ML20205L395

July 28, 2020, NEI Presentation on Risk Tool on Spent Fuel Dry Storage

ML20205L395
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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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©2020 Nuclear Energy Institute Rod McCullum, NEI NRC/NEI Performance Margin Workshop Risk Tool for Spent Fuel Dry Storage:

Making it Real July 28, 2020

©2020 Nuclear Energy Institute 2 Vision A world powered by clean and reliable energy Mission Promote the use and growth of nuclear energy through efficient operations and effective policy Nuclear Energy Institute

©2020 Nuclear Energy Institute 3 Industry Strategic Focus NATIONAL NUCLEAR ENERGY STRATEGY Appropriately value nuclear generation Create sustainability via improved regulatory framework and reduced burden

Innovate, commercialize, and deploy new nuclear Compete globally PRESERVE SUSTAIN INNOVATE THRIVE

©2020 Nuclear Energy Institute 4 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 begin in 2023-2024 Timeframe Work on permanent repository (Yucca Mtn.) on indefinite hold The imperative of dry storage efficiency - I

• As of June 2020

• • ISFSI = Independent Spent Fuel Storage Installation

©2020 Nuclear Energy Institute 5 The imperative of dry storage efficiency - II Status Plant Current Owner Current NRC Licensee License/Ownership Transfer Plants that have completed decommissioning but still have used fuel stored on site Rancho Seco SMUD SMUD Yankee Rowe Yankee Atomic Yankee Atomic Maine Yankee Connecticut Yankee Trojan Portland GE PGE 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 Plants* that have permanently shut down and entered decommissioning Humboldt Bay Pacific G&E PG&E San Onofre 1,2,&3 SCE SCE Crystal River Duke/ADP Duke/ADP Duke plant owner/licensee, ADP spent fuel owner/licensee & plant licensed operator 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 Plants that have announced intent to enter decommissioning Duane Arnold NextEra NextEra Indian Point 3 Entergy Entergy Pending to Holtec 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)

©2020 Nuclear Energy Institute 6 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

©2020 Nuclear Energy Institute 7 NUREG-1536 as Prologue - I NUREG-1536 Prioritization Process

©2020 Nuclear Energy Institute 8 NUREG-1536 as Prologue - II Proposed Risk Tool NUREG-1536 Appendix B

©2020 Nuclear Energy Institute 9 NUREG-1536 as Prologue - III The Devil is in the

©2020 Nuclear Energy Institute 10 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)?

NUREG-1536 as Prologue - IV

©2020 Nuclear Energy Institute 11 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

©2020 Nuclear Energy Institute 12 from the 1/23 NEI/NRC Margins Workshop

©2020 Nuclear Energy Institute 13 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 Where to Next?

©2020 Nuclear Energy Institute 14 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 licensees?

©2020 Nuclear Energy Institute 15 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 What will Next look like to NRC?