ML20094J180
| ML20094J180 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/2019 |
| From: | Charles Brown Advisory Committee on Reactor Safeguards |
| To: | |
| Brown, C, ACRS | |
| References | |
| NRC-0733 | |
| Download: ML20094J180 (109) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Metallurgy and Reactor Fuels Subcommittee Docket Number: (n/a)
Location: Rockville, Maryland Date: Tuesday, December 3, 2019 Work Order No.: NRC-0733 Pages 1-82 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 SUBCOMMITTEE ON METALLURGY AND REACTOR FUELS 8 + + + + +
9 TUESDAY 10 DECEMBER 3, 2019 11 + + + + +
12 ROCKVILLE, MARYLAND 13 + + + + +
14 The Subcommittee met at the Nuclear 15 Regulatory Commission, Two White Flint North, Room 16 T2D30, 11545 Rockville Pike, at 1:00 p.m., Ronald G.
17 Ballinger, Chair, presiding.
18 19 COMMITTEE MEMBERS:
20 RONALD G. BALLINGER, Chair 21 JOSE MARCH-LEUBA, Member 22 JOY L. REMPE, Member 23 24 DESIGNATED FEDERAL OFFICIAL:
25 CHRISTOPHER L. BROWN NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 NRC STAFF PRESENT:
2 JOSEPH F. BOROWSKY, NMSS/DFM/CTCFB 3 YOIRA K. DIAZ, NMSS/DFM/CTCFB 4 DARRELL S. DUNN, NMSS/DFM/MSB 5 ELIEZER B. GOLDFEIZ, NMSS/DFM/NARAB 6 MERAJ RAHIMI, NMSS/DFM/MSBJD 7 CHRISTOPHER M. REGAN, NMSS/DFM 8 ANTONIO B. RIGATO, NMSS/DFM/MSB*
9 JEREMY A. SMITH, NMSS/DFM/NARAB 10 JORGE SOLIS, NMSS/DFM/CTCFBCH 11 TRAVIS L. TATE, NMSS/DFM/NARAB 12 BERNIE WHITE, NMSS/DFM/STLB 13 VERONICA M. WILSON, NMSS/DFM/NARAB 14 15 ALSO PRESENT:
16 MARK RICHTER, NEI 17 18 19 *Present via telephone 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 C-O-N-T-E-N-T-S 2 Opening Remarks and Objectives 3 by Prof, Ronald Ballinger, Chair . . . . . 4 4 Staff Opening Remarks 5 by TBD (DSFM Management) . . . . . . . . . 6 6 NRC Presentation on NUREG-2216 7 by NMSS . . . . . . . . . . . . . . . . . . 8 8 Stakeholder Perspectives on NUREG-2216 9 by Mr. Mark Richter . . . . . . . . . . . . 32 10 Public Comments . . . . . . . . . . . . . . . . . 79 11 Adjourn . . . . . . . . . . . . . . . . . . . . . 82 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 (1:01 p.m.)
3 CHAIR BALLINGER: This meeting will come 4 to order. This is a meeting of the Advisory Committee 5 on Reactor Safeguards Subcommittee. I am Ron 6 Ballinger, Chairman of the Metallurgy and Reactor Fuel 7 Subcommittee. Members in attendance are Jose March-8 Leuba and Joy Rempe. Chris Brown is the designated 9 federal official.
10 The purpose of today's meeting is for the 11 subcommittee to receive a briefing on staff's 12 development of NUREG-2216, standard review plan for 13 spent fuel transportation and radioactive material.
14 Today we have members of the NRC staff and Industry to 15 brief the subcommittee.
16 The ACRS was established by statute and is 17 governed by the Federal Advisory Committee Act, FACA.
18 That means that the committee can only speak through 19 its published letter reports. We'll hold meetings to 20 gather information to support our deliberations.
21 Interested parties who wish to provide comments can 22 contact our office requesting time. That said, we set 23 aside ten minutes for comments from members of the 24 public attending or listening in to our meetings.
25 Written comments are also welcome.
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5 1 The meeting agenda for today's meeting was 2 published on the NRC's public meeting notice website, 3 as well as the ACRS meeting website. On the agenda 4 for this meeting and on the ACRS Meeting website are 5 instructions as to how the public may participate. No 6 requests for making a mistake to the subcommittee has 7 been received from the public. A transcript of the 8 meeting is being kept and will be made available on 9 our website. Therefore we request that participants 10 in this meeting use the microphones located throughout 11 the meeting room when addressing the subcommittee.
12 And when you do that, make sure the green light is on 13 when you talk. Participants should first identify 14 themselves and speak with sufficient clarity and 15 volume that they can be readily heard.
16 We have a bridge line established for the 17 public to listen in to the meeting. To minimize 18 disturbance, the public line will be kept in a listen-19 only mode. To avoid disturbance, we request that 20 attendees put their electronic devices like cell 21 phones and other things that make noise in a noise-22 free mode.
23 We'll now proceed with the meeting. And 24 I'll ask Chris Regan who's over there, Deputy Director 25 of Spent Fuel. Any introductory remarks to make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 before we begin today's presentations? So Chris.
2 MR. REGAN: Good afternoon. Thank you 3 very much for the introduction. I first want to say 4 thank you very much to the subcommittee for your 5 interests in our work in the Spent Fuel Program. We 6 have been doing a lot of work to establish and 7 basically you know, update our current regulatory 8 framework, the guidance that we have on the books at 9 the moment as we move forward facing a whole host of 10 new challenges. You'll see and hear from a fair 11 number of the Division of Fuel Management staff, each 12 in their own specific discipline of expertise as they 13 walk through each element or each part of the revised 14 standard review plan.
15 I wanted to mention that the scope of this 16 effort was largely and primarily a consolidation of 17 existing guidance. If I go back in my time machine 18 and look at the last time we updated the SRP, it would 19 probably be a fair number of years ago. Given the 20 magnitude of the effort, we took some time to come to 21 a point where we reach critical mass. And said okay, 22 now is the time we need to revise and update the SRP.
23 And finally made the decision that, that's what we 24 were going to do. And has brought us to where we are 25 today. So it's really a consolidation of existing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 technical guidance we have on the books. Technically 2 there is nothing really new here.
3 We do plan to continue our efforts to 4 improve the staff guidance. This is just the first 5 step in the process. I know that the subcommittee and 6 the full committee has interest in risk informing our 7 program. And that is definitely one thing on our 8 radar of what we are interested in doing when it comes 9 to our regulatory guidance. And we're continuing to 10 look for opportunities and identify where we can use 11 risk insights to inform our guidance.
12 We have already, I wouldn't say fully 13 completed, but we have significant milestones achieved 14 in a couple areas relative to where we have leveraged 15 risk insights. One of which is the graded approach 16 for storage certificates -- content in the certificate 17 and the Tech Specs itself. We have an interest in 18 incorporating the lessons learned from that into our 19 guidance at some point in time in the near future.
20 And also recently as of November, we 21 received a letter from NEI looking at assessing 22 performance margins. And that will -- in and of 23 itself, that effort as we walk through each of their 24 recommendations in that letter, for sure include 25 assessment and consideration of risk insights. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 that's another piece of data that will inform how we 2 move forward on improving our guidance to incorporate 3 risk insights.
4 I didn't have any other remarks. I would 5 like to thank the staff for their efforts pulling it 6 together. I know it's been a long road on the SRP.
7 And with that, I will turn it over to Jeremy Smith who 8 will lead off our presentation. Thank you.
9 CHAIR BALLINGER: Do I understand that 10 there's a staff person on the line?
11 MR. SMITH: That's correct.
12 CHAIR BALLINGER: Are you going to present 13 the first slide after this?
14 MR. SMITH: After my introductory slides.
15 CHAIR BALLINGER: Okay.
16 MR. SMITH: These are the first technical 17 --
18 CHAIR BALLINGER: Go ahead.
19 MR. SMITH: -- person that will be 20 speaking. So thank you for having us here today at 21 the subcommittee briefing. Like Chris had mentioned, 22 this has been a long effort to consolidate guidance.
23 And you know, we welcome any questions you might have 24 on the progress that we've made to date.
25 Today I'm going to be discussing the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 background of why we undertook this initiative. The 2 goals, our approach, the public comments that we've 3 received, and then a final summary slide.
4 So the Division of Fuel Management 5 recognized that there was a need to consolidate the 6 Transportation Standard Review Plans. The SRPs were 7 issued in 1999/2000 timeframe. And those were NUREG-8 1609 and NUREG-1617. And they included supplements to 9 them for specific topics; MOX fuel, as well as TPBARs.
10 In addition, over the last two decades, 11 we've had many interim staff guidance documents that 12 were issued to assist in implementing any changes to 13 Part 71 and any emergent issues that required 14 technical clarification. We also thought this would 15 be a good opportunity to improve the structure of the 16 SRP. And we are using a similar approach to NUREG-17 0800, which is used NRR, which essentially 18 consolidates all of the information into modular 19 chapters. So if there's a specific technical area, we 20 can just make that change to the SRP.
21 CHAIR BALLINGER: Can you hear him okay?
22 MALE PARTICIPANT: Yeah.
23 CHAIR BALLINGER: Okay.
24 MEMBER MARCH-LEUBA: While you're talking 25 about that, one of the beautiful things about NUREG-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 0800 is that it can be updated in ADAMS on a page by 2 page basis without having to issue a whole addendum.
3 Are you doing the same thing?
4 MR. SMITH: We plan to do the same thing.
5 And the main reason was because our interim staff 6 guidance process when it was first initiated, there 7 was no public comment period. It was very informal.
8 It was just hey staff, this is something you need to 9 be aware of and we would issue it. As time 10 progressed, those became more and more labor intensive 11 to issue an interim staff guidance document until it 12 was almost equivalent to issuing a little mini SRP.
13 So by doing this separate, we hope to minimize any 14 future use of ISGs at all. And we're going to be 15 sunsetting the existing ISGs.
16 MEMBER MARCH-LEUBA: Right. No, the 17 problem is typically ADAMS requires you to issue a 18 completed new revision of the document every time you 19 modify one column. And then they figure out a way, so 20 you can make these updates without having to issue the 21 whole thing.
22 MR. SMITH: That is our attempt.
23 MEMBER MARCH-LEUBA: Talk to them and make 24 sure you do.
25 MR. SMITH: I definitely will. So our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 goals in undertaking this effort, as always, we want 2 to maintain the safe and secure transportation of 3 radioactive materials. We think there will be an 4 increase in the efficiency reviews, primarily because 5 all of the information that is scattered throughout 6 numerous documents will now be consolidated into one 7 overall document. This effort is going to minimize or 8 eliminate the use of ISGs. Our intent is to eliminate 9 them. It will improve the efficiency of future 10 revisions as you stated that we should be able to do 11 this on a modular basis. And the ultimate goal is 12 have one SRP for all transportation package review 13 guidance.
14 The approach that we took on this, we 15 formed an internal NRC team consisting of staff from 16 all the technical disciplines that would be involved 17 in a review. And we consolidated the review guidance 18 found in NUREG-1609 and NUREG-1617. We also 19 incorporated the MOX and TPBAR supplements. We 20 incorporated the ISGs and any other technical 21 guidances being used currently on the street. And we 22 updated figures and references to regulations related 23 to all the specific review areas.
24 So NUREG-2216 does not introduce new staff 25 positions on technical issues. This is the way we are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 currently doing reviews. It was a concerted effort to 2 make sure we did not include things that have not been 3 reviewed yet. It incorporated our staff review 4 experience and practice in order to establish a 5 consistency of review across all of our reviewers.
6 The technical chapters were updated to consolidate all 7 of the current transportation guidance. And as part 8 of this effort, we created two new chapters; a 9 materials and a quality assurance. These two chapters 10 did not exist in NUREG-1609 or 1617, but were rather 11 incorporated by reference in various ISGs.
12 For public comments, we received four 13 public comment letters in response to our Federal 14 Register Notice; NEI, ORANO, HOLTEC, and one anonymous 15 comment.
