ML19126A027

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Memorandum to C. Regan Summary of April 23, 2019, Meeting with Nuclear Energy Institute to Discuss Proposed White Paper on Understanding Margin
ML19126A027
Person / Time
Issue date: 05/03/2019
From: Christian Jacobs
Spent Fuel Licensing Branch
To: Christopher Regan
Division of Spent Fuel Management
Jacobs C
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ML19126A026 List:
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Download: ML19126A027 (5)


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A. Hsia UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 3, 2019 MEMORANDUM TO: Christopher M. Regan, Deputy Director Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards FROM: Christian Jacobs, Sr. Project Manager /RA/

Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards

SUBJECT:

SUMMARY

OF APRIL 23, 2019, MEETING WITH NUCLEAR ENERGY INSTITUTE TO DISCUSS PROPOSED WHITE PAPER ON UNDERSTANDING MARGIN On April 23, 2019, staff from the Division of Spent Fuel Management held a public meeting with representatives from the Nuclear Energy Institute (NEI), at the U.S. Nuclear Regulatory Commission (NRC) Headquarters in Rockville, MD (see Enclosure 1 for attendance list). The purpose of the meeting was for NEI to present their approach on a proposed White Paper titled:

Defining Used Fuel Performance Margins.

After introductions, Mr. Robert Quinn (Westinghouse) gave a presentation (Enclosure 2) on the NEI White Paper concept. NEI stated that the current NRC regulations are overly conservative. NEI also stated that the objective of the paper is to improve safety by focusing industry resources on the most safety significant parameters, phenomenon, etc. and thereby improving regulatory efficiency. Specifically, NEI is seeking to continue dialogue with NRC in this effort to enhance used fuel safety by focusing resources on safety significant areas and to better define performance margins in the areas of thermal, radiological, source term, confinement, criticality and moisture. NEI also mentioned the use of topical reports as a potential process to addressing the issues on a generic basis.

There was discussion between NEI and NRC staff throughout the meeting, and the NRC staff asked questions about NEIs proposed white paper, schedule, and statements/conclusions made in the presentation, and ultimately what NEI was seeking to obtain from NRC and by when. NEI responded that they had identified a number of follow-up action items (seven from Industry and one for the NRC). The action items are as follows:

CONTACT: Christian Jacobs, NMSS/DSFM 301-415-6825

C. Regan

  • Industry: Identify priority Phenomena Identification and Ranking Table (PIRTs) in the White Paper and share this list with NRC early in the development process.
  • Industry: Provide cost/benefit information in the White Paper (with specific examples).

Overall cost-benefit analysis should be compared across disciplines so that efforts to identify and apply margin can be focused on the areas where there is the most bang for the buck.

  • Industry: Identify, in the White Paper, opportunities to generically address issues that are currently dealt with in individual licensing actions.
  • Industry: Identify areas where defining margin would require extensive effort to collect information and eliminate these areas from consideration (unless the cost/benefit of the effort can be justified).
  • Industry: Clearly explain in the White Paper the distinction between, and benefits of, changing a limit, and changing how compliance with the limit (whether it is changed or not) is approached.
  • Industry: Inform NRC on industrys position about the need for additional Boiling Water Reactor (BWR) burnup credit
  • Industry: Include in White Paper analyses of costs of future canister repair efforts to inform confinement margin discussion.
  • NRC: Provide information on Nuclear Reactor Regulation (NRR) Topical Report Office Instruction that might be useful in this effort (note that this information can be found in the Agency Documents and Management System (ADAMS) Accession Number ML18227A063, and was provided to NEI after the meeting on 4/24/2019; this action is closed).

There was no proprietary information discussed during the meeting. No regulatory decisions were made nor requested at this meeting. During the questions and answers session, one member of the public referred to a Nuclear Waste Technical Review Board report titled Evaluation of the Technical Basis for Extended Dry Storage and Transportation of Used Nuclear Fuel, December 2010 and asked why there was not more research being done on high burnup (HBU) fuel. The NRC staff responded noting that there has been further research on HBU fuel since 2010, including a high burn-up demonstration project ongoing at North Anna.

NRC staff also mentioned the Sandia National Laboratory (SNL) sister rod research program and agreed to provide a copy of that plan to the member of the public. Note that a link to the SNL research program was provided to the member of the public after the meeting.

In conclusion, NEI indicated they are: 1) planning to submit an industry letter to NRC on the White Paper approach in the April/May 2019 timeframe, 2) indicated that a Draft White Paper would be submitted in the August 2019 timeframe, 3) would be requesting another public meeting in the August 2019 timeframe regarding the Draft White Paper, and 4) would be following-up on the above identified industry action items.

Enclosures:

1. Attendance List
2. Presentation

C. Regan

SUBJECT:

SUMMARY

OF APRIL 23, 2019, MEETING WITH NUCLEAR ENERGY INSTITUTE TO DISCUSS PROPOSED WHITE PAPER ON UNDERSTANDINGMARGIN, DOCUMENT DATE: May 3, 2019 DISTRIBUTION:

DSFM r/f NRC attendees G:\SFST\Jacobs\NEI Public Meeting April 23, 2019\Meeting Summary/Meeting Summary 04-23-2019.docx ADAMS Package No. ML19126A026 Memo: ML19126A027 Slides: ML19109A134 OFFICE: DSFM DSFM DSFM NAME: CJacobs WWheatley (via email) JMcKirgan DATE: 5/1/19 5/3/19 5/3/19 OFFICIAL RECORD COPY

April 23, 2019 ATTENDANCE LIST Name Affiliation Christian Jacobs NRC/DSFM John McKirgan NRC/DSFM Chris Bajwa NRC/DSFM Darrell Dunn NRC/DSFM Meraj Rahimi NRC/DSFM Christopher Regan NRC/DSFM Jason Piotter NRC/DSFM Olivier Loreynie NRC/DSFM Tae Ahn NRC/DSFM Zhian Li NRC/DSFM Norma Garcia Santos NRC/DSFM Yoira Diaz Sanabria NRC/DSFM Donald Chung NRC/DSFM Travis Tate NRC/DSFM Damaris Marcano NRC/DSFM Patty Jehle NRC/OGC Rod McCullum NEI Mark Richter NEI Bruce Montgomery NEI Robert Quinn Westinghouse Keith Waldrop EPRI (Participating by phone)

Ricardo Torres NRC/DSFM Barbara Warren Citizens Environmental Coalition Zita Martin TVA Jana Bergman Curtis Wright Nine others unidentified NA Enclosure 1

ENCLOSURE 2: NEI Presentation Slides (ML19109A134)

Defining Used Fuel Performance Margins April 23, 2019 Enclosure 2