUNSERI: Just one more comment 14 about the consolidation. So you're bringing in the 15 interim staff guidance into the revision. It's my 16 understanding that some of those ISGs may be undergoing 17 revision themselves. So how are you dealing with --
18 I mean, is there really any new technical information 19 coming through revised ISGs?
20 MR. SMITH: There's no new technical 21 information. The ISGs are put in as they currently 22 exist. It's kind of the SRP is supposed to intended 23 to kind of represent a state of the current practice 24 of reviewers. So if the ISG in there -- currently being 25 used, it got incorporated into the SRP.
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20 1 I don't know if there's any draft ISGs that 2 are currently being developed. I don't think there 3 is currently.
4 CHAIR SUNSERI: Thank you.
5 MR. SMITH: So going back to the 6 background, 10 CFR Part 72 was revised in 2001, 2003, 7 and 2011 while these SRPs have been active. In 8 addition, interim staff guidance documents were issued 9 to assist in implementing changes to Part 72 as well 10 as emerging issues.
11 And one of the main reasons of doing this 12 whole thing is to improve the format for the SRP, having 13 two different SRPs, having to update both of them 14 because information changed, it affected both of them, 15 was inefficient. What we did was we kind of copied 16 the NRC's NRR NUREG-0800 for light water reactors format 17 so that we could update these in a more timely and 18 efficient on a chapter and section basis.
19 So the expectations we hope to get from 20 this effort is, first and foremost, to maintain the 21 safety and security of use of radioactive materials.
22 We want to be able to increase the efficiency of 23 reviews. We want to minimize or even eliminate the 24 use of ISGs in the future. We want to be able to improve 25 the efficiency of future revisions, and we want this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 to be a one-stop shop basically for all storage review 2 guidance. And we see this as a win-win for both the 3 industry as well as the NRC.
4 First of all, the reviewers will have all 5 the information they need to conduct a review in one 6 location. Likewise, the industry will have all the 7 information that we would typically be looking at 8 available to them in one location without having to 9 go to all these various documents to find it.
10 MEMBER STETKAR: I have to admit. I 11 haven't been following the evolution of the interim 12 staff guidance and the bits and pieces that you're 13 trying to consolidate. And I'm happy that you are 14 consolidating them. I think that it's a worthwhile 15 effort.
16 As I read through the NUREG, it struck me 17 that this isn't a particularly risk-informed review 18 process. There are places that allude to the word 19 "consequences". There are, in fact, some numbers that 20 are in there that are characterized as very low 21 probability. There are some discussions saying, well, 22 we can't quantify these things.
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22 1 and it doesn't dovetail very well with your 2 presentation. But if you can try to address that 3 because there is a Commission policy that we should 4 be using risk information and risk being frequency and 5 consequences and uncertainty.
6 I didn't get that notion here nor did I 7 get the notion that there's guidance that can be used 8 by applicants or by reviewers to think about how risk 9 might factor into these things. When you say things 10 like, no breach is acceptable, well, I'm sorry. No 11 breach is impossible. So you're saying that you cannot 12 achieve something that your guidance says you must 13 achieve.
14 So if you can during this morning, if there 15 are any areas that you can help me to understand how 16 the guidance integrates this sort of use of risk 17 information -- which we have done in guidance for other 18 reviews throughout the agency -- I'd really appreciate 19 that.
20 MR. LAYTON: Yes, thank you. This is Mike 21 Layton, and I greatly appreciate your observations on 22 that because as I mentioned in my opening remarks, we 23 have several ongoing activities that have yet to move 24 to fruition. And one of those is risk informing our 25 review process and our licensing process. And I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 applaud your observation about that has not been 2 incorporated into this guidance document as yet.
3 I would characterize that in our program, 4 we're very much in a continuing transition phase. As 5 you look at Part 72 requirements, I think you'll find 6 that the regulations themselves are rather prescriptive 7 which do not lend themselves very well to risk informing 8 as we go through the process. We have identified 9 several aspects of it where we think there is a broad 10 enough latitude where we can provide risk-informed 11 guidance without having to go through rule making.
12 I don't know that we have identified those 13 specifically in this presentation, but we're open to 14 the staff here that has been involved in these efforts.
15 May be able to talk a little bit about what is ongoing 16 and what efforts will be seen in the not too distant 17 future which we will incorporate into the guidance in 18 future revisions. But I do greatly appreciate your 19 observation with that. Thank you.
20 MEMBER STETKAR: Thanks. And I tried to 21 go back to Part 72. I didn't study it. I ran out of 22 time. And in cases where there was reference back to 23 Part 72 in areas that I kind of stumbled over, I 24 generally found, as usual, the rule is not as 25 prescriptive as perhaps you'd characterize it. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 rule tells you what ought to be done. It doesn't tell 2 you how to do it. And I'll give you one example, and 3 I promise I'm not going to delve into any more details.
4 But when I went through, for example, your 5 guidance on fire protection programs, you cite Reg Guide 6 1.189 which is typically characterized as the 7 deterministic, Appendix R-compliant way to develop a 8 fire protection program. You make no mention of Reg 9 Guide 1.205 which is the risk-informed fire protection 10 program.
11 The rule does not preclude using a 12 risk-informed fire protection program. Your guidance 13 does not acknowledge that one could be used. So those 14 are the types of examples that, as I went through this, 15 treatment of external hazards, treatment of a variety 16 of things where when I went back to rule, the rule does 17 not say, you shall use Reg Guide 1.189, or you shall 18 use 10 CFR 50 Appendix R-compliant fire protection 19 program according to the guidance there.
20 So anyway, that's enough. If you can help 21 me, if something pops into you mind as you go through 22 the presentation, I'd appreciate it. Thanks.
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25 1 in many cases. And so fire protection might be a good 2 example of that where this has been used in the past.
3 This is how we evaluated it. It's not to preclude 4 the use of the risk-informed Reg Guide.
5 MEMBER STETKAR: It's not. On the other 6 hand, if I'm coming in for an application --
7 MR. SMITH: I understand. I understand.
8 MEMBER STETKAR: -- I'm going to take the 9 path of least resistance and say, I've done what your 10 guidance says that your reviewers is going to review 11 me against.
12 MR. SMITH: Right.
13 MEMBER KIRCHNER: Along John's line of 14 risk-informed, what struck me overall is I wanted to 15 ask a question here on this slide. Will it also reduce 16 the number of amendments necessary or changes to 17 licenses?
18 MR. SMITH: I don't believe it's intended 19 to -- excuse me -- reduce the number of amendments.
20 Amendments are typically specifically called out when 21 there is a significant change that requires a new 22 evaluation of the safety basis that is used. The 23 efficiency is going to be gained in the reviewers are 24 going to know what information to look at and where 25 it is located as well as if new information becomes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 available that needs to be incorporated into the SRP.
2 The format that we have now established should be an 3 easier path to get it into an SRP in a more timely manner.
4 From a risk-informed basis, it would seem 5 to me this is a problem that you can bound, put an 6 envelope around it and say five -- and I'll just do 7 this off the cuff -- five percent maximum enrichment, 8 60,000 megawatt-days per metric ton burnup, et cetera.
9 And as Jose was saying, there are so many different 10 flavors of fuel out there.
11 Wouldn't this be a process that is amenable 12 to having a bounding envelope that would incorporate?
13 It doesn't take away the diligence necessary by you 14 or the applicant in your review and what they're 15 actually putting in. But in one sense from a 16 risk-informed standpoint, it seemed to me you can bound 17 this problem for most commercial fuel that's out there.
18 MEMBER BALLINGER: Yes, along those lines, 19 I mean, the consequences of a breach are zero or 20 effectively zero, ten to the minus something or other, 21 right? Not zero but very low, right? So that sort 22 of reinforces what Walt was saying. I mean, being so 23 specific when the consequences of a breach are so 24 minimal just begs the question of why aren't we doing 25 this risk informed? I mean, there's --
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27 1 MEMBER KIRCHNER: Just an observation.
2 MEMBER BALLINGER: -- an ongoing -- at 3 least there's supposed to be an ongoing effort with 4 respect to the staff to deal with the consequences of 5 a -- a consequence analysis which we're going to try 6 to focus on at a later date. Are you considering that?
7 MR. SMITH: The consequence analysis?
8 MEMBER BALLINGER: Yes.
9 MR. SMITH: This -- is this --
10 MEMBER BALLINGER: I mean, I'm sure the 11 NEI folks are going to be hard over on that, but --
12 MR. SMITH: Yes, like Mike Layton had 13 mentioned, these are separate initiatives currently 14 within our division that are being developed. So the 15 SRP as it is now is a state of the current practice 16 with the risk informing being developed and as it's 17 developed will be incorporated into the SRP.
18 MEMBER BALLINGER: But are they stovepiped 19 or are they complementary? Separate initiatives to 20 me means separate initiatives. But does that have to 21 be the case?
22 MR. SMITH: With specifically to the 23 risk-informing initiative, there's, I guess, a longer 24 time horizon on when that would actually become 25 effective. Right now, this SRP is intended to go live NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 end of July tentatively is the current schedule. The 2 risk-informing initiative isn't slated to conclude 3 until probably 2020 at some point. So there is a little 4 bit of a disconnect with the timing on it.
5 MEMBER BALLINGER: I'd say so.
6 MR. TATE: Yes, this is --
7 MEMBER BALLINGER: I'd say so.
8 MR. TATE: Yes, this is Travis Tate again.
9 I would say the efforts are not stovepiped even though 10 they are separate initiatives. One of the aspects of 11 our update to this SRP is to put it in a format that 12 is more readily easy to update in the future because 13 of the structure of the REG guide.
14 And what we're planning to do, we have these 15 initiatives ongoing, two more risk-informed as Mike 16 Layton was describing. And our plan is to do an update 17 once that process finishes on the risk-informed aspects 18 of storage.
19 MEMBER BALLINGER: You're up against it 20 with Part 72 because Part 72 does say no breach, period.
21 MR. TATE: Yes, yes, that's correct. But 22 we do intend to incorporate these aspects. This effort 23 was just, let's get this guidance as a first step of 24 consolidated into one document and then in a format 25 that could make it easy it update to these other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 initiatives that we have ongoing.
2 MEMBER CHU: But isn't it -- sorry. Isn't 3 it easier to do it now rather than finish it and then 4 start all over again incorporating whatever risk 5 informed? I'm thinking incorporating a risk-informed 6 approach is I don't think it takes that much more effort 7 and it allowed new, like, choice and new fuel types 8 coming in or new approaches and then give you that extra 9 flexibility and then avoiding all kinds of amendments.
10 Okay.
11 MR. RAHIMI: This is Meraj Rahimi, NRC, 12 DSFM. Let me give you a little bit -- an example in 13 terms of what Mike Layton mentioned that we are trying 14 to take one bite at a time in terms of risk informed.
15 For example, the current initiative that is underway 16 is now in the industry, NEI and NRC, that the risk 17 informing, the technical specification, what goes into 18 technical specification which goes back to the point 19 that Jose made that, why are we putting so much in the 20 tech spec that the industry has to come in every small 21 change put in an amendment?
22 And we thought actually that is very good 23 area, the risk informed, and try to put the guidance 24 out. We already have the guidance, NUREG-1745. It's 25 called the Content Format for Technical Specification.
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30 1 And with the pilot started -- we started two years 2 ago -- and we took one case which was, I think, technical 3 specification of 300 pages or so.
4 And we went through the technical 5 specification and we're at the point where towards the 6 end that we took out a lot of stuff from technical 7 specification from a risk point of view, from a safety 8 point of view that is not really needed in there.
9 So this is a separate effort. It's not 10 stovepiped. It's modularized. Once that effort is 11 done, our RSP says, if you want to write -- the staff, 12 if you want to write your technical specification, look 13 at the 1745. 1745 will give you advice based on this 14 pilot. These are the criteria that you should use.
15 So that effort that we started a few years 16 ago is going to take another year or so to finish that.
17 Once it's finished and it's already the SRP, will we 18 revise that chapter for the technical specification 19 that they will reference that you revise it?
20 So that's one example of the current 21 efforts going on. It's not stovepiped. It's more 22 modular because the effort is too much -- because that 23 was one area of both NRC industry identified that it 24 could be risk informed.
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31 1 my point and I think some of the other members' point 2 -- is this is proceeding at a glacial pace compared 3 to the burden that could be relieved if this thing is 4 risk informed. This is one area where the consequences 5 are so low that there's an opportunity to reduce the 6 burden on licensees for free basically.
7 MR. HSIA: This is Tony Hsia. I'm not Mike 8 Layton but I'm sitting in his chair. I'm the Deputy 9 of the Division of Spent Fuel Management, Mike's deputy.
10 Unfortunately, this morning, we both are double 11 booked. So we'll play tag team if you would allow me 12 to say a few words.
13 I'd like to just bring us back to the 14 genesis of this whole effort. A few years back when 15 Mike just mentioned today that while we were doing 16 Project Aim, a big effort to for each office to identify 17 the efficiencies we could gain by taking additional 18 effort. And this is one of them. There was a 19 commitment to the Commission, do we want to do this, 20 as well as transportation which you will here in a future 21 time.
22 So we were very careful. We presented the 23 plan through our office director, the Commission, that 24 we'll consolidate these existing guidances and ISGs 25 to really streamline this effort and make us and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 industry go through this licensing process more 2 efficiently and effectively.
3 So that's our starting point, then 4 throughout the time, we are being very careful. We 5 kept saying we are not injecting new guidance, new 6 initiatives into this consolidation effort. Yes, 7 we've heard various suggestions from the stakeholders, 8 hey, you should include this and include that. We're 9 very careful not to do that. That's our commitment 10 to the Commission.
11 But in the meantime, we're also mindful 12 of the risk informed. We should start to think about 13 risk-informed initiatives to how we can incorporate 14 risk-informed initiatives into all our reviews 15 including this one. So the decision was made, even 16 as of today, having heard the suggestions, 17 recommendations. We said we're going to stay with what 18 our commitment was to the Commission, that is to 19 consolidate the existing standard review plans and ISGs 20 to make this efficient.
21 To include risk-informed initiatives and 22 thoughts and method is not going to be a very easy effort 23 because then we really have to think through to, how 24 do we incorporate that and get stakeholder input and 25 all of that. That's the reason at this moment we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 not chosen to take that path.
2 But we're very mindful that's something 3 we start to do like Meraj and Mike and Travis mentioned 4 a little bit earlier that we have initiatives on 5 risk-informed licensing approaches and we also, during 6 our discussion with industry and stakeholders, we said 7 we are keeping those in mind. Let's finish this phase, 8 then we'll continue to incorporate as appropriate and 9 timely, the content, to incorporate the risk-informed 10 initiatives into future versions of this as well as 11 the transportation standard review plan.
12 MEMBER STETKAR: Do you have some 13 examples? I mean, you say this is so difficult to risk 14 inform this particular effort. As I said, as I read 15 through the however many pages there are, I made several 16 pages of notes about why aren't you thinking about this?
17 And I'm not developing fundamental 18 research. I'm developing this from a perspective of 19 things that are done and happened in this agency in 20 other licensing activities already. So I'm not 21 creating new types of research. I'm not creating new 22 types of analysis techniques. It's what other people 23 are doing.
24 So I'm a bit baffled about why it's so 25 difficult to apply those already developed techniques NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 to this particular type of activity, why that takes 2 years and years and years and years of apparently new 3 effort when the agency itself has already done the 4 legwork over in the operating reactors area in 5 preliminary guidance for reviews of new reactor 6 designs, evaluations of different types of hazards.
7 It exists. That knowledge exists in the agency.
8 Perhaps not in your part of the agency.
9 MEMBER RAY: But John, the context in which 10 spent fuel storage exists is very different than an 11 operating reactor. And trying to get the input to the 12 analysis that you're talking about, a consensus around 13 what would be the considerations in that different 14 context does seem to me to be a chore that could be 15 time consuming and therefore should take place after 16 this consolidation takes place.
17 MEMBER STETKAR: But I'll come back and 18 I'll say, earthquakes, fires, floods, material 19 degradation, leaking seals don't know whether they're 20 in an operating reactor or whether they're in a dry 21 cask storage. They don't know that.
22 MEMBER RAY: That's true.
23 MEMBER STETKAR: The material doesn't know 24 it and the hazards don't know it and the way of 25 evaluating the hazards doesn't care.
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35 1 MEMBER RAY: But the -- I'm trying to avoid 2 use of the word we don't want to get into here. But 3 the context in which dry storage exists is very 4 different than the context in which an operating reactor 5 exists. And I'm talking about security. And trying 6 to address that in this process here seems to me like 7 it is a big challenge.
8 MR. HSIA: If I -- and again, I'm an 9 old-timer. So let me think back when this agency 10 started risk-informed decision-making. The PRA policy 11 statement, if you recall, was in the early '90s. So 12 we're talking 28 years later that we -- of course, we 13 made strides, big strides in the reactor areas and that 14 was a good thing to do.
15 And in the dry storage arena, we are well 16 aware of the situation and we are really putting our 17 effort to -- I would call it baby steps, if you will 18 -- to be risk informed. That's why we started 19 initiatives of risk informing our license and review 20 of dry storage and transportation. That's why we've 21 had a pilot project working with the industry to go 22 and that's been very successful.
23 We're very happy to have that. But like 24 I said, as appropriate, we will like to incorporate 25 those insights we've gained -- through the pilot, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 through the baby step risk-informed initiatives -- to 2 be incorporated into our daily review.
3 We practice that already and even in our 4 -- when we develop our RAIs and our licensing reviews, 5 we keep asking ourselves, hey, what's the risk involved 6 in taking this? When a new amendment comes in, we do 7 think about that constantly.
8 But we have not incorporated and 9 institutionalized, if you will, into the standard 10 review plans. So our staff reviews can take that and 11 say, hey, go through a better guidance to focus on risk.
12 We're not there yet, but we are going that direction.
13 CHAIR SUNSERI: So let me ask a question 14 then from somewhat of a devil's advocate point of view.
15 And I don't know the answer to this question and it's 16 not meant to be a leading question either. But when 17 we talk about efficiencies of the process, what does 18 that gain us? Well, theoretically, it gains us better 19 utilization of our resources so that we can focus 20 resources from less safety implication or items of 21 higher issues of safety and publication, right?
22 So if I understand the statistics right, 23 there's something greater than 50 and less than 100 24 facilities in operation in this country right now, 3 25 proposed ones. Are we reaching a point of diminishing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 return where the effort to improve the efficiency is 2 outweighed by there's just not enough work left to 3 justify it? And I'm talking about the swap over from 4 the deterministic to the risk informed.
5 MR. SMITH: I don't think I'm the right 6 person to answer that question.
7 MR. HSIA: Again, this is Tony Hsia. I 8 don't think -- in my opinion, I don't think we're at 9 the diminishing return point. I think we should 10 continue to work toward more risk informed. But it's 11 going to take some time and we will continue to work 12 in -- like I said, we'll walk toward that direction 13 to be risk informed.
14 There are many, many dry cask ISFSIs out 15 there and we receive many license amendments on an 16 annual basis for both storage and transportation. And 17 those installations will be here for hundreds of years, 18 so to speak, or at least in our career. And my opinion 19 is that we should go toward that direction. We should 20 continue to try to be more risk informed.
21 CHAIR SUNSERI: Okay. So that was an 22 answer that addresses, I guess, that there is a fairly 23 high maintenance level back there beyond the existing 24 facilities then, that would you say there are a lot 25 of amendments then?
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38 1 MR. HSIA: Yes.
2 CHAIR SUNSERI: All right, very good.
3 Before I forget, I want to add to the record that Michael 4 Corradini, a member, has joined the committee.
5 MEMBER REMPE: So if we're done with the 6 risk-informed discussion, I have a smaller step kind 7 of question. I've heard you say we're trying to 8 document our knowledge base and provide all the 9 information there for the reviewers. As you went 10 through and combined these documents, was there an 11 active process saying, oh, we're citing the number here.
12 We ought to document a reference for why we have a 13 particular temperature.
14 There are a lot of times when we'll talk 15 about monitoring a cask or a storage facility and it 16 doesn't say what parameters. Was there an active 17 effort to say, we ought to document typically what 18 parameters? And I can give you some examples later 19 on as we go through the chapters and say, when I was 20 looking at this, I was thinking, jeepers. It seems 21 like you should provide some guidance there.
