ML20028F277

January 22 2020 Public Meeting Summary for Spent Fuel Performance Margins (Pkallan and Tinverso Edits)

ML20028F277
Person / Time
Issue date:	02/03/2020
From:	Paul Kallan NRC/NRR/DNRL/NRLB
To:	Tara Inverso NRC/NRR/DRO
Kallan P / 415-2809
References
ML2009C024
Download: ML20028F277 (12)

Text

February, 03, 2020 MEMORANDUM TO: Tara Inverso, Acting Deputy Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM: Paul B. Kallan, Project Manager /RA/

New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation

SUMMARY

OF THE JANUARY 22, 2020, CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS On January 22, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 1 public workshop with the Nuclear Energy Institute (NEI) and other industry representatives to discuss NEIs white paper on Spent Fuel Performance Margins (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971). The goal of the workshop was to reach a common understanding of the details of each recommendation, the proposed regulatory products, and the path forward to engage on individual recommendations.

Approximately 62 personnel attended, including 24 in person and 38 remotely via Skpe. The remote participants included members of the public.

The public workshop notice dated January 9, 2020, in ADAMS at Accession No. ML20009C024.

This meeting notice was also posted on the NRC public website. Enclosed is the meeting agenda (Enclosure 1), a list of participants (Enclosure 2), an overview of the meeting (Enclosure

3) and a table listing workshop outcomes and actions (Enclosure 4). NEIs presentation materials are available in ADAMS:

• Thermal Modeling and Phenomena Identification and Ranking Tables (PIRTs): ADAMS Accession No. ML20021A220

• Workshop on Spent Fuel Performance Margins: ADAMS Accession No. ML20021A221 In addition to the items discussed and listed in Enclosure 4, NEI stated that it intends to withdraw petition for rulemaking (PRM) 72-7, which was submitted by NEI on October 8, 2012 (ADAMS Accession No. ML12299A380).

Enclosures:

1. Meeting Agenda

2. List of Attendees

3. Meeting Overview

4. Table CONTACT: Paul Kallan, NRR/DNRL 301-415-2809

T. Inverso 2 In terms of next steps, the NRC is planning four additional workshops to discuss the recommendations in more detail. During the meeting, the attendees discussed the following possibilities:

o Thermal Parameters (~ February 2020) o Source Terms (~ March 2020) o Dose Rates (~ April 2020) o Graded Approach/Phenomena Identification and Ranking Tables (PIRTs) (~ May 2020)

The NRC may consolidate these meetings and/or shift the timeline for logistics purposes. In any event, these workshops will be posted to the NRCs public meeting website in advance of each meeting date.

ML20028F277 *via email NRR-106 OFFICE DNRL/NRLB: PM NMSS/DFM: (a) DD DNRL/NRLB: PM NAME PKallan TInverso PKallan (signed)

DATE 1/29/20 1/03/20 1/03/20 U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS

PUBLIC MEETING AGENDA

January 22TH, 2020 Time Topic Speaker 9:00 AM Introductions/Opening Remarks NRC/NEI 9:30 AM Industry Presentations NEI 12:00 PM Break for Lunch 1:00 PM Discussion on Recommendations NRC/NEI TBD Break (as needed) 3:30 PM Opportunity for Public Comment Members of the Public 3:50 PM Closing Remarks NRC/NEI 4:00 PM Meeting Adjourn Enclosure 1

U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS LIST OF ATTENDEES January 22th, 2020 Name Organization Andrea Kock U.S. Nuclear Regulatory Commission (NRC)

Jeremy Bowen NRC Tara Inverso NRC Yoira Diaz NRC Meraj Rahimi NRC Travis Tate NRC April Smith NRC Paul Kallan NRC Christine Lipa NRC Chris Bajwa NRC Joann Ireland NRC Jason Piotter NRC Alayna Pearson NRC Antonio Rigato NRC Caylee Kenny NRC Chi Min Chang NRC Daniel Doyle NRC David Tang NRC Donny Harrison NRC Ghani Zigh NRC Haile Lindsay NRC Jimmy Chang NRC Joe Browski NRC John Wise NRC Jorge Solis NRC Kenneth Armstrong NRC Norma Garcia NRC Rhex Edwards NRC Ricardo Torres NRC Timothy McCartin NRC Zhian Li NRC Rod McCullum Nuclear Energy Institute (NEI)

Mark Richter NEI Kris Cummings Curtis Wright Jana Bergman Curtis Wright Aladar Csontos Electric Power Research Institute (EPRI)

