ML19268A191

Transcript: November 1, 2017 - NRC: Afternoon Session

ML19268A191
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Issue date:	11/01/2017
From:	Haile Lindsay NRC/NMSS/DSFM/IOB
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Lindsay H
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DSFM Conference November 1, 2017 1:00 p.m.

>> All right, so if you can hear my voice and you're out in the lobby, if you can come on in we'd appreciate it.

We're going to continue our theme this afternoon, transportation of radioactive material, right? Okay.

Good timing. All right, so I'm going to turn the floor over to Patti Silva who is going to lead the next panel. There you go Patti.

>> Patti Silva: Thank you, and welcome to the afternoon session of our second day of Reg Con I hope you've been enjoying the conference. This is section session on transportation of radioactive material, we've got a number of different topics and perspectives to discuss here, part 37 --

>> I'm not sure your microphone is on, hang on.

>> Is it on? I think I can hear myself. Can you hear me? It's on. Okay, sorry. Sorry I was just going over what the topics were Part 37, some QA experience from my shop here actually in headquarters on transportation and then planning of shipments from -- we'll hear from Paul Schmidt from Wisconsin and Naval spent fuel transportation. I will do their bios between each of this presentations and then we'll do questions at the very end of the session.

So first up we have Adelaide Giantelli, she's a senior project manager with the source management and protection branch of the NRC. She was a senior project manager and team leader for the transportation security at NRC. She has past experience that encompasses both transportation safety and security for code of conduct radioactive material, special nuclear materials, and spent fuel materials. Prior to joining the NRC she spent five years in the engineering group at Transnuclear. She was on a team designing spent fuel storage casks and transportation packages. And she worked for the engineering consulting firm Dames and Moore. She holds a bachelor's degree and master's degree in mechanical engineering from Manhattan college in New York City.

Please welcome Adelaide.

>> Adelaide Giantelli: Good afternoon, everyone. Can you hear me? Today I'll be discussing the transportation security aspects of 10 CFR Part 37. Next slide, please.

I'm going to start out by saying that my presentation is going to focus on transportation security for certain byproduct material. I'm not going to be covering the security requirements of special nuclear material or spent nuclear fuel, this is only for these category 1 and category 2 quantities of -- this first slide just highlights what I'm going to discuss, I'll go first through the requirements of Part 37 then I'll cover some of the best practices and observations as seen through inspections over the last few years, and then I'll provide a case study of when some material was stolen back in 2011.

I'm not going to go into a lot of depth on this. For transportation security, there are three agencies that have authority over this area. Those agencies are Department of Homeland Security, Department of Transportation and the NRC.

In general, to avoid the overlapping or to share resources, we do have memorandums of understand nothing place with our federal partners, there's 1 from 1979 in a has been -- between the NRC and DOT that's been in place and more recently 2015, was put in place among the Department of Homeland Security DOT and NRC.

In general the way the division responsibility works with byproduct material is NRC regulates the licensees that are transporting the material and Department of Transportation regulates the carriers that actual move the material from point A to point B.

This slide is a list of all existing regulations that we have to ensure the safe and secure use, storage and transport of byproduct material. Most of these requirements have been in place for decades. We've always had a strong safety and security program to ensure that materials were controlled and no inadvertent exposures from that material, to minimize that.

September 11th as you all know changed that threat environment. At that time we participated in both international and domestic groups to determine what material needed additional protection.

Every radioisotope was evaluated for use and effective radiological dispersal device or effective (inaudible) device.

We also provided assessments with intelligence communities and law enforcement to try to figure out what would be the credible motivations intentions and capabilities of potential adversaries to (inaudible).

Then finally we also conducted security assessments that evaluated the physical protection systems of different licensees and considered different scenarios of how an adversary could try to get ahold of that material from them.

From all these activities we developed security orders and it was for category 1 and 2 materials which will be on my next slide but it was 16 radioisotopes with associated quantities.

Once those orders were in place the NRC began inspecting licensees for compliance and we can a public process to transfer away from -- to transition away from the orders to a generally applicable rule.

When we were getting into the rulemaking language we used many of the insights we gained over the years from inspections from our own self-assessments and external audits that (inaudible).

And our challenge was to create a security rule that incorporated realistic approaches to enhance the security, and interface it well with the already long established safety requirements. And on this slide see highlighted in red Part 37 is that rule that had most recently (inaudible).

So Part 37 is a comprehensive security rule for category 1 materials and you can see the table there on the left.

And its focus is to primarily prevent diversion of the material, but it does as a secondary byproduct provide protection against radiological sabotage. When you look at these requirements you can separate them into two basic categories. There's a performance based requirements for the physical protection of the material, and then there's the requirements that tend to be proscriptive or administrative that involve documentation so that we can conduct our inspections.

So for taking the first column, the security requirements during use of the material. Licensees are required to establish a security zone around the material, to monitor or detect any unauthorized entry or removal of the material.

That's important, unauthorized entry and removal are two separate requirements, they have to have two separate means to fulfill these requirements.

Alarms and surveillance are examples of methods that can be used.

And if there is any attempted, actual attempted theft or sabotage of the material, diversion of the material, then law enforcement has to be called. Appropriate action is to call law enforcement and then notify the NRC.

On this slide you'll see a couple items highlighted in red I will get into some more detail about the actual transportation security requirements in Part 37.

Going to the administrative side of the list, anyone with unescorted access to category 1 or 2 quantities of materials must be subject to a background investigation, and that investigation has to be completed before the individual has access to material.

The investigation includes fingerprinting and FBI criminal history records check, a verification of true identity, work and history verification, and a character and reputation determination.

Once the licensee gathers all this information, they have to make a trustworthiness and reliability determination.

On whether that person should be allowed unescorted access to material. And that determination has to be documented, it's one of the things our inspectors will (inaudible).

Also in material we have requirements for the documentation of security related information. Licensees have to document the physical security plan, and if they ship material they have to document their transportation security plan.

They have to keep track of all the individuals that have this unescorted access to category 1 and 2 material, and that list has to be kept up to date within 7 days.

The last major area of administer requirements is information protection. Security information is limited to those that determined to be trustworthy and reliable, and also those who have a need to know. a need to know is very important, the information that a person has access to should be consistent with their job function.

On the next few slides I'll go to the transportation security requirements.

Starting with the requirements for category 2 quantities of material, that's the smaller quantity of material, prior to transferring material the licensee must verify with the regulator that the person receiving the material is authorized to receive that type, form and quantity of material. In the past, this could be done with a back licensing between one and another, that can no longer done. This verification has to be done with the regulator.

Licensees are required to conduct preplanning and coordination activities with the receiving licensee. They have to establish no later than arrival time (inaudible) to initiate an investigation of a missing package.

For category 2 shipments, licensees must use carriers that have a package tracking system and that driver must have a reliable means to communicate from the transport:

If the material is lost or stolen the NRC is required to (inaudible) -- if the material is loss or stolen licensees are required to notify the NRC immediately and we must notify them of any suspicious activity related to the shipment.

There are situations where a licensee will transport their portable and mobile device to a temporary job site.

Besides the physical protection requirements that are in place for the material while in use, there are additional requirements for portable and mobile devices while stored on a vehicle at a temporary job site.

A common practice -- this is a common practice for radiographers is to store their devices on a vehicle while they're sleeping in a hotel room. For health and safety reasons, they're not allowed to bring the device into the hotel room with them, so it has to be kept outside on their vehicle. So in this situation, the licensees are required to have, in addition to the -- all the physical protection requirements while in use, they have to have two independent physical controls. They have to demonstrate that their vehicle or trailer is disabled while the device is stored on it, and they must employ all the physical protection measures while the material is stored on their --

not in their control, stored on a vehicle.

Moving on to category 1 quantities of material. In this case, similar to category 2, the licensee has to verify that the entity receiving the material is authorized to receive the material through the regulator. And because the quantities are so much more significant, there are additional requirements on these shipments. Licensees have to use carriers with movement control centers, the control centers have to have the ability to actively monitor shipments 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week, and have the ability to immediately communicate an emergency to the appropriate law enforcement officials.

Also, the licensees have to ensure that the carrier has both a primary and back up communications capabilities from the transport vehicle to request assistance in an emergency. The two communication capabilities cannot be subject to the same failure mechanisms. So for example, two cell phones with different carrier companies would not be considered a way of meeting this requirement. Since cell phones company typically share cell phone towers, once you take out the tower you've taken all the means to communicate out. So a combination of cell phone and satellite phone or cell phone and CB, those are things that are considered independent means of

communication.

Licensees are also required to preplan and coordinate their activities. With the receiving licensee including no later than arrival time. They also have to coordinate with state officials through which the shipment is passing.

And for shipments that are of long duration, where the driver has to rest in accordance with DOT regulations, an accompanying individual has to be with the shipment to ensure -- to provide the security while the driver is resting.

Next slide, please. The licensee also has to prepare procedures covering both normal and contingency operations, if something goes wrong during the shipment it should cover innovations, communication protocols, loss of communications, and any response to the actual attempted or suspicious activities related to theft or diversion of the shipment.

And they also have to protect the shipment information from disclosure to unauthorized. Again similar to category 2, if the material is lost or stolen or any suspicious activity, that has to be reported (inaudible). Next slide, please.

As a form for resources for everyone, we keep our -- the public website up to date with all the information relevant to Part 37. We have on the website resources for stakeholders, including sample guidance for how to implement Part 37, guidance on best security practices, and on special procedures, just to name a few.

And also, what we've done in the last few years is we conducted a review of our Part 37 requirements. And --

sections. And most of those sections were found to be clear, with no findings, and actually what we found is 50 percent of the violations were from the licensee failing to appropriately transition from the rule to the -- from the orders to the rule.

Going onto the next slide. Some best practices we found over the years. Some of the areas are inspectors would ask licensees to demonstrate how the physical protection system would work at a time when the equipment wasn't fully operable. Pointed out in red, a lot of time inspectors found the licensee didn't consider the operating environment of their equipment, chemical and (inaudible) would corrode the connections and it wouldn't operate.

So the solution is for licensees to continue to constantly routine test and maintain their materials.

Next slide. I'm going to skip to the next slide. We also found, when our inspectors went out security plans were stored on common servers, it wasn't licensees weren't protecting these plans, they were -- what they were doing was they were password protecting them but not realizing there were entities that could access the plans, such as the IT personnel.

So the solution to that is that the IT personnel should go under the TR requirements as well, they should be (inaudible).

Last slide is -- I've got like two more slides, can I just go through them real quick?

>> You can take some of my time.

>> We had situations where licensees didn't understand how to operate the security system. You know, there are folks who had the ability to operate the system and our inspector would go and ask and the person had no idea how to work the system.

So the idea on that is that licensees need to train (inaudible) responsibility to their security system, then the licensee has to train them and (inaudible).

So going onto the next slide. Back in 2011, (inaudible), for years we required licensees to report theft or loss of material. There are additional requirements in Part 37 to -- for reporting to us.

We retain all that information, and considering the amount of material that's out there, there has been very few

reports of theft. There are about 77,000 category 1 and 2 sources out there, and since May, 2006, there have been no thefts of category 1 materials, and only 6 thefts of category 2 materials.

-- they were all radiography cameras containing iridium-192. Most of the thefts represented crimes of opportunity because the vehicles were not properly secured, in accordance with our securing requirements.

And in all cases, they were recovered except one, in one case, I'll go briefly into the one time that the source wasn't recovered.

On July, 2011, a radiography camera with 34 curies of radium was stolen from a car in a parking lot and basically the camera was stored on a parking -- and the radiographers were sleeping in a hotel room. They had locked the device in a dark room but they did not lock the tailgate. At 4 a.m. the truck was broken into, the device and other tools associated with radiography were stolen.

When the licensees discovered the theft they contacted Austin police department, they contacted their regulatory authority, and the Austin police responded quickly and called FBI.

And the regulator notified our operations center. Immediately the regulator notified Texas association of pawn brokers and the institute of scrap recycling just to see if maybe that this radiography camera got dumped somewhere.

Police did find security footage at the scene and found some fingerprints but they could not match the fingerprints with anybody in a database.