22 And was that considered beyond the scope 23 of this effort because it wasn't in the old documents?
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39 1 them?
2 MR. SMITH: There was a distinct effort 3 by the SRP team and the technical team to try to 4 incorporate additional clarification and guidance on 5 any particular areas of the SRP where they thought it 6 would be --
7 MEMBER REMPE: Useful.
8 MR. SMITH: -- useful.
9 MEMBER REMPE: So when I start asking you 10 questions when we get to particular chapters, you'll 11 understand why I was kind of puzzled because some places 12 I saw it and other places I didn't. And it just seemed 13 like that was lacking in this combined document.
14 MR. TATE: This is Travis Tate again, and 15 that's a good point. And we'll be interested to hear 16 your feedback in those areas. I think what Jeremy was 17 referring to, I think the staff did try to focus on 18 those areas based on experience in our reviews. Where 19 we saw questions had come up, we tried to make sure 20 we put clarifying information in there just based on 21 our prior reviews, but --
22 MEMBER REMPE: I'm sure the staff is well 23 aware of where those numbers come from. But --
24 MR. TATE: Right.
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40 1 a lot of the staff is retired, I think it might be useful 2 to make sure that that's all in there.
3 MR. TATE: Sure, sure. Yes, we definitely 4 appreciate the feedback.
5 MR. SMITH: Okay. So for the SRP, the 6 approach that we took, we formed an internal NRC team 7 that represented all of the technical disciplines:
8 Structure, thermal, shielding, criticality, 9 confinement, materials, licensing. And what we did 10 was we started with the draft updates in NUREG-1567.
11 There had been an effort a number of years 12 ago to update NUREG-1567. It had gone all the way 13 through an OGC review. Unfortunately, at the time, 14 we didn't have the resources to bring it to fruition.
15 With that document, we merged the guidance that was 16 found in NUREG-1536.
17 We incorporated the ISGs and other 18 technical guidance into the consolidated update which 19 is NUREG-2215. We also updated figures and regulations 20 related to review areas which at the beginning of every 21 chapter, there is a table that delineates what 22 regulations going back to 10 CFR Part 72 are 23 incorporated in that particular chapter to make it more 24 clear to any potential reviewer. And then we issued 25 the draft NUREG-2215 for stakeholder feedback back in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 November.
2 After we received our public comments back, 3 we held a public meeting just at the end of March here, 4 a few weeks. And what we did was we focused on the 5 comments that were directly relevant to NUREG-2215.
6 We received 153 public comments, some of 7 them very short and sweet; some of them very lengthy 8 in nature. We expanded those out to over 250 individual 9 actionable comments from those 150 that we've gotten.
10 We created a matrix, kind of cross referenced what 11 chapters and such as those would affect.
12 Most of the comments that we received out 13 of those were outside of the scope of the SRP. There 14 was probably less than ten percent that actually had 15 specific relevance to what we were posing in the SRP.
16 And this meeting was attended by 26 industry 17 representatives and members of the public.
18 At the public meeting, we had boiled down 19 all of these comments into 19 consolidated comments 20 that we thought potentially could affect how we were 21 writing the SRP. What we did was we summarized each 22 comment that was received and we provided a proposed 23 response from the NRC to each of these. We held an 24 open discussion on each of these comments and we noted 25 anyone who had additional information to provide to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 this as well as proposed changes to our responses as 2 well as requested clarifications.
3 And what I've done is I've taken these 19 4 comments that we presented at the public meeting, 5 bundled them together into kind of a short, select set 6 of the important ones that we think would be of interest 7 to the ACRS subcommittee.
8 And the first comment we got kind of touches 9 on what it seems like a lot of interest from the members 10 here today that some of the other initiatives that we 11 currently have ongoing within the organization of spent 12 fuel management. These are included, syncing up the 13 SRP with the Graded Approach initiative, the revisions 14 to 10 CFR 72.48, which is our change request regulation, 15 as well as the MAPS initiative which is the managing 16 aging processes.
17 As I think we've kind of talked about 18 already, these are considered separate issues, not 19 intended to be stovepiped but really to be more 20 modularized as we go through and as we develop these 21 initiatives today will be incorporated into the SRP 22 in this new format.
23 CHAIR SUNSERI: And I think you may have 24 said it, but if you could repeat it. Is there a formal 25 plan for addressing these points that goes out to 2020 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 or something that I heard?
2 MR. SMITH: Right now, my plan only covers 3 completion of the SRP consolidation effort. It does 4 not incorporate any initiatives that might be 5 incorporated in a future revision.
6 CHAIR SUNSERI: And so is there somebody 7 else like you that has the follow on these then?
8 MR. TATE: Yes, the Graded Approach 9 initiative I think currently -- and I don't have the 10 schedule right in front of me, but -- I'm sorry. This 11 is Travis Tate -- is somewhere around July, summer of 12 2019, I think, is where we expect to have the revision 13 to the NUREG-1745 complete.
14 I think -- well, I can get you the schedule 15 for that, but just right off the top of my head, I think 16 that's when we were expecting to have that. We have 17 been engaged with NEI as well to try to work on basically 18 a plan that would provide guidance out to the industry 19 to start incorporating some of the risk-informed 20 information that we learn while we are updating the 21 1745 REG -- NUREG, I'm sorry.
22 CHAIR SUNSERI: And remind me what the 23 title of 1745 is.
24 MR. SMITH: That's the standard content 25 format for technical specifications.
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44 1 MR. TATE: Okay. Yes, September 2019 is 2 the date. I'm sorry. Right. And just to clarify, 3 the Graded Approach is a risk-informed approach to 4 storage.
5 MR. SMITH: And as part of these separate 6 initiatives, the NRC, in developing this SRP, was 7 committed to not adding new guidance at this point to 8 NUREG-2215. It's intended to give the scene of present 9 practice for reviews, including experience that we've 10 -- lessons learned that we've gained performing 11 reviews.
12 The next comment was regarding some of the 13 ISGs may not be incorporated correctly into this SRP.
14 Those include ISG-2, Fuel Retrievability, ISG-3, 15 Post-accident Recovery, 11, Cladding Consideration, 16 and 22, Potential Rod Splitting.
17 Based on the discussions with the public 18 and the industry, on ISG-2, we agreed that we should 19 make sure that we're consistent with ISG-2 and that 20 we would make some slight revisions to that section 21 of the SRP to reflect that.
22 MEMBER REMPE: Could you elaborate a 23 little more than that on each of these and what this 24 does?
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45 1 received on ISG-2 stated -- I'm paraphrasing here.
2 In attempting to incorporate ISG-2, the current draft 3 NUREG-2215 inappropriately changes the meaning of that 4 ISG. The language can be read to imply that a licensee 5 or CoC holder must use one or a combination of the three 6 listed methods for retrievability.
7 ISG-2, however, made it clear that these 8 are merely three acceptable means so that licensees 9 and CoC holders are welcome to propose and justify other 10 means. The NUREG-2215 should be clarified to maintain 11 ISG-2's intended meaning.
12 And our proposed response on that was that 13 we use the text that was identical to the technical 14 review guidance. However, staff recognized that the 15 recommendation section of ISG-2 uses the term 16 "acceptable means". We propose that we will be 17 revising NUREG-2215 to match the recommendation usage 18 that was used in ISG-2.
19 ISG-3, the comment was, in attempting to 20 incorporate ISG-3, Post-accident Recovery, the current 21 draft language of NUREG-2215 implied that a licensee 22 must maintain retrievability equipment rather than 23 preserving the language and intent of ISG-3 which 24 recommended that only the design include post-accident 25 recovery features.
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46 1 The proposed response from the NRC to that 2 was that the SRP indicates that the start does not need 3 to describe specific retrieval facilities, equipment, 4 and procedures for post-accident conditions because 5 of the wide variety of possible post-accident 6 conditions that may occur. As noted above, the 7 discussion on post-accident recovery and 8 retrievability will be clarified in the SRP.
9 On ISG-11, the comment was that, this ISG 10 was not incorporated correctly. The SRP contains 11 incorrect fuel cladding temperature limits. It also 12 does not include all of the acceptable combinations 13 described in the ISG.
14 For example, the SRP states that the low 15 burnup fuel cladding temperature limits is 570 degrees 16 C during normal conditions. The actual limit for 17 normal conditions is 400 degrees C. Furthermore, 18 ISG-11 says for both normal and accident conditions, 19 the fuel cladding temperature limit is 570 degrees C 20 while the SRP states that the higher limit only applies 21 to accident conditions.
22 The proposed NRC response to that was that 23 the staff agrees with this comment and that the SRP 24 will be revised to be consistent with the limits that 25 are outlined in ISG-11.
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47 1 This was a longer comment, ISG-22. So 2 industry's comments on draft ISG-22, potential rod 3 splitting due to exposure to an oxidizing atmosphere 4 during short-term cask loading operations in light 5 water reactors or other uranium oxide-based fuel, 6 suggested that the ISG created new requirements and 7 was implemented without sufficient risk consideration, 8 formal backfit analysis for broad based NRC management 9 and ACRS consideration.
10 In industry's view, those concerns were 11 not adequately addressed in NRC's response to our 12 comments. We believe this issue should've been 13 considered in the NRC generic safety issues program 14 described in the NRC Management Directive 6.4, Generic 15 Issues Program, to determine if a sufficient 16 enhancement to public health and safety justified the 17 cost of implementation of the actions described in 18 ISG-22. NUREG-2215 appears to exacerbate this 19 problem.
20 So in response to this, the NRC proposed 21 that the staff will take a look at this and plan to 22 conduct a focused review of how ISG-22 as well as all 23 of the ISGs were incorporated into the SRP to ensure 24 that no new staff regulatory positions were introduced 25 as part of this consolidation effort.
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48 1 The last bullet on the slide is 2 inconsistent regulatory position on fuel 3 characterization prior to storage. This one kind of 4 related back to a current information notice that went 5 live in January. While we were consolidating the SRP, 6 Information Notice 2018-01, noble fission gas releases 7 during spent fuel cask loading operations, was being 8 finalized.
9 The SRP staff worked with the information 10 notice staff to ensure that the information was 11 incorporated into the SRP from -- that information from 12 the IN was incorporated into the SRP and was consistent.
13 After discussions with the public at the 14 public meeting, the end result, we indicated that they 15 would prefer if the SRP only pointed to the information 16 notice instead of incorporating it directly into the 17 SRP. And that was, I think, the proposed action that 18 the NRC will take. We will just reference the IN.
19 Other comments that received that were not 20 directly related to the SRP consolidated effort. These 21 were mainly from members of the public. These include 22 the use of thin-walled cask at storage sites, 23 radioactive material releases, stress corrosion 24 cracking, conservative assumptions, and many of them 25 were specifically directed to material that is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 currently being stored in California.
2 The NRC's response was that these comments 3 were outside the scope of the NUREG-2215 and that these 4 types of questions had been asked and answered on 5 several occasions in different forums, including 6 several responses that can be found at ADAMS. And I 7 don't want to read you all the ADAMS numbers here.
8 Other changes and clarifications were --
9 there were several of them kind of from different 10 sources. One was regarding the requirement, if a pool 11 would be necessary at a facility to maintain the ability 12 to open canisters. The NRC's position was that we 13 clarified that a pool is not necessary and that you 14 should refer back to NUREG-1567 which has a specific 15 pool discussion.
16 The discussion in the room with the public 17 indicated that that might not be the most clear way 18 to do that. Some suggestions went from the realm of 19 changing the name of NUREG-1567 to be wet storage.
20 Other indications said maybe we should include all of 21 that pool information in this NUREG-2215. This is 22 currently being discussed with the staff at a level.
23 We're trying to come up with the best approach to 24 address this issue.
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50 1 do not do loading operations would receive already 2 canistered spent nuclear fuel or Greater-Than-Class 3 C waste. The NRC responded that we will add a 4 discussion indicating that a license needs to verify 5 that the materials to be stored at their facility meet 6 the specifications given in a license.
7 There was some discussion on how Part 20 8 regulations were integrated into NUREG-2215. The 9 expectation by staff is that the applicant can 10 demonstrate that their facility meets the 10 CFR Part 11 20 regulations during operations. The public was 12 concerned about that this might be adding new 13 conservatism in the SRP with regards to dose assessment.
14 And the NRC proposed that we would make that abundantly 15 clear in a slight clarification to the SRP.
16 A few other comments that were received 17 that might require changes are systems that are not 18 important to safety. The comment was that that is too 19 large of a spectrum. They were worried that it might 20 include things like restrooms or visitors centers on 21 a facility. And the NRC indicated that we would revise 22 that to make it clear that what is important to safety 23 would be clarified in that the ones that we provided 24 were only examples. So it wasn't implied to encompass 25 everything.
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51 1 MEMBER STETKAR: Jeremy?
2 MR. SMITH: Yes.
3 MEMBER STETKAR: You brought that up. And 4 again, I'm going to try to keep it at a fairly high 5 level. Is retrievability important to safety?
6 MR. SMITH: I'm not sure where to go with 7 this one.
8 MR. CALL: If I -- just not necessarily 9 answering directly to the question. My name is Mike 10 Call. Retrievability is not considered in terms of 11 there's the safety functions. There are important to 12 safety function. It's not considered to be one of 13 those. However, it is a regulatory requirement in Part 14 72 that retrievability be maintained. Now, how that's 15 --
16 MEMBER STETKAR: Again, as I read through 17 the guidance, it seems to be treated as an important 18 to safety function and therefore things that could 19 degrade retrievability are treated exactly the same 20 way as things that could results in a release to the 21 public.
22 MR. CALL: I think just because it's a 23 requirement in the Regulation 72.122 to be retrievable 24 -- whatever that ends up being which is where the ISG 25 went to -- that we ensure that requirement is complied NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 with.
2 MEMBER STETKAR: So anything in --
3 MR. CALL: So it's probably the same rule.
4 MEMBER STETKAR: -- the regulation --
5 regardless of however people were thinking when they 6 wrote it -- is equally important to public health and 7 safety?
8 MR. CALL: Again, it's --
9 MEMBER STETKAR: We don't have to 10 reconstitute a nuclear power plant after an accident.
11 We have to protect the health and safety of the public 12 from accidents.
13 MR. CALL: And understanding, as the ISG 14 points out, there are different meanings and different 15 ways that retrievability can be complied with and what 16 can be considered retrievability. And within that way 17 of considering what retrievability can be defined as 18 is where the flexibility can be built into what is 19 necessary to be done.
20 CHAIR SUNSERI: Does retrievability have 21 an important role during, like, say, an accident 22 recovery or something on these?
23 MR. CALL: No, from what I believe from 24 ISG, retrievability is not considered an accident 25 recovery. It's only for normal or off-normal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 conditions.
2 MEMBER POWERS: I think the answer I 3 would've given John, of course, is very similar to yours 4 that if it's in the regulation, then obviously the 5 Commission at the time felt it was important to safety.
6 I think their thinking about that was that 7 at the time the regulation was written, it was thought 8 that it would be necessary to take the fuel out of these 9 canisters, transport it to another site. And that 10 should the fuel have badly degraded and make 11 retrievability difficult, it would pose a hazard, both 12 to those doing the operation and to the public health 13 and safety.
14 I think there's been enough experience at 15 DOE facilities with precisely that operation to suggest 16 those people were perspicacious in imposing the 17 requirement.
18 MR. RAHIMI: Meraj Rahimi, NRC. I think 19 that's a good example Dr. Powers mentioned their 20 thinking at a time of those regulations. So what we 21 did, as part of risk informed a couple of years ago, 22 we went back to look at the ISG-2 definition of 23 retrievability. And what is the intent from the safety 24 point of view to be able to remove the fuel off the 25 site?
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54 1 So we came up with the option which now 2 the new ISG-2 is incorporating the SRP. You can either 3 retrieve the single fuel assembly or retrievability 4 means getting to remove the canister with the fuel in 5 it or the cask. If you can move the cask with the fuel 6 in it, that is considered retrievable.
7 So that's a perfect example that a couple 8 of years ago we went back and we looked at the definition 9 of retrievability and what is from the safety point 10 of view, the risk point of view, what makes sense.
11 And that's what has been incorporate into this SRP.
12 MR. SMITH: A couple of other changes that 13 were mentioned were SSCs that were important to safety.
14 And the NRC proposed that we would remove the gas 15 treatment and vent systems to make this section clearer 16 and also add detail to the SSCs that we listed were 17 not an exhaustive list.
18 We'd also received a few comments via the 19 HELMS petition for rulemaking. In that petition for 20 Part 72, there were six contentions that applied to 21 NUREG-2215. We reviewed those. They mostly are due 22 to our concern, long-term storage.
23 And in reviewing the SRP, we thought that 24 it would be premature to add any proposed rulemaking 25 issues that had not been decided into this SRP. But NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 that once those become an actual part of the rule that 2 the SRP would be modified to reflect that.
3 And the last change and clarification that 4 we did was the emergency plan information that was 5 contained in NUREGs 1536 and 1567 was incorporated 6 directly. It was found that that information was 7 slightly out of date. In response to that, the NRC 8 coordinated with NSIR to make sure that the regulations 9 that were -- the guidance that is in the emergency 10 planning section is reflected of what the current state 11 of practice is for the NRC.
12 So with that, I'm going to be turning it 13 over to the technical staff to discuss particular 14 technical sections of the SRP. They are going to 15 discuss items of interest that we thought might be of 16 interest to the ACRS subcommittee here today. Not all 17 the technical chapters have major changes or 18 enhancements as part of this consolidation effort.
19 Again, just to reiterate, NUREG-2215 is not intended 20 to introduce new staff positions, only the state of 21 current practice that is being used in the Division 22 of Spent Fuel Management.
23 MR. EVERARD: Good morning. I'm Steve 24 Everard. I'm a structural engineer with the Division 25 of Spent Fuel Management, and I manage the update of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 1 Chapter 4 of NUREG-2215.
2 So we pose no new staff positions with 3 respect structural matters in this NUREG. What we did 4 was combine and reorganize the content of NUREG-1567 5 and 1536 to better align with how the structural staff 6 performs a review.
7 The chapter was designed to walk the 8 reviewer through the various aspects of a review from 9 the description of the structures, systems, and 10 components to design criteria, the loads and load 11 combinations, the analytical approach used by the 12 applicant and then the normal, off-normal, and accident 13 conditions. And then finally, we rewrote the findings 14 to clarify the regulatory language and to better 15 identify the regulations that they address.
16 MEMBER STETKAR: Steve, to give you some 17 examples as I went through this thing. For example, 18 in Chapter 4, you talk about tornado wind loading and 19 tornado missiles extensively, and you cite Reg Guide 20 1.76, Reg Guide 1.117, and NUREG-0800, the standard 21 of Section 3.3.2 for tornado winds and missiles. We've 22 learned that in some parts of the country, hurricane 23 winds and hurricane-driven missiles are indeed more 24 important than tornado winds and missiles.
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57 1 we're writing this guidance today, not ten years ago, 2 why don't you refer to the Reg Guides on hurricane 3 missiles also and have the applicant use whatever is 4 the most bounding for their site? Or is that something 5 that we have to wait until 2020 to learn? And I'm 6 purposely being antagonistic because it's silly that 7 this agency gets stovepiped this way just because your 8 old things that you're borrowing from just tornados.
9 And that's why I'm going to bring this 10 example. I have 16 pages of examples like this of 11 things that we know today in this agency that you've 12 not incorporated here because you've apparently not 13 looked outside your own walls.
14 So why do you only look at tornado winds 15 and tornado missiles for dry cask storage? Why, if 16 I put a dry cask storage facility at Turkey Point, don't 17 I have to look at hurricane missiles because they are 18 much more important than tornado missiles at Turkey 19 Point or other places along the Gulf Coast? That 20 doesn't take research. It just takes writing about 21 four more words.
22 MR. EVERARD: Again, I don't want to sound 23 like a broken record but our charter was to combine 24 the content of NUREG-1536 and 1567. Again, this is 25 the standard review plan. So things like hurricane NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 winds can certainly be and probably should be looked 2 at and we'll review them in accordance to Reg Guides 3 and codes and standards that are currently out there.
4 MR. SOLIS: Good morning. My name is 5 Jorge Solis. I'm a senior thermal engineer at the 6 Division of Spent Fuel Management. Steve mentioned, 7 also, I manage the update for the thermal evaluation.
