ML18346A520

Presentation Slides: Mccullum Reg Con 12 12

ML18346A520
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Site:	Nuclear Energy Institute
Issue date:	12/12/2018
From:	Mccullum R Nuclear Energy Institute
To:	Haile Lindsay NRC/NMSS/DSFM/IOB
Lindsay H
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Understanding Dry Storage Safety Margin Rod McCullum NRC REG CON December 12, 2018

©2018 Nuclear Energy Institute

Industry 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

©2018 Nuclear Energy Institute 2

NMSS Commission Brief 10/11/18 Graded Approach to Licensing Reviews (RIRP-I-16-01)

• We expect this initiative to make the storage licensing process more effective. This effort would reduce the number of amendments needing NRC review and approval by adjusting the level of information included in the technical specifications. - Marc Dapas

• So the Fuel Qualifications Table can be placed in the SAR, and if the licensee wishes to do some changes to loading patterns or things like that need a modification to the Fuel Qualifications Table, they can do that on their own and not come in for an amendment. - Mike Layton Change Control

• We completed our review of the Nuclear Institute guidance document 12-04, entitled Guidelines for 10 CFR 72.48 implementation, Revision 1, and starting working on the draft regulatory guide that would endorse this guidance document. - Marc Dapas

• Regarding method of evaluation, weve had significant engagement with the industry to reach alignment on what is allowed, if you will, within the context of 72.48. - Marc Dapas Aging Management

• We are now working through the process to consider endorsing an industry-proposed format and content guide for aging management, NEI 14-03. These process enhancements have already demonstrated increased efficiencies in the reduction of number of request for supplemental or additional information. For example, weve receive three license renewal applications which were accepted and docketed without any requests for supplemental information. - John McKirgan

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NMSS Commission Brief 10/11/18 Thermal Modeling

• I had the opportunity of course to see the cask demonstration project at North Annaand then attend a Used Fuel Working Group meetingwhere a presentation was provided that showed that the thermal models are conservative when you look at the comparison of what that model predicts relative to the actual parameters, the temperature measurements youre seeing at the demonstration project. - Marc Dapas

• And so its with a positive outlook that were going to be able to reduce the uncertainties here in using the models, will facilitate more efficient reviews of the licensing actions. - Marc Dapas

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What the High-Burnup Demo tells us about Margin

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Dry Storage Safety Margin Model B Established Reality Model A Limit or Criteria What we are Where We debating Would Still Be Safe

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Change in Perceived Reactor Safety Margin NRC Safety Goal

? Factor Factor of 2-5 of 2-5 Margin to Safety Goal Factor NUREG-1150 - Severe Accident Risks of Demonstrates that five representative nuclear powers plants are well within the Safety Goal 100 - 10,000 NRC State-of-the-Art Severe Accident Consequence Analysis (SOARCA)

Applied state of the art modeling methods to assess consequences of reactor accidents 1985 1990 1995 2000 2005 2010 2015 Severe Accident Research - Improving State of Knowledge

Where is the Margin in Dry Storage?

Thermal Conditions Radiation Levels Canister Integrity

©2018 Nuclear Energy Institute 8

Where do we go from here Develop a systematic approach to applying known margin to facilitate more efficient reviews of licensing actions and safety focused inspections

• Industry should propose a solution

• Industry must pre-align with NRC on submittal form and approval/endorsement path

• NEI/EPRI collaborative effort

• Industry volunteers needed to support

©2018 Nuclear Energy Institute 9

Questions?

rxm@nei.org