16 MALE PARTICIPANT: So ORANO is TN?
17 MR. SMITH: Yeah, it's TN. TN is now 18 ORANO. And one comment that we got from several 19 sources was that NUREG-2216 and Regulatory Guide 7.9, 20 which is our standard format content guide for Part 71 21 applications, by issuing this SRP would become 22 consistent. And we are aware that they would be 23 inconsistent. That was a management decision that we 24 will draft the SRP first. And then subsequently 25 revise Reg Guide 7.9 in order to make them, you know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 harmonize together.
2 We reviewed, you know, several formatting 3 of the SRP or editorial type comments on it. Some of 4 the public comments requested additional guidance, you 5 know? However at this point in time, this is only a 6 consolidation effort. Any need for new guidance would 7 be looked at for a future revision to this SRP. Many 8 of the comments were out of scope for this 9 consolidation effort, primarily because it is only a 10 consolidation and does not expand upon the way we do 11 our technical reviews. And there were other changes of 12 clarifications that were requested.
13 MEMBER MARCH-LEUBA: This request for new 14 guidance, obviously a member of the public thought it 15 was important and it was lacking. So have you guys 16 any idea what that's about?
17 MR. SMITH: The additional guidance that 18 was requested?
19 MEMBER MARCH-LEUBA: Yes.
20 MR. SMITH: A lot of them have to do with 21 risk informing our regulations since that it is a big 22 effort at this point in time.
23 MEMBER MARCH-LEUBA: Okay, so that's a big 24 effort?
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14 1 there had been discussions back when we first started 2 this effort about you know, do we want -- you know, 3 because these were two efforts that were going kind of 4 parallel to each other. And the decision was made not 5 to tie up the SRP consolidation effort with, you know, 6 risk informing them at this point in time. So that we 7 could at least get the SRP out on the street.
8 MEMBER MARCH-LEUBA: So in your opinion, 9 there is no low hanging fruit where you can satisfy 10 these members -- if it's risk informed, it's not low 11 hanging fruit.
12 MR. SMITH: Right, right. It is not low 13 hanging fruit. Were there any other specific ones?
14 Do you remember, for additional guidance for the 15 technical areas?
16 MR. WHITE: Yes. Bernie White, Division 17 of Spent Fuel Management. We got some comments about 18 clarify what you mean by appropriate, inappropriate, 19 clarify, you know, comments like those as well.
20 MEMBER MARCH-LEUBA: Is there an actual 21 schedule, however theoretical it might be for 22 completing the risk informing process?
23 MR. SMITH: I really can't speak to that 24 since that's a separate effort. I'm hoping somebody 25 can --
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15 1 MR. REGAN: I'd like to capture more as a 2 living process, we're in a continuum. Every 3 opportunity we see where we can risk inform our 4 program, we're going to look at it and take a crack at 5 it. Case and point, you know, our Oversight Program 6 reviews risk insights to inform proposed options and 7 recommendations for Oversight Program for spent fuel 8 storage installations. And will continue as I 9 mentioned, a graded approach in the storage area on 10 how we can use the risk insights to inform how we 11 develop guidance for storage reviews. So it's not a 12 holistic, we're going to do one evaluation of the 13 whole program and incorporate risk insights and then 14 be done. It's more of a continuum as we work through 15 a whole host of issues that we have on the books to 16 incorporate them where we can.
17 MALE PARTICIPANT: Did we miss the person 18 on the line?
19 MR. SMITH: Oh no, we're coming up there.
20 So this is -- if we can tap into the line now, Chris.
21 We're going to start off with Chapter 2, which is our 22 structural chapter. And the way we have the rest of 23 the presentation laid out is we were going to cover 24 some of the chapters that we received comments on or 25 that had changes -- incorporation of ISGs. And we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 will let each technical discipline discuss those.
2 All right. Tony, are you there?
3 MR. RIGATO: Yes, I'm here.
4 MR. SMITH: Wow.
5 MEMBER MARCH-LEUBA: Yes, we can hear you.
6 MR. SMITH: We can hear you, Tony great.
7 Thank you.
8 MR. RIGATO: Sure. And so here on the 9 presentation, I've got -- it's on Slide 9. I don't 10 think that changed, basically the outline is still the 11 same from this morning. And basically we've 12 incorporated two ISGs. There's actually a third one 13 that's not listed here. I only realized afterwards 14 that he just didn't put it on the Table 1 of the SRP 15 to indicate that was included. And that is ISG-12, 16 which is the bundling of fuel.
17 But ISG-1 as it states here, it talks 18 about the description of damaged fuel. It's something 19 we work in tandem with the material scope and 20 criticality. Computational modeling, that's another 21 one that you'll also see. The thermal inspection 22 (phonetic) is basically providing a little more 23 guidance for a lot of these models that we receive.
24 Because a lot of the work that we do receives in terms 25 of amendment requests and so on are based on, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 know, analytical modeling itself, rather than physical 2 drop testing.
3 A lot of the comments were not very 4 specific. Some were very simple corrections, maybe 5 pointing, you know, to the right chapter. As Bernie 6 had alluded to previously some of the comments were 7 clarify or you know, could you expand upon. There was 8 also a request of a little bit of new information 9 beyond the scope of consolidation. One of the 10 examples was how to include statistical deviation in 11 structural characteristics and accident evaluation 12 ranges. But for the most part, there wasn't too much 13 to actually modify what we've already had in the SRP 14 in terms of you know, other comments in terms of 15 corrections or clarifications. And that's pretty much 16 it for this.
17 The next slide is thermal, so I'll let 18 those folks or experts take a crack at that. Thank 19 you.
20 MR. SOLIS: On the thermal part -- Well 21 again, according to what Jeremy mentioned, the content 22 was reorganized to align with current practices in 23 terms of the review areas for the contents. Also 24 added ISG-7, which is potential generic issue 25 concerning cask heat transfer in a transportation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 accident. Basically that through the effect of the 2 fission products and gases released when the spent 3 fuel rods break -- in the case they break. And the 4 effect on the thermal conductivity.
5 Also, as Tony said, we added ISG-21, which 6 is the use of computational modeling software. And 7 the regulatory language was clarified. And when it 8 comes to the comments really, very minor areas were 9 necessary to address them. So really nothing big.
10 Just the specific typos, clarifications. Added a 11 regulation where it's needed, et cetera.
12 MR. BOROWSKY: For containment, there were 13 no significant changes to the chapter. Table 4-1 was 14 added. And that basically showed relevant regulations 15 for each of the review areas. The chapter refers to 16 NRC information Notice 2016-04, which was published 17 many years after the previous SRP issuance states, 18 roughly the year 2000. There were some editorial 19 changes basically setting structure for example. And 20 there were discussions and terminology was clarified.
21 For example, replacing the word SAR with application.
22 Other than that, there were very little significant 23 changes.
24 MR. SMITH: Well, Chapter 5 is a shielding 25 chapter. I was not the technical reviewer for that, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 but he is currently on a fellowship to Japan for a 2 year. So he was unable to make this meeting with us.
3 Chapter 5 again, clarifies certain review topics 4 throughout the SRP, especially Chapter 5. We added 5 ISG-6, which is establishing the minimum initial 6 enrichment for the bounding design basis fuel 7 assemblies. ISG-21, which is kind of a common intro, 8 just that covers the use of computational model 9 software.
10 There were minor edits for clarifications 11 based on the public comments. And there were some new 12 methodologies proposed by the public, but they at this 13 point in time, are beyond the scope of this 14 consolidation effort.
15 MEMBER MARCH-LEUBA: Let's talk something 16 technical, what do you mean by minimum initial 17 enrichment? And I'm thinking of the effort -- we 18 keep asking the same question, are we going to go 19 above 5 percent? Is this addressed there or will it 20 have to be revised?
21 MR. SMITH: At this point in time, I think 22 we're still investigating the above 5 percent issue.
23 It was not incorporated into this SRP.
24 MEMBER MARCH-LEUBA: Isn't the staff now 25 actually finding a way to allow up to 10 percent?
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20 1 MR. SMITH: I know the staff is 2 investigating --
3 MEMBER MARCH-LEUBA: Yeah.
4 MR. SMITH: -- increased enrichments based 5 on the accident tolerant fuels.
6 MEMBER MARCH-LEUBA: Yeah.
7 MR. SMITH: And this is kind of an ongoing 8 -- I think there's a research effort on that right now 9 --
10 MEMBER MARCH-LEUBA: Right.
11 MR. SMITH: -- to determine how we can do 12 that.
13 MEMBER MARCH-LEUBA: Right. This being 14 life, you have to assume that if you can load a bundle 15 with 6 percent enrichment, it will develop a problem 16 and you'll have to transport it out to the plant.
17 Right? So whatever the maximum enrichment is, that's 18 where you have to assume at least one of the bundles 19 in the cask has.
20 MR. SMITH: Right.
21 MEMBER MARCH-LEUBA: So but to my original 22 question. What do you mean by minimal initial 23 enrichment in ISG-6?
24 MR. SMITH: Can I turn this over to a 25 shielding colleague of mine?
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21 1 MEMBER MARCH-LEUBA: Oh Veronica.
2 MS. WILSON: Is this on?
3 MEMBER MARCH-LEUBA: No, that one has not 4 worked this morning. You have to walk up there. And 5 you have to talk real close to it.
6 MS. WILSON: Really close? Okay, this is 7 Veronica Wilson, NRC, Division of -- what are we, Fuel 8 Management now?
9 (Off-microphone comments.)
10 MS. WILSON: Okay. Jose and I actually go 11 way back, so this is really fun. So in this context, 12 this is for shielding. And it's for establishing 13 source terms of spent fuel in which case to try to do 14 a bounding source term, they have to establish a 15 minimum enrichment rather than a maximum like in 16 criticality for instance. So to maximize -- because 17 like we want to store like a bunch of spent fuel.
18 It's like well how do you bound that? So from a 19 shielding perspective, generally maximum burn-up, 20 because more burn-up is more source term.
21 MEMBER MARCH-LEUBA: Wait, wait, wait.
22 MS. WILSON: Okay. And then minimum 23 cooling time because -- Yeah, minimum cooling time 24 because more cold is less source term. And then 25 minimum enrichment because the higher enrichments NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 actually give you less source term.
2 MEMBER MARCH-LEUBA: Oh, higher 3 enrichment, you get less source term?
4 MS. WILSON: Well it's -- So if you think 5 about if you burn a fuel assembly at the same power --
6 So if you get a fuel assembly that reaches the same 7 burn-up --
8 MEMBER MARCH-LEUBA: I get it. There is 9 less --
10 (simultaneous speaking) 11 MS. WILSON: -- then now you're getting 12 more neutron source. You're getting more --
13 MEMBER MARCH-LEUBA: I get it. You're 14 burning the same amount of 235, but there is less 238 15 for use --
16 MS. WILSON: Yeah. So it gives you a 17 higher source term and you have a lower enrichment.
18 MEMBER MARCH-LEUBA: Okay.
19 MS. WILSON: So this is just clarifying 20 that.
21 MEMBER MARCH-LEUBA: I should have known.
22 Thank you.
23 MS. WILSON: Yes, of course.
24 MEMBER REMPE: My understanding is that at 25 some point you do have different isotype mixtures if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 you do go to a higher enrichment. Right?
2 MS. WILSON: Yes. But in general, just to 3 speak of more like what is the bounding source term?
4 The lower enrichment will give you the lower bounding 5 source term even if it has like a different mix of 6 nuclides.
7 MEMBER REMPE: Okay. So there's nothing 8 in this NUREG-- or this SRP that will need to be 9 changed if they go to 8 percent?