8 And as it was mentioned, basically there 9 were no changes to the staff positions on the respect 10 to thermal matters. Again, the contents of NUREG-1567 11 and NUREG-1536 were combined and reorganized to better 12 align with how the thermal staff conducts reviews and 13 produces a safety evaluation report.
14 The regulatory language was clarified to 15 provide adequate reference between review areas and 16 the applicable regulations. And again, defined is 17 where we clarify the regulatory language and then 18 identify which regulations they address.
19 In addition to that NUREG-2152 -- which 20 is the Computational Fluid Dynamics Best Practice 21 Guidelines for Dry Cask Applications -- was added as 22 a reference as it provides additional detailed guidance 23 to review CFD applications to perform confirmatory 24 analysis.
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59 1 examples that I thought it would be good to provide 2 some references or some, this is what we typically do.
3 On page 165 out of 617, you say the applicant should 4 provide evidence that the decay heat removal system 5 will operate reliably under normal unloading 6 conditions.
7 It doesn't talk about typically what the 8 evidence is. You have, the SAR should also describe 9 all instrumentation used to monitor the storage thermal 10 performance, without saying, typically, applicants in 11 the past do this. To me, if I were a staffer, I would 12 like that information.
13 You cite temperatures that must not be 14 exceeded for normal conditions of storage in short-term 15 loading operations and then a different temperature 16 for off-normal and accident conditions. A reference 17 from where those temperatures came from I think would 18 be useful in the guidance. And you also have a basis 19 for stainless steel as well as Zircaloy that ought to 20 -- again, a reference is good to have.
21 And I think that gives you the idea of where 22 I was thinking that it might be good to go a little 23 bit more than just -- I didn't see it. I assume that 24 was what was in the old guidance documents. It would 25 be good to think about the better documentation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 informing the future staffers.
2 MR. SOLIS: Yes, in regard to the load 3 agents, I mean, that's generic. But after that, in 4 the thermal analysis, it's acceptable provided it's 5 for this task. So that's evidence that we passed to 6 --
7 MEMBER REMPE: That's good.
8 MR. SOLIS: -- the management.
9 MEMBER REMPE: But just tell people, this 10 is typically what --
11 MR. SOLIS: But that's --
12 MEMBER REMPE: -- we want to see.
13 MR. SOLIS: -- I think that's in the 14 details of the review. Like, it's for the review 15 requirements.
16 MEMBER REMPE: It's later on in another 17 section in --
18 MR. SOLIS: No, here.
19 MEMBER REMPE: In Chapter 5?
20 MR. SOLIS: Yes.
21 MEMBER REMPE: Okay.
22 MR. SOLIS: So what --
23 MEMBER REMPE: It wasn't clear to me when 24 I read it that that's typically all that's required.
25 MR. SOLIS: Yes.
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61 1 MEMBER REMPE: They talk about --
2 MR. SOLIS: That's, like, in that sentence 3 right there. But then later on in the review 4 procedures, there's detailed guidance on what they can 5 provide as evidence.
6 MEMBER REMPE: Okay. Well, connect it 7 well is where I'm coming from, and --
8 MR. SOLIS: And regarding the 9 temperatures, there's a separate chapter for materials 10 where all the temperature limits are specified.
11 MEMBER REMPE: It's in the SRP?
12 MR. SOLIS: Exactly, in Chapter --
13 MEMBER REMPE: But again, then have a 14 pointer --
15 MR. SOLIS: -- it's in Chapter -- I believe 16 it's Chapter --
17 MEMBER REMPE: -- and say that -- because 18 again, that you can find the references for that.
19 Connect the dots so people know. I don't know if it 20 was this section or later on, but they were talking 21 about making sure that the vents aren't blocked. And 22 they talk about inspections. And so sometimes I could 23 find what's typically required. Other times, I 24 couldn't find and I just think that it'd be good to 25 look at it with a critical mind saying, is this a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 1 complete set of information to give people?
2 MEMBER MARCH-LEUBA: This temperature 3 limit, the 400 degrees C, is it an SRP suggestion or 4 is it a regulation?
5 MR. SOLIS: Well, this is part -- this is 6 IG-11 and actually this is a material limit. It's not 7 thermal really. That's prescribed for us. And all 8 of the reasons for that limit are specified in -- are 9 now in the SRP in Chapter 8, I believe, in the materials 10 evaluation.
11 MEMBER MARCH-LEUBA: But the SRP only 12 suggests --
13 (Simultaneous speaking.)
14 MR. SOLIS: Exactly. That's one 15 approach. But I mean, they -- and I believe -- I mean, 16 there's materials from here that talk about for the 17 details of what would be acceptable. Really from a 18 thermal point of view, for me, that's just, I mean, 19 for my analysis.
20 MEMBER MARCH-LEUBA: What I'm coming from 21 is I'm not an expert on this but I heard a couple of 22 questions that the licensees are getting closer and 23 closer to the 400 limit, terribly close. So what 24 they're choosing to do is do a more sophisticated 25 analysis to show that they have a margin. But some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 other licensee can choose to say, well, maybe 400 is 2 okay. Maybe we can go to 425.
3 MR. SOLIS: As long as they provide the 4 reasons. And actually, they can support that from a 5 materials point of view that's something that we would 6 accept.
7 MEMBER MARCH-LEUBA: But the written 8 process of this SRP, I think a section in this area 9 of how will the staff review the new 425 limit.
10 MR. SOLIS: Well, again, I mean, this is 11 a standard review plan and it provides guidance.
12 MEMBER MARCH-LEUBA: This is 100 pages 13 long already. I mean, I can foresee that an applicant 14 instead will rather see the calculations and they come 15 up with 401.
16 MR. SOLIS: Right.
17 MEMBER MARCH-LEUBA: And they'll come back 18 with, say, hey, we want relaxation. Really, we want 19 425 because we can justify it. A little forward 20 thinking and have a small section, this is how the staff 21 such application. That's not an inconceivable 22 situation.
23 MR. SOLIS: Right.
24 MEMBER REMPE: And you can go further.
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64 1 were tests done on some fuel out in Idaho and basically 2 they found that the temperatures probably did go above 3 those limits. And that's why I think it would be good 4 to have the reference cited and how strong -- some 5 perspective about how strong that number really -- how 6 strong this basis is. And so again, it's something 7 you're preparing for knowledge management for people 8 in the future.
9 MR. SOLIS: Yes, and again, I mean, you're 10 referencing these Idaho tests. I know -- I mean, of 11 course, they know what parameters are going into the 12 cask, et cetera. But remember, we're reviewing at this 13 time. So for at this time, they're telling us, we can 14 put here 50 kilowatts and this is our temperature.
15 So we're reviewing against that. I mean, we don't 16 question how they get those 50 kilowatts.
17 MEMBER REMPE: But again, if you'll say 18 what the basis is, that gives them an idea of what --
19 if they want to try and justify it with 401 degrees, 20 if they have that reference there, they can say, well, 21 frankly, this actually -- and that reference. It gives 22 a little more basis. It gives the staff a basis. It 23 gives industry a little bit more guidance --
24 MR. SOLIS: Yes, and I think I already --
25 MEMBER REMPE: -- on how you --
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65 1 (Simultaneous speaking.)
2 MR. SOLIS: -- mentioned that from a 3 material's point of view, I think you would be reviewed 4 and it's found acceptable. It could change the 5 guidance that we have right now.
6 MR. WISE: This is a very low microphone.
7 (Laughter.)
8 MR. WISE: I'll just be real brief.
9 That's an excellent point. I'm sorry, John Wise, a 10 senior materials engineer. That's an excellent point, 11 and we have been faced recently with such a question 12 is, does it matter if it goes up to 400 degrees?
13 And so that is something it's kind of a 14 current thing we're working through and we've had some 15 current discussions on that on how we would define, 16 does it matter, or how would an applicant come in.
17 I think we're in a situation where it's kind of ongoing.
18 We're working through that right now and we're not 19 there yet for a standard review plan.
20 Because again, our standard review plan 21 is really a collection of our experiences in how we've 22 reviewed and a history of what we've found to be 23 acceptable. And so we're lagging a little bit. So 24 when we work through an application that proposes to 25 use 410 and if we ultimately approve such an approach, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 1 those lessons learned will be wrapped into the standard 2 review plan.
3 So I know it's not very satisfying to you.
4 But our standard review plan is sort of a product of 5 our experiences. And we --
6 MEMBER REMPE: So the point --
7 MR. WISE: Yes.
8 MEMBER REMPE: -- is put a reference. So 9 it's the product of your experience and this is based 10 on whatever that reference is. I know you can't --
11 you want to go live in July.
12 MR. WISE: Yes.
13 MEMBER REMPE: And I know you can't predict 14 the future. But give people a little bit more --
15 MR. WISE: Yes, we will --
16 MEMBER REMPE: -- information.
17 MR. WISE: -- take that point. In some 18 cases, we do have some references for where some of 19 those considerations came from. We have an appendix 20 on the pre-considerations. And that's part of what 21 rolled into the 400 degrees C. But point well taken 22 and we'll look for opportunities for explaining why 23 we have something.
24 MEMBER REMPE: Okay. Thank you.
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67 1 the risk-informed people again and that is the 400 2 degrees C limit is in place for one particular set of 3 criteria. But if you were to risk inform this, you 4 would discover that staying at a high temperature is 5 actually a good thing from the standpoint of another 6 characteristic, that is keeping the darn thing dry --
7 the surface dry. So it's another sort of case where 8 risk informing would make a difference.
9 MEMBER REMPE: That brings up another 10 point that I was -- there's nothing in here about --
11 some places, you may talk about humidity. But most 12 places, you don't give people much information about 13 with this drawing what humidity levels, how you verify 14 it. I think that some places I see it and some places 15 it's just --
16 MR. SOLIS: There's a --
17 MEMBER REMPE: -- open.
18 MR. SOLIS: -- specific reference to 19 another NUREG that we issued on environmental 20 parameters. That provides -- and actually, it's 21 referenced in the report in the standard review plan.
22 MEMBER REMPE: Okay.
23 MR. SOLIS: And it talks all about the 24 details about all the environmental parameters, 25 including humidity, wind, solar, insulation, elevation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 1 plan.
2 MEMBER REMPE: And it talks about the 3 instrumentation that you use? Because I know one place 4 -- and again, I'm not sure if it was in Chapter 5 or 5 a different place. I have some notes where I could 6 dig it out. But they do talk about it and they say 7 you should leak test. But then they don't say what's 8 an acceptable value for the leak test. And again, 9 typical values. So again, look at it with a more --
10 MR. SOLIS: Yes.
11 MEMBER REMPE: -- critical mind is where 12 I'm coming from to give people some guidance. And if 13 it is just typical values -- you don't want to have 14 a hard, fast limit -- just say that.
15 MR. SOLIS: Thank you.
16 CHAIR SUNSERI: Hey, Jeremy, I think we're 17 close to 10 o'clock here. Why don't we take a 15-minute 18 break and resume at -- well, we'll call it 20 minutes 19 so a quarter after by that clock. We're on break.
20 (Whereupon, the above-entitled matter went 21 off the record at 9:55 a.m. and resumed at 10:14 a.m.)
22 CHAIR SUNSERI: All right. Welcome back.
23 We're reconvened. Jeremy, cont.
24 MR. SMITH: Okay. I'm going to continue 25 with the staff technical discussions. We'll continue NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 1 on with shielding. Michael?
2 MR. CALL: Hello. My name is Mike Call.
3 Again, I'm the shielding criticality reviewer in the 4 division. Just to go over the shielding chapter, so 5 the changes that we -- some of the things that we did 6 with the shielding chapter as described here, trying 7 to better integrate -- improve the integration of the 8 review information in this chapter with the radiation 9 protection chapters. I'll explain why there are two 10 radiation protection chapters when we get to that point.
11 The shielding chapter basically supports 12 the radiation protection chapter in evaluating the 13 analyses to come up with the dose rates that would be 14 used in the radiation protection reviews to look at 15 compliance with the dose requirements in 72.104 for 16 the normal and anticipated occurrences, annual dose 17 limits as well as the accident dose limits in 72.106 18 and before Part 20 assessments are done to support the 19 assessments for Part 20.
20 So in terms of doing that integration, some 21 information that had been in the shielding chapter that 22 was more appropriate to be in the radiation protection 23 chapters was moved over there. Some information that 24 was more of a shielding type review was then moved from 25 the radiation protection chapter to the shielding NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 1 chapters. And the characterization of what was being 2 looked at and the findings were revised to be clear 3 on those points.
4 We incorporated our staff review 5 experience and practice for knowledge transfer. We 6 know that there have been some interesting cases that 7 have come involved in the shielding area. And so in 8 ensure that those experiences are adequately captured 9 so that if, say, those experiences were to happen again, 10 if a similar case were to come, that there would be 11 something that the staff could go to quickly and easily 12 to get an idea of the kinds of things and how to consider 13 that case.
14 And some of that also includes where we've 15 had to reach back to the attorneys and get some 16 clarification on implementation of requirements in the 17 rule. And so that kind of experience and information 18 has also been captured.
19 And we've clarified various review topics.
20 One of interest possibly or one that seems can be a 21 hot topic, particularly, it happens a lot in 22 transportation is with dose conversion factors. So 23 the explanation has been enhanced in terms of what dose 24 conversion factors we accept and the reasons for that 25 going back to the dose limit terminology and the rule NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 versus what's out there available in the public for 2 conversion factors. That's just an example.
3 Also, at various cases, the confinement 4 review and the thermal review sometimes need to obtain 5 help from the shielding reviewers for things like the 6 decay heat from the spent fuel that's based on the 7 proposed contents specifications or the radionuclide 8 inventory that they need to evaluate for containment 9 and confinement releases.
10 And since the shielding reviewer uses the 11 code to determine the shielding, the radiation source 12 term, that code also is adequate and appropriate and 13 also produces the decay heat evaluations and 14 radionuclide inventories depending on the parameters 15 for the spent fuel that you put into it.
16 Lastly, there was ISG-17. This is for 17 storage under Part 72 of Greater-Than-Class C waste.
18 This is a specific license issue only. And what we 19 did there was we ensured that that was appropriately 20 captured. Now, the ISG itself had an appendix that 21 proposed waste to modify the guidance. However, how 22 it was incorporated into the shielding chapter is a 23 little bit different from that.
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72 1 Greater-Than-Class C waste as part of specific license 2 amendments and is consistent with the statements and 3 consideration for the rule and the basis for why the 4 Greater-Than-Class C waste was added to Part 72.
5 So if there are no questions --
6 MEMBER REMPE: I have a question.
7 MR. CALL: Okay.
8 MEMBER REMPE: In the section, you talk 9 a couple of times about independent confirmatory 10 analysis.
11 MR. CALL: Okay.
12 MEMBER REMPE: Can you tell me just from 13 your experience what triggers the need for such 14 independent calculations historically?
15 MR. CALL: Sometimes that depends a lot 16 on the uniqueness of the application. Perhaps the dose 17 rates that are being estimated or maybe in terms of 18 working with a radiation protection reviewer who 19 usually is the same person as the shielding reviewer 20 how the estimated doses are in terms of the regulatory 21 limits.
22 So if dose rates are unusually high 23 compared to what have been typically seen for spent 24 fuel casks, that might be a trigger to have the reviewer 25 look at it and say, well, do I need to check to see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 something is okay?
2 Now, the confirmatory may be they might 3 just look more at what the sample input that the 4 applicant has provided. So they might not necessarily 5 do a detailed calculation on their own or they might 6 do some simplified calculations with the computer codes 7 that we have.
8 So there should be a section in there that 9 talks about what kind of level of effort should be 10 considered in doing an independent confirmatory 11 calculation. That's, I think, toward the end of the 12 review guidance of the Chapter 6, if I remember right.
13 I can pop that out here quickly, hopefully. I believe 14 it's Section 6.5.4.4.
15 MEMBER REMPE: Okay. Thank you.
16 MEMBER KIRCHNER: Mike?
17 MR. CALL: Yes.
18 MEMBER KIRCHNER: In practice, how is the 19 industry evolving? Are they evolving to a standard, 20 a certified cask and a standard overpack? And how does 21 that impact your workload and need for independent 22 review?
23 It would seem to me that they would -- going 24 back to one of my earlier points would be probably 25 designing and certifying such casks for a bounding NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 envelope and then that gives them flexibility or the 2 user of the cask flexibility in how it's loaded and 3 still stay within the shielding and dose guidelines 4 and thermal limits.
5 MR. CALL: There is a little bit of 6 different approaches between the different vendors that 7 I'm aware of that I've seen. In terms of how they 8 specify the contents and how they would propose to limit 9 the contents in terms of how they do the evaluations.
10 In terms of the hardware itself, there is fairly 11 defined, fairly consistent. There have been some 12 unique differences that have come along.
13 For example, we've had one vendor instead 14 of using a concrete cask that's a vertical silo above 15 ground, they have something in ground. And so the soil 16 surrounding this canister or in the steel sleeve that 17 it's in is more along the lines of the -- is the shielding 18 itself. And that can produce a unique scenario.
19 For example, usually when a general 20 licensee is wanting to expand their ISFSI and add more 21 casks out there, they have to do whatever excavation 22 to put pilings in, pour the pad, and then have more 23 room to put a vertical cask on. They're not disturbing 24 the shielding in that case.
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75 1 where you're relying on that soil, now you're disturbing 2 the soil next to it at a certain point. So there's 3 certain aspects again to that. But for the most part, 4 in terms of the metal casks or the concrete casks, those 5 that are vertical silos or the horizontal modules, those 6 are fairly consistent in terms of the hardware that's 7 looked at.
8 And so a lot of in terms of what we would 9 look at would be more of the content variations may 10 be there. But is it much? Are we seeing significantly 11 different dose rates versus what we've seen in past 12 experience where we found things to be acceptable?
13 And if they're fairly consistent with what we've done 14 there, then we might not do as much in terms of an 15 calculation or analytical analysis of what they've done 16 to confirm. I hope that gets to your question.
17 Next on the criticality chapter, you're 18 going to hear from me for a little bit. I think I have 19 a few chapters, so they put me one right after the other.
20 The criticality chapter, one of the 21 important things we did is we incorporated ISG-8, Rev.
22 3 which deals with burnup credit. Previously, when 23 we were updating NUREG-1536 to Revision 1 back in 2010, 24 this revision of ISG-8 was still undergoing process 25 and there had been some discussions to hold off on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 incorporating the ISG until Rev. 3 was completed.
2 So that's been completed for a few years 3 now. We've incorporated that. There had been some 4 minor additions to address further clarifying the scope 5 of what that ISG has been -- that guidance is based 6 off of and how things a little bit outside of that might 7 have to be addressed on a more case-by-case basis.
8 Those kinds of things, for example, ISG-8 9 is more focused on your PWR light water reactor fuel.
10 We've been doing some things in terms of BWR, but the 11 ISG guidance for that, that has come since ISG-8, Rev.
12 3. And so that kind of stuff, there's minor discussions 13 to address and point out aspects related to BWR fuel, 14 MOX fuel, and other unique things that worked within 15 the scope of what ISG-8, Rev. 3 was considering.
16 Again, clarifying certain review points 17 and regulatory requirements as needed, some of this 18 deals with questions that we've received from industry 19 via letters from specific entities, whether a licensee 20 or a vendor. For example, there's a requirement in 21 72.124(c) for criticality monitoring and under what 22 scenarios that criticality monitoring is required and 23 what that entails.
24 So we've had public meetings and responses 25 to letters that gone out in times past that have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 clarified what we found to be acceptable for use as 2 monitoring, when it's required which is very limited 3 for the rule. If you look at the rule, very confined 4 in terms of what conditions monitoring is required for.
5 And we've updated information to include 6 latest available tools for knowledge transfer. The 7 staff uses the scale code which is developed by Oak 8 Ridge. They've improved the capabilities for 9 examining these multi-group analysis or continuous 10 energy cross sections for your nuclear data. There 11 are also tools to -- when we look at the benchmark 12 analysis that are available for the staff to evaluate 13 whether the benchmark analysis for applicant's 14 criticality code calculations are appropriate or 15 acceptable.