Hatice Akkurt EPRI Keith Waldrop EPRI Jeremy Renshaw EPRI Enclosure 2

Jack Desando Exelon Michael Callahan GSI Stefan Anton Holtec International Andrew Orrell INL George Carver NAC International Andy Jung NWTRB Brad Blome Omaha Public Power District Douglas Yates TN Orano Raheel Haroon TN Orano Glenn Mathues TN Orano Don Shaw TN Orano Andrea Jennetta Platts Glenn Schwartz PSEG Nuclear Paul Plante The Yankee Companies Robert Capstick The Yankee Companies Steven Baker Transware Zita Martin TVA Carlyn Greene USC Robert Quinn Westinghouse John Phabe Westinghouse Marty Murphy XCEL Marvin Lewis Public 2

U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS On January 22, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 1 public workshop with the Nuclear Energy Institute (NEI) and other industry representatives to discuss NEIs white paper on Spent Fuel Performance Margins (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971). The goal of the workshop was to reach a common understanding of the details of each recommendation, the proposed regulatory products, and the path forward to engage on individual recommendations.

Approximately 62 personnel attended, including 24 in person and 38 remotely via Skpe. The remote participants included members of the public.

The staff participated in discussions with NEI on its plans for the recommendations listed in the white paper under Category 1, Actions that industry can take within the confines of existing regulations and guidance, and Category 2, Actions that NRC can take by tailoring their regulatory guidance as well as their review and inspection practices to recognize the existence of performance margin. The staff also discussed, at a high level, Category 3 recommendations, Actions that will need industry and NRC to engage in a dialogue to develop improved regulatory tools and guidance.

In the morning session of the meeting, NEI stated that it intends to withdraw petition for rulemaking (PRM) 72-7, which was submitted by NEI on October 8, 2012 (ADAMS Accession No. ML12299A380).

NEI then discussed the Spent Fuel Margins Industry Category 1 Recommendations, or the actions for the industry. These are as follows:

• Licensees/COC holders to define and utilize more realistic source terms, supported by conservative modeling in the downstream calculations, in their applications to demonstrate the adequacy of dry storage system design (Recommendation III-1).

• In cases where conservative source term calculations demonstrate compliance with 72.104 and 72.106, licensees/COC holders should also apply a source term uncertainty (i.e. burnup uncertainty) in their applications (Recommendation III-2).

• Assess how thermal modelling is done and what can be simplified. Develop an industry consensus based on thermal modelling methodology and document this as a best practice guide (Recommendation IV-3).

• CoC holds should amend their CoCs to follow the precedent established through Regulatory Issue Resolution Protocol 1-16-01 wherein a graded approach was developed to apply risk insights which resulted in a pilot amendment (#16) to Standardized NUHOMs Certificate of Compliance No. 1004 for Spent Fuel Storage Casks (Docket 72-1004) that achieved a 90% reduction in the amount of information requiring NRC approval in the Fuel Qualification Table and reduced the overall size of the CoC by 33%. NEI mentioned that the NRC would then have the action to review graded approach amendments as they are submitted (Recommendation VI-1).

Enclosure 3

Next NEI discussed the Spent Fuel Performance Margins Industry Category 2 Recommendations, or the actions for the NRC. These are as follows:

• NRC should develop an Acceptance Review Grading process that would assign varying levels of review to an application, form the time it is initially received, based on risk insights (Recommendation II-1).

• In the cases where applicants have applied conservative source terms, conservative modeling, and source term uncertainty (i.e. burnup uncertainty) in their applications NRC should conduct a much less detailed review (Recommendation III-3).

• In cases where applicants have applied the results of the PIRT described in Recommendation IV-1, NRC should revise its internal review guidance to limit the review to verification that the results of the PIRT have been appropriately applied instead of trying to independently repeat results (Recommendation IV-2).

The NEI discussed, at a high level, the Spent Fuel Performance Margins Category 3 Recommendations. The NRC and NEI determined that these recommendations should be discussed in more detail at a future workshop (likely in May 2020).

Following NEIs presentation, Westinghouse provided a quick update of the action items from the April 23rd, 2019 public meeting (A summary of that meeting is available in ADAMS at Accession No. ML19126A026.).

The next presentation was from the Electric Power Research Institute (EPRI), which discussed the benefits of Thermal Modeling and Phenomena Identification and Ranking Tables (PIRTs).

EPRI discussed the benefits of improved thermal models that had occupational dose benefits, dry storage operational benefits and reactor operation/safety benefits. EPRI also discussed the PIRT process, which is a systematic way of gathering information from experts on a specific subject, and ranking the importance of the information, in order to meet some decision-making objective, thus determining what has the highest priority for research on that subject. An important part of the process is to also identify the uncertainty in the ranking, usually by scoring the knowledge base for the phenomenon. EPRI used examples of thermal/decay heat modeling and fuel/cladding performance. EPRI mentioned that the PIRT process significantly reduced concerns with high burn up (HBU) fuel/cladding performance.

