ML20126G388

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April 15-16, 2020 Meeting Summary for Spent Fuel Performance Margins
ML20126G388
Person / Time
Issue date: 05/05/2020
From: Paul Kallan
NRC/NRR/DNRL/NRLB
To: Tara Inverso
Division of Fuel Management
Kallan P
References
Download: ML20126G388 (12)
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May 05, 2020 MEMORANDUM TO: Tara Inverso, Acting Deputy Director Division of Fuel Management Office of Nuclear Materials Safety and Safeguards FROM: Paul Kallan, Project Manager /RA/

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

SUBJECT:

SUMMARY

OF THE APRIL 15 - 16, 2020, CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS On April 15 - 16, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 1 public workshop with the Nuclear Energy Institute (NEI) and other industry representatives to discuss NEIs white paper on Spent Fuel Performance Margins (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971). The workshop built upon discussions held during the January 22, 2020 public workshop (ADAMS Accession No. ML20028F277) and March 25-26, 2020 public workshop (ADAMS Accession No. ML20106F135). On April 15, 2020, the meeting focused on three technical areas: dose rates, graded acceptance review process, and review approaches when Phenomenon Identification and Ranking Tables (PIRTs) are used in applications. The attendees aligned on detailed problem statements for the associated recommendations, planned regulatory products, and next steps. On April 16, 2020, representatives from the Electric Power Research Institute (EPRI) presented recommendations for future work related to gross rupture (e.g., determining the safety goal and clarifying the interpretation). Approximately 55 individuals from industry, vendor groups, public citizens, and NRC staff attended the workshop (some participating in portions only) via Skype and bridgeline. The NRC staff is planning future workshops to continue efforts on the white paper recommendations; the next will likely be scheduled in late May and June 2020.

The public workshop notices dated April 2020, can be found in ADAMS under Accession Nos.

ML20092G337 and ML20092H164. These meeting notices were also posted on the NRC public website. Enclosed is the meeting agenda (Enclosure 1), list of participants (Enclosure 2), an overview of the meeting (Enclosure 3) and a Table providing a summary of the discussion surrounding the problem statements, requested regulatory products, and next steps (Enclosure 4).

T. Inverso NRCs presentation materials are available in ADAMS:

  • Recommendation II-1 (Category II) RIRP for grading reviews: ADAMS Accession No. ML20099A149
  • Recommendations IV-2 (Category 2) RIRP: ADAMS Accession No. ML20099A154 NEIs presentation materials are available in ADAMS:
  • NEI Workshop

Introduction:

ADAMS Accession No. ML20104A589

  • Presentation on Dose Rate Recommendations: ADAMS Accession No. ML20105A002 Electric Power Research Institute (EPRI)s presentation material is available in ADAMS:
  • Gross Rupture Presentation: ADAMS Accession No. ML20106E952 In terms of next steps, the NRC is planning on conducting future workshops, as tentatively outlined below:

o Reprioritization of Thermal Recommendations, Gross Rupture, Remaining Category 3 Items (~ May 2020) o Source Term Options, Graded Acceptance Reviews (~ June 2020)

These workshops will be posted to the NRCs public meeting website in advance of each meeting date.

Enclosures:

1. Meeting Agenda
2. List of Attendees
3. Meeting Overview
4. Table CONTACT: Paul Kallan, NRR/DNRL 301-415-2809

ML20126G388 *via email NRR-106 OFFICE DNRL/NRLB/PM NRR/DRO/Special Assistant DNRL/NRLB/PM NAME PKallan TInverso* PKallan (signed)

DATE 05/05/20 05/05/20 05/05/20 U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS

PUBLIC MEETING AGENDA

April 15, 2020 Time Topic Speaker 9:00 AM Introductions/Opening Remarks NRC/NEI TBD Break (as needed Industry Presentations on Dose Rates (Recommendations V-1 and V-2): Draft 9:15 AM NEI Regulatory Issue Resolution Plans (RIRPs) 12:00 PM Break for Lunch NRC Presentation on Graded Acceptance Reviews (Recommendation II-1): Draft RIRP 1:00 PM NRC Presentation on Review NRC Approaches when PIRTs are used in an application (Recommendation IV-2):