16 MEMBER MARCH-LEUBA: So about Chapter 7 17 --
18 MR. CALL: Okay.
19 MEMBER MARCH-LEUBA: -- I'm reading here 20 that this requirement that the k-effective must be less 21 than .95 for all conditions including handling, 22 packaging, transfer, and storage.
23 MR. CALL: Yes, sir.
24 MEMBER MARCH-LEUBA: Now the question is 25 if I have a facility in Texas and I'm asking for a license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 for another facility and the fuel is going to be packaged 2 in a reactor in Ohio.
3 MR. CALL: Right.
4 MEMBER MARCH-LEUBA: Does the Texas 5 license cover the reactor in Ohio?
6 MR. CALL: So --
7 MEMBER MARCH-LEUBA: Because that's what 8 this says.
9 MR. CALL: So you're looking at in terms 10 of where a facility is receiving already-packaged fuel 11 but they're not going to be loading or unloading.
12 MEMBER MARCH-LEUBA: Your SRP tells me if 13 I want to license a facility in Texas, I have to 14 guarantee to you that the guys in Ohio are going to 15 load it properly.
16 MR. CALL: That is not what the SRP 17 intending to mean.
18 MEMBER MARCH-LEUBA: That's what it says.
19 I'm guessing it's not what you mean.
20 MR. CALL: The SRP, the way it's set up 21 is -- I mean, that is a particular type of scenario.
22 That's fairly specific to a particular license -- an 23 away-from-reactor license where they wouldn't be doing 24 their own packaging or loading or unloading. So 25 whatever the licensee has done, they would've had that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 particular licensee where the fuel was dealt with and 2 put into storage originally. That would be dealt with 3 by them.
4 Of course, the licensee receiving the 5 package would have to ensure that what they were 6 receiving is within the conditions of their license.
7 So however, what I would say more on the acceptance 8 testing -- or not acceptance testing, that's the wrong 9 words -- the receipt inspections, to ensure that they 10 have things that are consistent with the conditions 11 of their license, that's where they would be looking 12 to do that.
13 For example, something like that, what they 14 might be looking at incorporating by reference 15 something that's already been done and saying, we're 16 not necessarily doing that. But to show that even this 17 is here, it's incorporated by reference so they wouldn't 18 have to do the evaluations again for themselves.
19 MEMBER MARCH-LEUBA: And my point is I'm 20 sure that's the way you're going to do it when you're 21 doing it. But isn't that what the SRP tells you to 22 review? So there are some inconsistencies there.
23 MR. CALL: Well, we can put a specific 24 note, I think, maybe.
25 MEMBER MARCH-LEUBA: I know --
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80 1 MR. CALL: Because that's a more general 2 thing that's not just specific to the Chapter 7.
3 Because you would see that kind of play in different 4 areas maybe in the front matter, if it's not already 5 there, to add something to clarify for. And I think 6 we may have had something with regard to that based 7 off of a comment that we received from the public 8 comments to -- in a general area, note that.
9 MEMBER MARCH-LEUBA: When I'm sending you 10 a license, I don't want to have to be taking exceptions 11 from the SRP because this doesn't apply, this doesn't 12 apply.
13 MR. CALL: Right. Well, and for example, 14 in that particular case, you're going to be dry. And 15 so it's going to be --
16 MEMBER MARCH-LEUBA: That will be a clear 17 one which it's an exception and it clearly doesn't 18 apply. But it will be nice if the SRP already tells 19 you.
20 MR. CALL: It may not be in the crit 21 chapter. It might be in more of the front matter to 22 explain certain areas.
23 MEMBER MARCH-LEUBA: Look for it.
24 MR. CALL: Okay.
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81 1 facilities in play right now where fuel is moved from 2 various reactor sites to a centralized place already 3 which it would be a similar scenario in a place?
4 MR. CALL: There's one facility that has 5 been licensed but it's not operating.
6 CHAIR SUNSERI: Okay.
7 MR. CALL: And that would be private fuel 8 storage. In terms of other away-from-reactor license 9 facilities that have had fuel moved to them, you would 10 have the TMI 2 ISFSI in Idaho from the TMI Unit 2.
11 And you would have St. Vrain, I believe. Well, I think 12 there is St. Vrain fuel or Peach Bottom fuel that's 13 up in Idaho as well as ISFSI -- okay, I'm getting a 14 head shake no. That's not correct. Never mind. I'll 15 take it back.
16 The only instance then I could think of 17 from the TMI 2 fuel debris that was moved from Unit 18 2 after the accident from the cleanup and moved to the 19 Idaho ISFSI. But other than that, there have not been 20 any that have been moved from a particular license out 21 to a different location that I'm aware of. I'm going 22 to take a note here. Any other questions? Okay.
23 MR. WISE: Good morning. Again, my name 24 is John Wise. I'm a materials reviewer. The materials 25 chapter -- as we've discussed already, the materials NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 chapter in particular was ripe for opportunities to 2 provide more details and more references. And we took 3 that opportunity to do so, although we certainly will 4 take any other additional comments.
5 The materials chapter, by and large, our 6 position as you've heard this story already in the other 7 chapters, we didn't change our staff positions in our 8 revision of this chapter. But we did take the 9 opportunity to reorganize it in a more coherent manner.
10 And we did revise it to provide a lot more detail.
11 The materials area in particular is very 12 reliant on knowing where to find information, whether 13 it'd be mechanical property information from a 14 particular handbook or whether it's corrosion rate 15 information. In our chapters, there's a lot of 16 importance placed on the reviewer to find that 17 information in order to perform our review.
18 So we took that opportunity and we did a 19 lot more detail and many, many references. And I'm 20 just giving you an example here on this first slide 21 of what that might mean. Like, our current guidance 22 in 1536 is that's the general license guide, a standard 23 review plan.
24 You have these very high level comments 25 like, reviewers should analyze the potential for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 corrosion. And it doesn't go really much more than 2 that. And you can imagine it doesn't lend itself to 3 a terribly consistent review from reviewer to reviewer.
4 And it doesn't give the applicant a whole lot of 5 knowledge about what they're going to be asked about 6 when they come in for an application.
7 And so in practice, we've compensated for 8 that by internally sharing our knowledge with the 9 materials reviewer. So okay, what does it mean to ask 10 for somebody to demonstrate that corrosion won't affect 11 the performance of these components?
12 So in this new document, we took the 13 opportunity to really pull through that. We have a 14 whole new corrosion resistant section that's broken 15 out with the different materials, including references 16 of where to go, what handbooks to go to find corrosion 17 data for various materials. So that's just one example 18 of where we took an opportunity to really bolster the 19 amount of detail to really help the reviewer out and 20 help the applicant out. Next slide.
21 CHAIR SUNSERI: Well, I think --
22 MR. WISE: Yes.
23 CHAIR SUNSERI: -- that's a good example 24 of what you've been hearing from individual committee 25 members today about where there may be some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 1 institutional information that is not new technical 2 but it's new to be incorporated into the reference 3 document. And so highlighting that and making it 4 explicit is a good thing.
5 MR. WISE: Yes, message received. We will 6 certainly be looking, scrubbing this, taking these 7 comments into account for finding every opportunity 8 to really reference those, the basics for numbers you 9 see, et cetera. And that kind of leads us to the next 10 slide that specifically talks about the spent nuclear 11 fuel.
12 Now, we're kind of in an odd situation.
13 We have actually three guidance documents in progress 14 that all talk about spent nuclear fuel. And so in some 15 cases, we're juggling what goes in which document.
16 For example, we have the standard review 17 plan, how to review new applications for storage. Many 18 of you are familiar with the NUREG-2214 or the managing 19 aging processes and storage report which is about aging 20 management issues with all spent fuel components --
21 storage system components including fuel. And that 22 talks about the various aging degradation mechanisms 23 for spent fuel cladding, for example.
24 And then we have another document in 25 progress, NUREG-2224 that's specifically about high NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 burnup fuel. And that is coming your way a little bit 2 later this year. And it's really, we have a large 3 section in that particular document that's going to 4 be going out for public comment in a few months and 5 then circling back to this group later this year.
6 There's a large section of that document 7 that gets to telling the history of how we got to the 8 various recommended temperatures, et cetera. And so 9 it's there. So we've going to have to talk about how 10 best to make sure that we do everything we can to this 11 document to make it as complete as possible now, knowing 12 that that other document still has to go through a public 13 comment period and your review.
14 So we'll talk about that. The materials 15 reviewers will look at that and see, are there 16 opportunities for maybe some information in that NUREG 17 that might be able to be rolled into here? But again, 18 we're careful because we hadn't entered this process 19 intending to change our guidance here. You've heard 20 that story already several times. But we'll look for 21 opportunities to make sure this is as complete as 22 possible.
23 MEMBER REMPE: And I appreciate you did 24 have a lot of references that are in your Section 8, 25 especially compared to what I found in the thermal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 section. I would note that the thermal analysis 2 section has a temperature for peak cladding of stainless 3 steel. And your section, when you talked about the 4 peak cladding temperatures for the Zircaloy based 5 clads, you did provide a reference but you're silent 6 on anything --
7 MR. WISE: Okay.
8 MEMBER REMPE: -- stainless. So --
9 MR. WISE: Well --
10 MEMBER REMPE: -- look at them together 11 and I don't think you need to repeat the information 12 in both places. But try and coordinate and make sure 13 that it points to your chapter if that's where you want 14 to put all this information and that your chapter has 15 everything to support what's in the thermal --
16 MR. WISE: You're --
17 MEMBER REMPE: -- analysis section.
18 MR. WISE: -- understood.
19 MEMBER REMPE: Thank you.
20 MR. WISE: Again, what happened in 21 materials spent fuel area, again, we didn't change any 22 positions going into this new document. There was an 23 ISG that got rolled in that had been previously gone 24 out. So it was current guidance but we took the 25 opportunity to put it in and that's the ISG-24 that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 talks about demonstrating the performance of the high 2 burnup fuel cladding.
3 And that gets to actually the EPRI-DOE 4 demonstration cask that actually was loaded, I don't 5 know, six month ago. And maybe that's not right, but 6 at North Anna. And so that's just referencing that 7 activity that is, in part, to demonstrate the integrity 8 of the cladding in the long term, beyond 20 years.
9 In the initial comments by Jeremy when we 10 started today, there were comments from the industry 11 and one of them was about this information notice on 12 noble fission gas releases. And it was an issue where 13 we knew we were going to issue this information notice 14 but it hadn't gone out yet. But we kind of wanted it 15 to be referenced in this document.
16 And so we put the content of the information 17 notice in this document knowing that that information 18 notice was about to go out. And in the comment we got 19 from NEI was they were concerned that by kind of copy 20 and pasting that information notice into the standard 21 review plan that we might be inadvertently setting new 22 requirements of what a reviewer would be looking at 23 from an applicant.
24 That was never really our intention. Our 25 intention was just that it have a reference to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 information more for knowledge management purposes.
2 And so as Jeremy discussed earlier and as we discussed 3 in our public meeting with NEI that we'll be revising 4 this, it looks like, to simply provide that as a 5 reference and just be clear that there was no 6 expectation we were trying to impose new requirements 7 on a fuel characterization. And that's what that 8 information is about.
9 And I think we got positive feedback during 10 a public meeting about our resolution on that. We 11 provided a little bit more detail about the cladding 12 mechanical properties. Again, it's something that's 13 been a practice of ours but it actually wasn't in our 14 standard review plan. And that's about it.
15 And so again, the materials chapter and 16 summary was we tried to take the opportunity to make 17 it more coherent and more detailed. And we will 18 continue to do so based on our comments.
19 MEMBER STETKAR: John, can you help me with 20 something? This actually is what kind of started me 21 a bit on my risk-informed quest. So I'm going to have 22 to set this up, so bear with me for just a moment.
23 In Section 5.5.1.1 of the NUREG, there is 24 the following statement: Ensure that during storage 25 the spent nuclear fuel cladding is protected against NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 degradation that could lead gross fuel rupture and is 2 otherwise confined such that degradation of the fuel 3 during storage will not pose operational problems with 4 respect to its removal from storage.
5 For each type of fuel assembly proposed 6 for storage, confirm that the systems ensure a very 7 low probability, for example, 0.5 percent per fuel rod 8 of cladding breach during long-term, e.g. 40-year 9 storage. Okay. I see that.
10 How many fuel rods are there typically in 11 one of these casks?
12 MR. WISE: Boy, I'm trying to think. I 13 may have to phone a friend here. Ricardo or Meraj, 14 do you want to stand up?
15 MR. RAHIMI: And typically for the PWR 16 cask, you've got 37 PW over 200 rods in each fuel 17 assembly. So 37 times 200, that's the numbers of rods.
18 MEMBER STETKAR: Yes, I was guessing 19 depending on whether it was 15 by 15 or 17 by 17, anywhere 20 from, oh, 5,000 to 8,000 or so. So that says, well, 21 very low probability of cladding breach translates into 22 anywhere from, like, 25 to 40 or so rods over the life 23 of a cask with that very low probability, if that's 24 what that means.
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90 1 cite, for example -- and let me get this on the record 2 also -- 10 CFR 72.122(h)(1) actually states that the 3 spent fuel cladding must be protected during storage 4 against degradation that leads to gross ruptures where 5 the fuel must be otherwise confined such that 6 degradation of the fuel during storage will not pose 7 operational safety problems with respect to its removal 8 from the storage. That's the quote from the 9 regulation.
10 In Section 8.5.13.1, you say, the staff 11 considers a gross cladding breach as any cladding breach 12 that could lead to the release of a fuel particle greater 13 than the average size fuel fragment. You then go on 14 to say, modeling the fragments as either spherical or 15 pie-shaped pieces indicates that a cladding crack with 16 of at least two to three millimeters would be required 17 to release a fragment. Hence gross breaches should 18 be considered to be any cladding breach greater than 19 one millimeter.
20 Now, what does this all mean in terms of 21 risk? Does it mean that I have to ensure that I have 22 less than -- over the 40-year life of a cask, less than 23 -- I don't know, I'll use a round number -- 50 one 24 millimeter cladding breaches? And how do I do that 25 and how does that translate into risk to the health NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 and safety of workers and the public? And yet this 2 is what's in your guidance. So how do I interpret that 3 when I go apply for a license?
4 MR. WISE: Well, that's a big question.
5 MEMBER STETKAR: Well, it is. But indeed, 6 if I start thinking about what this is telling me, it 7 says, first of all, it establishes less than .5 percent 8 is a very low probability.
9 I don't know where that comes from, but 10 that establishes -- we've now established on the record 11 that means somewhere about 25 to 40 fuel rods with 12 breaches are apparently -- I don't know -- acceptable 13 or that's what I have to show that I have to be less 14 than that or not sure. And then what is a gross breach?
15 Well, a gross breach? Well, a gross breach apparently 16 is one millimeter.
17 MR. TORRES: This is Ricardo Torres. So 18 I'm a materials engineer and in the division. I'm the 19 primary author of that information notice 2018-01 which 20 deals with noble fission gas releases during spent fuel 21 loading operations.
22 MEMBER STETKAR: That's --
23 MR. TORRES: So --
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92 1 releases. I'm talking about breaches of the cladding 2 during long-term storage. It's sitting --
3 MR. TORRES: Sure.
4 MEMBER STETKAR: -- out on the pads --
5 MR. TORRES: All right.
6 MEMBER STETKAR: -- such that the cladding 7 does not degrade either through corrosion or whatever.
8 MR. TORRES: So let me --
9 MEMBER STETKAR: It would --
10 MR. TORRES: -- back up.
11 MEMBER STETKAR: Okay.
12 MR. TORRES: So with respect to the 13 criteria for gross ruptures, that actually comes 14 straight from ISG-1, Revision 2 which was incorporated 15 into this document. So that's just the first thing 16 that I wanted to mention with respect to that.
17 With respect to fuel qualification testing 18 which is what actually licensees do to demonstrate 19 whether or not they comply with the technical 20 specifications which identify whether or not you have 21 undamaged, intact, or damaged fuel.
22 What they generally do is they qualify the 23 fuel by sipping, by reactor operating records, by 24 ultrasonic testing the current. There are a number 25 of methods that are used for fuel qualification testing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 to make sure that the fuel that's actually loaded in 2 the cask complies with the technical specifications 3 and the condition which was analyzed in the safety --
4 in the design basis safety analysis.
5 And that actually leads me to the 6 information notice. The reason why we incorporated 7 the information from the information notice was we 8 recognize that this standard review plan was -- or I 9 guess prior standard review plans and our prior guidance 10 was very vague and on what the staff consider acceptable 11 or what were potential issues associated with fuel 12 qualification testing to ensure that the fuel that's 13 actually loaded in the designs complies with the 14 technical specification.
15 That's why we added that appendix which 16 NEI brought up, well, it's imparting additional 17 requirements. But we decided, well, we're going to 18 take it out. We'll just reference the IN. But in the 19 background section of the IN, you will find an extensive 20 discussion of what actually licensees do to make sure 21 that the fuel that's loaded in the cask to provide 22 reasonable assurance to our inspectors when they go 23 on site to evaluate the fuel selection records just 24 to make sure the complies with the design.
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94 1 your explanation. But since we're now into something 2 technical, maybe all the process was losing me. So 3 that's loading.
4 MR. TORRES: That's correct.
5 MEMBER CORRADINI: But the requirement is 6 40 years. So how do I do it 40 years hence?
7 MR. TORRES: So the --
8 MEMBER CORRADINI: Or is the assumption 9 is it --
10 MR. TORRES: -- reasonable assurance --
11 MEMBER CORRADINI: -- doesn't degrade 12 beyond?
13 MR. TORRES: Yes, we obtained reasonable 14 assurance that the fuel will remain in the analyzed 15 configuration by making sure that the peak cladding 16 temperatures are not exceeded which provides a 17 technical basis for assessing what is the long-term 18 degradation known as creep, hydride reorientation and 19 so on. That's one component.
20 The other one is providing an inert 21 environment to the fuel during loading operations 22 preventing any inadvertent ingress of oxidizing species 23 which actually leads to this ISG-22 which got 24 incorporated and discusses, well, what if you don't 25 want to use an inert environment? Or if oxygen gets NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 in there, what are the repercussions to that? That's 2 the guidance, ISG-22.
3 So we obtained reasonable assurance by 4 making sure that peak cladding temperatures are not 5 exceeded, by making sure that the loading conditions 6 are adequate, that the environmental fuel is 7 maintained. And ultimately, that serves to meet 8 72.122(h)(1) which is saying you have to prevent the 9 gross ruptures from occurring. That's our basis.
10 MEMBER CORRADINI: So let me just go a 11 little bit further. So if I understand this correctly, 12 there is a series of temperature, chemistry, humidity 13 controls that have to be maintained after I've 14 concluded, as John said, that 25 to 50 of these things 15 don't have -- do the sipping or some sort of initial 16 loading sampling are not greater than a certain number 17 and therefore implies a certain size hole, right?
18 MR. TORRES: Yes.
19 MEMBER CORRADINI: So how did the hole size 20 -- what calculation is -- what is the technical basis 21 for the original one millimeter? Because my -- again, 22 I could be wrong. But my guesstimate is that seems 23 that the consequences of such a release are very small 24 which means you've must have done some calculation that 25 says, I have a release. I have this sort of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 1 decontamination inside the canister. I have this sort 2 of decontamination around the concrete shielding. It 3 disperses and I still have a problem. Where is that 4 technical basis?
5 MR. TORRES: Okay. So the technical basis 6 for the one millimeter gross structural criteria is 7 in the appendix through ISG-1, Revision 2 which was 8 issued back in 2003. So with respect to risk, my 9 presumption from 15 years ago is that risk was not 10 necessarily a consideration in the drafting of ISG-1, 11 Revision 2. The idea of providing that one millimeter 12 criteria was to help licensees as they go through their 13 fuel qualification testing, well, really what are we 14 looking for?
15 So in practice, what generally happens is 16 if they sip the fuel and they see some sort of release, 17 they just qualify generally as damage conservatively 18 and they can it because they don't want to go in and 19 inspect. Well, is it one millimeter? Is it less than 20 one millimeter?
21 So how it's implemented in there is from 22 licensees to licensees. But what this SRP does and 23 what it was attempting to do is provide additional 24 guidance with respect to what we consider acceptable.
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97 1 the inert environment, and all the environmental 2 conditions, that still remains as it was before.
3 MEMBER CORRADINI: So okay. That's very 4 helpful. So if I've got this right, consequences, per 5 se, were not the driver for the technical basis.