The next four presentations were provided by Holtec, NAC, TN - Orano and TVA and consisted primarily of cost-benefit examples. TVA provided a licensees perspective on the cost-benefit.

In the afternoon session of the meeting, NRC, NEI, and industry discussed the Category 1 and 2 recommendations. These discussions focused on desired outcomes of each recommendation, associated details, and who (i.e., NRC or industry) would lead each recommendation. This information was captured in a table during the workshop and can be found in Enclosure 4.

2

At the end of the meeting, the NRC staff provided an opportunity to the public to provide any comments or questions. There was one comment from the public that meeting attendees should identify themselves prior to speaking in the workshop because the conversation was difficult to follow. The attendees committed to properly identifying themselves in future workshops.

3

Outcomes and Actions from the January 22, 2020 Workshop on Spent Fuel Margins Recommendation What is needed/Regulatory Details Workshop Date Lead Product IV-3 (Category (Cat) 1): Industry Best Practices Guide Would clarify performance metrics Late February 2020 Industry Best practices for thermal (followed by potential Nuclear and provide an integrated/aligned modeling methodology Regulatory Commission (NRC) approach on what inputs are documentation indicating relevant/important and needed consistency with NUREG 2152 for reasonable assurance.

Computational Fluid Dynamics Related to Category 3 Best Practice Guidelines for Dry Recommendation IV-1.

Cask Applications)

III-1 (Cat 1): Define and Industry to develop a Would clarify how regulatory limits March 2020 (near Industry utilize more realistic conservatisms roadmap and are implemented and Regulatory Information source terms develop guidance for end-users conservatisms are accounted for. Conference (RIC))

(licensees). Public workshop will give awareness to NRC and allow for NRC input on relative importance of conservatisms.

III-2 (Cat 1): Do not apply Using the conservatisms Would clarify how regulatory limits March 2020 (near RIC) Industry additional burnup roadmap above, industry will are implemented and uncertainty with describe the factors contributing conservatisms are accounted for.

conservative source term to the margins and gain calculations understanding of when applying additional burnup uncertainty may be unnecessary.

III-3 (Cat 2): Conduct less NRC to determine whether less Conservatisms roadmap could March 2020 (near RIC) Industry led detailed review when detailed reviews are warranted inform industrys use of RG 3.54 workshop; NRC conservative methods when conservatisms applied. Spent Fuel Heat Generation in an participation and used for source terms Public communication of any Independent Spent Fuel Storage determination of changes to review process (e.g., Installation. path forward for letter, future revisions to NRC reviews.

guidance)

Enclosure 4

Outcomes and Actions from the January 22, 2020 Workshop on Spent Fuel Margins Recommendation What is needed/Regulatory Details Workshop Date Lead Product V-1 (Cat 3): Dose rates & NRC public documentation that Industry may provide a product for April 2020 Industry V-2 (Cat 3): Modeling new industry guidance is NRC to review on potential dose rate evaluations to consistent with regulatory resolution of dose rate consider operating requirements (e.g., potential recommendations.

experience loaded clarifications on how to storage systems implement NUREG 1536 Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility, NUREG 2215 Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities; OR revisions to NUREG 1536, 2215)

II-1: Develop Acceptance Publicly available document that NRC make the criteria and May 2020 NRC Review Grading Process would describe the criteria for process public so that industry grading reviews (e.g., varying can anticipate scope of NRC scopes of review). review based on content of application.

Nuclear Material Safety and Safeguards/Division of Fuel Management (NMSS/DFM) licensing process expectations memo will provide a starting point.

2

Outcomes and Actions from the January 22, 2020 Workshop on Spent Fuel Margins Recommendation What is needed/Regulatory Details Workshop Date Lead Product IV-2: Limit Phenomena NRC will articulate how the Workshop to be conducted after May 2020 NRC Identification and Ranking application of the PIRT will be PIRTs report issued (draft (PIRT) reviews to reviewed in the licensing expected March 2020).

verification that results process applied properly (e.g. incorporation into the Standard Review Plan (SRP))

Remaining Cat 3 Items Prioritize the remaining Cat 3 May 2020 NRC recommendations and plan for next steps (similar to this table)

VI-1 (Cat 2): Amend TN COC 1004 Rulemaking To Be Determined Industry led for Certificate of Compliance ongoing (anticipated issuance (TBD) - if necessary future workshops, (COC)s to follow graded 1Quarter 2020). pending ongoing if necessary approach activities (including NEI to close the Regulatory Recommendation Issue Resolution Protocol VI-2) associated with the graded approach.

Vendors will evaluate the pilot for applicability. As appropriate, vendors will engage the NRC in pre-application meetings to submit similar license amendment requests to adopt the graded approach. The NRC will use precedence to review associated applications.

3