10 MS. WILSON: I am not going to speak to 11 that because I imagine that's future stuff that we 12 haven't really delved into. But in relation to just 13 this slide and shielding --
14 MEMBER REMPE: Okay.
15 MS. WILSON: -- for shielding stuff, 16 higher enrichment is generally better.
17 MEMBER REMPE: Okay, that helps.
18 MS. WILSON: Because you're not, you know, 19 not producing as much actinides and activations, and 20 you know --
21 MEMBER REMPE: Okay.
22 MR. SMITH: Okay. So on the criticality 23 chapter, we brought the SRP up to the current Part 71 24 regulations. Example of this is this is the transport 25 index was replaced with both the criticality safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 index and the transport index. We added the ISG-8 2 Revision 3, which is burn-up credit and the 3 criticality safety analysis for spent fuel, transport 4 and storage casks. This was a -- as you can see, this 5 ISG has already undergone three revisions. And it's 6 important because when these SRPs were originally 7 fashioned, they assumed a fresh fuel load-out. And as 8 the industry has progressed, they've requested burn-up 9 credit because you can fit more of the fuel assemblies 10 in any given cask.
11 We also incorporated ISG-19, which is 12 moderator exclusion under Hypothetical Acts Conditions 13 to meet the requirements of 10 CFR 7155(e). And we 14 added ISG-21, the use of computational modeling 15 software.
16 MR. DUNN: Okay for materials, we added a 17 chapter to provide review guidance. The materials 18 information was in various chapters -- various 19 technical review chapters in NUREG 1609 and 1617. So 20 there was no specific materials chapter in those SRPs.
21 And we also had a number of interim staff guidance 22 documents, which I have listed on the following slide, 23 that we incorporated to produce this materials 24 chapter.
25 We did receive a good number of very good NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 public comments. I think about five or six comments.
2 We took a look at those comments and in general, agree 3 with the substance of those comments. And have made 4 some proposed revisions to the SRP to address those.
5 I won't go into every one of the comments, but I would 6 like to address at least a couple of them that I think 7 are significant with respect to the SRP.
8 We received a comment about coating 9 qualification. We had a statement in there about, you 10 know, coatings should be evaluated by a qualified 11 coatings engineer. And the comment was that this is 12 not consistent with the review guidance that existed, 13 primarily in Chapter 2 of the NUREG 1609 and 1617.
14 And we looked at that comment and we agree with the 15 substance of that comment. And we have proposed to 16 remove that from the SRP.
17 We had another comment later on in the SRP 18 about the purity of cover gas and sampling of that.
19 And again, that was actually provided as an example of 20 a way to confirm that an inert environment had been 21 maintained for the transportation of spent fuel after 22 loading. And the comment that we got was that, that's 23 inconsistent with the current practices. And even 24 though we provided that information as an example, 25 when we went back and looked at that, we thought that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 well this was -- this was actually guidance that was 2 really a report that was developed primarily for 3 storage looking at the effect of contaminants over 40 4 years of time. So it wasn't really applicable to our 5 good example for a transportation system.
6 And we were also reminded of some of the 7 comments that we have received from Industry in public 8 meetings and other public comments where we provide an 9 example, but that example can kind of become the de 10 facto standard. And that was not our intent of 11 providing this as an example. So again, we're 12 recommending deleting that particular example from the 13 SRP.
14 And the final comment that I'd like to 15 speak to is one that involves the guidance that was 16 originally in ISG-11, Rev 3 on the thermal cycling 17 during drying for spent fuel. And originally what we 18 had in our transportation SRP that went out for public 19 comment was that thermal cycling criteria was 20 specifically for high burn-up fuel. And the comment 21 that we received was that's not what ISG-11, Rev 3 22 says. What it says is that criteria's applicable to 23 all commercial spent fuel types and burn-ups. And we 24 agree with the comment. That is what ISG-11, Rev 3 25 says. So we have proposed changes to the SRP to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 consistent with the information that is included in 2 ISG-11, Rev 3.
3 If there are other comments that come up 4 later on about some of the other comments we've 5 addressed, we can certainly talk about those. But 6 those were the three that I had intended to talk about 7 here. So next slide.
8 So this slide has the interim staff 9 guidance documents that were incorporated into the 10 materials evaluation chapter. The one in the center 11 there, ISG-15 is essentially the bulk of the materials 12 evaluation chapter. We also included ISG-1, Revision 13 2 in the chapter, as well as ISG-11, Rev 3, which I've 14 talked to. And ISG-22 on potential rod splitting due 15 to exposure to an oxidizing environment. And ISG-23 16 is included in Attachment 7(a) to the materials 17 chapter. That's all I have.
18 MR. SMITH: So the other chapter that we 19 added was a quality assurance chapter. We added this 20 chapter in order to provide a review guidance for 21 package applications that have the quality assurance 22 plan. And the content is very similar to what had 23 applied in NUREG 2215. It provides additional 24 guidance for applications that reference a previously 25 approved quality assurance plan. And we did receive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 one comment that questioned the need for a QA chapter 2 in the SRP. There is no need -- I believe -- Bernie, 3 can I give this one to you? I know you know more 4 about this than I do.
5 MR. WHITE: This is Bernie White, 6 Division of Spent Fuel Management. One of the 7 requirements in an application is a description -- in 8 the application for transportation packages, is a 9 description of the quality assurance program. So some 10 entities like Department of Energy don't have an NRC 11 approved QA plan. And so they provide us a 12 description of their quality assurance program and we 13 review that. Companies that we know have -- that we 14 do business with routinely that we know have a quality 15 assurance program, they just don't provide us anything 16 or just say we have one. It's Quality Assurance 17 Program No. XYZ.
18 MR. SMITH: So in summary, NUREG 2216 is 19 a consolidation of our existing staff guidance. The 20 new SRP does not introduce new positions by staff, but 21 rather just pulls it all together and clarifies some 22 topics that were presented in other reference 23 documents and the comments from the public indicated 24 areas where additional clarification may be needed.
25 CHAIR BALLINGER: That's it for you guys?
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29 1 MEMBER REMPE: Well since we're way ahead 2 of schedule, go to Slide 25 and let's look at the 3 picture --
4 CHAIR BALLINGER: Let's do something that 5 will get us behind schedule.
6 MEMBER REMPE: Well let's just talk about 7 the pictures. I was curious about them. What's the 8 upper left picture of?
9 MR. WHITE: It's Bernie White again, 10 Division of Spent Fuel Management. The upper left is 11 a pin puncture on -- I want to say it's one of the 12 TRUPACT packages that regulates for hypothetical 13 accident condition required of 9 meter drop test, a 1 14 meter pin puncture test, and then a 30 minute fire.
15 The upper left is a pin puncture. The picture on the 16 right is a 30 foot drop test, 9 meters. And then the 17 bottom left is a furnace fire test and a furnace on a 18 package.
19 MEMBER REMPE: Thank you.
20 MR. WHITE: You're welcome.
21 MEMBER REMPE: It was the most exciting 22 slide.
23 CHAIR BALLINGER: For the end reactor 24 fuel, I actually witnessed the drop test.
25 MEMBER REMPE: Okay.
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30 1 MEMBER MARCH-LEUBA: On the picture on the 2 right, that's a full size cask? I mean it looks very 3 small.
4 MR. WHITE: Yeah, my guess is that would 5 be a half or quarter scale test. It's hard to judge 6 from here. But most of -- So most of the bigger 7 packages like spent fuel packages of that size, they 8 do quarter half scale tests. Some of the smaller 9 packages, the drum size packages, they'll do full 10 scale tests.
11 MEMBER MARCH-LEUBA: So they do computer 12 modeling or some kind of a scaling fuel?
13 MR. WHITE: Spent fuel packages, they 14 will use that to -- I use the term "benchmark" their 15 computer modeling.
16 (Simultaneous speaking.)
17 MR. WHITE: Right. Some of the smaller 18 packages solely rely on drop tests. And they'll drop 19 the package in four, five, six different orientations 20 from 30 feet and several pin punctures as well.
21 CHAIR BALLINGER: There are a bunch of 22 other pretty exciting ones like that F4 Phantom flying 23 into the side of one of these things. And if you put 24 a picture of the Navy cask up there.
25 MR. WHITE: We have one, it's large.
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31 1 CHAIR BALLINGER: Thank you. So we need 2 to swap out and have any I folk who is here.
3 MR. RICHTER: I do have a brief question.
4 MEMBER MARCH-LEUBA: You need to put your 5 green light on.
6 (Off-microphone comments.)
7 MEMBER MARCH-LEUBA: No, he's not 8 scheduled to talk.
9 MEMBER REMPE: But he's got a question.
10 So pretend like you're at the mic and say your name.
11 (Simultaneous speaking.)
12 MR. RICHTER: This is Mark Richter, NEI.
13 I have just one question for the staff. I noticed on 14 some of the slides that you used the term "adding an 15 ISG." In other places, you indicated "incorporating 16 an ISG." You may have noted the difference or the 17 distinction between the two and I may have missed 18 that. But is there any difference in the processing 19 in adding versus incorporating?
20 MR. SMITH: I don't believe that the staff 21 intended a difference. The way we created the slide 22 -- each technical person created their own slide. And 23 so they used the word "incorporated" or "added."
24 MR. RICHTER: That's what I suspected. I 25 just wanted to be sure I wasn't missing some subtlety.
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32 1 Thanks.
2 (Off-microphone comments.)
3 MR. RICHTER: Okay, well, good afternoon, 4 everyone. For those of you who may not know me, I'm 5 Mark Richter. I'm a Senior Project Manager with NEI, 6 Nuclear Energy Institute. I work in the Used Fuel and 7 Deconditioning Program section. I'd like to first 8 thanks NRC and the ACRS Subcommittee for providing me 9 with an opportunity today to provide an NEI and an 10 Industry perspective regarding NUREG-2216. What I'm 11 presenting today is really a collective opinion -- an 12 assemblage of a variety of Industry inputs from 13 licensees, suppliers, and so forth. And we believe 14 it's really important that we have the opportunity to 15 be here today to share those with you to inform -- you 16 know, what you do going forward with NUREG-2216.
17 From our perspective, we think it's 18 especially important given the fact that, you know, 19 we're moving closer to the possibility of actually 20 transporting spent fuel to consolidate at interim 21 storage facilities, potentially as early as the end of 22 2023 or sometime in 2024. Which on the one hand, a 23 few years away is a few years away. But in our world, 24 a few years will pass pretty quickly. So from our 25 point of view, it's very timely and important that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 we're here today to talk about this.
2 And also we wanted to express our 3 appreciation for the staff's efforts to improve the 4 efficiency of the processes involved in reviewing the 5 transportation-related documents. And the benefits 6 hopefully that we'll achieve as an Industry from 7 consolidating the Standard Review Plan into one single 8 document. Much of which you've already heard 9 addressed by Jeremy and others earlier.
10 Okay, and I mentioned that this is 11 important to the Industry and I know the staff in 12 their presentation just a few minutes ago, you know, 13 focused on a lot of, you know, desired benefits and 14 anticipated benefits of the consolidation and 15 incorporation of a lot of the requirements into a 16 single document. But would like to reiterate from our 17 standpoint, the importance of that as well. You know, 18 we see this as an opportunity to consolidate much of 19 the guidance and improved regulatory efficiency in a 20 way that at least we hope, and I'm sure it's NRCs 21 intent as well, in a way that's consistent with NRCs 22 broader vision of transformational, you know, 23 transforming the way the NRC does business and you 24 know, transforming regulatory framework to make it 25 more efficient.
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34 1 And you know, from our perspective, you 2 know, a uniformed review basis that is clear and is 3 not subject or pruned to subjectivity and 4 interpretation of different reviewers is really 5 essential if we're going to achieve our shared goal of 6 improved regulatory efficiency. And I'd also like to 7 note too that, you know, coming into the meeting 8 today, I was really pleased to hear that a lot of the 9 work has already begun on addressing some of the 10 public comments, especially those related to 11 clarification and reduction of some of the 12 ambiguities. So I take that as a very positive sign 13 that some of those actions are already underway.
14 CHAIR BALLINGER: Do I read Bullet 2 to 15 mean that there in past times has been subjectivity to 16 interpretation?
17 MR. RICHTER: That may be subject to 18 interpretation. Well I think you know, without 19 pointing to any -- all kidding aside, without pointing 20 to any past history, you know we're just stating in an 21 affirmative way the importance of clear and 22 unambiguous communication is, you know, it's first and 23 foremost in being able to be effective and efficient 24 without any -- you know, it's not meant to be a 25 comment on previous documents or interpretation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 thereof. We are just looking forward with this. And 2 want to make sure it's as clear and as tight as 3 possible.