6 MR. TORRES: That's correct.
7 MEMBER CORRADINI: It was essentially ease 8 of identification and then remediation before 9 placement?
10 MR. TORRES: That's correct. That's 11 correct.
12 MEMBER CORRADINI: Okay.
13 MR. TORRES: Whether or not now in the 14 future we consider, well, what's really the 15 implications with respect to risk of this, a fuel 16 particular comes out of this one millimeter hole, that 17 would be something that we would look in a future 18 revision to the materials chapter. For now, we kept 19 the exact same technical basis as ISG-1, Revision 2.
20 That was our task.
21 MEMBER STETKAR: You said -- I just want 22 to make sure that I've got this. ISG-1, Revision 2 23 indeed is titled classifying the conditions of spent 24 nuclear fuel for interim storage and transportation 25 based on function. We're talking about the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 1 document?
2 MR. TORRES: That's correct.
3 MEMBER STETKAR: You cited an appendix 4 giving the technical basis, the appendix being about 5 two-thirds of a page long and doesn't have anything 6 technical in it.
7 MR. TORRES: Well, there is a --
8 MEMBER STETKAR: It has criteria.
9 MR. TORRES: It could not be in the 10 appendix. It could be in the main text.
11 MEMBER STETKAR: Oh, okay.
12 MR. TORRES: There is a discussion of the 13 assumptions. It's the same --
14 MEMBER BALLINGER: Part A of the 15 discussion.
16 MR. TORRES: -- set of assumptions.
17 MEMBER STETKAR: Part A of the discussion?
18 Okay, sorry.
19 MR. TORRES: Sorry. I don't have the 20 document in front of me and it's been a while since.
21 MEMBER STETKAR: Thank you.
22 MR. TORRES: Sure. I hope that helps.
23 MEMBER STETKAR: That helps me a little 24 bit. Thank you.
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99 1 if I look at Section 8.5.13.2.5, just out of curiosity, 2 you have thermocycling during drying operations. And 3 you're saying the reviewer should review the fuel 4 loading procedures to assure that any repeated 5 thermocycling during loading operations is limited less 6 than ten cycles and that the cladding temperature 7 variations during each cycle don't exceed 65 degrees 8 C. How would a reviewer do that?
9 MR. WISE: Well, that's the -- the 10 reviewer, when they're reviewing an application, 11 they're looking at the loading procedures section of 12 the application. And so the loading procedure, we 13 would expect to see that in the procedures. And after 14 that, it becomes an inspection issue. Whether they 15 follow the procedure or not, that's an inspection issue.
16 From a reviewer approving the application, I want to 17 be able to see their loading procedures and I want to 18 see these limits.
19 MEMBER REMPE: Do you let them to have a 20 thermocouple on every fuel that's gone in an assembly?
21 MR. WISE: Oh, so you're referring to 22 exactly how -- the means by which they will verify that?
23 MEMBER REMPE: Right.
24 MR. WISE: Yes, I think of it as 25 analytical. I've got to admit. I didn't --
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100 1 MEMBER REMPE: Yes, and so --
2 MR. WISE: I wasn't sure.
3 MEMBER REMPE: -- those kind of questions 4 I think, again, are things that ought to be thought 5 about with a critical mind before you put it in an SRP.
6 MR. WISE: Yes, I mean, it's --
7 MEMBER REMPE: Because --
8 MR. WISE: -- we believe in the numbers.
9 And so if there's an analytical approach that show 10 those numbers will be maintained, that's fine.
11 MEMBER REMPE: Okay. It's a validated 12 model --
13 MR. WISE: And so --
14 MEMBER REMPE: -- with experimental data 15 or something, right? And it's not --
16 MEMBER KIRCHNER: May I add in? So it's 17 interesting that these numbers have such precision.
18 So what empirical basis is behind these?
19 MR. WISE: Yes, and that gets to we 20 probably have an opportunity for putting some of the 21 information that's now in NUREG-2224 which was the basis 22 for some of this in here. Or we'll look for the 23 opportunity --
24 MEMBER REMPE: And just be careful because 25 --
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101 1 MR. WISE: -- because -- yes.
2 MEMBER REMPE: -- it's not so precise, I 3 think.
4 MR. WISE: Yes.
5 MR. TORRES: This is Ricardo Torres again.
6 Just go back to the actual numbers in ISG-11, Revision 7 3. The 65 degrees Celsius comes from the hysteresis 8 between this solution on precipitation of hydrogen 9 which was a consideration for the phenomena of hydride 10 reorientation and the implications as to whether or 11 not that mechanism could affect the mechanical 12 properties of the fuel down the long -- or the fuel 13 cladding in the long term. So that's --
14 MEMBER REMPE: So really what you're 15 looking for is an analysis that shows that you -- a 16 way belong that that there's enough confidence in that 17 you don't get to that number. And those kind of things 18 I think should be included in the guidance instead of 19 having some reviewer saying, I'm going to see some 20 temperatures here.
21 MR. TORRES: So we actually work also with 22 the thermal reviewers to make sure that the thermal 23 transience during the typical loading operation does 24 not result in those 65 degree drops that could maximize 25 hydride reorientation. But I'll just remind you guys NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1 that there's another document that also deals with 2 hydranal fuel that we'll present to you guys later this 3 year. And that will also explain what's our path 4 forward with respect to hydride reorientation and the 5 significance of that 65 degrees Celsius temperature 6 change.
7 MR. SOLIS: And this is Jorge Solis, a 8 thermal engineer. I'm just going to clarify that 9 that's another thing that we demonstrate in the thermal 10 section. And there's guidance about it and --
11 MEMBER REMPE: But there needs to be some 12 coordination.
13 MR. SOLIS: There is, yes.
14 MR. BOROWSKY: Good morning. My name is 15 Joe Borowsky. I'm a thermal and confinement reviewer 16 for the Division of Spent Fuel Management. I'll give 17 you a brief summary of the confinement work related 18 to the SRP.
19 There were no changes to the staff's 20 position regarding confinement. Figures and tables 21 were updated, specifically Figure 9-1 was updated to 22 show the interrelationships among the type of 23 discipline and review areas. In addition, Table 9-1 24 was updated to capture relevant regulations that are 25 used for the confinement review.
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103 1 In the text, most of the edits were 2 editorial in nature, including word choice and 3 clarifying text. As an example, clarifying 4 terminology and discussion were included as it relates 5 to dose calculations including a description of whole 6 body does and the assumptions of uniform body exposure 7 when calculating the dose.
8 MR. CALL: This is Mike Call again, 9 shielding, criticality reviewer. So there are two 10 chapters for radiation protection in the SRP and that's 11 because the scope of the different chapters, depending 12 on whether you're looking at a cask certificate or a 13 specific license for a facility.
14 Some of the significant differences 15 including for the facility license, it's a licensee 16 so you're also looking at evaluations or assessments 17 and discussions related to Part 20 and Part 20 programs, 18 looking more at various aspects of the Part 72 19 requirements dealing with radiation protection than 20 you necessarily do with a cask system.
21 So because of the scope was significantly 22 different and it was deemed to best to keep the two 23 chapters separate and to avoid a lot of confusion that 24 could've possibly arisen from trying to intermix them.
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104 1 chapter, we've done effort to improve the integration 2 of the review guidance with the radiation protection 3 chapter and the other chapters that feed into the 4 radiation protection review, including the shielding 5 chapter where you have the direct radiation dose rates, 6 confinement if there are any effluent dose rates that 7 are calculated, and waste management chapters which 8 may or may not have some of the same kinds of things 9 depending on the design of the facility.
10 We've incorporated again staff review 11 experience and practice for knowledge transfer, the 12 various things that I've mentioned for the shielding 13 chapter in terms of some unique cases and difficult, 14 challenging cases that we've seen and how we've 15 addressed those, including any input that we received 16 in the application of regulatory requirements from the 17 attorneys.
18 We've also clarified certain review 19 topics. Just to give an idea, let's see, some of that 20 clarification dealt with, I believe, more of the 21 incorporation and updating of references to the 22 industry standards as well as Reg Guides as those have 23 been updated since the last time NUREG-1567 was updated 24 dealing with difference. And so I think that that 25 covers those chapters. Are there any questions?
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105 1 Chapter 13 is the waste management chapter.
2 Just to note that this is for specific licenses only.
3 And so this came directly out of NUREG-1567. Again, 4 there were some integration that I mentioned before, 5 things that were more important to be in the waste 6 management chapter such as, for example, there was 7 information in the confinement chapter previously for 8 confinement evaluations that weren't related to the 9 casks themselves.
10 And because the casks is what the storage 11 system is, it was the staff made the distinction for 12 anything that was -- the other thing would be for any 13 kind of effluent that may or may not happen, depending 14 on the facility design. If we're dealing with 15 effluence from that, we would put that in the waste 16 management chapter.
17 Anything that was specific to dealing with 18 dose assessments perhaps were more in the radiation 19 protection chapter. And so again, this waste 20 management chapter feeds into, in that regard, the 21 assessments that come in the radiation protection 22 chapter.
23 I think what we also did in terms of we 24 added a little bit the standard format and content reg 25 guides for facility licenses, for the SAR for facilities NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 licenses. So we looked at the guidance that was in 2 there and information in those guides that seem to be 3 appropriate also to be in the SRP for the staff to be 4 aware of so they wouldn't have to go back to multiple 5 documents. We incorporated that as well.
6 And I believe that concludes that unless 7 there are questions.
8 MR. SMITH: Again, this Jeremy Smith. Oh, 9 sure.
10 MEMBER REMPE: Matt gave us assignments 11 that we had to look at, and he assigned me to Chapter 12 16. And is there someone here were I could ask 13 questions to Chapter 16, or did I waste my time? I've 14 got questions on it.
15 MR. SMITH: Sure. You can ask any 16 questions that you'd like. We should have the staff 17 in the room to represent it. The presentation only 18 covered kind of a sampling of changes that were made.
19 MEMBER REMPE: Okay.
20 MR. SMITH: But we welcome any questions.
21 MEMBER REMPE: Okay, good. Because I 22 didn't want to waste my time. But anyway, first of 23 all, basically on page -- in Section 16.46 on page 569 24 out of 617, I think you really should think about asking 25 some typical -- or providing some typical instruments NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 1 and control systems that need to remain operable.
2 How often do partial blockage events occur 3 in your experience? Because I mean, that's something 4 you talk about you're going to be monitoring. How often 5 do they occur? Is it every spring? Once a year? I 6 mean, do the birds get in? I think I remember hearing 7 stories about some birds getting into some of them at 8 one time. But has it occurred very often?
9 MR. CALL: I can't put a number to the 10 occurrences, but it does occur, whether it's, like 11 you've mentioned, birds or some other animal causing 12 some type of issue with nests, if there's excessive 13 snowfall --
14 MEMBER REMPE: So maybe --
15 MR. CALL: -- things like that, but I can't 16 --
17 MEMBER REMPE: -- but not once a year but 18 it does occur with the frequency that --
19 MR. CALL: It does occur. It's not --
20 MEMBER REMPE: Yes.
21 MR. CALL: I wouldn't say that it's very 22 rare.
23 MEMBER REMPE: Okay.
24 MR. CALL: It does occur, but I can't give 25 you a number.
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108 1 MEMBER REMPE: Okay. Then also tip-over 2 events is something that you're supposed to be 3 analyzing. Has that ever occurred? No?
4 MR. CALL: No.
5 MEMBER REMPE: So maybe again the risk 6 folks that are saying, think about this from a risk 7 perspective, maybe that's something that ought to be 8 considered?
9 MR. CALL: I think that's a nonmechanistic 10 analysis.
11 MR. EVERARD: This Steve Everard, a 12 structural engineer with DSFM. So the applicant is 13 required to demonstrate that due to a tornado missile, 14 seismic event, anything that could cause a cask to tip 15 over that it won't tip over. However, that said, I 16 believe the history is as a defense in depth mechanism, 17 the applicant should show that if the cask tips over 18 that it could structurally survive the tip over.
19 Now, if you have a cask that's horizontally 20 loaded or is underground, clearly a tip-over is not 21 credible. So we wouldn't expect you to demonstrate 22 the cask tip over -- that could survive a cask tip-over 23 event.
24 MEMBER REMPE: Okay. It's been a while 25 since I've read this, but I assume it's noted that if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 1 you have configuration, it precludes that you don't 2 need to do this evaluation.
3 MR. EVERARD: Again, this is guidance.
4 If you're the applicant and you have a configuration 5 that in which tip over is just absolutely not credible, 6 then --
7 MEMBER REMPE: That's a cask.
8 MR. EVERARD: -- you put it in your 9 application and we review it and accept it if it's 10 acceptable.
11 MEMBER REMPE: And the guidance says that 12 too, that you demonstrate that?
13 MR. EVERARD: Yes.
14 MEMBER REMPE: What about safeguards and 15 security events? Where is that addressed? It is 16 addressed someplace else, though? Okay.
17 MR. WHITE: So this is Bernie White, Senior 18 Project Manager in DSFM. For site-specific licenses, 19 security, and other things like the emergency response 20 plan or separate documents are submitted along with 21 the licensing application. So he wouldn't see that 22 in the SAR.
23 MEMBER REMPE: Okay. I think that's 24 enough of my questions.
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110 1 I promised myself that I will always bring this up.
2 We just had someone use the term "credible". I found 3 several citations in the document to the word 4 "credible".
5 What is a credible condition or what is 6 not a credible condition? There's no definition of 7 it in the glossary. It just says if something is not 8 credible, I don't care about it. If it is credible, 9 I do care about it. So what's credible? Getting 10 struck by a meteorite, is that credible?
11 MEMBER CORRADINI: He wants you to talk 12 about probability. He's trying to push --
13 MEMBER STETKAR: No.
14 MEMBER CORRADINI: -- us that way.
15 MEMBER STETKAR: Honestly, because the 16 criteria here says that if something is judged not 17 credible, I don't have to worry about it. If it's 18 judged credible, I do have to worry about it. So who 19 judges what's credible and what is it?
20 MR. WISE: I'm going to give a generic 21 answer and a somewhat specific answer. Specifically, 22 we use that term in the aging management realm and the 23 MAPS to be very clear that we mean that there actually 24 is a degradation mechanism that if operating could 25 degrade the function of a component in the extended NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 operation period.
2 So in that document, we actually defined 3 what credible meant. Now generically -- and I'll just 4 ask the staff to weigh on this as well -- engineering 5 judgment is what it comes down to. If somebody has 6 anything better, please weigh in. But I think it just 7 comes down to engineering judgment.
8 MEMBER STETKAR: Is getting struck by a 9 meteorite credible or not credible? Engineering 10 judgment, you're an engineer.
11 MR. WISE: I'm not a meteorite engineer.
12 I'm not an astronomer.
13 MEMBER STETKAR: But --
14 MR. WISE: I don't know what a meteorite 15 is, so --
16 MEMBER STETKAR: But my whole point is that 17 you are asking people specifically to evaluate certain 18 hazards -- identified hazards within this guidance that 19 may be less credible -- and I will never use the term 20 "incredible" -- that may be less credible than other 21 things that people just blindly, qualitatively says, 22 this is not credible.
23 So as soon as you -- and I'm not going to 24 say anymore because I promised myself anytime anybody 25 uses the term "credible" in one of these meetings, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 1 will challenge them. It's a meaningless term unless 2 you define for an applicant and for a reviewer what 3 you determine is credible and what you determine is 4 not credible. What are those criteria?
5 Some people will say incredible means 6 impossible, cannot happen, physically precluded.
7 Other people will say, no, it's got some motion of 8 frequency. So if it does have some motion of frequency, 9 what is that? And that gets us back into the discord.
10 MR. RAHIMI: There are a couple of terms, 11 credible, non-credible, likely versus unlikely. These 12 are the terms you will see in the Part 72. And 13 historically, what is non-credible -- I mean, on the 14 reactor site -- you look at the reactor sites. Any 15 event that has a probability less than ten to the minus 16 six, it's considered non-credible.
17 MEMBER STETKAR: Well, be careful because 18 there's guidance on the reactor side that says ten to 19 the minus -- anything that's more than ten to the minus 20 seven you have to look at. There's other guidance that 21 says anything less than ten to the minus four you don't.
22 So don't play those games. I've raised the same 23 comments throughout ten and a half years regardless 24 of who the presenters are.
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113 1 on your own petard. If the probability of a canister 2 breach is less than ten to the minus seven, are you 3 saying that's incredible?
4 MR. RAHIMI: Yes, I mean, if --
5 MEMBER BALLINGER: Okay.
6 MR. RAHIMI: -- I look at the --
7 MEMBER BALLINGER: End of story. End of 8 story.
9 CHAIR SUNSERI: If somebody in the 10 audience had something to say, you need to come up to 11 the microphone.
12 MR. CHUNG: My name is Donald Chung. I'm 13 the probability risk assessment analyst in the Division 14 of Spent Fuel Management.
15 There's two ways to look at this here.
16 One is the frequency. The other one is that you've 17 got to remember this is a passive system. There are 18 no moving parts. So when you look at frequency, you 19 can't really assign a frequency because you can't 20 evaluate components' failure rates.
21 So you're looking at it mechanistically.
22 It's your mechanism for that failure. If your can 23 is sitting horizontally, is it going to tip over?
24 Mechanistically, there are no ways for it to tip over.
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114 1 possible. It's non-credible.
2 MEMBER CORRADINI: So I don't know. We 3 still have the industry to come and make some comments.
4 But you're saying that under certain initiators, but 5 there's other initiators that we're not talking about 6 here. And Joy brought it up in terms of security.
7 There are other initiators that one has to still 8 consider that could cause intrusion or a release.
9 I think where I thought Joy was asking a 10 question and I don't remember what chapter she reviewed 11 to make her feel better.
12 MEMBER REMPE: I think you were assigned 13 that chapter than.
14 MEMBER CORRADINI: You were doing such a 15 good job. But I think there's other -- you're talking 16 about one mechanism, but there could be a range of things 17 that cause a failure.
18 MR. CHUNG: Yes.
19 MEMBER CORRADINI: Okay.
20 MR. CHUNG: Yes.
21 CHAIR SUNSERI: So I think John's point 22 has been made on this. I'd like to continue on here.
23 MR. SMITH: Okay. This is Jeremy Smith.
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115 1 described here today. The intent was not to introduce 2 new information into this SRP. It was to enhance the 3 two SRPs as they existed to bring it to one cohesive 4 current review practice within the Division of Spent 5 Fuel Management. And with the interactions we've had 6 with the public, the comments that we've received 7 indicated there are areas where additional 8 clarification would be definitely beneficial. And we 9 will make those changes as necessary. And that is my 10 presentation.
11 CHAIR SUNSERI: All right. Jeremy, thank 12 you and thank you for your staff's time on this. At 13 this point, I'd like to ask for a change of the 14 presenters and have Rod McCullum from the Nuclear Energy 15 Institute come up and provide their perspective.
16 (Pause.)
17 MR. McCULLUM: Okay. And my name is Rod 18 McCullum, the Nuclear Energy Institute. I represent 19 the nuclear industry that has reviewed NUREG-2215 and 20 did provide written comments on it. On March 23rd, 21 we had a public meeting with staff to discuss those 22 comments. I will try to give you some perspective on 23 where we stand on this. Although to some extent, my 24 presentation has been rendered a bit superfluous by 25 all the questions you've asked so far.
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116 1 I very much welcome the fact that this 2 subcommittee is paying attention to this. Used fuel, 3 as we call it, doesn't get a lot of attention because 4 it is one of the least interesting things that NRC 5 regulates. It is one of the least interesting things 6 because it is one of the lowest risk things. Is it 7 regulated that way? No.
8 I've often said -- and before this 9 committee as well -- that dry storage regulation is 10 upside down from a risk perspective. If you look at 11 thresholds for regulatory intervention, if you look 12 at the level of detail that's in a dry storage license 13 or a certificate of compliance, it is lower thresholds, 14 higher level of detail than a reactor license. Why 15 is that? Well, it's a journey that we have traveled 16 down.
17 We have a lot of efforts -- and staff has 18 alluded these -- where we are working with staff to 19 try to fix that. Does NUREG-2215 fix that? No. Staff 20 has told you it was not intended to. We have some things 21 going on in parallel here. We have heard stovepiping.
