ML20205L616
| ML20205L616 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| TLiu NMSS/DFM/MCAB 404.997.4730 | |
| References | |
| I-20-01 | |
| Download: ML20205L616 (2) | |
Text
SPENT FUEL STORAGE AND TRANSPORTATION ISSUE RESOLUTION PLAN Issue Number: I-20-01 Performance Margins Recommendations: III-3 (Cat 2), V-1 (Cat 3), V-2 (Cat 3), VI-1 (Cat 1),
VI-2 (Cat 3)
Rev. 7.23.2020 Note: This document is DRAFT and the positions noted therein are preliminary NRC staff potions. This DRAFT is being made publicly available to support discussions at a July 2020 public workshop.
Title:
Risk-informing Part 72 CoC shielding reviews I.
Summary of Resolution Plan The NRC is engaged in developing strategies to make review and approval of CoCs for spent fuel dry storage systems more efficient with respect to shielding and dose rate evaluations. The NRC staff is evaluating the following industry recommendations in in the Nuclear Energy Institutes (NEIs) Spent Fuel Performance Margin White Paper (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971) Defining Spent Fuel Performance Margins, to see if it can address the NEI concerns through its efforts:
III NRC should perform a less detailed review when conservative modeling is used V NRC should revise guidance to use representative rather than bounding dose rates V NRC should revise shielding review guidance to use industry experience showing conservatism within analyses VI NRC and industry should align fuel qualification with practice in current operating reactors VI CoC holders should amend CoCs to use the graded approach method to reduce TS volume These recommendations are related to Recommendations III-1 and III-2 in the Nuclear Energy Institutes (NEIs) Spent Fuel Performance Margin White Paper ADAMS Accession No. ML19318D971). In Recommendation III-1 and III-2, industry is exploring whether applicants could apply more realistic assumptions in their source term calculations when other conservatisms are included. As part of those recommendations, the industry will develop a conservatism roadmap to demonstrate what uncertainties are currently included in models for understanding and relative ranking based on importance.
In parallel with industrys activities on Recommendations III-1 and III-2, the NRC staff plans to identify and evaluate transformative approaches and develop review guidance based on known conservatisms and appropriate level of review within the defined source terms. The guidance would also describe how the review would consider conservatisms identified in Recommendations III-1 and III-2.
The NRC staff will lead this activity by taking the following actions. The NRC staff will seek and incorporate external stakeholder feedback (i.e., industry and public) as noted and at additional intervals as appropriate and identified during this activity.
Develop alternative licensing approaches Conduct a public workshop to discuss alternatives and receive feedback from stakeholders Use public feedback and develop draft review guidance Evaluate and incorporate, as appropriate, the specific recommendations made in Recommendations III-1 and III-2 into draft review guidance.
Pilot the approach on an appropriate application Conduct public meetings to inform and obtain feedback from the stakeholders, including the general public, the general licensees, and the cask vendors, on the potential changes in the regulating approach Conduct a public meeting(s) to present major conclusions and potential resolutions of the RIRP issues from pilot review Update NRC review guidance, as appropriate, and make revised guidance publicly available.
II.
Proposed Actions and Due Dates ACTION RESPONSIBLE PARTY DUE DATE
- 1. Develop alternative licensing strategy NRC June 23, 2020 (COMPLETED)
- 2. Conduct a public workshop to provide additional details and receive feedback from stakeholders All July 28, 2020
- 3. Incorporate feedback from stakeholders and develop draft review criteria NRC Fall 2020
- 4. Await conclusions of spent fuel performance margins white paper Recommendations III-1 and III-2, V-2.
All December 2020 (assumption)
- 5. Review results of Recommendations III-1 and III-2, and incorporate into draft review guidance to address V-2 NRC February 2021
- 6. Conduct public meeting to present revised guidance All April 2021
- 7. Select pilot application to apply risk-informed review method.
NRC/Industry May 2021
- 8. Gather lessons learned on pilot review NRC/Industry TBD
- 9. Conduct a public meeting to review lessons learn/modify approach as needed NRC TBD
- 10. Update NRC review guidance to incorporate risk insights NRC TBD
- 11. Hold public meeting on draft guidance NRC TBD
- 12. Finalize review guidance and utilize for upcoming reviews NRC TBD