4 Okay and the way that we undertook the 5 review is a little bit different than what the staff 6 provided in their presentation. They basically went 7 chapter by chapter and provided a summary of some of 8 the comments and some of the early actions or 9 anticipated actions. Our approach, as you know, the 10 document is pretty lengthy. It's, I guess, close to 11 500 pages if you count each page front to back.
12 And you know when Industry reviews a 13 document like this, we tend to do it as a team and NEI 14 collects a lot of different inputs from a lot of 15 different sources. So from our perspective, we tried 16 to provide comments, you know, by category or type, 17 rather than by chapter or by section. And as you can 18 see on the slide here, we've captured those in four 19 general areas.
20 One being integration of ISGs and other 21 documents. From our standpoint, you know, clearly 22 identifying the areas of the NUREG to tie to each of 23 those references is important again for improving 24 efficiency and review. We identified a number of 25 areas where there were some undefined or nonspecific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 terms. And also some general comments that may be you 2 know, somewhat open to interpretation. So our 3 recommendation there was to kind of tighten that up 4 and get a look at some of those areas. You know, 5 consider maybe some different words or word choices to 6 improve the clarity.
7 Technical considerations, we found a 8 number of different areas where there may have been --
9 you know, we raised some flags or some of our 10 reviewers raised some flags relative to what was being 11 expected or required. And whether or not that was 12 above and beyond what might be needed to demonstrate, 13 you know, the reasonable assurance of public health 14 and safety.
15 And then also too, we were looking for 16 anything that resembled new requirements. And if we 17 saw anything that looked like a new requirement, at 18 least from our perspective, to flag that and suggest 19 that a basis -- a technical basis for justification be 20 provided along with that.
21 MEMBER MARCH-LEUBA: And Mark, what is the 22 status of your recommendations? Are you satisfied 23 with the way the staff handled your recommendations?
24 Or just thank you very much and come back in?
25 MR. RICHTER: Right. Well you know, as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 indicated by really all of the staff that presented 2 today, that we're just in the beginning of a process.
3 I'm encouraged by the fact that, you know, coming in 4 here today, I'm already hearing that, you know, some 5 of the -- I guess some of the low hanging fruit has 6 already been picked up. I think there's more 7 substantial things that probably will take more work, 8 maybe greater collaboration with Industry to develop 9 an understanding of what some of our perspectives are.
10 But I think in terms of your question, the status, 11 it's early in the process. But I think some of the 12 work, you know, it's evident it's already underway.
13 MEMBER MARCH-LEUBA: So you see a path 14 forward for --
15 MR. RICHTER: I see movement in the right 16 direction. The path I think will be better defined as 17 we go further along and maybe dig into some of the 18 more --
19 MEMBER MARCH-LEUBA: I see some of those 20 like reasonable assurance is in the eye of the 21 beholder.
22 MR. RICHTER: Sure. Yeah.
23 MEMBER MARCH-LEUBA: Those are not low 24 hanging fruit like --
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38 1 more difficult to resolve. Others, you know, maybe 2 address more simply.
3 MEMBER MARCH-LEUBA: But you're at least 4 not completely unhappy.
5 MR. RICHTER: No, not at all as of today.
6 I see, you know --
7 MEMBER MARCH-LEUBA: Thank you.
8 MR. RICHTER: -- that those comments have 9 been taken to heart and they're working on addressing 10 them, so that's all good.
11 CHAIR BALLINGER: In looking at -- We may 12 be getting ahead of ourselves a little bit, at least 13 I may, but in looking at your slides, I've read -- you 14 know, I see what you're getting at. But I didn't see 15 a slide that said here are the key points of 16 difference that need to be resolved. In other words, 17 the real -- if there are any real substantive issues 18 where there's a difference that we really need to talk 19 to each other more carefully about.
20 MR. RICHTER: Yeah. What I plan to do at 21 the end when I close our portion of the presentation 22 is really speak a little bit to the white paper that 23 we've heard mentioned here a couple times. Not so 24 much to contrast that or present it in a way that it 25 shows differences. But more in a way where it shows NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 opportunity to improve the regulatory framework and 2 increase efficiency in the review. Better use of 3 resources across the whole Agency, not just in this 4 particular area.
5 SO you know, if you look at the comments 6 we have preceding that, I don't know that I can sit 7 here and say one is potentially more important or more 8 impactful than another because even a simple 9 interpretation of a word or a phrase, while on the 10 surface, looks insignificant, could lead to a pretty 11 impactful conclusion. So to your point, I don't have 12 a listing that sort of ranks by priority; most 13 important, somewhat important, and --
14 CHAIR BALLINGER: But you're operating 15 under the previous NUREGs anyway.
16 MR. RICHTER: Yes. Yes. Okay, let's see.
17 Where am I? The slides caught up with my paper. As 18 I mentioned earlier, you know, in each of the four 19 areas or categories of comment, we tried to provide 20 some examples. Certainly not meant to be an 21 exhaustive or an exclusive list, but merely examples 22 of the types of things that were identified. And has 23 been mentioned, you know, in the previous 24 presentation, some of those have been addressed or are 25 in the process of being addressed. But if you look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 NUREG 2216, it in many ways is an integration of other 2 documents into a single document.
3 And again, this integration presents an 4 opportunity to improve review efficiency. But there's 5 some things that couldn't be done structurally with 6 the document and how it's organized to facilitate the 7 review and some of those are listed here. One is a 8 list of the supporting Reg guides and NUREGs. That's 9 been provided in Section 2, but it seemed to be absent 10 in the other sections. And I know this was created in 11 a modular fashion. But you know, I think there's an 12 opportunity there to replicate the good practices from 13 one chapter to the next in terms of, you know, how the 14 supporting information is detailed. We think that not 15 only will help the reviewers, but it will also help 16 licensees in preparation of any documents that they 17 submit. It will be a handy reference to put some of 18 those things together.
19 MEMBER REMPE: On the first bullet, you 20 kind of skipped over it.
21 MR. RICHTER: Oh, I'm sorry.
22 MEMBER REMPE: I was going to ask why on 23 earth -- what difference does it make? You have a Reg 24 Guide 7.9. They reference it throughout the SRP. Why 25 does it -- you know, they said they're going to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 updating it. Why is it so important to have it as an 2 appendix in this document? And if they do what Jose 3 is suggesting, they could update it in a modular 4 fashion. But it's guidance.
5 MR. RICHTER: Right.
6 MEMBER REMPE: It's not part of the SRP.
7 Why was that so important?
8 MR. RICHTER: Well again, it's identified 9 as an example of the type of thing that could be 10 addressed in organization. You know, certainly we 11 don't lay this out as a mandate for the staff that you 12 must do this. You know, this represents some of the 13 comments that we received. Some of our members felt 14 was important --
15 MEMBER REMPE: But why was it important is 16 what I'm asking? I don't see why it's important to 17 have it as part of this.
18 MR. RICHTER: You know, I think -- and I'm 19 now speaking on behalf of others clearly, but I think 20 it's really for sake of continuity and completeness.
21 Others that may be new to the business will read this.
22 It may help their understanding of how you got to 23 Point B from Point A historically. It's a matter of 24 reference.
25 MEMBER REMPE: Well it is sited in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 document.
2 MR. RICHTER: Is it in a technically 3 important sense? Probably not to your point. But 4 from sort of a comprehensive approach, some people 5 thought it would be important to have that. Are we 6 good? Next slide.
7 Okay, there were a number of examples 8 throughout the NUREG where there were some undefined 9 or nonspecific terms. For example, words like 10 accurately or correctly appear. You know, from our 11 perspective, they have the potential to be subjective 12 and to lend themselves to different interpretation by 13 different people. You know, what does accurately 14 mean? What does correctly mean? So that's something 15 that we wanted to bring attention to.
16 Then also too, in particular a number of 17 our members flagged the interpretation of the word 18 "reasonable" at least in the context of cladding 19 degradation and high burn-up fuel. So you know, we 20 see there's an opportunity for NRC and the National 21 Labs maybe to work collaboratively to help put better 22 definition on that. That's kind of a suggestion 23 maybe, more for future work than for the editing and 24 revising of the draft. But I wanted to put that out 25 there also as another example of an opportunity to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 improve clarity.
2 CHAIR BALLINGER: Well you used the word 3 "vastly". What does vastly mean? You know, like a --
4 When you say "vastly", different interpretations. To 5 me that means a very, very large difference between 6 one person's opinion and another. I thought there was 7 an actual number of the fraction of fuel that could be 8 breached or something like that. There was actually 9 some number of inches or something like that. That 10 there was actually a number. Is Darrel here?
11 MR. RICHTER: Oh, in terms of the --
12 CHAIR BALLINGER: Am I reading something 13 very different?
14 MR. RICHTER: Is that the 1 square 15 millimeter that you're referring to?
16 CHAIR BALLINGER: There were some numbers 17 associated with that. So I don't know how that can be 18 interpreted as different.
19 MR. DUNN: So there is guidance. It's in 20 ISG-1 --
21 CHAIR BALLINGER: Yeah.
22 MR. DUNN: -- Revision 2.
23 CHAIR BALLINGER: Yeah.
24 MR. DUNN: It talks about what is and what 25 is not damaged cladding.
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44 1 CHAIR BALLINGER: Yeah.
2 MR. DUNN: And so cladding that has a pin 3 hole or a hairline crack can be considered intact. If 4 it's greater than a pin hole or a hairline crack, it's 5 considered damaged. And that's the definition that's 6 in ISG-1, Revision 2.
7 CHAIR BALLINGER: Okay.
8 MR. DUNN: And I think that would be the 9 basis for --
10 CHAIR BALLINGER: So really after you got 11 the damaged, right, cladding degradation -- Okay, I 12 thought there was ten inches or something like that.
13 I thought I read a number somewhere. Maybe I'm just 14 -- if you don't know --
15 MR. DUNN: I think that -- I'm pretty sure 16 that -- isn't that for -- I think it's not for the 17 definition. I think that's for a different analysis.
18 CHAIR BALLINGER: Okay, all right. I'm 19 just mistaken then.
20 MEMBER MARCH-LEUBA: Just for the record, 21 you need to tell the court reporter your name.
22 MR. DUNN: Okay, this is Darrell Dun from 23 NRC.
24 CHAIR BALLINGER: I mean I look at -- you 25 know, I look at that bullet and I say now there's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 difference. But if the cask is leak tight, does it 2 matter? Does it change the source term? Does it 3 change anything?
4 MR. RICHTER: Well, you know -- and I 5 think some of the questions that you pose sort of get 6 at the heart of some of the questions, we've from the 7 Industry, think about as well. You know, at what 8 level do these things matter? Or at what point do 9 they matter rather? And at what point do they not?
10 So these are the kinds of things that we're hoping to 11 address going forward. And also again with the white 12 paper which has probably been mentioned now 37 times 13 today. And we'll hear a few more times before we're 14 done, I think.
15 Okay, next slide. Okay. Yeah, 16 utilization of general comments. You know, one of the 17 things that we've identified is statements along the 18 lines of reviewers should verify. And that term is 19 typically used in a context of calculations that have 20 been made within an NRC-approved QA program. And by 21 definition really shouldn't have any mistakes or 22 errors.
23 And we're concerned that -- at least we 24 have the impression at times that reviewers spend a 25 lot of time and resources seeking what appears to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 independent verification of model results that have 2 been generated by models within an approved QA 3 program. And that, you know, diverts resources and 4 time away from other activities or other areas. And 5 again, we really think that the focus needs to be on 6 doing what needs to be done to provide reasonable 7 assurance. And to do anything beyond that is not 8 necessarily in keeping with principles of good 9 regulation.
10 MEMBER REMPE: So I agree with you that 11 the staff should focus on risk important issues. But 12 I think it's a bit naive to say just because someone 13 has an NRC approved QA program, there shouldn't be any 14 errors.