22 I'll tell you where we have landed. I think you've 23 obviously read our comments. And again, to this 24 committee, my charge would be please stay engaged here 25 because this is important. If we can go to the next NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 slide, and there we go.
2 There's a history behind this map. We 3 loaded the first dry storage casks in 1986 so we've 4 been at this for over 30 years now. They were initially 5 licensed for 20 years. We've now extended licenses 6 to 60 years by 40-year extensions. We've loaded over 7 2,700 of these by now. This says 2,698, but that was 8 at the end of the year. They loaded all year long.
9 We've learned a lot. We've learned about 10 how safe these things are. We've learned a lot about 11 how much design margin. The regulatory framework and 12 the guidance you're seeing that's being incorporated 13 at 2215 reflects that learning. I mean, these ISGs 14 were part of a learning process. When they first came 15 out, they didn't get public review. They didn't come 16 before this committee, the lower numbered ones.
17 We learned. They got more review. They 18 came before this committee. This consolidation is 19 coming before this committee. The real thrust of our 20 comments and the thrust of my presentation here is, 21 does simply consolidating this -- does it capitalize 22 on what we have learned? And the answer is no.
23 Our initial comments to NRC were, whoa, 24 whoa, whoa. Don't consolidate the stuff that isn't 25 quite there yet that's still part of the upside down NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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118 1 regulatory framework. And give us a chance to improve 2 and then they consolidated it. They told us, well, 3 we have a commitment to the Commission. We got a firm 4 no on that.
5 And we want to do this in a collegial manner 6 going forward. So our compromise we reached with the 7 staff was that, okay, go ahead and consolidate what 8 exists because it does help that they're all in one 9 documents. And one of the features this document has 10 that's positive is it can be revised by chapter.
11 So we hope to very surgically incorporate 12 the results. And I'm hoping this committee can help 13 push us along at better than a glacial pace because 14 we have been moving glacially.
15 Industry first visited this topic of dry 16 storage regulation being risk upside down in 2012, and 17 we filed a petition for rulemaking, PRM 72-7. It was 18 accepted for consideration of rulemaking which meant 19 they'd think about it and they never had the resources 20 to actually put it in play.
21 We also submitted NEI 1204, a guidance 22 document. The goal was to get more information under 23 licensee control and to have an acceptable process for 24 managing information over licensee control. So we're 25 not putting all these resources into regulating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 something that's not important to safety.
2 I think it was Dr. Stetkar that said earlier 3 that the rule isn't that prescriptive. The guidance 4 got a lot more prescriptive. It grew this way because 5 as we were learning, dry cask storage is an unexpected 6 solution to an unanticipated problem. Remember the 7 fuel was going -- Part 71 came before Part 72 because 8 the fuel was supposed to go straight out of the pools 9 to Yucca Mountain. A funny thing happened on the way 10 to forum, but --
11 So as we created this new solution -- and 12 it really is. Dry cask storage, when you look at the 13 safety and operational record of all of these loadings 14 is one of the great industrial success stories of our 15 time when you consider that it came about quite quickly 16 and has been so successful and what major components 17 these things are.
18 And so as we learned, reviewers as 19 reviewers will do, they ask a lot of really good 20 questions. And as licensees do, they take the path 21 of least resistance. They answer those questions and 22 they put the answers in the licenses.
23 So we have dry cask storage CoCs that run 24 about 100 pages. Some of them get up to 250-300 pages.
25 They have a level of detail again that is excruciating.
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120 1 And again, we're working on fixing it. And 2215 is 2 not the fix.
3 Why is this important? Let's go to the 4 next slide. This is what NEI is doing and maybe why 5 we need to move a little bit faster here too. This 6 is our national nuclear energy strategy.
7 It is no secret to anybody in this room 8 that the nuclear industry is having trouble competing 9 in today's electricity markets. The halt of the VC 10 Summer construction project, the recent bankruptcy of 11 FirstEnergy, all the premature shutdowns. Wind, 12 solar, and natural gas are changing the way electricity 13 is priced in ways that are very good consumers.
14 If nuclear is going to play in this game, 15 we have to be able to compete. So we have preserve, 16 sustain, innovate, and thrive. I'm not going to go 17 into our whole strategy here. Preserve is about market 18 reforms we're seeking where the markets give nuclear 19 a level playing field.
20 Sustain is where we exist in here.
21 Innovate and thrive, if we can get the regulatory 22 framework to be risk appropriate which is part of 23 sustain and part of what I'm talking about here, then 24 we can innovate and thrive which really makes us 25 competitive with wind, solar, and natural gas because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 1 there's a tremendous amount of innovation going on 2 there.
3 But if you read what's under that 4 sustainable, it creates sustainability by improved 5 regulatory framework and reduced burden. There is a 6 tremendous amount of burden in dry storage regulation.
7 It was put in all those ISGs through that process of 8 asking all those questions as we were learning, and 9 it's still there in NUREG-2215.
10 We need to fix that. Consolidation alone 11 doesn't fix it. It just puts the problem in one place 12 where we can get at it easier. And we are getting at 13 it. And how are we doing that. Go on to the next slide, 14 please.
15 These are the two outcomes and policy 16 actions. Discipline and stability in the 17 requirements, again, when we petitioned for rulemaking, 18 it wasn't because the rule needed to change. It's 19 because we wanted the criteria for what goes in -- we 20 wanted to stabilize by rule the criteria for what goes 21 in a license. And we were going to discipline the 22 system by rule.
23 Now because the rulemaking couldn't 24 happen, we engaged in a pilot activity with those same 25 criteria and we've reached agreement with staff on those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 criteria. That's this graded approach CoC. So you 2 can see the two main things. We're trying to increase 3 the progress of risk-focused regulation. And in dry 4 cask storage, risk-focused regulation doesn't mean --
5 and some of you are going to consider this an anathema.
6 But it doesn't mean go out and do a bunch of PRAs.
7 They did a couple, and your predecessor 8 committee, the Advisory Committee on Nuclear Waste, 9 heard very detailed presentations on two PRAs of dry 10 cask storage -- one done by EPRI, one done by staff.
11 They both came out with numbers in the ten to the minus 12 thirteenth and ten to the minus fourteenth range.
13 Instead of saying, well, why are we even 14 worried about regulating in this area, the answer was, 15 well, we better concentrate on the ten to the minus 16 thirteenth stuff because they're way more risk 17 significant than the ten to the minus fourteenth stuff.
18 The word "credible" was tossed out. I 19 don't --
20 MEMBER BALLINGER: We need to be a little 21 bit careful there about those studies. They had to 22 do with dropping and breaches in handling and things 23 --
24 MR. McCULLUM: Right.
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123 1 dealing with degradation during storage.
2 MR. McCULLUM: Yes, and that's why we put 3 in place what I feel is a very conservative aging 4 management framework. And if you did PRAs of those 5 mechanisms, I think you'd come out with similar numbers.
6 I'm not thinking we want to put the resources in to 7 doing that. Where we are with staff right now is let's 8 start with the assumption that dry storage is no more 9 risky than reactors. Even there, there's a lot we could 10 improve.
11 For example, what we're trying to do with 12 the graded approach CoCs, the idea of using firm 13 criteria and not just reviewer curiosity for what goes 14 in a license has already been done once before. If 15 you remember the 1990s, the improved tech specs for 16 reactors.
17 Reactors went through the same learning 18 process. Reactor licenses were a function of good 19 questions that were asked along the way and answers 20 that were given for the sake of expediency in getting 21 the facility's license. And when we got to the improved 22 tech specs, we created a world. And then we put in 23 place risk informing where, with the complexity of 24 reactors, we did do VRAs.
25 We got to a world now where you look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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124 1 capacity factors, we're operating over 90 percent.
2 We're operating safely over 90 percent. We wouldn't 3 have got there with a cumbersome, overly burdensome 4 set of tech specs.
5 So that worked, and what we're trying to 6 do in the Graded Approach initiative that's one of our 7 focus areas is to do that. That pilot that TN is 8 producing an amendment. It's under review with staff 9 right now, an amendment to a TN, Transnuclear Americas' 10 CoC, will have a lot less detail in it. That means 11 it won't need to be amended every time a spacer grid 12 gets changed or every time some new detail that's not 13 safety significant gets changed.
14 A lot of the burden here is all that 15 regulatory traffic that's driven by the level of detail.
16 We intend to institutionalize that in durable guidance 17 or maybe in the rule. We're having discussions with 18 staff now whether rulemaking might ultimately be 19 necessary. But we don't want to -- we've been doing 20 this glacial. I mean, I've been having this dialogue 21 with staff since 2012 and my predecessors were having 22 it long before that.
23 So we'll have a result in terms of the pilot 24 CoC getting an SER, a safety evaluation report, around 25 the June time frame. I believe that's still on track.
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125 1 So we'll have a precedent. We've got to 2 institutionalize that precedent.
3 What this is about is putting more 4 information under licensee control. You talk about 5 all these details inside licensee documents, in the 6 safety analysis report that the licensee controls under 7 the change control process, in this case, 50.59, 8 72.48. And then the really important safety stuff 9 should go in the CoC.
10 So stuff is going to come out of the CoCs, 11 go into the safety analysis report. We have to have 12 a change control process that works, 72.48 was broken.
13 And also in 2012, we proposed an NEI guidance document 14 to fix it, NEI 1204. That's why it's 12. It was 15 proposed in 2012.
16 We have been negotiating with staff down 17 to every punctuation mark in that guidance document 18 in public meetings and in several letters. We finally 19 reached the end of that negotiation. And just last 20 month, we submitted the final, final, final version 21 of NEI 1204. So we now have a change control guidance.
22 Now neither the results of the pilot nor 23 the change control process -- and please, NRC, endorse 24 that or at least write us a letter that says it's 25 acceptable to use as soon as possible. And we plan NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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126 1 on it, our used fuel management conference this May, 2 are training both industry and NRC folks on that. It's 3 a much more efficient process. It works in conjunction 4 with what we're trying to get with the Graded Approach 5 CoCs.
6 We successfully implemented a new learning 7 approach to aging management, NEI 1403, because we 8 didn't have a lot of -- getting to Dr. Ballinger's 9 question, we didn't have a lot of experience with the 10 aging of these casks. And how do we answer those 11 questions that weren't addressed in those PRAs back 12 then?
13 And well, we've got to collect data going 14 forward. The high burnup demo project has already been 15 talked about. EPRI came out and did susceptibility 16 requirements. Let's do the most intensive inspections 17 on the casks that are in the most corrosive environments 18 and we're applying that.
19 All of this learning that we put in place 20 tollgates. Do you pay for a highway before you build 21 it or do you pay for it by collecting? Well, it's 22 E-ZPass now. Nobody throws money out the window. But 23 do you pay for it as you go?
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127 1 programs based on the information you were getting from 2 these R&D projects such as the inspections which are 3 evolving and such as the high burnup demo which is in 4 progress.
5 That was institutionalized in 1403 which, 6 again, NRC, please endorse that. But even if you don't, 7 you already incorporated it by referencing NUREG-1927, 8 Rev. 1. So that exists. The last two CoCs and two 9 site-specific licenses have already been renewed for 10 four years using that approach. That's also not 11 necessarily reflected in 2215.
12 We're trying to prevent risk-uninformed 13 regulatory actions from occurring. That's why we were 14 concerned about new information. Okay. If 2215 isn't 15 going to capture the improvements, don't throw new 16 curiosities at us. And in the area of fuel 17 characterization -- and I love the Q&A on that -- yes, 18 there was some information that we felt was taking us 19 in the wrong direction. Why do we need to know down 20 to that level of detail when our existing 21 characterization processes have worked fine?
22 The Information Notice 18-01 cited four 23 examples where during the drying -- and if you're going 24 to induce a flaw in cladding anytime in storage, it's 25 going to be during the drying process. That's when NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 you're the most stressed. Twenty-seven hundred 2 loadings, four times we induced a small -- whether it 3 was a crack or a pinhole and we detected some fission 4 products in the drying process.
5 That's a pretty good record. That, again, 6 goes to the risk being very low here. So it kind of 7 tells me that our characterization processes are 8 working. We kind of saw 2215 telling us do some 9 additional things. As you were questioning, Dr.
10 Stetkar indicated without really knowing what you were 11 trying to get at.
12 What we're trying to get at is what we've 13 got right now. And remember retrievability, they 14 redefined ISG-2 in its latest revision. That's 15 retrievability by canister. It's not important to 16 reconstitute the reactor after the accident. It's 17 important to retrieve the canister.
18 Industry maintains we'll never open the 19 welding systems. We think they can go right into Yucca 20 Mountain with an overpack as they are. We filed a 21 contention in the licensing process to that effect.
22 And if it's not going to be Yucca Mountain, we think 23 that we'll fight to make sure. Because if there's any 24 risk in this, it would be unloading and handling all 25 of the fuel assemblies loaded in 2,700 casks. That's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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129 1 not where you want to go. So retrievability is in a 2 good place right now.
3 Thermal modeling, talk about pushing the 4 400 degree -- one of the thing the demo is teaching 5 us and I can't get ahead because there's some stuff 6 that's going to come out about the data from the demo.
7 It's being thermocoupled to death right now.
8 We're finding out our thermal models are 9 very overconservative. We're going to find out we have 10 a lot more margin. So we're already overregulated for 11 what the risk is, and we're going to find out the risk 12 is even lower, at least the margin is even greater.
13 So NRC has this transform initiative. The 14 industry would like to see us not just make these 15 incremental improvements you see at the top of the list 16 here but further transform and having the ISGs in a 17 form where they can be more readily revised by chapter.
18 Hopefully, we can grab on to the transform 19 bandwagon because in an industry struggling to survive 20 economically, there is no room for a regulatory 21 framework that regulates things that just aren't 22 important to safety. There just is no room for that.
23 So if we can go on to the next slide.
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130 1 a minute. Don't re-institutionalize the learning 2 process when we haven't institutionalized where the 3 learning process got us yet. And we've agreed on that.
4 Staff was very responsive. Okay. Go ahead. Meet 5 your milestones at Commission but make sure we take 6 the next steps.
7 Let's not just say, okay, been there, done 8 that and leave it in place for 2012 to 2018 is six years 9 and then six more years I'm back here before this 10 committee giving the same talk. And I've given this 11 talk before. I think I gave it back when the petition 12 was in play.
13 Consolidation was not sufficiently 14 explained. I think we've got some explanations.
15 You've asked for some more. I hope you get your 16 answers. Expanding the scope, the ISG review, there 17 was new information in there. The people who put 2215 18 together, they're very dedicated, hardworking staffers 19 came up with some questions and they've expanded the 20 scope.
21 They've agreed NRC has satisfied this 22 comment as well as the fourth one. They've agreed if 23 we're just going to consolidate, we're just going to 24 consolidate. In terms of what's going to be new or 25 different, that goes to the next steps.
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131 1 And you've also asked in addition to 2 peeling back, you've asked some questions. I think 3 Dr. Rempe particularly, you've asked some questions 4 that maybe there's some other things that should be 5 addressed too.
6 So that's not going to happen in 2215.
7 If we can't fix the risk thing, let's not make that 8 more broken. But I think where this committee's 9 attention to incredibly valuable is keeping the focus 10 going forward and let's take those next steps.
11 Okay, consolidate. Now it's in one place.
12 It's an easier target. But consolidate is not the 13 same thing as fixing it. We've agreed with staff on 14 that and we'll go and take those next steps.
15 This third comment, this is for shutdown 16 plants going from a site-specific Part 50 license to 17 a Part 72 license. We felt that this guidance could 18 trigger -- some of us felt this guidance would trigger 19 rewriting the emergency plans.
20 You don't have to interpret the guidance 21 that way. So what we agreed with was, okay, we're going 22 to address that there's an ongoing decommissioning 23 rulemaking and we think we can solve that problem there.
24 So that comment, we're withdrawing that comment 25 essentially. Going onto the next slide which I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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132 1 we're getting close to the end.
2 So my message to you would be quite simple.
3 Again, we've had a good dialogue. The staff has agreed 4 not to add detail. The staff has agreed not to add 5 regulatory positions. That's a victory in not getting 6 worse, not a victory in getting where we're striving 7 to go.
8 I would look at ISG-22. We felt that 9 industry's comments when that ISG came out were not 10 effectively addressed. We feel that should've been 11 looked at in the generic issue process. And if it had 12 have been, its risk significance would not have been 13 sufficient to cause it to be an ISG or now to be a part 14 of 2215.
15 So while we've agreed not to add anything 16 new, that's something old we'd suggest maybe you leave 17 out. And again, I mentioned we're dropping the comment 18 on the EP guidance.
19 And the last two bullets summarize 20 everything I've been saying. This is a necessary but 21 not sufficient step. We need to take the next steps 22 to become more risk appropriate. We're not there.
23 And the committee, if the committee says, well, hey, 24 don't do the NUREG until you are there. Well, that's 25 another thing.
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133 1 But we've agreed with staff to work with 2 them, I think, constructively. We can best work with 3 staff from this basis going forward. The continued 4 attention by this committee to assure that that happens 5 and it happens in a timely manner.
6 Dr. Ballinger's comments about the glacial 7 pace at which we're proceeding, industry doesn't have 8 time for a glacial pace. We're losing plants at a very 9 much real time.
10 So that concludes my comments, and I'll 11 take any questions. I'd love some of the questions 12 you gave those guys because I have my own answers.
13 But if you can think of them again.
14 CHAIR SUNSERI: Questions for Rod?
15 MEMBER POWERS: One of the points you made 16 earlier was that the consolidation was only getting 17 problems that you identified in one place.
18 MR. McCULLUM: Right.
19 MEMBER POWERS: And I did not get a sense 20 from you on is that a good thing to do or is that no 21 help at all to have it all in one place where you can 22 get at it?
23 MR. McCULLUM: It's an okay thing to do.
24 I mean, one of the things that always -- and the reason 25 --
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134 1 MEMBER POWERS: Discount the opportunity 2 cost --
3 MR. McCULLUM: Right.
4 MEMBER POWERS: -- right now.
5 MR. McCULLUM: Right.
6 MEMBER POWERS: I mean, there clearly is 7 an opportunity cost associated with consolidation.
8 Consolidation is something that --
9 MR. McCULLUM: Yes --
10 MEMBER POWERS: -- reasonably can be done.
11 MR. McCULLUM: Yes, now we have a place 12 we can -- the problem with the ISGs, it was a very 13 hodgepodge regulatory framework. Some of them got 14 revised multiple times. They weren't really interim 15 because some of them live for over a decade. They 16 didn't really just apply to the staff because they've 17 said things the licensees had to pay attention to.
18 And those things weren't really necessarily guidance.
19 They took on a connotation of requirements.
20 Now we're putting it in one thing that 21 clearly is a standard review plan. We all know what 22 a standard review plan is. We know what it means.
23 It makes a little easier to attack but that's all.
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135 1 plan. I can reconcile that against the standard review 2 plan.
3 We're still talking to them on how to do 4 that most efficiently. But it does help to have it 5 all in one place. But in terms of fixing the problem, 6 again, it doesn't.
7 MEMBER POWERS: Yes, I mean, that was your 8 point and I understand that point. But the question 9 was ---
10 MR. McCULLUM: It's an okay --
11 MEMBER POWERS: -- does that --
12 MR. McCULLUM: -- thing to do, yes.
13 MEMBER POWERS: It's a step.
14 MR. McCULLUM: It's an okay thing to do.
15 MEMBER POWERS:; The other point that you 16 made -- and I'm going to paraphrase substantially here.
17 I'm going to give more of my interpretation than what 18 you said is that we don't have adequate risk information 19 to risk inform this and we don't have time to get it.
20 MR. McCULLUM: And I don't think it would 21 be worth taking the time and resources to get it. I 22 think we know that dry casks involve substantially risk 23 than reactors. And what we have asked staff is to start 24 from that point and work backwards. And I think at 25 the end of the day we're still going to have a regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 framework that's very conservative. The public seems 2 to be more concerned about --
3 MEMBER POWERS: That question that comes 4 up -- and indeed it was raised here -- was this risk 5 level is within a different context, I believe was the 6 word that was used --
7 MR. McCULLUM: Yes.
8 MEMBER POWERS: -- than the reactor? And 9 that is a security context as much as a random, natural 10 accident.
11 MR. McCULLUM: Well, no, and it is in a 12 different context. And I think those two things have 13 to look -- it is appropriate to protect an ISFSI only.