Drive by searches were done, over aerial, flyovers to try to find the camera. A reward was offered. And groups like Department of Transportation were notified, people that would be mowing the lawn on the side of the highways were notified to look for this. Local hospital groups were also alerted to the possibility that individuals with radiation industry injuries could be coming into their emergency rooms.

The emergency -- the radiation emergency assistance center Oak Ridge, Tennessee, provided resources for the medical teams if they needed assistance.

NRC we alerted the Mexican authorities of the theft and CDC was notified to be on the look out for the camera being transported.

--- NSA also performed flyovers and the camera was not found.

Since then, the source has decade -- since it's never been recovered, has decayed to background levels. It was thought that the camera was stolen for business purposes and not (inaudible).

As a result of the incident, the (inaudible) inspections were done, and it was determined that the radiographer and the licensee were at fault and it was a case where it shows how much coordination happens when a source actually goes (inaudible). (inaudible) at every level are (inaudible).

Thank you.

(Applause.)

>> Patti Silva: Thank you. Next up is Earl Love. Earl is currently a senior in transportation and storage safety inspector here in Spent Fuel Management division, he's been an inspector for 10 years here after he worked in the nuclear industry for 16 years performing lead quality assurance functions of nuclear quality assurance, power duration equipment and services, decommissioning regulatory compliance and performance assessment programs and projects.

Prior to joining the NRC he was a supervisor of supply oversight at transnuclear in the 90s he worked in the nuclear industry as a senior quality assurance engineer in various Yankee Power companies as well as Northeast

Utility Service Company, who at the time was operating company of the Millstone nuclear power station.

He also worked as a senior is technical specialist for Duke engineering and services in the quality assurance branch. Mr. Love holds a bachelor of science degree in mechanical engineering from Wentworth institute of technology in Boston. Welcome, Earl.

>> Earl Love: Thank you, Patti for that introduction. Good afternoon everyone.

The Office of Nuclear Materials Safety and Safeguards division of Spent Fuel Management is responsible for regulating activities which provide for the safe and secure storage of spent nuclear fuel and transportation of radioactive materials regulated under the Atomic Energy Act.

The NRC's requirements for packaging and transportation of radioactive materials can be found in 10 CFR Part

71.

Regulations in this Part applied to any licensee authorized by specific or general license issued by the commission to receive, possess, use, or transfer licensed material, including fissile material if the licensee delivers that material to a carrier for transport, transports the material outside the site of usage, as specified in the NRC license, or transports that material on public highways.

I mention the word packaging. So I think it's important that I distinguish between packaging versus package.

Some of this is common knowledge to most of you. Package means the packaging together with its radioactive contents. As presented for transport. Packaging means the assembly of components necessary to insure compliance with the packaging requirements.

Concerning the contents of packages, there are two types. A, and B. The B package means licensed material in which activity limits correspond to the maximum activity of radioactive material for special form material, and specifically requirements for shielding and survivability of the package during and after an accident that are different from type A package.

So for the purposes of this presentation, the primary subject is specific only to the quality assurance inspection activities related to type B packages.

In a manner that insurance safety and security by licensees that implement a regulatory program involving activities that include licensing, inspection, assessment of licensee performance, events analysis, enforcement, and identification and resolution of generic issues.

Next slide, please. That's good right there. I have five sections up there that I'd like to discuss, each focuses on QA and regulatory compliance. First is our regulatory framework. Next is QA program requirements. Then program implementation expectations, and lastly a description of the agency's inspection program that includes a discussion on certain types of violations that we encounter during the performance of packaging inspections.

My intent is not to make you an expert in the area of packages used for transportation of radioactive materials, which most of you probably are already, but rather, to raise your awareness on the importance of regulatory compliance and inspection, related responsibilities to assure safety and security by licensees and users of the transportation packages.

And implementing a regulatory program. Next slide, please.

The NRC's regulations state that a licensee -- a license to transport radioactive material that is granted under the provisions of 10 CFR Part 71, subpart C, general license, applies only to a licensee who has a QA program approved by the commission as satisfying the provisions of subpart H, quality assurance of 10 CFR Part 71.

The granting of a license also affords NRC an opportunity to perform inspections, and to take appropriate regulatory action should a safety or noncompliance matter be identified.

SFM's inspection branch oversees the design, manufacture, use, and maintenance of packages that are used to transport radioactive materials, including spent nuclear fuel from commercial nuclear power plants.

You note in this slide the last bullet talks dry cask storage vendors for the dual purpose designs. With respect to those vendors, the dual purpose designs, meaning storage and transportation. Whole tech international, NAC International and TN Americas all have a fleet of transport cask systems. All total approximately 15, that are separately serviced under 10 CFR Part 71 for the transportation of spent nuclear fuel from spent fuel pools to IFSI. Next slide, please.

Proper handling of nuclear material helps protect the safety of the public and plant workers. To achieve this the NRC works with the DOT and DOE in the United States, and within the IAEA internationally.

Together, these agencies help make sure nuclear materials and packages are transported safely around the world.

DOE is responsible by law for the disposal of spent fuel from the nation's power reactors. DOE transports radioactive material under the auspices of their own DOE -- of their own authority.

DOE's transportation activities must also meet DOT transportation requirements.

DOT coordinates with the NRC to set rules for the packaging of nuclear materials. DOT also works with the NRC in affected states to regulate the transport.

DOT regulates carriers, sets standards for routes, and is responsible for international agreements of the transport of all hazardous materials.

The agreement states are U.S. states to which under the Atomic Energy Act NRC relinquishes portions of its regulatory authority to license and regulate byproduct materials, source materials, and certain quantities of special nuclear materials.

After designation as an agreement state, the NRC reviews agreement state programs for continued adequacy to protect public health and safety, and compatibility with the NRC's regulatory program. Next slide, please.

What I'm showing here is a typical type B package for shipment of solid and liquid radioactive materials. This is a portable, light weight and compact industrial radiographic exposure device used for industrial applications of gamma radiography to inspect materials and structures.

So previously, all changes made to quality assurance program approvals had to be prior to reviewed and approved by the NRC before they could be implemented. QA program nonreduction and commitments are those that involve administrative improvements and clarifications and editorial changes, and do not reduce the effectiveness of the program. Those changes need not be submitted to the NRC for review and approval.

10 CFR 71.106 requires that changes to quality assurance programs that do not reduce commitments be submitted to the NRC every 24 months instead.

With the reporting period starting on the day of the vendor's last program approval.

If changes made to a quality assurance program are not made in the preceding 24 month period, it is expected to report that no changes were made.

If amending your quality assurance program approval determines a reduction in commitments, or terminate an approval, this too must be requested in writing. Next slide, please.

As stated in the previous slide, regulations include requirements for quality assurance programs for entities that engage in activities involved in the transportation of radioactive materials.

Prior to commencing activities subject to the QA requirements, a QA program description must be submitted to the NRC for review and approval.

The QA program user must also develop implementing procedures for the users QA program to ensure compliance with NRC's QA requirements.

The NRC conducts independent periodic inspections of QA program users to assess the quality of program implementation.

QA requirements are also imposed on those who submit an application for approval of a package design under the provisions of subpart D of 10 CFR Part 71.

After NRC staff technical review determines that the QA program description and packaging design meets regulatory requirements, a certificate of compliance is issued. Next slide, please.

Prior to the use of any package for the shipment of license material subject to Part 71, each licensee must obtain commission approval. And I can -- there's a common theme here, I don't know if you get it, but you need to submit your quality program for approval.

Each licensee is required to file a description, along with discussion of which requirements of subpart H are applicable and how they will be satisfied.

There are a total of 18 criteria that must be addressed by the licensee to the extent applicable. These criteria are delineated in 10 CFR Part 71, subpart H.

The extent of detail is left up to the applicant. The NRC has received and rejected QA program descriptions that basically reinstated the QA program criteria. These programs descriptions were rejected as they were simply a reinstatement of NRC QA program requirements, not a description, of which elements were applicable to the supplier's activities nor a description of how they would be satisfied.

The NRC has received QA program submittals that were extremely detailed to the point they contained actual implementing procedures. These programs were also rejected as the NRC staff only reviews QA program descriptions and not detailed implementing procedures. Next slide, please.

We've developed a program for procedures for these reactive and planned inspections and is responsible for their implementation.

Inspections are conducted by trained and qualified safety inspectors well-versed in assessing QA program implementation adequacy. Assessing QA program implementation adequacy. Inspection teams usually consist of two to three inspectors and are sometimes augmented by NRC technical staff, if there is a specific complex technical issue that needs to be looked at during an inspection.

Next slide, please. Scope and extent of inspection dependent upon activities at the inspection site. Those include the times we do full scope inspections, all 18 criteria. Corporate inspections, with all fabrications. By corporate inspections I mean the certificate of compliance holders, the designers, who are not fabricators, those designers typically subcontract the fabrication of the packaging out to fabricators. We also go to the fabrication facilities to do inspections as well for compliance to subpart H.

And contracted fabrication facilities which, I just mentioned. Inspection guidance contained in NRC inspection procedure 86001, design fabrication and testing, and maintenance of transportation packagings. If anyone is interested in seeing exactly the criteria that we inspect to. Other than subpart H.

Inspections are typically conducted over three to 5 day period, and include an in depth review of program documents, interviews with personnel, and observation of field activities. We like to be as performance based as possible during these inspections to verify implementation of the program.

Inspection results are communicated verbally at the end of the inspection and subsequently documented in a written report. QA program nonconformances to the program requirements are dispositioned in accordance with the severity and in accordance with NRC written enforcement policy. Next.

Next one, please. A cylindrical stainless steel lead shielded packaging for shipment of type B quantities of radioactive waste materials and byproducts source and special nuclear material in the form of solids, solidified material and resins what you see up there.

This is packaging commonly used at nuclear plants for shipment of spent resins. This is a cylindrical stainless steel lead shielded packaging with a thick outer and inner stainless steel shell designed for the transport of radioactive waste materials.

Simple nonconformances typically require a response by the QA program user as to why the nonconformance occurred and what actions that have taken or will be taken in order to prevent its recurrence.

We've had 33 performance based inspections over the last four years, of CFC QA program approval and certificate compliance holders. 11 are planned for 2018, we've done international inspections in Canada, France, India, Japan and in the United Kingdom. Of the 33 inspections, 23 violations were identified, 15 severity level 4 notice of violations, and 9 were noncited violations. Next slide, please.

Here's a package used to transport fuel elements that have been irradiated in various test and research reactors.

Happened to be at MIT, it was undergoing a helium leak test. Next slide, please.

NRC compliance inspection program. Common 10 CFR 71 subpart H quality assurance findings.

The criterions. Based on the four year trend we've got quality assurance program, design package control, instructions, procedures, drawings, purchased material, equipment and services, corrective actions, and quality assurance records. Next slide.

I'm not going to read it but you can see some of the common inspection findings. Some of the -- well just about every one is considered a major -- not a major violation, but issues with implemented QA program but are kind of unique in their own way, right on down from training to design control to calibration to nondestructive examination and failure to maintain QA records. You can read the rest.

So in summary, next. Cask and packaging designers are responsible for insuring the fabricated cask components comply with the design as approved by the NRC. To do this they're required to have a quality insurance program that meets 18 criteria described in the regulations.

The NRC oversees the design, manufacture and use of packages in transportation casks. This oversight performed by trained, qualified inspectors ensures licensees and designers are following safety and security requirements, meeting the terms of their license, and implementing QA programs.

QA program nonconformances are dispositioned in accordance with the severity, and in accordance with NRC written enforcement policy.

Package and cask design applications, the NRC's document of reviews, the NRC inspection reports, are all available on the public -- to the public on the agency website at NRC.gov.

And that concludes my presentation. Thank you.

(Applause.)

>> Patti Silva: Thank you, Earl. So our next presenter is Paul Schmidt, he's the chief of radiation protection in the Wisconsin Department of Health services. Prior to joining this section in 1989 he worked for many years in the nuclear power industry preceded by three years as a federal regulator. Oh, he's one of us. Mr. Schmidt serves as the governor appointed state liaison officer at the nuclear regulatory -- to the Nuclear Regulatory Commission

for Wisconsin, and represents the state on the midwest radioactive materials transportation committee.