15 I keep thinking about the AP when -- well, 16 another design center which had an established, I'm 17 sure, NRC approved QA program. But people make 18 mistakes and somebody made a change in one part of the 19 design and didn't tell someone in a different part of 20 the design with the NRC approved QA program. And 21 perhaps the Control Room didn't have enough shielding.
22 Okay? So maybe that comment should be interpreted as 23 they should focus on risk important issues, instead of 24 saying just because you have an approved QA program, 25 there shouldn't be errors. It just seems naive to --
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47 1 MR. RICHTER: Well, again, this is an 2 example, not meant, you know, to exclude other 3 examples or identified as the only one. But this is 4 an area that we can point to that -- you know that we 5 would say to your point, focus on what's, you know, 6 important of being risk-informed as opposed to other 7 things.
8 MEMBER REMPE: Right. Yeah, it's just 9 maybe talk to whoever provided the comment that they 10 ought to think about what they're saying.
11 MR. RICHTER: Well, I'm sure -- I 12 understand what they're saying. And you know, I don't 13 want to misquote them or mischaracterize their intent.
14 But you know, from their perspective, I believe, you 15 know, they had basis for making that -- expressing 16 that kind of concern. So we wanted to use that as an 17 example. Again, it's not to be treated as "the 18 example", just an example.
19 MEMBER REMPE: Okay.
20 CHAIR BALLINGER: The second bullet, I 21 just have a problem with there being a conflict. I 22 mean you've got a reviewer that's reviewing an 23 application. His or her job is to ensure that there's 24 an expectation of reasonable assurance. Beyond that 25 is too far. But that person's job is to check things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 out. So I just don't see a conflict.
2 MR. RICHTER: Well --
3 CHAIR BALLINGER: Maybe I'm just 4 misreading something.
5 MR. RICHTER: No, I follow your question.
6 And I appreciate where you're coming from with that.
7 I think from the Industry perspective, it's -- you 8 know, at what point do you continue to invest 9 resources in evaluating differences -- maybe 10 differences in models, differences between models, and 11 measured results. Where in the differences are still 12 well within the margins of a particular measurement 13 that you're looking at.
14 CHAIR BALLINGER: Well that's not 15 inconsistent. I mean that's different from the second 16 bullet, is it not?
17 MR. RICHTER: In what way? I think I lost 18 your question.
19 CHAIR BALLINGER: Well the reviewer is 20 simply trying to verify that what the applicant says 21 is correct. And now I agree -- I would agree 22 personally that pushing it to an absurd level is not 23 the right thing to do --
24 MR. RICHTER: Right.
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49 1 reasonable assurance.
2 MR. RICHTER: Correct.
3 CHAIR BALLINGER: Okay.
4 MR. RICHTER: And that may be a better way 5 to state the point that we're trying to make that, 6 that's -- I think you're hitting it pretty closely.
7 CHAIR BALLINGER: Okay.
8 MEMBER MARCH-LEUBA: Again, this is a 9 subcommittee meeting and this is not the ACRS 10 position's, but members opinions. But I think you're 11 not making yourself a favor with these examples. When 12 I'm reading that the reviewer should not be encouraged 13 to verify the analysis in search of errors, I cannot 14 possibly agree with that statement. The reviewer 15 should be encouraged categorically to review it for 16 errors. And that's what their job is. So maybe 17 you're using the wrong language and you mean something 18 else. But if you keep sending those comments to the 19 staff, you're not going to go anywhere. And you 20 shouldn't go anywhere.
21 MR. RICHTER: No, I appreciate the 22 comment. I think --
23 MEMBER MARCH-LEUBA: I think it means 24 something else.
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50 1 little more closely with the way he characterized it.
2 So I'll take that advise and we'll --
3 MEMBER MARCH-LEUBA: Okay. You're --
4 (Simultaneous speaking.)
5 MR. RICHTER: -- address a little 6 differently than --
7 MEMBER MARCH-LEUBA: I mean, the staff is 8 not going to take you seriously when you say something 9 like that. I mean I don't take you seriously.
10 MR. RICHTER: Okay. Well, I appreciate 11 the feedback. Thanks. All right.
12 Okay, a couple of technical examples that 13 we flagged. One, dealing with high burn-up fuel. You 14 know, by our read collectively, you know, we thought 15 that there's an implication that high burn-up fuel is 16 somehow different than other spent fuel. And as such, 17 requires special treatment. So you know, with that in 18 mind, there's a couple of questions that we've 19 identified that we think need to be answered if that 20 is indeed the case.
21 You know? Is it more susceptible to 22 breaking and shifting of low burn-up fuel? If not, 23 then is there a distinction that's really necessary?
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51 1 in terms of if there was a distinction, what is the 2 basis for some of the distinctions that are made?
3 MEMBER MARCH-LEUBA: Does the Industry 4 have any basis for saying it's not?
5 MR. RICHTER: I'm sorry?
6 MEMBER MARCH-LEUBA: Do you have any basis 7 for saying HBU -- high burn-up units of fuel -- is not 8 more susceptible to breakage than low burn-up fuel?
9 If you have such data, then you can provide it to the 10 staff.
11 MR. RICHTER: Right.
12 MEMBER REMPE: Like why are you doing the 13 high burn-up demo if you have such data? I mean --
14 MR. RICHTER: I understand the point, but 15 I think what the Industry folks were suggesting was 16 that -- if we're going to hang our hat on a 17 distinction, then there should be some basis for 18 saying that in the document.
19 MEMBER MARCH-LEUBA: Well the basis is --
20 I have the suspicion as a regulator that hey, 21 something that has been for 12 years inside a reactor 22 is probably more brittle than something that is new.
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52 1 the safety of the public. So unless you have data 2 that says it is not, I don't see a path forward.
3 MR. RICHTER: Okay.
4 MEMBER MARCH-LEUBA: But you probably are 5 right that those fuel limits are gas -- I mean they're 6 10 percent less strong than the other ones. And 7 that's 10 percent is not verified. But unless we have 8 data, we cannot do it.
9 MEMBER REMPE: Maybe after the high burn-10 up demo is done and if they ever get to examine the 11 fuel out of it, they'll have a reason to revise it.
12 MR. RICHTER: Yeah. So your counterpart 13 really is just as valid. I mean we're asking for the 14 basis for distinction. And the challenge is, while we 15 are in a position to provide that distinction as well 16 for the same basis that we're asking for.
17 MEMBER MARCH-LEUBA: Yeah, but your point 18 is valid. It points towards the research area or DOE 19 to --
20 MR. RICHTER: Right. Yeah, questions that 21 are unanswered basically is I guess maybe the best way 22 to characterize that. Questions that remain to be 23 answered.
24 CHAIR BALLINGER: I think the 45,000 is 25 arbitrary.
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53 1 MEMBER MARCH-LEUBA: Absolutely.
2 CHAIR BALLINGER: I mean that is 3 arbitrary.
4 MR. RICHTER: Right. Okay, then another 5 example that would fall into the technical category by 6 our categorization has to do with credit for soluble 7 boron. You know, our readers thought that was a 8 restriction on where credit may be taken for soluble 9 boron in the proposed document. While the ISG that 10 was pointed to in creation of the NUREG doesn't appear 11 to contain any such restriction. So you know, if 12 we've missed the point --
13 MEMBER MARCH-LEUBA: So let me ask the 14 staff, are you guys familiar with ISG-8? Because if 15 ISG-8, Rev 3 did not contain a restriction for soluble 16 boron, my personal opinion is it should have. So 17 maybe it's an error. But do you guys have an opinion?
18 MR. SMITH: For the soluble boron, you 19 know, we've been looking at when they are loading the 20 casket to make sure that it's not a misload accident.
21 It just kind of a check to make sure that the proper 22 soluble boron was present in the pool when it was 23 loaded. We will look at clarifying that language a 24 little bit to make sure that there's no confusion on 25 that.
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54 1 MEMBER MARCH-LEUBA: If it's during the 2 loading, one can take credit for operator monitoring 3 and ensuring that you do have the boron salt in there.
4 If it's during transportation where it's been out of 5 your eyes, then you cannot over ten years.
6 MR. RICHTER: That's correct.
7 MEMBER MARCH-LEUBA: So there might be a 8 distinction in my opinion. When you have eyes on the 9 borated water, you may take credit for it. But over 10 long term, boron plates, it operates, god knows what 11 happens.
12 MR. RICHTER: Okay, the next slide 13 addresses the requirements. And I think again not 14 anticipating or understanding what I was going to hear 15 when we put this together, I think a lot of the items 16 that have been laid out here are in the process of 17 being addressed if I'm not mistaken. So there's 18 really not --
19 CHAIR BALLINGER: Each one of them 20 actually.
21 MR. RICHTER: So there's really not --
22 I'm sorry, what was that?
23 CHAIR BALLINGER: Each one of them 24 actually.
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55 1 all the comments to make sure that we provide 2 appropriate responses.
3 MR. RICHTER: So we're very pleased that 4 the staff has been so quick to respond to some of our 5 comments. And I won't invest really any more time 6 talking about these at this point. So you know, 7 revision is underway to address those.
8 So as we move towards conclusion here, 9 there's some recommendations that sort of are 10 overarching here that kind of capture a lot of what 11 we've been talking about by example. One of course 12 being identifying reference and supporting documents.
13 Being able to point to them clearly in the text of the 14 NUREG if it makes sense to do that. That's really 15 just to help a licensee, as well as the reviewer be 16 able to get to the appropriate section or the 17 appropriate document that supports part of the review 18 guidance. Looking to clarify any ambiguities or lack 19 of specificity in certain terms and statements, you 20 know, knowing that it's not a perfect world and the 21 language itself isn't perfect. It's almost impossible 22 to avoid all subjectivity, but you know, do what can 23 be done to minimize that.
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56 1 requirements to only that which is necessary to 2 demonstrate reasonable assurance. Again, if there are 3 new requirements or something different in the way of 4 a technical directive that's down in the body of this 5 document, you know, we would ask that a basis or a 6 compelling technical argument be provided to kind of 7 support that or give the reviewer, as well as the 8 licensee a better understanding of the what and why of 9 a particular activity that's required.
10 And then one of the things here that 11 again, I want to spend a little bit of time just 12 reviewing is the white paper we submitted back on 13 November the 8th, defining spent fuel performance 14 margins. We think that there's a lot of potential 15 there to inform the NUREG. Not just now, but also 16 going forward many opportunities there. And I just 17 wanted to pass along a few thoughts on that before I 18 wrap up.
19 You know, right now we've talked about 20 conducting business under the current regulatory 21 framework. And while it may be debatable to the 22 degree of which it's inefficient or burdensome, I 23 think to the point that there's incentive to create 24 NUREG-2216, clearly there's a desire on the part of 25 staff to be more efficient in the regulatory framework NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 and process as that reduces the burden not only to 2 themselves, but to Industry as well. And do it in a 3 way that is consistent with principles -- NRCs 4 principles of good regulation.
5 Dry storage and transportation cask 6 licensing processes are resource intensive and time 7 consuming, especially now in light of what we believe 8 are pretty high levels of safety and low risk 9 significance in the activities around what are 10 addressed in 2216. And some of the detail that's 11 required in the licensing documents requires licensees 12 and the cask vendors themselves to submit a large 13 number of license amendment request for what could be 14 relatively simple design changes. And you know, we 15 think in many cases, these changes have negligible if 16 any impact on safety. And the concern from our 17 standpoint is that both Industry and NRC resources are 18 diverted from some more safety significant activities.
19 And your point, Joy, that's risk informing. You know, 20 putting your resources where they matter.
21 And you know, we can put some numbers on 22 the degree of this problem for the Certificate of 23 Compliance holders, as well as the staff. If you look 24 back over the last 25 years, I believe there are 15 25 NRC approved dry storage certificates of compliance.
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58 1 Those have been amended 74 times. Preparation of the 2 amendments requires between two and nine months of 3 effort on the certificate holders part. And 4 potentially one to three years of review at NRC staff 5 level.