14 And obviously if it's a dry cask facility inside a 15 reactor fence, the security context is the same. But 16 we are now, more and more, finding ourselves with 17 facilities that are simply dry casks inside a fence.
18 It is sufficient to protect them from a 19 security standpoint differently than you protect 20 reactors. And you have to look at the risks here.
21 There is not a dry cask accident that has an off-site 22 dose consequence.
23 And more importantly, nothing at a dry cask 24 happens fast. If I damage the overpack, if I damage 25 the canister, do you have to really get -- and I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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137 1 want to get into security space. I can't get in there 2 because I don't know this stuff for a reason.
3 You envision an incredible scenario that 4 it would take to work your way through all those barriers 5 and damage enough cladding to release -- and again, 6 it's not all in releasable form. It's not an energy 7 like a reactor, the hydrogen explosions, the 8 temperatures and pressures.
9 There's not an energy to drive a release 10 in order to get gaseous fission products out of a cask 11 and release them in any quantity. You're really going 12 way beyond credible. There's plenty of time for a 13 measured security response to that scenario and a 14 measured mitigation response to that scenario.
15 So I would say it's in a different context 16 and it's in a different context for an appropriate 17 reason because reactors, as we've seen, things happen 18 very fast. In dry casks, they don't. You don't have 19 the driving mechanisms for the kind of release that 20 can affect public health and safety with a dry cask.
21 Therefore -- and you see this in the 22 decommissioning rulemaking -- it's already codified 23 in exemptions. And all the rulemaking is doing is 24 turning those security and emergency preparedness 25 exemptions into rules so we don't have to keep issuing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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138 1 them over and over again. That's bad regulation.
2 Is that there's a logical step down in the 3 degree to which you need to provide guards, gates, and 4 guns as you move from an operating reactor to a shutdown 5 reactor with fuel in the pool to a shutdown reactor 6 with even cooler fuel in the pool to a standalone ISFSI.
7 And that's being very well thought out.
8 So I would say that from that standpoint, the current 9 security framework or the current security context is 10 appropriate and it would not cause me to think any 11 differently about further risk informing the dry 12 storage regulatory framework.
13 MEMBER RAY: Well, I think that may be the 14 point that we're trying to make which is trying to 15 quantify that risk in the context of this kind of a 16 process just isn't something that can be done offhand.
17 MR. McCULLUM: It can't be done offhand 18 and I would again maintain it's not necessary. I mean, 19 a lot of this is common sense.
20 MEMBER RAY: That's fine. We don't need 21 to argue that further. In fact, I don't think we're 22 arguing, but that's just the point to be made --
23 MR. McCULLUM: Right.
24 MEMBER RAY: -- which is what dominates 25 in an operating reactor doesn't dominate in dry storage.
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139 1 MR. McCULLUM: Right.
2 MEMBER RAY: But there still are risks.
3 MR. McCULLUM: Yes.
4 MEMBER RAY: And whether one wants to 5 proceed and try and quantify all of them is something 6 to be debated separately. At least not insisted upon 7 as part of this process here.
8 MR. McCULLUM: Right. I heard the word 9 a couple of times in your dialogue. Again, this was 10 a great dialogue. I am going to pay -- I usually don't 11 put a lot of credence in transcripts. But that 12 discussion we had earlier, I'm going to pay a lot of 13 attention to.
14 I heard the word "enveloping" and we don't 15 want to quantify -- in reactors, we had a need to 16 quantify risks because there's some things that were 17 harder to envelope. But these things are easier to 18 envelope. And I will tell you that envelope is down 19 here and we're still up here.
20 MEMBER RAY: Yes, I think so too. But 21 neither you nor I, or I think any of us here, are in 22 a position where we can confidently say we know what 23 the possibilities are, that we can then quantify them.
24 MR. McCULLUM: Right, and --
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140 1 anything you've said. But that doesn't reach closure.
2 MR. McCULLUM: And I will tell you, EPRI 3 is doing some work on, okay, what if over time we get 4 a crack in a cask? First thing you do is you lose helium 5 and then what if you had some damage cladding? EPRI, 6 Energy Power Research Institute is undertaking that.
7 I know we heard the staff is doing some work on that.
8 MEMBER BALLINGER: They're about as 9 glacial as --
10 MR. McCULLUM: Well, yeah. Again, that's 11 why the growing imposition with the staff is guiding 12 the improvement efforts I spoke of is, let's just start 13 with the proposition that there's -- the risk is not 14 greater than that of a reactor.
15 Even with just that proposition, I think 16 we can reduce the burden a lot here. And then 17 this -- then as the glacial stuff comes online.
18 This isn't, you know -- I think one of the 19 things that's really going to rock our world here is 20 going to be the results from the -- the thermal results 21 from the demo. I think we're extremely 22 over-conservative in the thermal profiles, you know.
23 We tried to get that demo cask as close 24 to 400 degrees as we could. We specially handpicked 25 the hottest jewel Dominion would let us put in there, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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141 1 and, you know, again, the results are being checked 2 and double-checked. We were playing round robin, so 3 I can't get ahead of it, but I think it is common 4 knowledge that we didn't get any more calls, you know.
5 And our models would have told us we would 6 have got a lot closer. So, again, we know the risks 7 are lower than where we're -- than the way we're 8 treating them now. We can work with that at a faster 9 than glacial pace.
10 We can work with what we know now. We've 11 loaded 2,700 of these systems. Only four times did 12 we detect fission products upon drying, and then, we 13 didn't detect much, so it was a small flaw we opened 14 up, and a small number of rods out of thousands that 15 were in that cask.
16 And then, again, that's where you stress 17 the cladding most. We have had a demo cask before.
18 It was the low burn-up demo. We opened the cask in 19 Idaho, and anybody who hasn't read the reports of that, 20 those were quite remarkable to me.
21 Someone who doesn't have a lot of time to 22 read a lot of scientific reports, those captured my 23 interest, because that fuel came out of there in just 24 a good a shape as it went in.
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142 1 low burn-up and high burn-up is artificial. In fact, 2 NRC has done some work that tells you because, you know, 3 the pellets swell more, you giving the cladding more 4 strength by being up against the pellet, that actually 5 high burn-up fuel might perform better in storage than 6 low burn-up fuel.
7 So, you know, we're not ready to say, oh 8 in that case let's just throw more regulation out the 9 door. We don't work that way. We work glacially.
10 But we can work -- you know, what we're learning is 11 telling us we're headed in the right direction, and 12 I really hope this committee can help drive us in that 13 direction, because, you know, way too -- yeah, a lot 14 of industries cost, and dry storage get passed on to 15 DOE in our liability.
16 But, you know, you only have so many 17 engineers. You only have so many experts and 18 criticality. You only have so many licensing experts 19 on any given site.
20 And when all those people's time and 21 resource is spent on unnecessary dry storage paperwork, 22 they're not doing other things They're really 23 important to the safety of the plant.
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143 1 and dedicated people working in dry storage that might 2 be better off working somewhere else that was more 3 significant.
4 We've got, for example, we're bringing 5 accident-tolerant fuels to marketplace. Those were 6 mentioned earlier, I think, by Dr. Rempe. And we're 7 going to need NRC to move faster on those than they 8 have in the new fuel designs in the past, for them to 9 get here in time to help the industry economically.
10 This is where you improve economics by 11 improving -- by putting more safety in the fuel.
12 CHAIR SUNSERI: Okay, Rod.
13 MR. McCULLUM: Anyway, I'm digressing.
14 I'm sorry.
15 CHAIR SUNSERI: No, that okay. I think 16 that would be a great place to stop if I were you, but 17 I'm not you, but is there anything else that you would 18 like to add?
19 MR. McCULLUM: Your hint is well taken.
20 I thank you all for the opportunity.
21 CHAIR SUNSERI: Okay, I appreciate it.
22 All right, at this point in time I'd like to open up 23 for public comments. So, at this time if there are 24 members of the public that have been listening in, this 25 is your opportunity to make a comment or statement.
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144 1 Please identify yourself and make your statement. Is 2 the phone lines open? Anybody that would like to make 3 a comment?
4 MS. GILMORE: This is Donna Gilmore.
5 CHAIR SUNSERI: Yes, Ms. Gilmore, please 6 go ahead.
7 MS. GILMORE: Hey, I heard somebody -- I 8 heard this. The -- I know that the NEI was talking 9 about all this low-risk and all this kind of thing, 10 and I -- and then I didn't know the name of the ACR- -- I 11 think it was ACRS -- person that was talking, yeah, 12 we don't think we know what the possibilities are.
13 I just wanted to mention and get on our 14 record, nuclear waste technically leaves (telephonic 15 interference) December 2017 document on DOE (telephonic 16 interference).
17 OPERATOR: This is the operator. Martin, 18 you are in conference.
19 MS. GILMORE: Do other people need to go 20 on mute? Hello?
21 CHAIR SUNSERI: I'm sorry. Ms. Gilmore, 22 please proceed.
23 MS. GILMORE: Okay. You know, where they 24 talked about the set nuclear fuel, that it was critical 25 to be able to monitor the fuel because of the hydrogen NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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145 1 gas explosion risk. So, I just wanted to counter that 2 NEI comment of low consequences there.
3 And I really appreciate the staff input.
4 This was a very useful discussion. You know, I'd like 5 to mention that anywhere in the new regs where they 6 use the word assumption, the more you can include 7 references for those assumptions, I think, will help 8 everybody to understand. And I think that some of you 9 are doing that. So, that's great.
10 Let's see, hold on for just a second, sir.
11 And then, Donald Chung in his definition of crit- -- I 12 agree with the point on defining credible, and I think 13 John -- Donald Chung's comment that there's a mechanism 14 for that failure, that's credible for the scientific, 15 that would be great, to add the definition like that.
16 Anyway, let's see, I think that's all for now. Thank 17 you.
18 CHAIR SUNSERI: Thank you. Any other 19 members of the public for comments?
20 MR. LEWIS: Marvin Lewis, member of the 21 public.
22 CHAIR SUNSERI: Thank you, Mr. Lewis.
23 Please go ahead.
24 MR. LEWIS: Excellent, thank you. All 25 right, I was listening to Donna and she's got a terrible NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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146 1 echo in there, but I think it came over. And when 2 she raised the question of hydrogen and reorientation, 3 and I just wanted to point out that EPRI's got a 4 document -- DWR Fuel Cladding hydrogen pickup at long 5 resonance times -- and this is one of the things I'm 6 thinking of, as one of the questions raised, yes, maybe 7 it's okay for a few years, but over long resonance times 8 we really don't know what happens with this hydride.
9 Now, my question's a little more of a 10 comment, and the comment -- and a very simple comment.
11 We're adding a lot of radioactivity to the biome, the 12 fuel, the air, the water, the soil.
13 And if you look at the fuelogical times 14 and go back to the Precambrian, life on this earth was 15 not holding on too well. And then there was an 16 explosion of life in the Precambrian. Some of this 17 life took a good hold and we wound up 200 million years 18 later, 250 million years later, yeah, man.
19 But if we're going to go back to the 20 radioactive background in the Precambrian, namely about 21 700, 600 millions per year, we may stop evolution, which 22 means that the human race may stop.
23 And I'm wondering if we really want to 24 increase the radioactivity of the earth that much.
25 Thank you.
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147 1 CHAIR SUNSERI: Thank you, Mr. Lewis.
2 Anyone else on the line? Okay, so let's close the phone 3 lines now, and I'd like to hear from individual member 4 comments now. Oh, I'm sorry. John remind me. Anyone 5 in the room would like to make a comment?
6 MR. HSIA: This is Tony Hsia. On behalf 7 of the Division of Spent Fuel management staff, we just 8 want to thank the committee for giving us valuable 9 comments. Those many, many are good suggestions and 10 comments we take into consideration.
11 I also want to assure you that we are very 12 focused on our safety mission, as to ensure safety of 13 the dry storage of spent fuel. But also, we don't 14 forget that we're taking the right direction.
15 The risk is relatively low compared to 16 reactors, and we'll continue to work with the committee, 17 as well as the other stakeholders, to march toward more 18 risk-inform, to -- although we take -- we have taken 19 the first necessary step to consolidate the standard 20 review plan, all the comments from you and other 21 stakeholders we'll take into consideration as we march 22 toward more risk-inform.
23 But in the meantime, we remind ourselves 24 we are ensuring safety, but we have the reasonable 25 assurance of safety insurance. That's recognizing the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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148 1 risk associated with the dry cask. We just want to 2 thank you for your input.
3 CHAIR SUNSERI: Thank you. Anyone else?
4 All right, now we're ready for individual member 5 comments. Let's start with Joy. And, as you make your 6 comments, I would also like to know if you would like 7 for the full committee to be more involved in this 8 revision. And, if so, what drives you to that 9 conclusion, or that viewpoint?
10 MEMBER REMPE: Well, first of all I want 11 to acknowledge that I appreciate the staff's efforts 12 to do this elevation. I know I had a lot of nitpicks 13 about things, and was kind of pushing to do a little 14 bit more.
15 I hope you can accommodate a lot of those 16 requests. But I do think it's worthwhile to have what 17 you can from the ISGs incorporated, and not have a 18 hodgepodge of documents.
19 With respect to the full committee getting 20 involved, it's my understanding that we will have 21 another subcommittee meeting that meets on this before 22 the document finalizes.
23 I mean, after this -- or if this is going 24 to be the last shot.
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149 1 other committee, but I wasn't planning on having another 2 one for this specific consolidation.
3 MEMBER REMPE: Because I thought, you 4 know, I'm thinking about the history of this. And at 5 first it was suggested that we don't even review this 6 and wait until the final public comments have been 7 addressed fully. And that has not yet happened.
8 And so, I thought it was going to come back 9 to ACRS after that happened. And I assumed you'd have 10 another subcommittee meeting on that. What is the 11 process in your vision, Matt?
12 CHAIR SUNSERI: Well, so in my view this 13 was going to be the final subcommittee review. And 14 then we would decide whether or not we'd need additional 15 action after this review today. So --
16 MEMBER REMPE: So, if we don't have a full 17 committee meeting, we've never got any letter on this 18 at all.
19 MEMBER CORRADINI: I think that's what 20 Matt --
21 CHAIR SUNSERI: That's correct.
22 MEMBER CORRADINI: Matt -- I think 23 that -- that's --
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150 1 or this is all we need for the moment?
2 MEMBER REMPE: Then I guess I -- is there 3 going to be an opportunity where we'll see -- I mean 4 a lot of times there was information today where the 5 staff was not giving us the final document. They just 6 said, yeah, we're going to do something. Is there a 7 schedule planned on when that would happen?
8 CHAIR SUNSERI: Well they're scheduled to 9 issue their final document in July. What we heard 10 today, if I'm not mistaken, was the staff's addressing 11 of the public comments that they have. So this -- what 12 we heard today is what the final is in -- what the --
13 MEMBER REMPE: I think we'll be --
14 CHAIR SUNSERI: -- final document is 15 intended -- how the final document was intended to 16 address the public comments.
17 MEMBER REMPE: We don't have a copy of the 18 updated 2125. It has all of those comments addressed.
19 And so, I think it would be good to have a full committee 20 meeting, and see that document and write a letter.
21 But I -- I guess I assumed that we'd have a subcommittee 22 meeting before that happens.
23 But I definitely think, as I said, I 24 wouldn't have a full committee meeting until we can 25 see the final document. Okay?
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151 1 CHAIR SUNSERI: Thank you. Walt?
2 MEMBER KIRCHNER: I missed the opportunity 3 to ask Mr. McCullum more specifically what the NEI 4 suggestion is with regard to ISG-22. It says the 5 conclusion was, should carefully reevaluate ISG-22.
6 Can --
7 CHAIR SUNSERI: Can we have a more 8 specific --
9 MEMBER KIRCHNER: What does that mean?
10 CHAIR SUNSERI: Is this on?
11 MR. McCULLUM: Yes.
12 CHAIR SUNSERI: And I apologize. I lost 13 over -- Rod McCullum, NEI, I'm apologizing again. Our 14 recommendation is that they not incorporate it. They 15 just simply leave it out. We feel that this should 16 have been addressed in the generic issue process, not 17 through guidance.
18 And we feel had it gone into the generic 19 issue process, it would not have demonstrated the safety 20 significance to be warranting regulatory action.
21 So, our recommendation -- again, we're 22 holding on our agreement not to add anything new here, 23 but we think that's something old that can be left out.
24 Thank you.
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152 1 the staff told us they're still trying to decide what 2 to do on that at the beginning of the presentation today.
3 Right? They have --
4 CHAIR SUNSERI: Right here, here's the 5 staff --
6 MEMBER REMPE: There you are. There you 7 are. Yes.
8 MR. SMITH: The intention is, you know, 9 we received the public comments, we've had a public 10 meeting to discuss the comments. We've now met with 11 the ACRS subcommittee, and have your comments. The 12 intention was to take that information back to make 13 the final revisions to the NUREG-2215.
14 MEMBER REMPE: So, with respect to ISG-22, 15 you've not decided yet. What's your -- or have you 16 decided? What are you going to do on it? That's why 17 I was kind of stumbling about it.
18 Are we going to have another subcommittee 19 meeting to figure out some of these outstanding issues 20 and know what it is, before it goes to full committee?
21 Because the full committee meeting will be much 22 shorter.
23 MR. WISE: John Wise, NRC. We wish to keep 24 this document to the current staff practice on guidance.
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153 1 we stand right now.
2 MEMBER CORRADINI: So, just so I'm clear, 3 so that means you'll incorporate it into 4 the -- consolidate it into the guidance, or leave it 5 as a separate ISG? I guess that's what Joy was asking.
6 MR. WISE: Yes, this is John Wise. Yeah, 7 it's been part of a guidance for years now, and we're 8 going to keep it as part of guidance. And just like 9 all 24 or 25 ISGs, this is now part of 2215.
10 MEMBER REMPE: I thought you were going 11 to reevaluate that, so I missed that point when we 12 asked --
13 MR. SMITH: I just want to be clear.
14 MEMBER REMPE: Yeah.
15 MR. SMITH: The intention is, we're going 16 to reevaluate to make sure we didn't introduce any new 17 regulatory positions with respect to the ISG. Not that 18 we were not going to incorporate the ISG.
19 MEMBER KIRCHNER: Okay, thank you. And 20 then, Jeremy, if I may, this draft new reg 2224, if 21 I have that number correctly, on the high burn-up fuel, 22 and when are you expecting to see that or present that 23 to us?
24 MR. SMITH: So, there is going to be 25 another subcommittee meeting --
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154 1 (Simultaneous speaking.)
2 MR. SMITH: Yeah, after.
3 PARTICIPANT: -- speak to reg 2224 that 4 going to be coming later this year?
5 MR. TORRES: Yeah, so, actually we expect 6 to get the NLO from OGC this week if -- fingers crossed.
7 And then it will go to admin, and it may take a couple 8 of months before it finally gets published and FRN comes 9 out. We expect there to be a 45-day comment period.
10 So, sometime later this spring, maybe early 11 summer the latest, I expect this document will be out.
12 MEMBER KIRCHNER: And then, the 13 expectation is that within form any as-needed basis 14 or appropriate, it would result in a possible revision 15 to 2215, if I can get my numbers correct, with regard 16 to high burn-up fuel.
17 MR. SMITH: Correct. As these 18 initiatives are developed and finalized, then we will 19 put them -- state them to the revisions and new reg 20 2215.
21 MEMBER REMPE: But the high burn-up demo 22 examinations don't occur for many years. So, it's 23 doubtful that particular one will causes changes, is 24 my understanding.
25 MR. SMITH: That's most likely --
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155 1 MEMBER REMPE: Okay.
2 MR. SMITH: -- I think. Okay?
3 MEMBER KIRCHNER: All right, thank you.
4 CHAIR SUNSERI: So, at no offense to my 5 colleagues that have already started this, this is our 6 time to provide comments, not to carry on the meeting.
7 Okay? So -- but since this is an informational 8 gathering meeting, I mean, I would entertain any radical 9 questions that you might have. Just wanted to clarify 10 how this was going to factor in.