His education background includes an MS and BS degrees from Iowa state university, he also functions as the primary state radiological coordinator responsible for coordinating the state's technical response to all radiological incidents impacting Wisconsin and developing protective action recommendations.

>> Paul Schmidt: Thank you. Good afternoon, everyone. I appreciate the introduction, also appreciate the chance to be here today and speak with an acronym friendly audience about the transportation of radioactive materials, provide a bit of state perspective on that. As Patti mentioned, my day job is the radiation program director for the state of Wisconsin. In addition I'm one of the Wisconsin appointees to the midwestern radioactive materials transportation committee. Not everyone may be familiar with this committee, so if I could have the next slide, please.

This committee was originally established by the council of state governments midwest office in 1989 to bring the midwestern states together to identify, prioritize and work with the Department of Energy to resolve regional issues related to DOE shipments of radioactive waste and materials, including spent nuclear fuel.

Now, as you might guess, DOE provides the funding for this committee and it's worked through three cooperative agreements. One is with their Carlsbad field office for shipments to the waste isolation pilot plan. The other is with their office of nuclear energy for future spent fuel and high level waste shipments, and final one is with the DOE office of environmental management office of packaging and transportation, for everything else.

Now a quick look at a U.S. map shows why there's a focus on the midwest here, since it's a chill point for lack of a better term, for any shipments going across the U.S., from point of origin to a disposal or storage site. In recent years they've also seen more Canadian highway route control quantity shipments going to radiation facilities around the country.

A committee membership consists of representatives of the executive and legislative branches, of government in the 12 Midwestern states, I won't bore you going through the list but some background you can see on the slide, obviously Wisconsin is one of those states.

We met biannually twice per year, one meeting in conjunction with the national transportation stakeholders forum.

The attendees, in addition to the mandated folks, also include tribal representatives, folks from the DOE obviously, folks from your agency, Nuclear Regulatory Commission, Earl leaston some of you may remember was an attendee in the past, nuclear utility representatives, and a variety of others as well that have an interest in transportation. But the bottom line is this committee is the primary forum through which the Midwestern states have and will likely continue to be at least in the near future involved in planning and preparing for DOE shipments.

One of our primary products I'll focus on next is a document called the planning guide for shipments of radioactive material through the Midwestern states. Can I have the next slide, please.

This planning guide, as the name implies, is a guidance document. It was originally developed in 2002, in response to increasing number of radioactive materials shipments through the midwest, some from DOE cleanup campaigns.

The planning guide was created and routinely updated, a very important point here especially for people who use this document, with a number of objectives in mind. One is that it wants to present the Midwestern states preference for how shippers should conduct radioactive material shipments through the region.

Also wants to provide shippers with a single source of accurate and updated information for planning shipping activities. And basically, it's one stop shopping for shipment planning through the Midwest. It's not a large document I brought a copy it's also readily available online as well CSG.org website.

I want to give an example of how shippers can practically use this type of document. Just as an example. Let's say a shipper wants to know who in each state received an advanced notice of shipments required under 10 CFR

71 and 73. Check the guide, it's in here and routinely updated. If a shipper wants to know what fees do I have to pay in each state, and there are a number of the midwestern states that do charge fees for shipments going through their states. Check the guide, it's all in there what the fees are per vehicle, per cask, whatever it may be, it's all in there, routinely updated.

Who do I have to contact to arrange a CVSA, commercial vehicle safety alliance level 6, which is radioactive vehicle inspection. It's in the guide, just check it out, it's in there.

If there's an emergency while I'm in a particular state whom do I call to report that emergency, and how do I do it.

Check the guide, it's in there.

The planning guide also details the components of a transportation plan, and this is something of particular value to a state or others who may not be as familiar with shipment planning as a corridor state. A corridor is just a state along major routes for DOE shipments.

I'll provide you a sample shortly showing the value of this resource from personal perspective here. But ultimately what we want to do is improve the efficiency of the transportation process for both shippers and states along those routes.

Next slide, please. I mentioned the commercial vehicle safety alliance, a little bit about this organization. The commercial vehicle safety alliance, or CVSA is a nonprofit association made up of local, state, provincial, territorial and federal commercial motor vehicle safety officials and industry representatives. The goal of this alliance is to achieve uniformity, compatibility and reciprocity of commercial vehicle inspections and enforcement by having certified inspectors conducting truck inspections, focusing on trucks here, using uniform inspection procedures.

There are about 13,000 CVSA a certified inspectors throughout North America, this is a large group of people.

But there's a very small subset here that looks at the radioactive piece of this. Just to give you an example, in Wisconsin the number of inspectors certified to conduct CVSA level 6 inspections, which are the radioactive shipments, is 4. So it's a much smaller group of the larger group.

Worth noting, too, that federal regulations require CVSA point of origin inspection of trucks used to transport shipments of highway route control and quantities, larger quantities above a certain threshold. It's worth noting there is no equivalent shipment for rail shipments. Rail shipments are inspected under the authority of the federal railroad administration or FRA using FRA certified inspectors. However they do not have the same level of standardization, I'll use that as the best term I can come up with, as the CVSA inspections do.

The midwest has long advocated for DOE, federal railroad administration and states to work together to streamline and standardize those rail safety procedures in anticipation of large quantities of spent fuel and high level waste moving by rail.

Now besides reciprocity, there are three attributes of the CVSA inspection program that stand out as essential to the success of the national rail inspection program. Detailed listing of items checked and defects found; the ability to pass information along to inspectors in other states in a secure manner; and the signature, basically the certification by signature, of duly certified state inspectors who conduct those inspections.

And there's a subgroup of the national transportation stakeholders forum called the rail routing ad hoc working group which is specifically working on this task.

Can I have the last slide please here. What I want to end with is a practical example of the benefits to my state of participating on this Midwestern radioactive rails transportation committee and the information available in the planning guide, a practical example here. A number of years ago, I think many people are familiar with this, there was a federal initiative begun to replace high enriched uranium fuel, and I'll focus on the research reactors here, so used in the university research reactors, with low enriched uranium fuel. Kind of a nonproliferation issue. Our university reactor in Wisconsin was last on the list, scheduled for the 2009-10 time frame.

The problems we had at that time were two fold. One is Wisconsin at that time had none of the transportation

infrastructure inherent in a corridor state, Illinois is an example. We had no fees, we weren't charging fees for shipments across the state, so no funding to support a program. We had limited general awareness of just what transportation of radioactive materials was all about, especially larger quantities. We had no training of local responders along major transportation routes, that's not --we had no program for that. We had no routine radiological emergency preparedness planning outside the nuclear plant risk counties, we had it there but basically nowhere else. We had no routine escorts for radioactive shipments like a lot of the corridor states do.

So we had a lot of deficiencies there going into this.

The other thing we had going against us is the only people who had any knowledge of a prior university research reactor fuel shipment that had occurred in our state decades ago at that time had long since retired, so we were really starting from scratch on this process.

And my enviable job at the time was to advise our emergency management agency on exactly what was needed at the state and local level to facilitate the shipment. And the answer was we needed a transportation plan.

That unfortunately no one including myself, I'll be honest, had any experience with up to that point. Fortunately, though, I was a member of this midwest radioactive material transportation committee, and I turned to this group for advice, and this group had the right mix -- fortunately had the right mix and types of people, it had basically my contemporaries in other states who had already done this, so I could get that perspective from them. We had state patrol, the security folks that were participating on this group, so I had access to their knowledge. We had emergency management folks in the other agencies so I could get that perspective. The NRC, or at least as I mentioned had been a routine participant so I had access to him for his perspective on it, they were able to answer all my questions, advise me on pitfalls and lessons learned from the other states prior shipping campaigns and provide specific training to the state and local agencies that we felt was necessary to facilitate development of this transportation plan.

Planning guide detailed all the components we needed to consider in a transportation plan, it's all list nd this guide. What are the facets we need to look at in developing a transportation plan. Things like route selection. So the appropriate group in our folks worked with the shipper to look at what route was going to be taken.

We had to look at the safe parking aspect of it, in case there's a problem where does this go, and of course the security folks, the state patrol, worked with the shipper on that specific piece.

What would the package even consist of, what would it look like. So we had literally training on this. What does a CAT look like, what's going to be in it, what are the inherent safeguards safety piece that goes along with it, so people were aware of that up front. No surprises there.

Who received what level of notification. And I have to mention Adelaide here, we had specifically asked for the NRC to come and provide training to our state and local agencies on just exactly what is safeguards information and how do you protect it.

Adelaide and possibly Earl and one other came from headquarters here to provide that training, because we needed that level of information, and they were able to provide it to us, it was greatly appreciated.

The inspection piece, who is going to inspect this, what's it going to look at it, what's it going to look at, that was all arranged and we coordinated with the state of Illinois, who came up and do their state inspections, up in Madison, at the point of origin, but we were able to do that coordination working through this committee, so it worked out really well there.

The emergency management piece of it what local agencies are going to be told, what are they going to be told and when, and all that.

The public and political information. The term I heard earlier was public and intergovernmental outreach. We felt that was a very important piece of this, because we not only wanted to know what do we tell the public through press releases and this type of thing, this is going to be very visible on the university campus, but also what do you tell local government agencies as well as government agencies within the state government. What do they

need to know, what should you tell them. So we had to look at that piece as well.

And then the escort piece as well. Were we going to escort this, who was going to do it. We ultimately decided we were going to be the ones at the state level who were going to escort this shipment. So we made the plans necessary to do that.

But the bottom line here is working with the licensee and the shipper, we developed a detailed transportation plan for the shipment that resulted in the successful campaign with no surprises, which is our bottom line. So thank you very much for your attention, happy to discuss this a little further later.

(Applause.)

>> Patti Silva: Thank you, Paul. Barry Miles, he currently serves as deputy director of the reactor refueling division in the headquarters of the Navy Nuclear Propulsion Program in Washington, D.C. his responsibilities include management of all Naval new and spent fuel shipping container work in the nuclear program including design, analysis, certification, manufacture, logistics, use, unloading and ultimate mat disposal.

He holds a bachelor's in chemical energy. Yay I'm chem-y too. From the University of Virginia -- not me -- but masters in finance from George Washington University, and he has over 40 years experience in nuclear -- in Navy Nuclear Propulsion Program.

If you would have told us ahead of time we would have given you the walking mic and you could have gotten around.

>> This working? Hi, thank you very much I appreciate the opportunity to be here. As Patti said I'm responsible for the shipping container program at headquarters nuclear Navy program, and in my group we take care of all aspects of the shipping containers. The design, certification, procurement, manufacture, logistical use and ultimate mat disposal so it's pretty much cradle to grave.

In that certification piece we currently have 11 active NRC certifications of our shipping containers for shipping spent fuel and highly radioactive material. And with those 11 certifications, several of those have multiple cargos so I would guess we have about 25 total safety analysis reports that are currently active.

What I want to cover in this next slide -- and my challenge is, I want to skip several of these slides, I see the monitor over there. In the Navy we believe in trust and verify, so I've got my own thing going here, and so I'm starting now. Okay.

We maybe cheat a little bit. I want to cover these four major areas. I want to give a very short description of our program, I want to talk about our container shipments, but I really want to focus on this third area, I want to focus on our accident exercises that we run periodically. About every two years. And then lastly, two or three photos of our most current -- our new test spent fuel shipping container the M-290. Skip the next two slides. Go back one, there we go thanks.

We were founded in 1948 so we've been around about 70 years.

Currently we're regulating 101 reactors, about comparable to what you here at the NRC are looking at in the commercial industry.

All the aircraft carriers and all the submarine in the Navy are nuclear powered now, and then we have four stationary platforms that we use for training. Two of those are in upstate New York, and two of them are converted ballistic missile submarines that are moored at the mouth of the Cooper River in South Carolina.

Next slide. This is kind of what we call our bubble chart. This is the areas that we have responsibility for. We have the headquarters over at the Navy yard where I am, about 500 folks. What we're really about is upper right-hand corner is about the ships. But we also have -- we regulate and oversee the nuclear work done at six shipyards, where our ships go in.