Draft RIRP TBD Break (as needed) 3:30 PM Opportunity for Public Comment All 3:50 PM Closing Remarks NRC/NEI 4:00 PM Meeting Adjourn Enclosure 1

U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS

PUBLIC MEETING AGENDA

April 16, 2020 Time Topic Speaker 1:00 PM Introductions/Opening Remarks NRC/NEI Presentation on recommendations for future work on the interpretation and 1:10PM EPRI guidance related to gross rupture (10 CFR 72,122(h))

2:00 PM Opportunity for Public Comment All 3:50 PM Closing Remarks NRC/NEI 4:00 PM Meeting Adjourn 2

U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS LIST OF ATTENDEES April 15 - 16th, 2020 Name Organization Andrea Kock U.S. Nuclear Regulatory Commission (NRC)

Tara Inverso NRC Yoira Diaz NRC Paul Kallan NRC Donald Chung NRC John McKirgan NRC Jorge Solis NRC Meraj Rahimi NRC Joann Ireland NRC Timothy McCarthy NRC John Wise NRC Chris Bajwa NRC Haile Lindsay NRC Jason Piotter NRC April Smith NRC Brian Wagner NRC Veronica Wilson NRC Donnie Harrison NRC David Decker NRC Jimmy Chang NRC Darrell Dunn NRC David Tarantino NRC On Yee NRC Ray Kellar NRC Arlette Howard NRC Alana Bell NRC Kenneth Armstrong NRC Casper Sun NRC Brian Wagner NRC Patricia Jehle NRC Zhian Li NRC Ricardi Rodriguez NRC Ahn Tae NRC Ricardo Torres NRC Rod McCullum Nuclear Energy Institute (NEI)

Mark Richter NEI Jana Bergman Curtis Wright Tom Tramm Certrec William Szymcak Energy Solutions Enclosure 2

Aladar Csontos Electric Power Research Institute (EPRI)

Hatice Akkurt EPRI Keith Waldrop EPRI Jack Desando Exelon Michael Ford Ford ES&H Solutions Stefan Anton Holtec International Stanley Orrell INL Don Shaw TN Orano Rick Miliore TN Orano Glenn Schwartz PSEG Nuclear Paul Plante The Yankee Companies Steven Baker Transware Zita Martin TVA Robert Quinn Westinghouse Donna Gilmore Public Jan Boudart Public 2

U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS On April 15 - 16, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 1 public workshop with the Nuclear Energy Institute (NEI) and other industry representatives to discuss NEIs white paper on Spent Fuel Performance Margins (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971). The workshop built upon discussions held during the January 22, 2020 public workshop (ADAMS Accession No. ML20028F277) and March 25-26, 2020 public workshop (ADAMS Accession No. ML20106F135). On April 15, 2020, the meeting focused on three technical areas: dose rates, graded acceptance review process, and review approaches when Phenomenon Identification and Ranking Tables (PIRTs) are used in applications. The attendees aligned on detailed problem statements for the associated recommendations, planned regulatory products, and next steps. On April 16, 2020, representatives from the Electric Power Research Institute (EPRI) presented recommendations for future work related to gross rupture (e.g., determining the safety goal and clarifying the interpretation). Approximately 55 individuals from industry, vendor groups, public citizens, and NRC staff attended the workshop (some participating in portions only) via Skype and bridgeline. The NRC staff is planning future workshops to continue efforts on the white paper recommendations; the next will likely be scheduled in late May and June 2020.

In the morning session on April 15, 2020, NEI presented opening remarks for workshops on the White Paper, which included the following stated goals:

  • Maintain focus on public health and safety
  • Utilize risk principles and graded approach
  • Understand the role of margins in licensing
  • Transform NRC and industry licensing practices
  • Enable flexibility to enhance safety Industry then made a presentation on Radiation Safety and discussed proposed guidance revisions intended to focus industry and staff resources on radiological issues of highest safety significance. This presentation provided the basis for industrys recommendations V-1 and V-2 in the White Paper.

Following this presentation, NEI discussed its draft RIRP Recommendations V-1 and V-2 related to revised guidance to reflect application of realistic dose rates and modeling of dose rates to recognize operating experience from loaded dry storage systems (Recommendations V-1, V-2 (Category 3).

