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July 28, 2020, NEI Presentation on Risk Tool on Spent Fuel Dry Storage
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Site:	Nuclear Energy Institute
Issue date:	07/28/2020
From:	Mccullum R; Office of Nuclear Material Safety and Safeguards, Nuclear Energy Institute
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	TLiu NMSS/DFM/MCAB 404.997.4730
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Risk Tool for Spent Fuel Dry Storage:

Making it Real Rod McCullum, NEI NRC/NEI Performance Margin Workshop July 28, 2020

Nuclear Energy Institute Vision A world powered by clean and reliable energy Mission Promote the use and growth of nuclear energy through efficient operations and effective policy

Industry Strategic Focus NATIONAL NUCLEAR ENERGY STRATEGY PRESERVE SUSTAIN INNOVATE THRIVE Appropriately value Create sustainability Innovate, Compete globally nuclear generation via improved commercialize, regulatory framework and deploy and reduced burden new nuclear

The imperative of dry storage efficiency - I Used fuel inventory*

Approximately 85,000 MTU Increases 2 - 2.4k MTU annually ISFSI** storage 143,920 assemblies 41,000 MTU (48%)

3,283 casks/modules loaded 73 Operating dry storage ISFSIs Eventual deployment at 76 sites (119 reactors)

Long term commitment to ISFSIs Licenses being extended to 60 years Licenses extensions approved at 32 sites Contents will continue to evolve Transport to CIS in TX or NM could *As of June 2020 begin in 2023-2024 Timeframe ** ISFSI = Independent Spent Fuel Storage Installation Work on permanent repository (Yucca Mtn.) on indefinite hold ©2020 Nuclear Energy Institute 4

The imperative of dry storage efficiency - II Status Plant Current Owner Current NRC Licensee License/Ownership Transfer Rancho Seco SMUD SMUD Plants that have completed Yankee Rowe Yankee Atomic Yankee Atomic decommissioning but still Maine Yankee have used fuel stored on Connecticut Yankee Trojan Portland GE PGE site Big Rock Point Entergy Entergy Pending to Holtec Lacrosse Dairyland Power Energy Solutions Pending to Dairyland Power Zion 1&2 Exelon Energy Solutions Pending to Exelon Humboldt Bay Pacific G&E PG&E Plants* that have San Onofre 1,2,&3 SCE SCE permanently shut down and Crystal River Duke/ADP Duke/ADP Duke plant owner/licensee, ADP spent fuel owner/licensee & plant licensed operator entered decommissioning Kewaunee Dominion Dominion Vermont Yankee ADP ADP ADP purchase from Entergy closed 1/19 Fort Calhoun OPPD OPPD Oyster Creek Holtec Holtec Holtec purchase from Exelon closed 7/19 Pilgrim Holtec Holtec Holtec purchase from Entergy closed 8/19 Three Mile Island 1 Exelon Exelon Three Mile Island 2 FENOC FENOC License transfer to Energy Solutions pending Indian Point 2 Entergy Entergy Pending to Holtec Duane Arnold NextEra NextEra Plants that have Indian Point 3 Entergy Entergy Pending to Holtec announced intent to enter decommissioning Palisades Entergy Entergy Pending to Holtec Diablo Canyon Pacific GE PG&E

Does not include shutdown plants that are co-located with an operating reactor (Indian Point 1, Peach Bottom 1, Fermi 1, Dresden 1 & Millstone 1)

Enabling the imperative

The risk tool presented by NRC on June 23 has the potential to result in significant improvement in dry storage licensing efficiency

Realizing this potential will require:

Well defined and actionable Risk Significance Determination Criteria

Qualitative Assessment of Risk

Consistent Application of these Criteria

NUREG-1536 as Prologue - I NUREG-1536 Prioritization Process

NUREG-1536 as Prologue - II Proposed Risk Tool NUREG-1536 Appendix B

NUREG-1536 as Prologue - III The Devil is in the

NUREG-1536 as Prologue - IV Industry has little visibility on how the NUREG-1536 prioritization process has been used by NRC

What proportion of reviews were classified as High, Medium, and Low?

Was there a measurable difference in the conduct of the review between each category?

Is this difference quantifiable in terms of resources applied (NRC and Licensee)?

What does this have to do with performance margin?

If we are spending 1000 - 2000 manhours*

developing more discrete models to find a <

5 degree difference in temperature, have we sufficiently prioritized our efforts? *based on 1/23 workshop

from the 1/23 NEI/NRC Margins Workshop

Where to Next?

NRCs proposed risk tool has the potential to be an instrument of transformative change, if:

It brings real utility to the process originally envisioned in NUREG-1536

It is built on a thorough understanding of performance margin

It results in a demonstrable and transparent change in how low and medium priority licensing reviews are conducted

What will Next look like to licensees?

Will we see a difference in review scope?

Will we see a difference in review duration?

Will we see a difference in the number/type of RAIs?

Will process enable licensees to seek a specific review priority?

e.g. be visible during pre-application interactions

What will Next look like to NRC?

Safety focus will enable staff to stay ahead of growing workload associated with spent fuel storage Staff resources will be available for full scope of integrated fuel cycle NRC processes will be more transparent to stakeholders/public

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