We have two schools for training our new enlisted men on the fundamentals of nuclear power, and we, after they go through the schools, we send them to those land based platforms for operational training before they have to deal with that kind of training in the environment.

We have an industrialized base of about 700 vendors that we use. And in the far left -- 9 o'clock position is very important, that's our facility in Idaho, the Naval reactors facility, which (inaudible). That's important because that's where we send all of our spent fuel that we remove from our ships.

And then we have two laboratories that are devoted entirely to our work, one the Bettis laboratory in Pittsburgh and the other the Capwell laboratory up in Schenectady, New York.

Each of these places not including the ships we have a field office, and head of that field office then reports directly to our four star admiral director and is basically his eyes and ears, and we have 16 of those field offices.

This covers the overview of the program. So let's talk about our container rail shipments. Next slide.

In shipping by rail, and we ship exclusively all of our nuclear fuel by rail, products, that is, for about 60 years. We have two kind of fuel shipments, new fuel before it goes into the ship, and the used fuel, or we commonly say the spent -- (inaudible)

The unique thing about all our shipments that's different than the ones that NRC regulates is our shipments are all national security shipments. Both the national security exemption and Department of Transportation (inaudible)

We do ensure that we meet all other DOT requirements except for those three listed there. We don't placard our containers. We don't give advanced notification to the (inaudible)

And we don't put anything on the shipping papers that we give the railroads, something that would specifically say it was fuel, we delete that information. But all of that information is carried by our couriers that escort the shipments. So they have that information available should there be an accident or incident involving one of our shipments.

Skip that one.

So what are our shipping routes. Here's map of the United States and it's really very simple, and basically it's from the shipyard to Idaho. You can see the green star out there is our destination so it's very few routes that we use. We use mainline rail carriers and they take us on the most direct route. Next slide.

I'll skip through a lot of this but basically we have three pillars that we rely on for the safety of our shipment.

The rugged nature of the fuel, robust shipping containers we use and our shipping practices. Next.

So talk about the fuel, the fuel is solid but the main thing about it it's built for combat shock. It has the advantage that we need to make sure that that fuel will survive in a battle condition. So it's designed to stay intact and continue operationally at least 50 Gs.

As a result, our cladding fully contains all our fission products so therefore the requirements for this to be on a war ship makes our fuel particularly well suited for transport and for eventual storage. Next slide.

most of you guys know the background here. The reason we have the best shipping containers is because of the very important and robust rules that the NRC issues (inaudible).

Those are our two main shipping containers today, top one is M 140, bottom is the M-290, they're at least 10 inches thick stainless steel, that robust size results in very low radiation levels.

That box are the Department of Transportation requirements and for example take on contact our typical reading

is in the neighborhood of 1 to 2 millirem per hour, and that might be an entire reactor inside (inaudible) that's about two orders of magnitude lower (inaudible).

The third pillar for -- that we've designed for our safety is our shipping practices. I highlight on here three things.

One, we constantly monitor the location and status of where the shipment is using the same agency and satellite tracking that monitors weapon shipments. We figure if it's good enough for the weapon shipments, (inaudible) that same system.

We make advanced arrangements with police and then we escort them with our specially trained couriers. 24/7 surveillance, and also provide immediate emergency response.

What was the priority these couriers have? It's exactly that order, first render emergency first aid. Anybody hurt in an accident that occurs, then they'll summon resistance, they'll prevent further injury. And lastly they'll verify the radiological condition of the (inaudible). Because of the NRC rules and robust shipping containers, there would not be any release in any conceivable accident.

So we can take care of the injured person first and get aid there before we have to go determine the levels of the container. Next slide.

Now I want to go into the major portion of my discussion which would be to talk about our accident exercises.

First of all what are our objectives they're listed here. First of all these are objectives we have as a program. And every participating organization in an exercise (inaudible). What we want to do is we want to familiarize the stakeholders involved with our shipping practices and with the characteristics of our containers. We want to evaluate how our couriers interact with the (inaudible), want to get a good understanding of what kind of com links will be set up. Lastly, we want to make sure that we as a program can integrate into the unified command that's set up at an accident.

Where we've done these in the past, this same map of the United States shows that. Again, we do the exercises along our shipping route. We try to spread it out all over the country, and each time we have one we try to kind of fill in the gap so that we hit all the regions the best we can.

Started in 1996 doing these exercises, we do one about every two years, so we've done 11 as of today. I missed the first one, but I've been able to make the last 10.

The last one was in New York, just past June the first and I'm going to get into some photographs from that.

This gives you an idea of the kind of agencies and the number of them that are involved in one of our accident exercises. This is the cover sheet of the program we had for our demonstration exercise on June 1st, 2017.

And you can see it includes the city, the county, the cities and the state agencies, the railroad, our program, all interacting together.

We had about 14 different agencies involved in this accident exercise.

So this depicts the planning process that we go through for a typical exercise. This is what we did the last time but it's very similar, it's about a year long process. About a year ahead we check out a site, we figure out where should we simulate that the accident occurred. Where should we physically do the demonstration and exercise.

(inaudible) observers, and the tents and videos, do it in a safe environment.

So there are usually a simulated place and the actual place we run the exercise. And about 9 months ahead we bring in key players and we say okay, let's set up a schedule, let's set up a plan of how we're going to go run this thing.

(Inaudible) to four consecutive months of work leading up to the final demonstration. We'll have a scenario

planning meeting. This is what they want to do, try to integrate that and we'll come up with a scenario.

Then we'll bring all the (inaudible) together and do a tabletop. Sit around a table, go through the scenario, ask each individual what would you say, what would you do, who would you call, how would you react. Get comfortable of (inaudible).

Then we go out and do a field exercise, where we run the exercise. And that basically is from the very beginning to end exercise, we'll go grab everybody, we'll sit around and have a hunch, talk about what went right, what went wrong, (inaudible) all that and say okay let's go out and run it again. So we actually go out and run it again the same day. And we've already got the training benefit. We run it again because we're getting ready for a demonstration a month later. It's more like a show.

We did it on June 1st, and that's where we invited people (inaudible) responders who immediately responded who might be close enough by that they could come. (inaudible)

I have 20 slides. Okay. You get me off focus. Okay. We invite the state representatives, and then Department of Transportation, FRA, FBI, Homeland Security, NRC, et cetera.

What is the scenario like. I'm not going to go through the whole scenario but the bottom line is we have a shipment that's going from a shipyard to Idaho, it goes through a railroad crossing, a truck runs into the rail car, containing the container, derails the rail car. We (inaudible) communications are set up, they establish unified command.

We're now always having a resident, this is what's going to happen in real life. The resident is going to show up for sure. And the whole thing is going to be on social (inaudible) Early on, but we certainly do that every time now.

And how do you deal with that. (inaudible).

Agencies come in and do surveys. Verify that (inaudible) we pretty much declare the accident exercise over, and it continues on to Idaho.

The rest of these is photographs I'll go through this as fast as I can. Basically this was the city of Mechanicville near Albany New York, that yellow line was the train coming down through the city, the red circle is a railroad crossing, this is a close-up of it. Next slide, this is even closer. So this is standard smalltown USA. There are thousands of these railroad crossings. The most likely places (inaudible)

Unfortunately railroad crossing accidents happen every day. That's why we usually have a scenario here, and how it evolves is dependent on what the (inaudible).

We actually -- that's where we simulate it happened. We actually held it in a rail yard about three quarters of a mile away, and that's shown here on this picture. Next slide. Next slide.

So here's the day of the demonstration. We have a tent set up, excuse me, we have a stand, tents we have people in the stands, on the right-hand side is a video crew tent on the left-hand side you can't see is a media tent for the media, they're observing the exercise. Next slide.

Another picture of the tents from another direction. Next slide. So here's the beginning of the exercise, that trains bring the container in, we bring an actual container, empty. I will tell you how everything progresses would be (inaudible)

We're simulating it's loaded in the accident. So next slide. So the dump truck comes down, we're simulating it hit the rail car. Came kind of close on this one, it was about 18 inches. We like it to be realistic but sometimes you get a little nervous. But it worked out fine.

We didn't want to really have an injured driver.

The train continues, of course, because of its momentum and this is about a typical distance you can see our

container down on the right and where the truck was. Next slide.

One of our two couriers that were accompanying the shipment. Industrial security foundry, it's not a Rad Con, (inaudible). The sign on the back of the rail car says (inaudible)

Simulated collision. We want to keep people away (inaudible) our courier this gentleman on the right is reaching the first responder, that's the Mechanicville fire chief. (inaudible)

The responders are taking care of the injured, they (inaudible) put them in an ambulance, take them to the hospital. Second group of responders arrive, each (inaudible) briefs each group that arrives to make sure they understand what (inaudible).

This is one of our couriers who was taking radiation readings, they're all trained to do this. We have the readings from when we left the shipyard, and compare those readings to the (inaudible).

This is the county coming to take similar readings. Next slide.

At the very end, when we're all done, we do allow the observers to come up close to the train, we don't let you come up and hug it because railroads are really strict about not having people ride on their (inaudible). You can get up within about 8 or 10 feet. (inaudible) posing for photos as needed. Next slide.

This is one of the plots of our exercise, a communication diagram, (inaudible) idea I know it's an actual, an idea of how many different agencies (inaudible) this particular one in fine print somewhere should be the NRC.

(inaudible) we had one (inaudible) that it wasn't a concern, and why it wasn't.

Lastly let me just show you pictures, this is our new ES -- should be the container M-290. We delivered 25 of these, we're going to (inaudible)

Put it through first use two years ago, it's taken off the rail car and moved to a building facility. Next slide. This gives you a perspective of how large this container is. Getting ready to be loaded with spent fuel from the enterprise which we just (inaudible) two years, we loaded 16 containers, the first one was shipped to Idaho in August of 2016, the rest of those, excuse me, containers were shipped this past March. That particular container (inaudible).

Lastly, these are the first three 90 containers on their maiden voyage. I used to be in the submarine part of the business, and now I'm in shipping containers I still like to think I've got a fleet and we're doing (inaudible). Hard to -- I've still got to feel like I'm Navy related. And that concludes my presentation. Thank you very much.

(Applause.)

>> Patti Silva: All right, so it's time once again for questions. Does anybody have any questions for the panel in the room?

Operator, do we have any questions on the phone?

>> Yes, Donna Gilmore your phone line is open. And as a reminder, if you have questions on the phone line it's star followed by the number one.

>> Patti Silva: Thank you.

>> Yes Donna Gilmore, D-o-n-n-a, G-i-l-m-o-r-e. On the Naval shipment, you know, we hear about real accidents and things less than 1 percent of the federal rail systems are affected. Are there special inspections that are done or more inspections that are done on the routes that you take to ensure there aren't going to be any rail bridge failures or other failures?

>> Barry Miles: Is this working? We at the Naval nuclear program do not do any special inspections. We rely on

the railroads to ship us on the safest route and the most direct route. Quite frankly, it's clearly their incentive to do that. They normally move us on a special train, which means they don't move us with other commodities. We don't require that, we believe the NRC requirements put us in a very good position with an extremely robust container in any type of accident we're not going to have a radiological insult to the environment.

So we don't do any special inspections, but the railroads do move us on their best track and they move us as quickly as they can.

>> Okay, thank you. And have you ever been in any accidents at all?

>> Barry Miles: I presume you're talking to me because I'm probably one of the few people in shipping now.

>> Yes

>> Barry Miles: No, we've never had any kind of accident or incident with a loaded spent fuel shipment. We've had one accident with an empty M-140 container in September of 2005 we had a rail accident -- we had a rail yard accident where they literally turned one of our rail cars over and toppled an M-140 spent fuel shipping container.

I have some pictures of that, if somebody wanted to see it, but -- and so we reacted to that the same way we would react to a loaded shipment, in that we mustered the program, we got on scene quickly, we did radiation readings to confirm that there was no activity or problem.

There is some contamination inside these containers obviously when they're empty, but we did that, we activated our emergency control center. That was the incident in which I informed the NRC because we knew we were going to get some media, and I wanted to let them know it was an empty shipment so that they would be able to advise their management up the line.

And I had our deputy call the executive director over here to give the same message. But that was the only accident we had.