In the afternoon session, the NRC presented its draft RIRP on graded acceptance reviews (Recommendation II-1). The staff discussed an acceptance review grading process that would assign varying levels of review to an application based on risk insights. Next, the NRC presented its draft RIRP on review approaches when Phenomena Identification and Ranking Table (PIRT)s are used (Recommendation IV-2).

Enclosure 3

Next the NRC and industry discussed a few action items from the meeting which are as follows:

  • NEI: Share how operating experience could be presented as part of industry spent fuel licensing applications
  • NRC: Make source term options and pros/cons (in response to Recommendation III-3) publicly available before the next workshop on that topic
  • NRC: Respond to several questions related to NUREG-2152 at the next workshop, including how the NUREG is used, whether it went through a public review process, and whether the level of effort described is commensurate with the safety goal At the end of the day, the NRC staff provided an opportunity to the public to provide any comments or questions. There were no comments from the public on topics discussed at the meeting.

In the afternoon of April 16, 2020, EPRI delivered a presentation on the background and history of gross rupture. The attendees discussed the following next steps:

  • Determine safety goal for gross rupture (NRC action)
  • NRC agreed to utilize and participate in the PIRT process to define gross rupture
  • Develop actionable performance metrics to address the safety goal At the end of the meeting, the NRC staff provided an opportunity to the public to provide any comments or questions. There were four comments from the public that were that were addressed at the meeting.

2

Summary Table:

April 15-16 Workshop on Spent Fuel Performance Margins Topic Recommendation Lead Problem Statement Requested Regulatory Next Milestone (short) Product Dose Rates V-1 and V-2 NEI Explore whether changes Revisions to NUREG- ** Consider staffs work on to NUREG-1536 and 1536 and NUREG-2215. recommendation III-3 as part of path NUREG-2215 could (Note: NUREG-2215 will forward on V-1 and V-2. Merge into future enhance ways that subsume NUREG-1536.) workshop (TBD for June/July 2020)**

applicants demonstrate (and the NRC reviews)

  • Industry proposal: In Develop proposed changes to NUREG-compliance with FSAR, provide dose 2215. (Industry lead) radiological safety rates for a typical cask requirements (25 design with Provide indication of how experience-based mrem/year site at representative content. information would be presented as part of boundary, 5 rem/year per Associated analyses the application (graded review) person) establish methodology to determine site Conduct public meetings to discuss boundary dose. proposed changes and close gaps in any
  • Consider changes to areas of misunderstanding.

occupational exposure evaluations

  • Review and revise guidance on modeling, considering operating experience Graded II-1 NRC Should applications be Revisions to (or New) Develop a high-level draft grading process Acceptance assigned varying levels of Review Guidance Reviews NRC review based on Conduct a public workshop incorporated risk insights?

Pilot approach Enclosure 4

Summary Table:

April 15-16 Workshop on Spent Fuel Performance Margins Review IV-2 NRC When applicants apply the Revisions to (or New) Perform a peer review of PIRT Approaches results of a PIRT in Review Guidance implementation (once the three PIRTs when applications (via a topical (plus gross rupture) are available and PIRTS are report), should NRC limit implementation guidance is available)

Used in an its review to verifying that

  • Also - industry will revise its RIRP Application the results of the PIRT on IV-1, IV-3, IV-4, and IV-5 have been applied appropriately? Conduct a public workshop to discuss NRC NRC results of NRCs peer review develop safety goal Develop draft review guidance definition as precedent NEI will submit a letter with insights action for relative to the safety goal development.

the gross rupture definition PIRT NRC and NRC/EPRI EPRI will form a PIRT team to develop an actionable definition of gross rupture and associated fuel metrics 2

Summary Table:

April 15-16 Workshop on Spent Fuel Performance Margins Potential Future Workshop Timeline Potential Topics June/July 2020* Graded Acceptance Reviews

  • Review draft approach (if available)

Thermal Margins (IV-1 through IV-5, with the exception of IV-3)

  • Review industry updated RIRP for IV-1 through IV-5
  • Present PIRT reports
  • NRC to present safety goal with respect Gross Rupture Dose Rates
  • NRC options for source term reviews (III-3)
  • These workshops may be as early as May/June 2020.

Remaining Category 3 Items 3

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