6 In a few cases, it's actually taken longer 7 than three years. The process itself typically 8 involves a couple of rounds of requests for additional 9 information. Staff can also issue requests for 10 supplemental information and request for 11 clarification. And for most of these, usually you're 12 looking at one to two dozen RAIs. And many of those 13 RAIs have many subparts. And the concern there is it 14 gets back to reasonable assurance. To what degree do 15 some of these things need to be assessed and broken 16 down in order to provide that level of reasonable 17 assurance without going overboard or going over the 18 top, you know, as we pointed to earlier.
19 So you know, with that in mind, we know 20 the process is important. And we know it takes time.
21 But there's a degree to which there may be some 22 unnecessary delays that could be avoided or minimized, 23 you know, if we take a closer look at the processes 24 and inform them based on the actual risk which is one 25 of the things that we hope the white paper puts some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 light on and actually begins a discussion. You know, 2 it's certainly not the answer. It's the beginning of 3 a discussion that will lead to you know, we hope 4 better information and some answers relative to some 5 of the margins that actually exist. And that's not 6 only true just you know, for away from reactive 7 storage sites, but operating plants are also impacted 8 by this as well.
9 You know, you have operating plants that 10 every time you make a change to the approved content 11 section of the Certificate of Compliance, you know, 12 for fuel type or heat loading requirements, you could 13 find yourself in a situation where there are identical 14 casks at the same storage facility that are loaded 15 under different amendments. So some of our numbers 16 indicate to us that it's not unusual for a single 17 ISFSI, a single dry storage facility to have somewhere 18 between two and seven distinct and different sets of 19 licensing documentation. And site specific 20 calculations for casks that are essentially identical 21 in design.
22 CHAIR BALLINGER: So are you suggesting a 23 50.59 like process?
24 MR. RICHTER: Potentially. I mean that 25 could be a model. Yeah, and just following along the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 thought here about new amendments. It takes about six 2 months to a year of utility and vendor effort to put 3 that together. And again, it's part of a very 4 engaging and time consuming process where the impact 5 of safety may not be relevant because there may be no 6 real impact for the changes that are made. And I 7 think we gain a lot of valuable information with the 8 Orano pilot project on the graded approach as an 9 example of the types of things that can be done under 10 the auspices of the licensees or certificate holders 11 and program, you know, outside of formal NRC review.
12 MEMBER MARCH-LEUBA: Mark, for my 13 education, describe a little bit what you mean by a 14 license amendment. Is it any time you add a new cask 15 or is it when you have a new type of cask or when you 16 reach a limit of the cask that you would authorize.
17 When do you issue an LAR? Give me an example.
18 MR. RICHTER: Yeah. No, no, I think --
19 and I may ask the staff to help out here. But I think 20 the three examples you provided, all of those would be 21 possibilities for a licensed amendment.
22 MEMBER MARCH-LEUBA: If I want to add one 23 more cask of the same type once I'm already licensed, 24 do you do any in LAR? You need to say it to the 25 microphone.
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61 1 MR. WHITE: I'm sorry. Bernie White, 2 Division of Spent Fuel Management. For storage cask, 3 which is what he's talking about, if you have -- if 4 you're loading a cask that's built under Amendment 2 5 and you order two more casks under Builder Amendment 6 2, you do not need to send anything to NRC for a 7 license amendment or a certificate amendment as we 8 would call it. Because it's already approved for what 9 you're going to load. If you have a fuel assembly or 10 decay heat or something like that, that's outside the 11 bounds of what we have approved in the certificate, 12 then one would.
13 MEMBER MARCH-LEUBA: So if they're loading 14 a different type of cask --
15 MR. WHITE: Right. Right.
16 MEMBER MARCH-LEUBA: -- that is not 17 approved --
18 MR. WHITE: Right.
19 MEMBER MARCH-LEUBA: -- they need to do an 20 LAR.
21 MR. WHITE: Right. And we do have a set 22 of 50.59 equivalent in Part 72. It's 72.48. We don't 23 have it in transport, which is what the SSRP is about.
24 And there are reasons why we don't have it in 25 transport.
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62 1 MEMBER MARCH-LEUBA: On the transport, 2 there is something equivalent to a licensee --
3 operating license for transport?
4 MR. WHITE: No, we have a Certificate of 5 Compliance for the design just like we do for storage.
6 MEMBER MARCH-LEUBA: And then once they 7 have the certificate for this cask, they can ship 8 1,000 --
9 MR. WHITE: You can do as many of them as 10 you want. As long as they meet the design, you can 11 make as many shipments as you want as long as they 12 meet the design.
13 MEMBER MARCH-LEUBA: So you just have to 14 certify for the limiting condition --
15 MR. WHITE: Right.
16 MEMBER MARCH-LEUBA: -- and don't do it 17 again.
18 MR. RICHTER: Yeah. The 50.59 type 19 process that you asked about, that's really the 72.48 20 process that is embodied in NEI's 1204 Guidance 21 Document, which is in the process of -- the most 22 current Revs in the process of endorsement. So 23 Industry would have, you know, the opportunity to use 24 that as a model for that process -- the updated 25 revision, which I think is coming out sometime in 2020 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 -- early 2020, I think from what we've heard recently.
2 MR. RAHIMI: Can I --
3 MR. RICHTER: Sure.
4 MR. RAHIMI: Meraj Rahimi, Division of 5 Fuel Management at NRC. I think what Mark listed here 6 in terms of there are 72 different amendments, you 7 know, these are in the context of storage. I think 8 all this talk was in the context of storage casks.
9 Which we have already embarked on this. This is what 10 is in the technical specification, specific heat load 11 patterns that is approved. And any time the licensee 12 wants to put sort of a fuel with a different heat load 13 -- they want to change the heat load pattern, that's 14 what he's referring to. They have to come in for an 15 amendment.
16 MEMBER MARCH-LEUBA: You probably mean an 17 increased heat load pattern.
18 MR. RAHIMI: No, the heat load pattern --
19 No, given the same heat load, there's a specific heat 20 load pattern that, you know, you put in, in you know, 21 internal because the top peak clad temperature is 22 calculated based on the pattern. Even the heat --
23 MEMBER MARCH-LEUBA: So the loading of the 24 cask --
25 MR. RAHIMI: The loading pattern, that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 right.
2 MEMBER MARCH-LEUBA: So you have a 3 different radial distribution?
4 MR. RAHIMI: That's right. So I think 5 that's what Mark is referring to.
6 MEMBER MARCH-LEUBA: Is there no way to 7 bound that so you don't have to do it again?
8 MR. RAHIMI: That's right. I mean you 9 could -- we also have said that the -- I mean you 10 could come in with you know, a 2D analysis for 11 different combination per mutation of heat load 12 pattern. And yeah, provide that. And that's --
13 Actually it is sort of a subject of a topical report 14 that has been submitted by one of the vendors now, 15 specifically a method and approach that we can review 16 and approve --
17 MEMBER MARCH-LEUBA: In operating plants, 18 when you load a new core, you don't necessarily issue 19 a license amendment as long as you use approved 20 methods.
21 MR. RAHIMI: That's right.
22 MEMBER MARCH-LEUBA: So what you're saying 23 we're missing here is a topical report that tells you 24 the procedure that we follow. And as long as the 25 follow-up procedure and the criteria is satisfied, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 don't have to look at it?
2 MR. RAHIMI: That's right. That is the --
3 currently you know, a topical report that we just 4 received -- that we haven't received yet, that they 5 have to talk with us. But on the graded approach, 6 it's another effort that we are doing in terms of 7 okay, all these things that were put on Tech Spec.
8 Anytime they're outside of Tech Spec, of course they 9 have to come in --
10 MEMBER MARCH-LEUBA: Sure.
11 MR. RAHIMI: -- for amendment. So is 12 there any way you know, to come up with a bounding way 13 that the -- not to tie them down?
14 MEMBER MARCH-LEUBA: Yeah, but there are 15 two ways. Either you do a bounding calculation where 16 you demonstrate that your new cask has a better power 17 distribution than the old one -- than the bounding one 18 or you have an approved methodology that he has to 19 follow.
20 MR. RAHIMI: Right.
21 MEMBER MARCH-LEUBA: And approved criteria 22 that he's satisfied and he's within that, yes, that's 23 when I load fuel in my plan -- operating plan. I 24 don't have to contact you.
25 MR. RAHIMI: That's right.
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66 1 MEMBER MARCH-LEUBA: I just inform you 2 what I'm doing.
3 MR. RAHIMI: Yeah. I mean this -- I mean 4 the applicant, they're free, you know, to do that --
5 come up with a bounding analysis, not specific to the 6 you know, heat load pattern.
7 MEMBER MARCH-LEUBA: Yeah, it doesn't mean 8 to be bounding. What I'm saying is in operating 9 plants, I have approved topical reports that tell me 10 how I analyze a LOCA.
11 MR. RAHIMI: Yeah.
12 MEMBER MARCH-LEUBA: And as long as I 13 follow the methodology and my temperature is below 14 2200 Fahrenheit, I'm okay.
15 MR. RAHIMI: Yeah.
16 MEMBER MARCH-LEUBA: I don't have to 17 change the license. Is this not what happening here?
18 Is this a case by case basis?
19 MR. RAHIMI: Yeah. I mean most of the 20 time, I mean they look at, you know, their customers 21 -- the cask vendors for this specific site. They say 22 okay, this is the sort of total decay heat. You know, 23 they have 45 kilowatts. So they sort of set the 24 design based on total kilowatt and the kilowatt per, 25 you know, cell. And they do the analysis. They say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 okay, this is the loading pattern and also the dose --
2 the dose calculation comes into play with that, you 3 know, loading pattern. And that's when they analyze 4 for. But yes, I mean they can similarly you know, 5 come in -- I mean look at the you know, different 6 combination, not specific to the specific pattern as 7 long as, you know, they demonstrate they meet the dose 8 limit. They meet the peak clad temperature limit, 9 they're fine.
10 MEMBER MARCH-LEUBA: Yeah, but do they 11 need to send you the calculations and you need to 12 review them and sign them on the SAR?
13 MR. RAHIMI: No, if they haven't done 14 that, right. If it's the original -- if it was 15 approved for a specific heat load, yes, you know, they 16 have to come in. But what I'm saying is that they 17 don't -- I mean they have the freedom of you know, 18 doing all different combination and do the analysis.
19 And that's how the Tech Spec can be written. And they 20 don't have to come in.
21 MEMBER MARCH-LEUBA: I guess I'm a little 22 confused then. I mean, I see room for improvement.
23 MR. RAHIMI: Yes, certainly. I mean we'll 24 discuss that with the Industry.
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68 1 think the bounding calculation on the one hand sounds 2 appealing because you can do a -- create a large 3 boundary that includes a lot of different combinations 4 within that. But then you start infringing upon some 5 of the -- some of the efficiencies that you hope to 6 gain by being able to make some of these decisions on 7 your own without having to come back in with a formal 8 process. You know, there are some things that you 9 know, we believe we should be able to change without 10 seeking some approval or concurrence to do that. And 11 you know, that gives the licensee flexibility in 12 equipment they can load, what they load, how they load 13 it. It gives them some latitude. And if the bounding 14 captures everything, then you start giving up some of 15 the flexibility that you hope to seek by achieving 16 some independence, you know, using risk informed 17 approaches like we're talking about here.
18 MEMBER MARCH-LEUBA: Yeah.
19 MR. RICHTER: I mean there's probably 100 20 different examples you could name, but --
21 MR. RAHIMI: I mean you're right. I mean 22 you start losing the efficiency because generally the 23 cask vendors, they try to maximize the pay load --
24 optimize the pay load.
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69 1 you and I'm certainly no expert or not familiar with 2 this topic, all I hear is we'll hit the limits. We'll 3 hit the limits. We'll hit the limits. I mean if the 4 limit is 400 degrees or 300 degrees, we're getting at 5 298 all the time. Because you want to load as many as 6 you can.