Now, you might say how do you recover from that. Quite frankly, the railroads are recovering from derailments every day. If you look at a locomotive, it's about the same weight as a spent fuel shipping container, around 100 -

- M-140 is 170 tons loaded. And the engines are somewhere maybe 100 or more tons.

So they know how to recover from that type of a situation. In this case they got a rail recovery team in, they had the container uprighted back on the tracks in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The whole process would have been exactly the same if it had been loaded, except, again, you'd have had the media attention.

>> Right. I have a question, (indiscernible), are there any like accidents specific statistics available, accident statistics available to the public, where you can see that.

>> I'm not sure that anyone on the panel knows that information.

>> Okay.

>> Well, there's -- the DOE has emergency transportation teams that are available to fly immediately to any event of a problem of one of the DOE shipments.

>> Interfuel has nuclear material database which collects all the events reports from both NRC and agreement state licensees for the last umpteen years. So any accidents involving materials would be in that database, as well.

>> Yeah, those are probably not rail, right?

>> No, they're mostly by vehicle.

>> Yeah. Different issue.

>> Operator? Is there anybody else on the phone that has a question?

>> OPERATOR: Yes, we have a few other questions.

>> Let's give someone else an opportunity.

>> Okay. Our next one is from Jan ledar, your line is open.

>> Hi. I have to apologize for this question, I was confused by Ms. Giantelli's talk because she kept talking about class -- category, she didn't say class she said category 1, 2, 3, et cetera. And I'm used to thinking of nuclear waste and categories A, B, C and D, and high level waste is I think the D category.

So I was just -- C when she was talking about category 1, 2, 3, and I don't know what she meant.

>> Adelaide Giantelli: This is Adelaide Giantelli, I apologize for that. When you're in transportation space there are type A and type B packages. And then for low level rad waste disposal there's different categories A, B and C. For security, we have categories 1, 2 and 3, it's code of conduct, it's an international agreement that when it comes to byproduct material these quantities of materials, it has nothing to do with the packaging that it's in, it has to do with the quantity and activity of material for 16 specific radioisotopes and that's what the category 1 and 2 is referring to.

For example for cobalt 60 if you're transporting more than 30 terabecquerels, that's a category 1 quantity regardless of what kind of package it's in. If it's above that amount, you have to implement the security requirements.

>> Did you say 30 becquerels?

>> Yeah, terabecquerels.

>> 30 terabecquerels, is that what you said?

>> Yes, terabecquerels.

>> Oh goodness, that's a lot.

>> Yes. For category 2 it's 3 tenths of a terabecquerel. You have to implement a lower set of -- a less stringent set of security requirements during transport.

So it's based on activity, it really is not the same as the type A type B packaging limits, whether it's in special form or not special form, it's all about the activity in the shipment itself. Whether or not you put the security on it.

>> Okay, and so this is the 1, 2, 3, is the amount of activity in the shipment.

>> Yes, it's based on activity. So it's independent of all those other -- the type A type B, and the low level rad waste disposal quantities.

>> Okay, so the low level rad waste given a number or do you give it a letter?

>> Adelaide Giantelli: As long as a shipment is one of these 16 isotopes and it's above a certain quantity, it gets 1 or 2. And it could be rad waste disposal facility it could be going to another licensee, it just depends.

For security purposes.

>> It does, yes. Okay, thank you.

>> Thank you.

>> OPERATOR: Next question is Gary Hedrick, your line is open.

>> Yeah, hi, Gary Hedrick of (indiscernible), I will start out by apologizing I rambled on a bit. But just a brief question about (indiscernible) transportation it seems so -- obvious that you're transporting nuclear waste, and there's an attempt to make the shipment less conspicuous, it seems like also if you had a cover of some kind protecting it, it would also offer another layer of protection.

I'm just curious if that's considered or in practice or what.

>> Adelaide Giantelli again, for (inaudible) discuss the Navy shipments. The safety security interface was considered for shipments of larger quantities of materials, and there was some thought about removing placards or changing the papers, this is way back when, but it was decided for safety reasons, the safety outweighed the security requirements. That the first responder needs to know what's in that shipment, so they can respond accordingly.

So that -- and the member of the public, so it's basically more important for safety -- safety was overriding security in that situation. So it was considered at one point, but it was decided that trying to make the shipment more invisible (inaudible)

>> And do they do that with weapon grade? I've heard that they use -- weapon grade I thought they use smaller quantities, ship discretely when they have weapon materials and things that military uses. Is that true?

>> I don't think anybody here is knowledgeable about the weapons shipments. Other than the weapons -- other than the security communication system which is used to track them, I am familiar with that, but I'm not familiarity with the shipments themselves.

>> Okay, I'll leave it at that. Thank you.

>> Adelaide Giantelli: My statements are all about commercial shipments of materials.

>> Yeah. All right, thanks.

>> Patti Silva: Is there anybody else on the phone that has a question?

>> OPERATOR: Yes, we still have a couple questions from earlier people that asked questions.

>> Patti Silva: Okay.

>> Marvin Lewis your line is open.

>> Yes, am I through?

>> Yes.

>> Wonderful. Look, I'm sorry I'm not going to ask a question, but this young woman's presentation, I'm asking a question about a previous presentation, and of course I missed a name, that's normal.

But the presentation was about inspections. And I hope you don't mind me using the words prejudicial and bias, but I have -- I've been around several industries, and I noticed there is a prejudice and there is a bias. But isn't sexual prejudice, it isn't a color prejudice, it isn't race or whatever you want to call it. It's a bias that you don't mess

with somebody who can give an adequate defense. In other words, mess with small business rather than a big company or corporation. You mess with people who have not had much experience in court, rather than somebody who is always in court.

And that sort of thing. And I just was wondering, I'm sure that you follow the regulations and history on prejudice and biases due to color, race, religion, and whatever. But I was wondering, do you have any way of making sure that the inspectors and the auditors are not being biased by, hey, we can really mess with this guy because he can't set up an adequate defense.

Now, if you feel that would be better as a comment than a question, I'd be very glad to go with it.

Over and out.

>> Patti Silva: All right. Okay, I think with that, we're right up against break time. So 15 minute break, back in 15 minutes for the last session. Thank you so much.

(Applause.)

(Break.)

>> We're going to start here any second now.

Okay, if you please come in and take your seats.

Okay, everybody, Travis, this is the one we were waiting for.

>> Travis Tate: All right, if we could take our seats we'll get started with the last session.

All right, good afternoon, welcome to the -- not welcome, I guess, congratulations for making it to this point.

This is the last session of the 2017 Reg Con, my name is Travis Tate, I'm the branch chief of the criticality shield and the risk assessment branch in the Division of Spent Fuel Management. Just a little background on myself, I joined the agency in 2001 in the Office of Nuclear Reactor regulation and worked in various positions there and supervisory positions in NRR, and I joined NMSS just about a year ago so this is my second Reg Con, and I've been around long enough now I'm starting to recognize faces and names. It's good to see everyone.

Just a quick reminder. There are feedback forms we would, you know, just ask that you would fill these out before you leave today to give us feedback on how we can improve the conference.

Today we've got a panel of I think John termed it as mixed bag of cats and dogs. But we thought it would be a good opportunity to just give you an update on the status of a lot of our initiatives that we've been working hard on over the past year. So which have Ricardo Torres, Donald Chung, Patti Silva, Jeremy Smith and John McKirgan will give presentations today.

I guess with that, I will get us started. The first speaker will be Ricardo Torres, he is a materials engineer in the renewals and materials branch of the Division of Spent Fuel Management. Ricardo is a reviewer for Part 71 and 72 licensing actions, and has supported multiple efforts on aging management of concrete structures, fuels, and neutron absorbing materials in dry storage systems.

Ricardo holds a Ph.D. in material compliance from the University of Florida. I did not realize that, Ricardo, I'm a University of Tennessee graduate. So. We'll deal with that later.

And a bachelor's and masters in polymer science from case western reserve university. And prior to the NRC he worked as a senior engineer at Savannah River National Laboratory. Welcome, Ricardo.

(Applause.)

>> Ricardo Torres: Good afternoon again. This presentation will not be on spent fuel, it's going to be on a new initiative related to Boral, a neutron absorbent material used in dry storage systems. Next slide, please.

What's Boral? Boral is a neutron absorber material is cermel laminate plate. It's made by mixing aluminum, boron and carbon powders which is centered and hot rolled between aluminum cladding. Generally the boron carbide content B10 being the neutron material, varies between 35 and 65 weight percent, and that correlates to a core porosity as well. Just because of the nature of the propagation process the material is not 100 percent dense.

With respect to the credit of Boral for neutron absorption, that is only credited during cask loading operations for subcriticality control. During normal conditions of storage there is no moderator inside the canister or cask, so the Boral is not credited for subcriticality control. Next slide, please.

Now, the pertinent criticality we get regulations in dry storage are 10 CFR 72.124A, which affect both general and specific license systems for spent fuel handling, packaging, transfer and storage, need to be designed to be maintained subcritical. And it also has a double contingency requirement for potential accidents for making sure that the fuel remains subcritical.

Now, for the cask designs 10 CFR 72.236C states that the cask needs to be designed and fabricated to be maintained in a subcritical condition under all credible conditions.

Next slide, please.

So why are we bringing up Boral? This may be somewhat of a deja vu for some of you of you guys have been in spent fuel storage for awhile.

Back in 2004 the issue of Boral performance in dry storage was first raised, as a generic safety issue by the NRC.

That generic safety issue stemmed from the operating experience in spent fuel racks in wet storage, back in the 80s blistering of Boral was first observed, and the concern was during potential cask reflooding there could be blistering of the Boral in dry storage systems.

So as I said, in 2004 the issue was first accepted for review internally. To close that issue, Oak Ridge national laboratory conducted a literature review and a criticality assessment based on the test results that the NRC got to review at that time.

The test results that were reviewed were whole text proprietary results as well as EPRI's results on Boral testing, they had their own test program.

However, the conclusions of the Oak Ridge -- well, the conclusions of the Oak Ridge report stated that even blistered Boral would remain effective during dry storage operations. However, it noted the lack of testing that had been conducted on older Boral.

So I guess to provide some perspective on this, initially Boral was the trademark by Brooks and Perkins back in the 80s, the company got purchased by AAR cargo systems back in the 80s, and eventually by ceradyne in 2006.

As a result of the operating experience during wet storage in the 80s, 90s, and as a result of the blistering experience observed in a Spanish cask in 2000, 2001, ARR cargo systems implemented a manufacturing improvement program in which they changed certain parameters, they increased -- they improved material purity that was used in the powders that are used to manufacture the material, they incorporated dry passivation to help inhibit the blistering material, they recommended higher boron carbide contents, and they also changed the lubricant used during the hot rolling process which was determined to potentially increase the susceptibility to pitting, which is the mechanism by which water enters the core of the Boral.

So Oak Ridge noted that the test data that had been used to close out GSI-196 had been obtained with newer

material, material that had been fabricated after ARR cargo systems instituted this manufacturing improvement program.

The GSI was closed in 2006, and the issue with older Boral material was addressed by stating that the IAEA at that time had a program, the spent fuel assessment research program, in which at that time it was expected for the member states to address the issue of Boral blistering. However, that did not occur. Next slide, please.

So fast forward, 10 years later our organizational culture encourages supports and respects different views, and the NRC has a program in place in which any staff member can raise an issue up to the office of enforcement in which, if they do not agree with a given policy decision taken by management.

So fast forward 10 years after the closure of GSI-196, in 2016 a former NRC staff member presented a differing professional opinion for formal review and evaluation, and it dealt with the concerns related to older Boral, as I had discussed in a previous slide.

A month later, in July of last year, the NRC office of enforcement established a review panel to review the DPO concerns, and in September of last year the panel issued a memorandum with conclusions and recommendations to the director of the office of nuclear material safety and safeguards. Next slide, please.

So the concerns presented by the DPO were the stakeholders of dry storage systems and transportation packages had not been adequately informed by the NRC of safety and operational problems that may result from potential Boral degradation. This could include erosion of subcriticality margins, hydrogen generation, and higher occupational doses if the Boral blistering leads to bound fuel assemblies at the time of retrieval.