11 MEMBER KIRCHNER: Thank you.
12 CHAIR SUNSERI: For Vic -- Yeah. And like 13 I said, I didn't mean any offense. Jose?
14 MEMBER MARCH-LEUBA: Okay, I have two 15 comments. The first one is more generic. I understand 16 that this is a combination of two documents into a single 17 one, not a modification. But for future direction, 18 I would love to see less reliance on the specific of 19 fuel, and more reliance on a bounding analysis to 20 minimize another license amendment that we require 21 every year. So, once you have a ten-by-ten element 22 in there, any ten-by-ten element within less than 50 23 feet and it's, I think, something similar to a 5059 24 process. The licensee makes evaluation and tells us 25 our license coverages.
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156 1 The second comment is related to something 2 that we -- yes, here in a moment I go, that there is 3 some experiments being conducted on the casks, and they 4 count -- the thermal calculations are missing grossly 5 the estimates on temperature.
6 That's not control at this end. That's 7 how thermal calculations are no good. And I hope the 8 staff is going to look into that, because unless you 9 can point out what particular item you're making a 10 concern about, you're missing the temperature by a total 11 of two. That's not good. So, definitely you need to 12 follow up on that.
13 CHAIR SUNSERI: And would you like to have 14 full committee --
15 MEMBER MARCH-LEUBA: I think that we've 16 already heard enough and most of the members are here.
17 Unless a letter is required by the staff, I would not 18 have a full committee.
19 MEMBER STETKAR: I'll be brief. I think 20 there's benefit to bring it to the full committee.
21 And I'd suggest for the subcommittee to engage with 22 the staff on a briefing on that risk-informed pilot 23 project with the transnuclear certificate of 24 compliance, so that the subcommittee can learn what 25 has been done, what's being done, in that area.
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157 1 CHAIR SUNSERI: Thank you. Pete?
2 MEMBER RICCARDELLA: I have no comments.
3 CHAIR SUNSERI: Mike.
4 MEMBER CORRADINI: I guess I do think we 5 want to have a branch of the full committee for even 6 a brief letter. I guess my only additional comment, 7 a lot of what my colleagues have said is, we keep on 8 talking about the risk but I keep on thinking about 9 the consequence of a failure, versus the frequency of 10 what would cause a failure.
11 So, I kind of agree with Harold in the sense 12 that it's going to be difficult for all the various 13 initiators to understand the frequency, given how wide 14 ranging they could be and how different they are in 15 the reactor.
16 On the other hand, it strikes me there's 17 an awful lot of margin in the kind of detailed technical 18 bases that are defining what a failure is, and is allowed 19 to be a failure.
20 And it seems to me it's important for the 21 staff to identify what that margin is, and I don't -- and 22 whether EPRI is doing it in collaboration with the 23 staff, or staff is doing, I think that's important.
24 So, that's what I would put in the letter, 25 beyond the fact keep on proceeding to consolidate.
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158 1 I think consolidation is good, but I don't -- I do not 2 have the belief that it improves things. What improves 3 it is somehow knowing what the margin is, and try to 4 decide, is the margin that large that I actually can 5 have some flexibility in regulation? That's it.
6 CHAIR SUNSERI: Thank you. Dana.
7 MEMBER POWERS: I've got a couple of things 8 that are nitty gritty, and something to address your 9 question. I would become cautious about trying to be 10 absolutely comprehensive in this consolidation. It's 11 been my experience that standard review plans never 12 have the information you would like -- all the 13 information you'd like to have when you're confronting 14 something new.
15 And when you're confronting something 16 that's been done before, what you look for in the 17 guidance of the standard review planning that is more 18 philosophical, the details, the specifics, you go to 19 the safety evaluation reports of things that have gone 20 before.
21 So, I would be less given to go very 22 specific and tend to be as philosophical. I understand 23 the thinking that was going on in the various things, 24 rather than specific details of -- with references.
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159 1 safety evaluation reports. And if it's new, they're 2 going to have to march out on your own anyways. You 3 got --
4 We've talked some about risk information 5 and risk-informed. And Dr. Ballinger pointed out a 6 very good example of where there are conflicts on what's 7 conservative and what's not conservative. Depends on 8 what -- where you're sitting and what you're looking 9 at.
10 I think we don't have the risk information 11 that we have for reactors, to apply to this particular 12 activity. In that regard, I don't think the ACRS itself 13 needs to get deeply involved in this consolidation.
14 I think the committee's time and efforts 15 would be much better expended by focusing on how we 16 make better use of risk in this particular area. How 17 we get the necessary risk information, instead of 18 anecdotal accounts, and I'm very sensitive about 19 Mr. Ray's comment about the context within which risk 20 has to be considered through.
21 What we'd really like to ascertain is, what 22 are the risk achievement and risk reduction worth of 23 the various requirements that we're imposing. Because 24 these are burdens.
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160 1 implication or a magnitude on the public health and 2 safety, we really are burdening both the staff and the 3 licensees by continuing to impose it.
4 There's where I think the committee ought 5 to work, and the consolidation itself and the specifics 6 of it and things like that, is much -- the guys to ask 7 about that are really the guys that have to use it, 8 not the committee.
9 CHAIR SUNSERI: Thank you. Harold.
10 MEMBER RAY: I'll just agree with Dana.
11 I have no other comment.
12 CHAIR SUNSERI: Okay. Margaret?
13 MEMBER CHU: I think there are enough 14 high-level comments that I recommend would bring them 15 to the full committee, and then write a letter. Thank 16 you.
17 MEMBER BALLINGER: I agree with Mike and 18 with Dana, the combination of those two --
19 MEMBER POWERS: Who are orthogonally 20 opposed.
21 MEMBER BALLINGER: Pretty formidable.
22 Pretty formidable.
23 MEMBER POWERS: So we span the entire 24 available space.
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161 1 should -- I agree about the consolidation part, as well, 2 but the real high-level thing is what you guys have 3 commented on. I think we should bring it to the full 4 committee and write a letter where it gives us an 5 opportunity to stress those things, should we decide 6 to do that, in one person's not-so-humble opinion.
7 MEMBER POWERS: I mean, is it useful to 8 write a letter in this context that has an impact?
9 Or is it better to write a letter a priori outside of 10 this context. These guys got a job to do, and quite 11 frankly, it's a job that primarily serves their internal 12 interest.
13 I mean, their taking in documents, turning 14 it into one, that just makes it easy to get to. The 15 danger they involve is that it's so damn long that nobody 16 can remember what you said on page 100 by the time they 17 hit page 600.
18 MEMBER CORRADINI: But -- I guess I agree 19 with you, Dana, but isn't -- if we're going to encourage 20 them to think about some other things beyond just 21 consolidation, isn't this the time to do it? Or you 22 think you should wait? That's what I guess I didn't --
23 MEMBER POWERS: I don't think there's any 24 need to wait, but I don't think there's a need to tie 25 it to this activity. I think the problems that we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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162 1 in this set of regulations, vis-a-vis the commissions 2 implore that we make greater use of risk in the 3 regulatory process, have been manifest for a long time.
4 And to insist that people use risk 5 information when they don't have said risk information, 6 is unfair and impracticable. So, what they're going 7 to have to do is exactly what we did in the reactor 8 world, which we spent a huge amount of resource to get 9 the risk information.
10 Once we had the risk information and we 11 got the analysis of five representative plans, and then 12 asking licensees to turn around and analyze their own 13 plans, and we compiled a vast quantity of risk 14 information, then we could go about risk-informing the 15 regulation.
16 I don't think that a body of empirical 17 evidence exists right now. And, to say, oh, well this 18 is not risky because I think it's not, is not a 19 persuasive way to do regulations.
20 MEMBER BALLINGER: I haven't heard about 21 the a priori option, but I would agree with that. On 22 the issue of risk, if the risk were to be, I don't know, 23 judged to be ten to the minus whatev- -- sixth or 24 seventh, or whatever the number turns out to be for 25 a breach, or whatever we define it, then I would say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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163 1 we don't have the information.
2 But, if it's determine that the margin is 3 so large between the risk here -- even if it's an 4 engineering judgment and the reactor-type risk, then 5 not having detailed information just adds -- just is 6 accounted for by uncertainty. But if you get four 7 others of magnitude from the extremes -- no 8 overlap -- then that's an important thing to 9 understand, as well.
10 MEMBER POWERS: Well, I think you have to 11 be very careful about using wild-ass guesses --
12 MEMBER BALLINGER: I'm not talk- --
13 MEMBER POWERS: -- disguised as 14 engineering judgment, because you run into the problem 15 the public will be concerned that you haven't considered 16 this or that or the other thing --
17 MEMBER BALLINGER: Yeah.
18 MEMBER POWERS: -- and so a more systematic 19 evaluation that's fairly transparent is far more 20 persuasive than saying, I'm a good engineer and I've 21 thought about this a lot, and I've concluded there's 22 four orders of magnitude of anything.
23 MEMBER BALLINGER: Well, anything below 24 ten to the minus sixth, in my opinion, is a WAG anyway.
25 MEMBER POWERS: Usually, it means that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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164 1 you've left something out.
2 CHAIR SUNSERI: Okay, anything else, Rod?
3 Thanks. All right. It'd all be clear advice.
4 (Laughter.)
5 CHAIR SUNSERI: Clear as normal feedback.
6 Well, I'd like to take this opportunity to thank both 7 Jeremy and Rod for putting together the information 8 that you shared with us today. It's -- clearly you 9 enhanced our knowledge of what was going on in this 10 situation, and apparently -- or it's clearly apparent 11 that there's a lot of good work and effort going into 12 the consolidation effort and there'll be some benefit 13 from it when it's done.
14 I think clearly, from the feedback that 15 you've heard from us today, there's more work to be 16 done, though. And so, I'm going to carry forward the 17 recommendation to the full committee that we do review 18 what's going on, not to hold up the consolidation 19 effort, but to take a bigger, broader look, and make 20 sure that, as maybe one of the slides said, to assure 21 that the ongoing improvement efforts are effective, 22 and lead to safety objectives that we all want to see.
23 So, that would be the conclusion, and we are adjourned.
24 (Whereupon the above-entitled matter went 25 off the record at 12:17 p.m.)
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Advisory Committee on Reactor Safeguards Subcommittee Meeting on Radiation Protection Briefing on Draft NUREG-2215, Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities DSFM SRP Team Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission April 4, 2018
Outline
- Background
- Expectations
- Approach
- Public comments
- Changes and Enhancements 2
=
Background===
- Recognized the need to update both the Storage and Transportation Standard Review Plans (SRPs)
- Storage SRPs issued in 2000/2010
- NUREG-1536, Standard Review Plan for Dry Storage Systems at a General License Facility
- NUREG-1567, "Standard Review Plan for Spent Fuel Dry Storage Facilities
- 10 CFR Part 72 was revised in 2001/2003/2011
- Interim Staff Guidance (ISGs) documents were issued to assist in implementing changes to Part 72 and emergent issues
- Improved the format for the SRP
Expectations
- Maintain the safe and secure use of radioactive materials
- Increase efficiency of reviews
- Minimize/eliminate the use of ISGs
- Improve efficiency of future revisions
- One-stop for all storage review guidance
Approach
- Formed an internal NRC team representing all technical disciplines
- Started with the draft update to NUREG-1567
- Merged the guidance found in NUREG-1536
- Incorporated ISGs and other technical guidance into the consolidated update (NUREG-2215)
- Updated figures and regulations related to review areas
- Issued draft for stakeholder feedback
Public Meeting
- Held a public meeting on 03/23/2018
- Focused on comments that are directly relevant to NUREG-2215
- Received 153 public comments
- Most comments were outside scope of SRP
- Attended by 26 industry representatives and members of the public
Public Meeting (concluded)
- Presented 19 public comments that may result in changes to NUREG-2215
- Summarized each comment
- Provided NRC proposed response to each
- Open discussion on each comment
- Noted speakers, proposed changes to responses, and provided clarifications
Comments
- Sync SRP with Graded Approach, 10 CFR 72.48, and MAPS initiatives
- ISGs not incorporated correctly
- ISG-2, Fuel Retreivability
- ISG-3, Post Accident Recovery
- ISG-11, Cladding Considerations
- ISG-22, Potential Rod Splitting
- Inconsistent regulatory position on fuel characterization prior to storage
Comments (concluded)
- Comments not directly related to NUREG-2215
- Use of thin-walled casks at storage sites
- Radioactive material releases
- Conservative assumptions
- Many specifically directed to material stored in California
- Other Changes and Clarifications
Technical Staff Updates
- Not all technical chapters have major changes or enhancements
- NUREG-2215 is not intended to introduce new staff positions
- SRP is intended to provide a current state of how staff performs reviews
Chapter 4: Structural
- Staffs position continues to be maintained
- Content was reorganized to align with current review practices
- Regulatory language was clarified
Chapter 5: Thermal
- Staffs position continues to be maintained
- Content was reorganized to align with current review practices
- Regulatory language was clarified
- Referencing NUREG-2152 Computational Fluid Dynamics Best Practice Guidelines for Dry Cask Applications
- Additional guidance to perform CFD confirmatory analysis, and to perform solution verification (discretization error)
Chapter 6: Shielding
- Improves integration of review information with the Radiation Protection Chapters
- Incorporates staff review experience and practice for knowledge transfer
- Clarifies certain review topics
- Incorporates guidance for supporting Confinement and Thermal reviews, as needed
- Includes ISG-17 (GTCC waste)
Chapter 7: Criticality
- Incorporates ISG-8, Rev. 3 (Burnup Credit), with minor additions
- Clarifies certain review points and regulatory requirements, as needed
- Updates information to include latest available tools for knowledge transfer
Chapter 8: Materials
- Content reorganized and revised to provide a greater level of detail to existing guidance, reflecting current staff review practice. For example:
- NUREG-1536, Rev 1: The reviewer should analyze the potential for corrosion
- NUREG-2215: A new section, Corrosion Resistance, was added to specifically discuss the corrosion of carbon and low-alloy steels, austenitic stainless steels, and duplex stainless steels
Materials (concluded)
- Spent Nuclear Fuel
- Staffs position continues to be maintained
- Consolidates existing guidance (e.g., ISG-24: High burnup fuel integrity - EPRI/DOE demonstration cask at North Anna)
- Discusses recent IN 2018-01: Noble fission gas releases during loading
- Provides additional detail on defining cladding mechanical properties
Chapter 9: Confinement
- Staffs position continues to be maintained
- Most changes of editorial nature, for example cask to storage container
- Updated figures related to review areas and regulations related to the review
- Clarified terminology and discussion related to dose calculations
Chapters 10 A&B:
Radiation Protection
- Maintains two separate chapters
- Improves integration of review guidance with Shielding, Confinement, and Waste Management Chapters
- Incorporates staff review experience and practice for knowledge transfer
- Clarifies certain review topics
Chapter 13: Waste Management
- Improves integration of review guidance with Radiation Protection, Shielding, and Confinement chapters
- Clarifies certain review topics
Summary
- NUREG-2215 is a consolidation of existing staff guidance
- The new SRP is not intended to introduce new positions by staff
- Comments from the public indicated areas where additional clarification may be needed
Backup Slides Welding Welding: no significant changes
- The guidance follows the structural design criteria and generally relies on ASME and American Welding Society Codes For example, the staff has accepted:
ISGsSFST-ISG-1, Revision 2 Damaged Fuel SFST-ISG-2, Revision 2 Fuel Retrievability SFST-ISG-3 Post Accident Recovery and Compliance with 10 CFR 72.122(l)
SFST-ISG-4, Revision 1 Cask Closure Weld Inspections SFST-ISG-5, Revision 1 Confinement Evaluation SFST-ISG-6 Establishing Minimum Initial Enrichment for the Bounding Design Basis Fuel Assembly(s)
SFST-ISG-7 Potential Generic Issue Concerning Cask Heat Transfer in a Transportation Accident SFST-ISG-8, Revision 3 Burnup Credit in the Criticality Safety Analyses of PWR Spent Fuel in Transport and Storage Casks SFST-ISG-9, Revision 1 Storage of Components Associated with Fuel Assemblies SFST-ISG-10, Revision 1 Alternatives to the ASME Code SFST-ISG-11, Revision 3 Cladding Considerations for the Transportation and Storage of Spent Fuel SFST-ISG-12, Revision 1 Buckling of Irradiated Fuel Under Bottom End Drop Conditions SFST-ISG-13 Real Individual SFST-ISG-14 Supplemental Shielding SFST-ISG-15 Materials Evaluation SFST-ISG-16 Emergency Planning SFST-ISG-17 Interim Storage of Greater Than Class C Waste SFST-ISG-18, Revision 1 The Design and Testing of Lid Welds on Austenitic Stainless Steel Canisters as the Confinement Boundary for Spent Fuel Storage SFST-ISG-19 Moderator Exclusion Under Hypothetical Accident Conditions and Demonstrating Subcriticality of Spent Fuel Under the Requirements of 10 CFR 71.55(e)
SFST-ISG-20 Transportation Package Design Changes Authorized Under 10 CFR Part 71 Without Prior NRC Approval SFST-ISG-21 Use of Computational Modeling Software SFST-ISG-22 Potential Rod Splitting Due to Exposure to an Oxidizing Atmosphere During Short-Term Cask Loading Operations in LWR or Other Uranium Oxide Based Fuel SFST-ISG-23 Application of ASTM Standard Practice C1671-07 when performing technical reviews of spent fuel storage and transportation packaging licensing actions SFST-ISG-24 The Use of a Demonstration Program as a Surveillance Tool for Confirmation of Integrity for Continued Storage of High Burnup Fuel Beyond 20 Years SFST-ISG-25, Revision 0 Pressure Test and Helium Leakage Test of the Confinement Boundary for Spent Fuel Storage Canister SFST-ISG-26A, Revision 0 Draft - Shielding and Radiation Protection Review Effort and Licensing Parameters for 10 CFR Part 72 Applications (CANCELLED)
NEI Comments on Draft NRC NUREG-2215 Standard Review Plan for Spent Fuel Dry Storage Systems & Facilities Advisory Committee on Reactor Safeguards April 4, 2018 Rockville, MD
Used Fuel Storage - Current Situation
- Used fuel inventory*
- Approximately 80,960 MTU
- Increases 2 - 2.4k MTU annually
- ISFSI storage*
- 117,579 assemblies
- 33,515 MTU (39%)
- 2,698 casks/modules loaded
- 72 Operating ISFSIs
- 1 pool ISFSI, 1 modular vault
- Projections for 2020
- Estimating 86,000 MTU total
- Estimating 35,000 MTU at ISFSI
- 3,200 casks/modules loaded
- At 76 ISFSIs
- Almost all plant sites + Morris &
INEL
- Fuel from 119 reactors
- As of December 31, 2017
NEI Strategic Focus NATIONAL NUCLEAR ENERGY STRATEGY PRESERVE SUSTAIN INNOVATE THRIVE Appropriately value Create sustainability Innovate, Compete globally nuclear generation via improved commercialize, regulatory framework and deploy and reduced burden new nuclear
NEI SUSTAIN Regulatory Priorities Sustain: Desired Outcomes and Policy Actions
- Discipline and stability in NRC requirements (e.g., backfit rule, licensing processes, processes for transitioning plants to decommissioned status)
- Increased rate of progress in the application of risk-focused regulation (in SLR, digital I&C, and accident tolerant fuel)
Dry Storage Strategic Focus
- Graded Approach CoCs
- More efficient change control process
- Implement learning approach to aging management
- No new risk-uninformed regulatory actions
- Thermal Modelling Regulatory Roadmap
- Transform Dry Storage Regulation
NEI Comments on Draft NUREG 2215
- Would undermine ongoing improvements (graded licensing approach, change process, ISFSI renewal)
- Consolidation not sufficiently explained, expands scope, and does not consider ISG review history
- Could trigger unnecessary rewrite of ISFSI-only Emergency Plans
- Advances new and inconsistent positions on fuel characterization prior to storage 5
Conclusion
- NRC staff has been highly responsive to industrys comments (March 16 letter and March 23 public mtg.)
- Agreement on level of detail and commitment to ensure no new staff regulatory positions are welcome
- Staff also should carefully re-evaluate ISG-22
- Industry will pursue ISFSI only EP comment elsewhere
- Consolidating ISGs and prior NUREGS is a necessary but not sufficient part of establishing a more risk appropriate used fuel dry storage regulatory framework
- Both industry and NRC must commit to next steps to assure ongoing improvements are codified and extended 6