7 MR. RAHIMI: That's right. You want to 8 load as many as -- especially on the decommissioning.
9 I mean they're loading two year cooled fuel.
10 MEMBER MARCH-LEUBA: Well I see the room 11 for improvement is follow the line that we use -- the 12 staff uses for breaking reactors where you license a 13 process that they must follow with -- I mean you have 14 to use the codes this way. You have to calculate this 15 criteria. And this is how you do the calculation.
16 And as long as you're below the criteria, you just 17 send me the results and I don't need to sign. I mean 18 that's how operating plans work.
19 MR. RAHIMI: Right.
20 MEMBER MARCH-LEUBA: They have their 21 methods in Tech Specs that follow them. They don't 22 have to call for an LAR error.
23 MR. RAHIMI: I agree. I agree. Yeah, 24 that's --
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70 1 for a 72.48 process for transportation. Is that what 2 you're arguing for back and forth here?
3 MR. RAHIMI: No.
4 CHAIR BALLINGER: No?
5 MR. RAHIMI: No, this was the most 6 comments was in the context of Part 72 of the 7 efficiency -- I think he's talking about it with 8 respects to Part 72.
9 MR. RICHTER: Right.
10 CHAIR BALLINGER: Well I can tell you that 11 there are at least nine revisions to the CoC for the 12 HOLTECH-Hi-STORM 100. And I can tell you that there 13 are at least 14, I think I remember it right, for the 14 UMAX. So the CoC amendments, there's a lot of them.
15 MR. RICHTER: Right. Yeah and maybe I 16 didn't set this up as well as I could have. But you 17 know, a lot of the examples I had -- what we're 18 talking about here, the 74 different amendment 19 requests and so forth, that's true. It's all in the 20 context of Part 72. But to that point and the white 21 paper helps to address this. There are a lot of 22 opportunities to look at some of those conservatisms 23 that have been identified and to the degree that we 24 can look at that and apply it to what we're doing in 25 transportation, we want to be able to have that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 conversation.
2 I'm not saying it's a one for one mapping 3 of 72 into 71. But there's a lot of opportunity that 4 we've identified looking at storage that you may be 5 able to leverage. It may be the seed of the next good 6 idea, you know, for Part 71 or for transportation. So 7 you know, I don't want to maybe oversell, you know, 8 what we have in the white paper. Oversell what we've 9 learned from looking at a 72 perspective. But only to 10 suggest that we believe that there's probably a lot of 11 opportunity there as well for transportation, just 12 like we've found in storage. And you know, there's 13 details, you know, to be developed. But you know, I'm 14 hoping we're at the very front end of a long dialogue 15 here to sort this out with staff and Industry.
16 MR. RICHTER: I think I'll conclude there 17 because I think we've really talked around this final 18 slide and what this is really all about. So to sit 19 here and regurgitate four bullet points probably isn't 20 going to add any value. But I think the discussion 21 was good. And I think it kind of gets to what we're 22 trying to do, which is improve efficiency and identify 23 opportunities to do that based on margin.
24 MEMBER REMPE: Well since we're way ahead 25 of schedule and while we're just opining on this white NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 paper -- I actually pulled it up. I had not seen it 2 before this meeting. It wasn't provided to us. What 3 is the next step? Are you going to try and have a 4 pilot project? I mean it's going to take -- if you 5 did this, it will take a while for the staff to find 6 a way to implement it --
7 MR. RICHTER: Yes.
8 MEMBER REMPE: -- and it will cost money 9 for the staff, as well as the Industry. With the 74 10 LARs, they've got a path forward. So you know, 11 they've got a system that works. And to change it, 12 yeah, it ought to be changed. Everybody agrees to 13 this. But is it going to be cost-effective? And how 14 do you -- What's the next step? And again, this is 15 way beyond the discussion today. But I'm just 16 curious. It's good to throw rocks.
17 MR. RICHTER: It's interesting you asked 18 the question because I got an email this morning 19 before I came up here for this meeting from someone 20 from Andrew Cook's staff trying to schedule and set up 21 an initial workshop between staff and Industry to have 22 that exact discussion. You know, how do we take 23 action? You know, how do we begin to approach some of 24 the recommendations? You know, what can we take care 25 of quickly? What's going to take, you know, more time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 and resources? So early next year, we're going to 2 have that initial meeting. You may have more detail 3 on that than I do, Meraj, so if can add to that.
4 MR. RAHIMI: Yeah, we did receive the 5 white paper. And we're responding with the letters by 6 December 20th to NEI, what the next step would be.
7 And I think what NEI -- they presented the white paper 8 at the public meeting that we had about a week ago as 9 part of the Part 72 rule making. And a series of the 10 workshop is being discussed at this point because that 11 was the NEI's suggestion. You know, we agreed in term 12 of the -- as he's listed, there are four specific 13 technical areas that these recommendations touch on; 14 source term, criticality, you know, safety, fuel 15 qualification. And what NEI has specifically sited, 16 the margin, you know, basically they say there is too 17 much margin in there. For example, boron credit in 18 BORAL. Why are you limiting us to 75 percent credits?
19 You know, why not 90 percent? Why not 100 percent?
20 I mean there has been, you know, 21 historical data based on that because of non-uniformed 22 distribution of the ten for criticality safety. So we 23 have to go back. I mean there is, you know, 24 supporting data from 20 years ago. You know, why does 25 staff, you know, have that position? So we agreed to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 really discuss and touch on these specific areas where 2 we see what was reasonable or is too conservative, we 3 can reconsider these positions. And that is what --
4 that's what paper is really focused on. And also the 5 bigger picture in terms of the -- how you could take 6 the pilot -- we're about to finish these risk 7 informing the Tech Spec. Taking a lot of stuff from 8 the Tech Spec that really doesn't have that safety 9 significance, putting in the FSAR. And that's another 10 area of discussion in terms of how you can apply that 11 approach to other designs.
12 So as Mark mentioned, there's 16 13 recommendations in this white paper. And there are 14 about four of them -- this is what Industry -- they 15 believe they can do now on their own. There are three 16 specific recommendations that the NRC, which is 17 regarding risk informing. And there are 16 other --
18 there are nine other recommendations -- seven or nine 19 other recommendations more long-term like the peak 20 clad temperature, why 400? What is the basis? And 21 then what happens if you go, you know, beyond 400? So 22 those specific areas. And we agree, we can -- I think 23 that's basically what the response is going to be.
24 MR. RICHTER: Right. And I think 25 everyone, at least between Industry and staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 recognize that a lot of the requirements that exist 2 now in current regulation were based on as much a lack 3 of specific knowledge 30 years ago as what we're 4 trying to do now based on new and current knowledge 5 that's going to inform, you know, a new regulatory 6 framework. You know, because absent knowledge -- what 7 do you do to be safe? You just add more margin just 8 to be sure. Right?
9 So now, you know, with the benefit of 10 history and better analysis over the last several 11 decades, you know, Industry thinks it's time to maybe 12 look again. And see if we can do something that 13 aligns with the staff's need to provide the reasonable 14 assurance and the Industry's desire to be more 15 efficient. And somewhere those trajectories ought to 16 cross.
17 MEMBER REMPE: There were some interesting 18 recommendations in there. But I just am wondering how 19 -- maybe you can get the low hanging fruit first and 20 do something that increases efficiency for everyone.
21 And then try and deal with some of the others.
22 MR. RICHTER: I think we're on the very 23 front end of that process, trying to --
24 MS. DIAZ: This is Yoira Diaz from 25 Division of Fuel Management. I just want to amplify NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 what Meraj said with regards to this white paper. The 2 question that you, Joy, asked about what is the cost 3 benefit of going through all these recommendations.
4 And what is the level of effort we're going to put in 5 getting things done is the same question that we asked 6 NEI to explain to us what is the cost benefit of doing 7 any of these recommendations.
8 As you said, there are things in there 9 that are low hanging fruits that we can implement 10 tomorrow if we want to -- or the Industry can 11 implement tomorrow if they want to. But we're more 12 concerned about the long-term ones is how much we're 13 going to get in terms of efficiencies from the long-14 term recommendations that NEI has submitted to us.
15 And that's a question that we will have to discuss 16 with the NEI in these workshops that we're going to 17 plan to have early next year.
18 MEMBER REMPE: Okay, it will be 19 interesting. Thank you.
20 MEMBER MARCH-LEUBA: But without doing the 21 exercise, my guess is if they went into the trouble of 22 writing those recommendations in the white paper, it's 23 because they think it's worth it to them. They've 24 already run the cost benefit in their mind. So of 25 course it would be maybe other than in cost of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 implementing, this is the benefit you get. Now not 2 the cost to you to transport it. But can we do it in 3 six months unless it takes six years? And I'm going 4 to start with the six month one. And I'm just 5 targeting something.
6 MR. RICHTER: Yeah. And to your point, 7 the cost benefit I think has been intuitively 8 addressed, you know, by the suppliers and some of the 9 licensees. You know, maybe they haven't put numbers 10 on it. But intuitively they know, you know, we're 11 doing this and it takes this much time. It costs this 12 much money. But if we make these changes, we know it 13 will take less time, cost less money, we'd be more 14 efficient, et cetera, et cetera. The next step is you 15 quantify it and try to put some numbers on it to 16 demonstrate it.
17 MEMBER MARCH-LEUBA: My point is the cost 18 you considered -- was this cost of shipping this cask 19 from here to Nevada. NRC needs to consider is the 20 cost it will take to get that modification in place.
21 So even if you can save that much on Recommendation 22 No. 13, but if it can be done in a week, that's the 23 one I would vote for. So there are two costs. The 24 cost you would save when you transport it and the cost 25 it's going to take for the staff to get on board and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 be able to agree with you. And that second course, I 2 don't think you have considered. So during the 3 workshop, you should consider that cost.
4 MR. RICHTER: Good point. Thank you.
5 CHAIR BALLINGER: Well it's been 6 constructive. And I mean that specifically, I think 7 it's been constructive. Are there any other -- Are 8 you all finished?
9 MR. RICHTER: I would just like to maybe 10 follow up to your comment about this being 11 constructive. I'm not sure that my portion of the 12 presentation ended the way I anticipated that it 13 would.
14 CHAIR BALLINGER: I'm being subjective.
15 MR. RICHTER: I understand. I am too.
16 But I think it went in a direction that I think was 17 positive. You know, it allowed us -- gave us a forum 18 to discuss some of these other things. And kind of 19 get them out a little bit more in the open. And you 20 know kind of put some detail on it for those that are 21 maybe a little bit newer to some of the issues. And 22 I only see good coming from it. I've taken some notes 23 here that I'm going to carry back in terms of how we 24 characterized certain things. I'm sure staff has 25 taken notes as well maybe with you know, help inform NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 their understanding of our perspective on things. So 2 I think, you know, as we heard into January, we both 3 will come in a little better off than we were prior to 4 today because we had this discussion. So for that, I 5 appreciate the opportunity.
6 CHAIR BALLINGER: I think we now need to 7 get public comments. If there's anybody in the room 8 now that would like to make a comment. It looks a 9 little sparse. Is the public line open? Is there 10 anybody -- members of the public out there that would 11 like to make a comment? Not hearing any static, I'm 12 afraid that it's a dead line. Either that or we're 13 just too good for a change.
14 MEMBER MARCH-LEUBA: We're in a different 15 room. This one seems to work.
16 CHAIR BALLINGER: Oh, okay. Okay, not 17 hearing any, by way of information, the staff is not 18 interested in a letter. This was for information 19 only. And we have not scheduled a full committee 20 meeting. But that is not my call. That's the call of 21 the members of this subcommittee. And I'm a little 22 bit embarrassed -- actually a lot embarrassed that 23 there's only three of us here. So what do you think?
24 MEMBER REMPE: I assume in you're asking 25 what I think is whether do we need to have a letter on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 this --
2 CHAIR BALLINGER: Yes. No, no, they don't 3 want a letter --
4 (Simultaneous speaking.)
5 MEMBER REMPE: -- is that what you're 6 asking?
7 CHAIR BALLINGER: -- but it's up to us.
8 MEMBER REMPE: Yeah. I don't have any 9 burning comments that would make it worthwhile to have 10 a letter. So that's fine with me. I am interested in 11 how this white paper moves forward with the staff.