I guess I should provide some background, and I should have said this earlier on. Blistering of Boral occurs, there are two ways it can occur. It occurs via oxidation of aluminum in the core, the aluminum powders oxidize and that leads to hydrogen generation. Clearly if aluminum reacts with the water it -- and oxidizes it produces hydrogen exp. that hydrogen can result in blistering bulging of the cladding of the Boral.

Another mechanism is also known as flash steaming, if the material -- if the water enters the material, the cladding, actually the sheathing that covers the Boral, it can also result in flashing depending on the heat uprate, and that can also lead to blistering and bulging. So just that provides some background on the hydrogen generation that's listed here.

So GSI is the other concern, the GSI-186 closure did not account for older Boral, as I just mentioned earlier. And for purposes of the DPO, the older Boral refers to material fabricated prior to circa 2001.

And it also stated that because that test data wasn't reviewed, that it should be obtained. Next slide, please.

So the panel reviewed the concerns, and they performed a new literature review, and evaluated test data available at that moment, at the time of last year, mid-last year, and concluded that subcriticality margins, the data so far does not indicate that those margins are eroded significant to constitute a significant safety concern.

However, there is uncertainty with respect to older Boral. There are -- the concerns with respect to retrievability of bound fuel assemblies and potential increased radiation exposure, occupational dose exposures, due to those bound assemblies are currently well addressed by our staff review guidance. And the concern about hydrogen generation and potential combustion is also well addressed by our standard review plans and information notices that have been issued on this subject, particularly as it pertains to closure, welding closure operations. Next slide, please.

So the recommendation by the DPO panel were to communicate to stakeholders that degradation of Boral has been observed under simulated dry storage loading operations. And that repeated cycles could lead a licensee to be outside the design basis for subcriticality margin.

It also recommended exploring an investigation of older Boral material, as was recommended in the closure of GSI-196. And it recommended using material obtained under an NRC EPRI cooperative research program

currently in place, actually I think it just recently ended, in which Boral material had been obtained from the Zion spent fuel pool, and testing done on material on the representative dry storage operations. Next slide, please.

So in February of this year the office director issued a tasking memo in which it instructed the staff to conduct an operating experience assessment of dry storage systems and transportation packages that had incorporated older Boral and that had been subjected to reflooding operations.

The objective of that assessment was to determine if degradation of Boral has been observed during loading operations. Compare the assessment of those findings to on or about ridge final letter report that was used for closure of GSI-196. I'd also make a recommendation as to whether or not we should conduct testing with older Boral. Next slide, please.

The staff was also instructed to determine if we could obtain samples of the Boral obtained from the Zion spent fuel pool and whether or not we could conduct testing under dry storage conditions and the cost associated with that. In addition, as a final step was to issue a position paper in which we document the assessment findings and the test feasibility, and we provide a recommendation for a path forward to the NMSS director. Next slide, please.

So over the course of starting I guess in March, ending in June, we conducted inspections of the three major vendors, NAC international, TN Americas and Holtec International. We sought operating experience on degradation of Boral. We also reviewed vendor specific proprietary test programs on older Boral, and we obtained data on the inventory of dry storage system designs.

We also, under the existing MOU between the NRC and EPRI, we obtained a copy of a report of EPRI's test program on older Boral, and we reviewed that and we documented that internally.

Next slide, please. So the findings of the operating experience assessment are that no spent fuel transportation packages incorporating older Boral have been shipped into the United States. There's no operating experience recorded by the vendors on degradation or reflooding operations of dry storage systems incorporating older Boral.

Next slide, please.

The vendors are well aware of the operating experience by Spain on the blistering of the dual purpose cask, and two of these vendors have conducted proprietary test programs to demonstrate that degradation of Boral is not credible in their specific dry storage systems designs. And approximately 9 percent of the dry storage systems design loaded today, 241 systems, incorporate older Boral. Next slide, please.

In interest of time just to show the systems -- the designs that have been loaded under the ISPSI location, the designs that incorporate older Boral. Next slide, please.

So where we stand is that we've completed two reports, draft reports which are currently under management review, internal review. One incorporates the inspection findings of these three special inspections, and the position paper as requested by the office director.

In addition, we, as part of that position paper, we're planning on proposing an independent test program per the design basis loading conditions of those systems in the previous slide. The MPC, UMS systems for NAC, the TM designs, TM 40, the OM 7 P, and the MPC 68 for Holtec.

We are exploring obtaining material not from the Zion spent fuel pool, we realize that's not the one that is most representative of the one that would have been used for cask loading since it's been sitting in a pool for awhile.

We plan on engaging with industry as we put together a test matrix and we figure out the specifics of the test program once we have a contract.

With that, I thank you for your attention.

(Applause.)

>> Travis Tate: Thank you, Ricardo. Our next speaker is Donald Chung. Donald is a reliability and risk analyst at

the U.S. Nuclear Regulatory Commission, he has over 30 years of experience working in the nuclear industry.

He supported the NRC Office of Nuclear Reactor Regulation in risk-informed regulatory decision-making for over 10 years, and currently he is leading the effort to improve the efficiency of regulatory activities for spent fuel dry storage.

Prior to joining the NRC he held the position of senior engineer for design tech and Johnson controls. He has a bachelor of science in material science and a doctorate in nuclear engineer from the University of Maryland.

Welcome to Donald.

>> Donald Chung: It does work, okay. Thank you for your perseverance and hanging to the last session.

Yesterday morning the office director, Mark DuPont, provided (inaudible) one of the things that he said was that (inaudible) compliance and tech specs are overly proscriptive. And this morning, another Mark, Mark Richter from NEI said efficiency doesn't mean less safety, efficiency means resource could be better allocated to area of greater risk.

I'm very glad to hear these two statements because they kind of join together, and they dovetail into my presentation on improving efficiency based on risk-informed graded approach.

(inaudible) always start with this slide. This slide shows the results from 2 PRA and risk assessments that were performed. One was performed by the NRC, the other one was by EPRI.

NRC one looked at a cask storage system at a PWR site and EPRI -- I'm sorry, canister system at a PWR site, and EPRI system looked at cask system. They looked at two time periods, the first year and subsequent year storage on an espici.

(inaudible) involved loading of the dry storage system and moving the package. (inaudible)

These two studies came out with similar results, they show that first there are no credible actions for prompt (inaudible), for latent cancer risk, are in the level of 10 to the minus 12 to 10 to the minus 14 per year.

(inaudible) goal is 2 times to the minus 6. These numbers are 6 order of magnitude or more below the commission safety goal.

So in other words, dry storage is very safe, very low risk.

In terms of looking at the regulation for dry storage, three parts of the regulation. First, there is the certificate of compliance. (inaudible) to the certificate of compliance there's technical certification, then there's FSAR, final safety analysis report.

These three pieces make up the regulations for spent fuel dry storage. Now, what's the difference. The difference is that information that's in the certificate of compliance and in a tech spec cannot be changed unless a license amendment request is submitted.

In the FSAR they are open to the 7248 process. (inaudible) mention improving by risk-informed graded approach, what does that mean. This is a little bit different from Part 50 risk-informed. The reason is because in Part 50, the PRA for every plant.

We have the SPAR models and the licensee have their models, and there's a reason for that, because for reactors the risk is significantly higher than for dry storage.

Dry storage, the risk is so low it can't justify doing that level of PRA study. So our evaluation we look at the generic data from the two existing PRAs. And when we say graded approach, what we do is we have extra knowledge from technical reviewers, and we also have generic data from these two PRAs.

The technical reviewers note the history, requirements and the COC and tech specs, some of these COCs and tech specs have been around for awhile, they've gone through numerous amendments and things were added for various reasons. The PRA identified the dominant contributors to risk associated with dry storage.

(inaudible) improving efficiency (inaudible) to build a little more consistency between the level of risk and level of regulation. By providing more opportunities for less important changes to be evaluated by the 7248 process, we improve efficiency. (inaudible) information is not critical to safety, we can look at it and say hey, do they really need to be in the COC and tech specs.

This is a -- it's not an eye chart, it's basically a flowchart of the two processes. The vertical -- if you're looking at it this way, it's the vertical process is basically the license amendment process.

What I need to tell but license amendment process is if a change needs to go through the license amendment process, once the licensee provides us the license amendment request, the limited resources and staff available, it typically takes 18 months for us to go through the evaluation process.

Whereas if something is evaluated by the 7248 process, (inaudible) safety significance, that change process could go forward very quickly. Almost immediately the changes can be addressed, and can be handled.

How do we go about evaluating the information that's in the COC and tech spec, what really needs to be in the COC (inaudible) what can be moved to FSAR.

There's currently a pilot right now over the last I guess year and a half almost two years we've been working with NEI and the industry in developing three sets of criteria.

These criteria basically captures what's in the regulation, the code federal regulations Part 72, and there are three group of criteria, the first one basically addresses approved content. If something is approved content it has to be in the COC and tech spec. Limiting conditions, and then the third category is no significant hazard consideration.

If a requirement that's currently in the COC and tech specs doesn't fall under approved content, doesn't fall under limiting conditions, and doesn't introduce any significant hazard, then it's eligible to be considered as something that could possibly be moved to the FSAR.

That's basically the process. So our graded approach, look at these three categories of requirements that kind of captures the (inaudible) process I guess last year.

What we've done this year is captured in this slide here, early this year March we basically finalized -- we kind of flesh out the available criteria for dry cask storage, and then in June of this year, end of June, TN Americas (inaudible) pilot amendment and we basically decided this is -- basically had evaluation form for every single requirement that's a COC and tech spec. This is 99 requirements. We basically broke it down to two parts, we completed the first part and we provided our RAI, for the first part, to TN America, am August, where they can be working on part of it while we work on the second part.

Again, our goal is to be efficient.

(inaudible) the second part in September to TN Americas. (inaudible) this is our chart, our goal of when we will complete it.

(inaudible) right now our goal is to have our safety evaluation written sometime next year. We're currently looking at I guess it's end of March, April time frame. Hopefully this process would help lay out a method for improving efficiency.

Once this is completed, (inaudible) on how it all works out, we may do additional pilots, assuming no additional pilot is required, our goal is to go forward, update the current guidance documents, NUREG 1745. For COC and tech specs. That's our (inaudible).

Again is complete review of the industry pilot amendment application, modifying the COC and tech spec and then of course updating the NUREG 1745. That's our path forward. And next slide.

That's our current plan, and that's tend of my presentation. I guess we'll address questions at the end of the presentation.

(Applause.)

>> Travis Tate: Thank you, Donald. Our next speaker is Patti Silva, Patti is the chief of inspections and operations branch in the Division of Spent Fuel Management at the NRC. She has been with the NRC for 15 years, and has over 30 years of federal government experience. She holds a bachelor of science in chemical engineering from New Mexico state university. Welcome Patti.

>> Patti Silva: I'm here to discuss an update on where we are on the NEI 1204 review. So for those of you who don't know what that is, that has to do with implementation of the 72.48 requirements in the regulation which is our change process. Next slide. There you go.

Our current guidance is the (inaudible) guide and it's the NEI 9607 appendix C has the (inaudible) so NEI proposed a 1204 revision zero to this guide, and it's got several clarifications and additions, it has appendices with various examples and such, with they are not currently requesting endorsement of, and they're, like I said, they're requesting endorsement of the NEI 1204 in a regulatory (inaudible).

-- here, we viewed the rev 0 over like three years in three different letters responding to NEI, and NEI let us know early on that after our first letter that if we're going to have multiple ones they weren't going to address our comments until we got to all three letters, all the interim letters completed, which we finished in April of 2015.

So in March of 2016, we had a public meeting with NEI on our comments in which NEI identified 11 key and fundamental issues, I think there were four issues and 7 fundamental issues. (inaudible)

So we had that meeting on those key issues, and then we (inaudible) summary reply based on those issues in August of 2016.

They responded to those issues revisions which we aligned on 10 of the 11 issues, of those 11 issues.

The one outstanding issue which I'll talk about in a little bit is the method of -- use of method of evaluation in the change process. So we had subsequent meetings, we had a public meeting in May -- May 11, and then we had another meeting in -- in July of this year; as well.

So after those meetings and our discussions, NEI submitted what they called Rev 1 draft A in early September, which is what we're reviewing right now.

As I said, the outstanding issue is method of evaluation language in the 1204, and so we've been looking at this since we've got this updated version, and the NRC -- and we feel that the NRC and industry are aligned in principle on the use MOEs -- we want to make sure -- we're developing a technical basis to make sure this change in practice of use of MOEs is within the regulations. So we're checking on that. And we're identifying if there's any additional communications we need to make if we change this practice of how we've used MOEs.

(inaudible) -- NEI a response on rev 1 draft A. We hope sometime in November, this month. And then the NRC and NEI will have a public meeting to discuss our comments.

And then NEI will resubmit with the actual Rev 1, I'm assuming Rev 1 draft A and NRC will review and draft the Regulatory Guide for concurrence on that (inaudible)

-- for us to review -- I can't give you a date because I don't know when NEI would submit but then it would take us another about three months to draft the Reg Guide then it goes into the Reg Guide process.

(inaudible) other references here in case you want to look up the documents and the string of things that have gone on in the NEI 12-04. That's all I have.

(Applause.)

>> Travis Tate: Thank you, Patti. Our next speaker is Jeremy Smith. Jeremy is currently a senior nuclear engineer in the criticality shield and risk assessments branch in the division of Spent Fuel Management. Prior to joining Spent Fuel Management in 2002 he worked on NMSS field cycle safety and safeguards division, in both the fuel cycle licensing branch and special projects branch, as a project manager and criticality safety reviewer.

Prior to joining the NRC in 1998, Mr. Smith worked for several years in the nuclear industry as a senior nuclear engineer for Lockheed Martin at the Portsmouth gas diffusion plant, as a systems engineer for Commonwealth Edison at the LaSalle county nuclear station, as an engineer at the DC Cook nuclear power plant.

Mr. Smith received a BS in nuclear engineering from the University of Michigan and an MS in environmental management from the University of fimlay. Welcome, Jeremy.

>> Jeremy Smith: Today I'm going to be talking about our effort here to consolidate and update the standard review plans for spent fuel storage as well as transportation.

For introduction I'm going to go over why we're consolidating these SRPs, what we expect as a result of this consolidation, as well as a schedule for issuing the updated SRPs.

Why do we want to consolidate the SRP? Our management recognized there's a definite need to do that.

Storage SRPs NUREG 1536 and 1567 are about 18 years old now. (inaudible)

Almost 20 years there's been a couple supplements but both of those supplements are about (inaudible) during that time Part 71 and 72 have both undergone some revisions. As well it's kind of plugged the gaps that exist (inaudible)

Interim staff guidance documents ISGs to assist in implementing these changes. (inaudible)

Hope to increase the efficiency when performing our reviews. Eliminate use of ISGs in the future. And we also want to make future revisions to the SRPs easier.

Our ultimate goal is to basically be a one stop shop for all our SRP information. We think that's kind of a win-win, one our reviewers will have all the information they need to do a review in one specific location.

As well as the applicants will know exactly what the NRC is looking for without having to go to all these various documents.

By doing this, we are getting some very large documents. They're on the order of 600 plus pages each. By incorporating the approved guidance into one location it should be more convenient to find the applicable information.

A little background. You know, we had a visibility study -- feasibility study done that indicated that consolidation of the SRPs would be the desired path forward. Part of the study we recommended the use of the NUREG 0800 model which is used at NRR and a couple of advantages of that are the chapters are subdivided into independently revisable sections. By doing so, we would be able to hopefully eliminate the need for future ISGs.

We also recommended a revised chapter order to account for the merged information.

Storage SRPs as well as transportation SRPs are very similar documents but not identical documents. So (inaudible) approach for the storage SRP, we formed an internal team at the NRC that represented all of our technical disciplines.

-- contractor was helping to us draft this SRP counterpart group of also technical experts, and worked directly with them formulating the updated language as well as making sure the merged information from the ISGs was incorporated correctly.

-- started with the draft update to NUREG 15.67 which is the SRP for spent and dry storage facilities, we merged into that NUREG 1536, which is the SRP (inaudible)

Pertinent guidance into that document, and all told there's about 21 ISGs that are now folded into this one (inaudible) so we feel we've closed the gaps that the ISGs (inaudible).

We interacted directly with them we used some lessons learned from our experience with the storage SRP Significant comments back from (inaudible) learned better (inaudible) point was NUREG 1609 which was the SRP for transportation packages of radioactive (inaudible) NUREG 1617 which is the SRP for (inaudible) merged the information into two supplements.

(inaudible) merged about 10 ISGs into this transportation SRP.

Our schedule for the storage SRP. Well, the draft NUREG that is currently going through our internal publication process, NUREG 2215 is the standard review plan for spent fuel dry storage systems and facilities. (inaudible).

The public comment period should be out any day now hopefully very soon. Once it goes out there will be a 45 day comment period. Get the comments back and start to resolve them. Our ACRS which is our advisory committee on reactor safeguards may want to look at it, and they kind of are a check on any documentation that we write. (inaudible) what the public has to say. They may look at it they may not because it's really no new information it's just a consolidation of existing information.

Through all of that, the final publication of NUREG 2215 is expected in the third calendar quarter of 2018.

-- for the transportation SRP which is NUREG 2216, the standard review plan for transportation package approval, are in the final process of the NRC review team finishing up its internal review.

-- transportation SRP out for public comment in the second calendar quarter of (inaudible)

-- first calendar quarter of (inaudible).

Firstly, we want to get these bad boys out. Let's look at them, finally get them issued.

Once we have officially issued these SRPs we will begin working on the regulatory guides, to harmonize them with these SRPs.

-- all issued about 1989 so they are very dated. With this new information hopefully we can bring everything into good alignment. Those are Reg Guide 3.48, 3.61 and 3. (inaudible)

That was issued in 2005, so not as out of date but still it's been awhile since it's been updated.

The last thing we have are any future updates to the SRP will be done as needed, and this is intended to hopefully replace the ISG process.

(inaudible)

-- update that is needed this consolidation is going to enhance the safety, the efficiency of reviews, and revisions of the SRP in the future, and beware that the SRPs will be coming out very soon for public comment.

(Applause.)

>> Travis Tate: Thank you, Jeremy. And our final speaker today is John McKirgan, chief of the spent fuel licensing branch in the Division of Spent Fuel Management. He has over 25 years of government experience.

Since joining the NRC John has held a number of leadership positions in the agency.

Prior to coming to DSFM he worked in the Office of New Reactors where he served as chief of the AP1000 licensing branch, chief of the reactor systems branch, and chief of the containment systems and ventilation branch.

He entered the agency in the office of nuclear security and incident response in the Division of Security Policy.

Prior to joining the NRC he worked for the naval service warfare center in -- rock, Maryland, where he performed tests and analysis of Naval weapons systems. He holds a bachelor and masters degree in mechanical engineering from the University of Maryland at College Park. And John we're running on schedule, so no pressure.

>> John McKirgan: Thank you. Thank you Travis. Thanks, everybody, for sticking around, the last talk of the last session, and it's on fees. So it's the end of the day, somebody has got to pay the bill.

You know, when I actually volunteered to do this talk, and some people looked at me combined of funny because fees aren't an area that a lot of the tech am organizations get into. When I reflect back on my own entry into the agency, I knew we were a fee recoverable agency but I didn't really understand a lot of what that meant, and how fees were calculated, and how they were meted out to the various fee classes. And I have come to discover it's a very interesting and important area of the agency. And enables the agency to function.

So I actually volunteered to do this presentation, and lots of senior leadership in the agency has also got a high focus on fees, fee transparency, openness, have major focus for the agency, and there have been a number of initiatives going on along those lines, and I just wanted to take a little bit of time today to talk about some of the initiatives that really impact spent fuel (inaudible)

The commission has looked at this, they've had meetings with stakeholders, OCFO has put out Federal Register notices for public comments on fees, fee transparency. I wanted to start with some of the stakeholder feedback that we got. This is right out of the one of the SECYs, SECY I think it was 160097, and I really bolded just a couple of the ones I wanted to speak to today but I just wanted to present them all for everybody's awareness.

You can see there's a fairly broad spectrum of (inaudible) that we got from stakeholders, cuts across the agency, but the (inaudible) acting on within NMSS and certainly within DSFN so I wanted to talk about those for a little bit.

Certainly you'll see that the NRC does not provide cost estimates on technical reports and licensing actions. The DSFM actually had been trying to provide estimates in our acceptance letters but we did take that (inaudible).

Agency-wide initiative, but I did want to give you a snapshot of what's coming in that area, as well. So if I could go to (inaudible)

There are a number of initiatives, but in this talk for the interest of time, Travis, I just wanted to talk about three. I wanted to talk about fee estimates, I wanted (inaudible) EPIDS which I'll describe in a minute, EPIDS and CACS, we're an acronym heavy agency, and you'll be on the edge of your seats on what EPIDS are and what they stand for (inaudible) being an area that we got some feedback on people didn't know what common licensing actions cost, and there wasn't a readily available resource for people for planning pups. Among things the agency has done since this is an agency wide initiative was to take some of the more common licensing actions that the agency undertakes, including licensing and oversight activities, (inaudible) estimates out publicly available for vendors, stakeholders, to use for awareness, and to aid in your planning, your budgeting activities. Which we know are important.

Often as I've interacted with external stakeholders, I've discovered that a lot of our external stakeholders (inaudible) what our reviews cost. And so I (inaudible) information to get to people (inaudible)

Maybe we'll just jump to the next slide. This is on the web page, so you can go home and look at this. But what we tried to capture here for Part 71 and Part 72 is to capture some of the common licensing actions that we do.

Renews, amendments, new certificates, we've tried to break those down. We tried to bin them a little bit into high complexity or low complexity.

This data was really developed through a sampling of recently completed actions, so it is not 100 percent of all the cases that we've ever done, that even this initiative kind of right sized for (inaudible) research enterprise (inaudible) really accurate (inaudible) ballpark here, so these are samplings and estimates that were recently completed cases, and (inaudible) our format and staff hours, because as many of you are aware, the labor rate changes from year to year, and that is another kind of exercise in how that calculation is done.

-- provide some estimate on hours, and then if there are contractor costs that are often associated with some of these actions we're trying to capture (inaudible) get some public information out, so that people can know what we're charging, these are as a sampling, and we do plan to update this on a biennial basis because as (inaudible) lot of areas, we would expect to see these estimates come down, that would be our goal, since we want to be more efficient. And I spoke earlier on that.

And this is on the website, so you can look at this at any time. And find your individual action here, so these are averages, your individual case may cost more, it might cost less, but this is (inaudible)

EPIDS are enterprise wide project identifiers, it's a new nomenclature, it's a new taxonomy CFO is introducing into our vocabulary. CFO is looking at a couple things they were trying to address here agency wide. There were some billing errors we wanted to eliminate, so this is trying to get well on some billing errors that had occurred across the agency.

They were looking for the capability to enhance their reporting. We often get very short turn around questions from Congress from oversight or from other external stakeholders asking what various elements of our program cost, and the goal here was to have a (inaudible) that would enable us to rapidly respond to authorize queries.

A brief vocabulary lesson. (inaudible) codes or CACs, we use CACs to (inaudible) all of our work. That's (inaudible) and many of you have probably seen that on the correspondence we send, generally when we send acceptance letters or RAIs we'll say please refer to the docket and CAC number so you (inaudible).

-- errors, and then we're going to go to an EPID which will be a project unique identifier. (inaudible)

This is the taxonomy for the EPID, it consists (inaudible) letter there whether it's licensing or inspection or rulemaking or research, thrtion a four digit calendar year -- there is a four digit calendar year so that's something to (inaudible) used to operating in fiscal years you may have your own fiscal years that you're operating under but that will be a calendar year digit. There is an alphanumeric whether will describe whether it's a new application, amendment or renewal, and that again is going to help us in some of our reporting as people ask how much are you spending on renewals or certain amendments. This taxonomy will help us (inaudible).

That last four digit number that's going to be a unique number assigned to each case. CACs were (inaudible) that last four digit sequence in the EPID is going to be unique to each application that comes in.