12 And so I hope when the staff has a good feeling about 13 what they think they're going to do or not do, they'll 14 come back and let us know. I think that the issue of 15 spent fuel in the U.S. is an important issue that 16 needs to be addressed in the area of Nuclear. And the 17 U.S. has not been making much progress over the years.
18 So I would like to hear back from you all.
19 CHAIR BALLINGER: We'll just keep getting 20 informed.
21 MEMBER REMPE: Yeah.
22 CHAIR BALLINGER: Jose?
23 MEMBER MARCH-LEUBA: I'll second Joy's 24 opinion. If the staff does not need a letter, I don't 25 see writing a positive letter will make anything NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 1 positive. So we will only write one if we have 2 something negative to say. And I don't have anything 3 negative to say. So I recommend not to write it.
4 MEMBER REMPE: However, we don't make 5 decisions on our own. So you'll need to discuss this 6 at P&P.
7 MEMBER MARCH-LEUBA: Right. I think we 8 do. Typically we recommend the thing of the 9 subcommittee.
10 MEMBER REMPE: Ron can come at P&P and say 11 hey, we had this subcommittee meeting and the 12 subcommittee members did not think a letter was 13 necessary. And then we vote.
14 MEMBER MARCH-LEUBA: Yeah.
15 MEMBER REMPE: Because again, we aren't 16 empowered on our own.
17 MEMBER MARCH-LEUBA: Yeah, you're more 18 familiar with our bylaws than I am.
19 MEMBER REMPE: I'm getting more and more 20 familiar with them than I thought I would ever have to 21 be.
22 MEMBER MARCH-LEUBA: Typically we ask this 23 question of our subcommittee and everybody says yes, 24 we should have a letter because they're asking for 25 one. This is the first time I've had this question NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 asked whether we don't need a letter.
2 CHAIR BALLINGER: We could push this out 3 to 5:00 if we really want to.
4 MEMBER REMPE: I don't think so.
5 CHAIR BALLINGER: Bring in pizza or 6 something like that. But absent of burning desire to 7 continue, we are adjourned. Thank you.
8 (Whereupon, the above-entitled matter was 9 concluded at 2:41 p.m.)
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ACRS Subcommittee Briefing on Draft NUREG-2216 the Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material SRP Team Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission December 3, 2019
Outline
- Background
- Goals
- Approach
- Public comments
- Summary 2
=
Background===
- Recognized the need to consolidate the Transportation Standard Review Plans (SRPs)
- Transportation SRPs issued in 1999/2000
- NUREG-1609, Standard Review Plan for Transportation Packages for Radioactive Material
- Supplement 1, Standard Review Plan for Transportation Packages for MOX-Radioactive Material
- Supplement 2, Standard Review Plan for Transportation Packages for Irradiated Tritium-Producing Burnable Absorber Rods (TPBARs)
- NUREG-1617, "Standard Review Plan for Transportation Packages for Spent Nuclear Fuel
- Supplement 1, Standard Review Plan for Transportation Packages for MOX-Spent Nuclear Fuel 3
Background - continued
- Interim Staff Guidance (ISGs) documents were issued to assist in implementing changes to Part 71 and emergent issues
- Improved the structure for the SRP
- Similar to NUREG-0800 structure
- Modular chapters 4
Goals
- Maintain the safe and secure transportation of radioactive materials
- Increase efficiency of reviews
- Minimize/eliminate the use of ISGs
- Improve efficiency of future revisions
- One SRP for all transportation package review guidance 5
Approach
- Formed an internal NRC team consisting of staff from all technical disciplines
- Consolidated the review guidance found in NUREG-1609 and NUREG-1617
- Incorporated the MOX and TPBAR Supplements
- Incorporated ISGs and other technical guidance
- Updated figures and references to regulations related to review areas 6
Technical Staff Updates
- NUREG-2216 does not introduce new staff positions on technical issues
- Incorporates staff review experience and practice for consistency of review
- Technical chapters were updated to consolidate all current transportation guidance
- Added two new chapters
- Materials
- Quality Assurance 7
Public Comments
- Four public comment letters were received
- NEI
- ORANO
- HOLTEC
- Anonymous
- NUREG-2216 and Regulatory Guide 7.9, Standard Format and Content of Part 71 Applications for Approval of Packages for Radioactive Material need to be made consistent
- Formatting of the SRP or editorial comments
- Some public comments requested additional guidance; a need for new guidance would be considered in future revisions
- Many out of scope for this consolidation effort
- Other changes and clarifications 8
Chapter 2: Structural
- Added ISG-1, Rev. 2, Damaged Fuel
- Added ISG-21, Use of Computational Modeling Software
- Public comments were varied in scope
- Simple corrections
- Clarifications
- New information beyond scope of consolidation
- An example was to include statistical deviation in structural characteristics and accident evaluation ranges 9
Chapter 3: Thermal
- Content was reorganized to align with current review practices
- Added ISG-7, Potential Generic Issue Concerning Cask Heat Transfer in a Transportation Accident
- Added ISG-21, Use of Computational Modeling Software
- Regulatory language was clarified
- Very minor edits were necessary to address public comments 10
Chapter 4: Containment
- Added Table 4-1 showing the relevant regulations for each review area
- Added NRC Information Notice 2016-04, ANSI N14.5-2014 Revision and Leakage Rate Testing Considerations
- Changes of editorial nature
- Clarified terminology and discussions 11
Chapter 5: Shielding
- Clarifies certain review topics throughout SRP
- Added ISG-6. Establishing Minimum Initial Enrichment for the Bounding Design Basis Fuel Assembly(s)
- Added ISG-21, Use of Computational Modeling Software
- Minor edits or clarifications based on public comments
- Some new methodologies proposed by public, but were beyond the scope of this consolidation 12
Chapter 6: Criticality
- Brought the SRP up to the current Part 71 regulations
- Transport Index (TI) is replaced with
- Criticality Safety Index (CSI) and
- Transport Index
- Added ISG-8, Rev. 3, Burnup Credit in the Criticality Safety Analyses of PWR Spent Fuel in Transport and Storage Casks
- Incorporated ISG-19, Moderator Exclusion Under Hypothetical Accident Conditions and Demonstrating Subcriticality of Spent Fuel Under the Requirements of 10 CFR 71.55(e)
- Added ISG-21, Use of Computational Modeling Software 13
Chapter 7: Materials
- Added chapter to provide review guidance
- NUREG-1609 and NUREG-1617 did not have a materials chapter
- Integrated guidance from ISGs
- Minor edits or clarifications based on public comments 14
Chapter 7: Materials - continued Materials Evaluation chapter incorporates information from the following interim staff guidance (ISG) documents:
- ISG-1 Revision 2: Classifying the Condition of Spent Nuclear Fuel for Interim Storage and Transportation Based on Function
- ISG-11 Revision 3: Cladding Considerations for the Transportation and Storage of Spent Fuel
- ISG-15: Materials Evaluation
- ISG-22: Potential Rod Splitting due to Exposure to an Oxidizing Atmosphere During Short-Term Cask Loading Operations in LWR or Other Uranium Oxide Based Fuel
- ISG-23: Application of ASTM Standard Practice C1671-07 when performing technical reviews of spent fuel storage and transportation packaging licensing actions 15
Chapter 10: Quality Assurance
- Added chapter to:
- Provide review guidance for package applications that contain a QAPD
- Content is similar to NUREG-2215
- Provides additional guidance for applications that reference a previously approved QAPD
Summary
- NUREG-2216 is a consolidation of existing staff guidance
- The new SRP does not introduce new positions by staff
- Comments from the public indicated areas where additional clarification may be needed 17
Backup Slides 18
Interim Staff Guidance
- SFST-ISG-1, Revision 2 Damaged Fuel
- SFST-ISG-2, Revision 2 Fuel Retrievability
- SFST-ISG-3 Post Accident Recovery and Compliance with 10 CFR 72.122(l)
- SFST-ISG-4, Revision 1 Cask Closure Weld Inspections
- SFST-ISG-5, Revision 1 Confinement Evaluation
- SFST-ISG-6, Establishing Minimum Initial Enrichment for the Bounding Design Basis Fuel Assembly(s)
- SFST-ISG-7, Potential Generic Issue Concerning Cask Heat Transfer in a Transportation Accident
- SFST-ISG-8, Revision 3 Burnup Credit in the Criticality Safety Analyses of PWR Spent Fuel in Transport and Storage Casks
- SFST-ISG-9, Revision 1 Storage of Components Associated with Fuel Assemblies
- SFST-ISG-10, Revision 1 Alternatives to the ASME Code
- SFST-ISG-11, Revision 3 Cladding Considerations for the Transportation and Storage of Spent Fuel
- SFST-ISG-12, Revision 1 Buckling of Irradiated Fuel Under Bottom End Drop Conditions
- SFST-ISG-13, Real Individual
- SFST-ISG-14, Supplemental Shielding
- SFST-ISG-15, Materials Evaluation
- SFST-ISG-16, Emergency Planning 19
Interim Staff Guidance
- SFST-ISG-17, Interim Storage of Greater Than Class C Waste
- SFST-ISG-18, Revision 1 The Design and Testing of Lid Welds on Austenitic Stainless Steel Canisters as the Confinement Boundary for Spent Fuel Storage
- SFST-ISG-19, Moderator Exclusion Under Hypothetical Accident Conditions and Demonstrating Subcriticality of Spent Fuel Under the Requirements of 10 CFR 71.55(e)
- SFST-ISG-20, Transportation Package Design Changes Authorized Under 10 CFR Part 71 Without Prior NRC Approval
- SFST-ISG-21, Use of Computational Modeling Software
- SFST-ISG-22, Potential Rod Splitting Due to Exposure to an Oxidizing Atmosphere During Short-Term Cask Loading Operations in LWR or Other Uranium Oxide Based Fuel
- SFST-ISG-23, Application of ASTM Standard Practice C1671-07 When Performing Technical Reviews Of Spent Fuel Storage And Transportation Packaging Licensing Actions
- SFST-ISG-24, The Use of a Demonstration Program as a Surveillance Tool for Confirmation of Integrity for Continued Storage of High Burnup Fuel Beyond 20 Years
- SFST-ISG-25, Revision 0 Pressure Test and Helium Leakage Test of the Confinement Boundary for Spent Fuel Storage Canister 20
Part 71 Background
- DOT regulates
- carriers (road, rail, air, etc)
- Import and export of radioactive material
- packages for small quantities of radioactive material - Type A Packages
- NRC
- Regulates Domestic Type B and Type A Fissile Packages
- Technical Review & Recommendation to DOT on Revalidation of Foreign Packages
- Lead agency for inspection of NRC holders of Certificates of Compliance, fabricators, licensee shippers and carriers 21
Part 71 Background (2)
Part 71 Table A-1A1 and A2 Values for Radionuclides Symbol of Radionuclides A1 (TBq) A1 (Ci) A2 (TBq) A2 (Ci)
Co-60 4.0X10-1 1.1X101 4.0X10-1 1.1X101 Cs-137 (a) 2.0 5.4X101 6.0X10-1 1.6X101 Sr-90 (a) 3.0X10-1 8.1 3.0X10-1 8.1 U (enriched to 20% or less) (g) Unlimited Unlimited Unlimited Unlimited a A1 and/or A2 values include contributions from daughter nuclides with half-lives less than 10 days.
g These values apply to unirradiated uranium only.
22
Part 71 Background (3)
- NRC Approves Package Designs - Primary safety is in package
- Part 71 contains package approval standards (performance-based regulation)
- Any licensee can use NRC-approved package
- Agreement state licensee, DOE, and international shippers also use NRC-approved packages
- Approve packages via certificate of compliance for use with General License provisions
- General licensees must use the package in the manner in which it was approved 23
Part 71 Background (4)
- Three safety functions
- Shielding
- Containment
- Subcriticality
- Margins for safety functions after tests for
- Normal conditions of transport and
- Hypothetical accident conditions
- NRC approves the package design that was evaluated
- QA Inspection for package fabrication 24
Part 71 Background (5) 25