That's CACs and EPIDS (inaudible) invoice enhancement.

Invoicing is another area we got a lot of feedback from our external stakeholders, the clarity, content and level of detail in invoices was something that the stakeholders were asking for some more information on. Let's (inaudible).

We're still in the process of working through invoices (inaudible) initial information that you might find useful. Of course you'll find your CAC, your EPID, your docket, all that information will still be there. The hours, the billing rate, contractor charges will also be listed there. But the other new piece of information is individual staff reviewer names will start to show up on invoices, and some of you might find that of interest. So this is really intended to get that extra level of openness and transparency, and detail that the stakeholders were asking for in terms of

(inaudible).

Billing cycle. If you do have feedback, please let me know or let your (inaudible)

Last slide on the last talk of the last day of the conference, I wanted to bring it back to safety. Safety is why we're here. We are a safety agency. I wanted to bring it back to our mission. And you know, fee billing is an essential component of the agency's (inaudible) billing or fee recoverable agency, we need it to be accurate. (inaudible) that confidence.

All across the spectrum (inaudible) public, so we (inaudible)

Another message I wanted to get out, the agency is taking what we believe to be very meaningful steps to improve the accuracy (inaudible).

Continue to be our focus, and (inaudible) agency to continue to (inaudible).

(Applause.)

>> Travis Tate: All right. Is my microphone working? There it is. Okay, let's go to questions here in the room first of all, and please be aware that we have about an hour on the schedule for the questions, I believe. 30 minutes on the schedule for the questions.

The sooner we get done with these the sooner you can get to your airplane. So please --

>> Thank you. Question for Jeremy.

>> Yes.

>> Existing SRPs for storage, 1536, 1567, they have chapters on tech specs 12 and 16 respectively.

How is that going to be rolled into your combined SRP, and with NUREG 1745 hanging out there separately. And I have a recommendation if it's not too late.

>> That's a good point. So the (inaudible) SRP is (inaudible)

>> (inaudible) from Walter information, I also have a question for Jeremy on SRPs. Just let me repeat what I understand. The current process is basically the consolidation of the existing documents into two new documents without any changes to them.

>> That's what we're striving for.

>> Okay, but then the in the comment period, it gives actually the opportunity to (inaudible) documents.

All the comments are involved. So that is the opportunity for the industry or for us to comment on this, go through this, and if we then all agree that something should be changed, that is the time where that will happen.

>> (inaudible) there will be some kind of resolution based off of those comments.

>> Yes, understood. And then the other -- for a brief comment, I mean it's probably just (inaudible) I understand there will ab completely new structure to the documents?

>> (inaudible)

>> We look forward to your comments on those changes as well.

>> Okay because I remember the 1536 Rev 1 had kind of -- there was new chapter that was basically inserted

and all kind of chapter number after that changed, and we thought it kind of -- we had quite some confusion. So for example we didn't follow that in our FSARs because I don't remember which FSAR has the (inaudible).

If we can minimize the changes there that's probably avoids some confusion.

>> We did try to minimize the changes.

>> We'll comment on that when we see it.

>> Oh, sure. Just for your general information there's no requirement to follow the chapter layout that we have outlined in the SRP.

>> Understood, yes.

>> If do you different from it I would suggest maybe having a roadmap of features on hey we're addressing this, this and this chapter, just (inaudible).

>> Thank you. Okay.

>> Excuse me, sorry for the interruption, this is the operator. There's some fading in and out when the speakers are speaking, so the phone line -- people on the phone line are -- you know, hearing -- it's fading in and out. And I just wanted to let you know that.

>> I've been told that there might be a buffering issue, I'm not sure. This time of day the internet here at the NRC is quite busy, and I thought that that had been identified as the problem yesterday when the same issue was brought up.

(inaudible) indication of something different from the audio box up above us.

(Inaudible) gave me a thumbs up. I'm on track. Okay. Please bear with us as best we can. This is modern technology with a real heavy set of air quotes on either side of "modern". So we'll try to do our best.

>> My name is Don Shaw, still spelled D-o-n S-h-a-w, I'm from Pan American licensing. My question is for John, our invoices currently have all the individual contributing dates rolled up into one number for each certificate. So then we have to split those out into the licensing actions. Which we can do, but it would be much more convenient if each licensing action had (inaudible).

>> I do not know offhand. It had been my understanding that with the breakdown by EPIDS that you would see that, but I can't -- now that you ask that question, it's something I'll go back and consult with my CFO colleagues and see if we can get you an answer for that.

>> Thank you, John.

>> Okay, next?

>> Operator, do we have anybody on the line that has a question?

>> OPERATOR: Yes, on the phone line we have ray lesh, your line is open.

>> Okay, hello. Yes, thanks again. I was trying to get in on the transportation section. My question has to do with the features of these railroad cars. Now, I talked to a transportation expert about monitoring of the heat and bearings so forth of these cars. I understand in most railroad cars they don't have integrated monitoring within the car, in most cases, and that that was one of the things they wanted to include in these.

So that's one question, is that -- and then the whole question about I heard that there was some sort of RFP or design going on of a new railroad car that would accommodate some of these larger canister systems with the

overpacks. Can someone comment on that?

>> The probability that somebody that was doing that discussion is still here when they've got to catch an airplane is probably pretty low. Is anyone in the room an expert on this?

Nobody seems to be jumping up and down.

>> We'll take a question (inaudible).

>> Okay, the director here says that they will take the question, and it will be addressed on the web. Is that good enough for you?

>> Yeah. I just wanted to say, just from a logistics standpoint, it would be nice if we could get not just the slides, but also some video of the speakers. Because it really helps the understanding of what's going on in the room if we -- the remote people here could have that benefit. Maybe you could look into that, because I understand on the internet these days they actually do have that kind of capability.

Okay. Thank you.

>> Okay, thank you, that's somewhat limited by the room that we're in. If we were in the commission's chambers that might have been a little bit more possible, but our cameras are fixed in the auditorium here.

Is there anybody --

>> Yeah.

>> OPERATOR: Yes, Gary Hedrick, your line is open.

>> Yeah, hi, thank you. I'll be brief because I'm asking the same question I asked yesterday, but I think is to the wrong panel. So my question briefly has to do with the testing of canisters, I noticed today they were talking about bolted canisters.

I'd like you to either confirm or deny the experimental unwelding of a thin canister such as the ariva canisters being used at San Onofre.

>> Okay I'm casing the room here for somebody that can speak to this issue. Again, since we don't have a camera showing you, we're getting sparse in the crowd.

Can we take this one under advisement right now and answer it on the internet as well?

>> Yes, I'd just like that confirmed one way or another. Thank you.

>> Okay, thank you.

>> OPERATOR: Thank you. Our next question ace Hoffman your line is open.

>> Thank you, I just wanted to add that it's the last half hour, the last 45 minutes, there hasn't been a single speaker that we could hear. That's all. Thank you.

>> Thank you for the input. The audio people do need to know that sort of thing so that we can improve our system.

>> OPERATOR: Thank you. Donna Gilmore, your line is open.

>> Okay, thank you. On the Boral panel issue, I think I heard Ricardo say that you don't take credit for any criticality in dry storage, it's always when you're loading into dry storage, and so my question -- and then I was

doing some research after you said that, and it looks like there's a need, or there's an accident, where it ends up back in the water, you need some kind of criticality control. How is that addressed in the CFR 71 issue?

>> Okay. The issue at hand, you want to know what happens (inaudible) and is not able to perform adequately, whether or not repackaging would be have to be done on a dry transfer (inaudible)

>> OPERATOR: This is operator, you are fading in and out.

>> Okay, I think I heard what you're saying, you're saying that you might need to use a dry fuel handling type transfer instead of putting something back in the pool. That's kind of related to what I was saying.

But I did hear you correctly when you said that you don't get any credit for neutron absorption, criticality, in dry storage. So we kind of have a hole there for the issue that you just mentioned and if there was an accident or ended up in some water somewhere, in a river or whatever, in case there was an accident.

So those two conditions are basically still kind of outstanding issues, is that what I'm hearing?

>> Ricardo Torres: I think what I'm telling you is that during normal conditions of storage there's no moderator inside the canister. Therefore, the Boral does not provide criticality control.

The concern of the Boral here is, once again, with respect to reopening a cask and having to reflood the cask, and whether or not that Boral would be able to perform adequately.

Also in the event that a cask has to be reflooded during loading operations, whether or not the Boral would blister, the boron carbide would redistribute and the Boral would no longer be as effective as intended in the design basis.

My second point with respect to the alternatives are, as I said, the dry transfer facility. And the other potential is for the repackaging or the reflooding to be done in the presence of boric acid.

Ultimately what we're looking for is there needs to be sufficient B 10 in the pool in the cask so that the subcriticality margins are met.

>> Which it sounds like is not necessarily the case right now. You know, given this issue, and given the issue of the operating data that we do have about the hydrogen buildup with high burn-up fuel, it seems the safest way to unload would be in a dry handling facility.

Now, someone mentioned yesterday that Oak Ridge was doing something about portable hot cells, but I had read from somebody from Oak Ridge that it wouldn't be feasible to have a hot -- portable hot cell that would be large enough to move fuel assemblies from one container to another.

So I would like to get more information on that issue. Who would be the right person to talk to about that?

>> Ricardo Torres: That would be DOE, under the purview of DOE.

>> And who would that be?

>> Ricardo Torres: I can't really speak to that, Donna.

>> Is Andy Griffith still there or not? Do you know? Can't hear you.

>> We can look at a DOE point of contact and get you that information so you can get ahold of DOE.

>> Okay. All right. It's Donna Gilmore at Gmail.com.

>> Yes, and we'll contact you offline.

>> Okay, thank you.

>> Okay, question from the room.

>> Yes this is Robin Johns from southern nuclear. One of my jobs is to write (inaudible) method of evaluation changes under 50.59.

(inaudible) are you -- where do you think you're going to come out there? Do you feel like it's going to be similar to -- similar flexibility as that we have under 50.59? You all said you're all still working on that, I just -- (inaudible) where you think you're going to end up.

>> (inaudible)

We have not been (inaudible) to try to validate --- 1748. (inaudible)

>> Okay, any more questions? Okay, I think what we want to do is end on a high note. So I want to have a one minute commercial before I let Mike have the floor again to end us on that high note.

Okay. This has been a great meeting. We've had a couple of frustrations with microphones not being able to be heard and things like that, but overall this was a great meeting and a great venue to do it in. One thing that I would need from a bunch of you is that I'm going to be sending a PDF file to hyley that has an evaluation form on it for Chris and me that tells us how well we have done as facilitators.

If the NRC had to go outside and hire facilitators rather than train them themselves and use them interior like this, it probably would be an order of magnitude cost more, because of the types of meetings that we have and the complexity of these things.

So this is really a cost saving effort, and we want to be as efficient with it as possible, and make your meetings as effective as possible. So if you wind up getting one of those from hyley please fill it out and email it back so we can get that feedback. But I appreciate your time here, and thanks for everything that I learned.

>> If everybody can take a big deep breath, it's the end of the day. I really do want to thank my division staff who volunteered to help put this conference together and have it run smoothly. Also, our facilitators. So if my staff and volunteer can kind of stand up so we could all thank them.

(Applause.)

And I also greatly appreciate the etiquette and the decorum that everybody showed during the Q&A sessions.

That's something that really allowed us to have a really meaningful conversation over the last couple of days.

I want you all to recognize that we are all members of a community for the safe management of spent nuclear fuel. That's industry, vendor, the regulators, federal labs, the private research organizations. Not least, the interested parties who participated in this conference remotely. Even though it was a challenge because of the technology. We do appreciate your patience in being able to stick with us for the two days.

We also want to challenge you that the conversations that we had over the last two days really need to continue, and that's so that we all have a shared understanding of the available information that's out there for managing spent fuel, and also common understanding of everyone's viewpoints.

So with that, 2017 DSFM Reg Con is adjourned. Safe travels, everyone.

(Applause.)

>> OPERATOR: Thank you, this does conclude the call, you may disconnect your lines, thank you for your participation.

(Meeting adjourned)