ML20262H260

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Summary of Public Workshop with Nuclear Energy Institute on Spent Fuel Performance Margins
ML20262H260
Person / Time
Issue date: 09/24/2020
From: Tilda Liu
NRC/NMSS/DFM/MCAB
To: Christian Araguas
Division of Fuel Management
TLiu NMSS/DFM/MCAB 404.997.4730
Shared Package
ML20262H259 List:
References
Download: ML20262H260 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 24, 2020 MEMORANDUM TO: Christian Araguas, Acting Deputy Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM: Tilda Liu, Senior Project Manager Material Control and Accounting Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUBJECT:

SUMMARY

OF SEPTEMBER 9, 2020, CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS On September 9, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 1 remote public workshop with the Nuclear Energy Institute (NEI) and other industry representatives to continue dialogue on recommendations contained in the NEIs white paper on Spent Fuel Performance Margins dated November 8, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971). This workshop built upon previous held meetings and workshops including those conducted on January 22, 2020 (ADAMS Accession No. ML20028F277), March 25-26, 2020 (ADAMS Accession No. ML20106F135), April 15-16, 2020 (ADAMS Accession No. ML20126G388), June 11, 2020 (ADAMS Accession No. ML20170A355), June 23 (ADAMS Accession No. ML20197A299), and July 28, 2020 (ADAMS Accession No. ML20223A352), respectively.

During the September 9, 2020, workshop, the NRC staff and the industry discussed two NRC staff led initiatives for transforming spent fuel licensing reviews: (1) a method of evaluation in lieu of having detailed content specifications to demonstrate that a shielding design would meet the pertinent regulatory requirements, and (2) a draft internal procedure in applying risk tool for reviewing license application requests.

The following discussion materials were used by the NRC staff during the subject workshop:

  • An Alternative Approach for Licensing Spent Fuel Dry Storage Systems: Shielding Method of Evaluation (ADAMS Accession No. ML20248H381)
  • Consideration of the Method of Evaluation Approach (ADAMS Accession No. ML20248H382)
  • Draft Internal Procedure for Applying Risk Tool in License Application Request (ADAMS Accession No. ML20248H556)

The following discussion material was used by the industry during the subject workshop:

CONTACT: Tilda Liu, NMSS/DFM/MCAB 404-997-4730

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  • NEI/Industry Input for September 9 Technical Workshop (ADAMS Accession No. ML20248H363)

During the September 9, 2020, workshop, the NRC staff shared a draft document entitled, An Alternative Approach for Licensing Spent Fuel Dry Storage Systems (DSS): Shielding Method of Evaluation (MOE), with the industry, for information and discussion purposes, and to facilitate the discussion. The NRC staff emphasized that the information provided in the subject draft document was solely for the purpose of further exploring the feasibility of an MOE approach, and outlined a number of MOE related considerations including required documentations for supporting design certification(s). In response, the industry shared its inputs with the NRC staff, including its understanding of the proposal on the MOE approach related to shielding, and the associated graded acceptance review process involving license application requests. In preparation for the upcoming joint tabletop efforts between the NRC staff and the industry, NEI mentioned that it plans to provide the NRC with an example application to facilitate the staffs review of the MOE approach.

Finally, the NRC staff summarized the workshop by sharing a detailed listing of technical topics related to the NEIs November 8, 2019, white paper. The summary chart listed requested regulatory products, and associated milestones for the NRC and the industry. The NRC staff and industry continued to refine project plans and identify next steps for enhancing spent fuel storage licensing.

At the end of the workshop, the NRC staff provided an opportunity for the members of the public to comment or ask questions regarding NRCs regulatory process related to the topics discussed, and there was one question raised by a member of the public during this comment period. Because the question topic raised by the respective member of the public was outside the scope of the meeting, and the staff experts were not present to address the question, the NRC staff requested the member of the public email the request for an NRC response.

More than 30 individuals from industry, vendor groups, public citizens, and NRC staff attended the workshop (some participating in portions only) via Skype and telephone bridge line. The discussions held during this workshop benefited both the NRC staff and industry representatives, as they provided an effective and efficient forum of communication for all parties involved. No NRC staff decision was made during the meeting. contains the meeting agenda for the September 9, 2020, workshop, as previously posted in the NRCs public meeting notice (ADAMS Accession No. ML20234A732). Enclosure 2 lists those who participated in the September 9, 2020, remote public workshop. Enclosure 3 provides the detailed meeting summary for the workshop. Enclosure 4 is a summary table which the NRC staff shared with the industry during the workshop.

Enclosures:

1. Meeting Agenda
2. List of Participants
3. Meeting Summary
4. Summary Table: September 9, 2020, Workshop on Spent Fuel Performance Margins

ML20262H259 (package); ML20262H260 (cover letter)

OFFICE NMSS/DFM/STLB:LA NMSS/DFM/MCAB:PM NMSS/DFM:DD NAME SFigueroa TLiu CAraguas DATE 9/22/2020 9/ 22/2020 9/24/2020 MEETING AGENDA CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS September 9, 2020 Time Topic Speaker 2:00 p.m. - 2:10 p.m. Introductions/Opening Remarks NRC/NEI 2:10 p.m. - 2:55 p.m. Open Discussion on Tabletop Strategy for Alternative NRC/NEI Approach to Conducting Shielding Reviews 2:55 p.m. - 3:40 p.m. Open Discussion on Future plans to Walkthrough NRC/NEI Applications of Risk Tool for Spent Fuel Storage Licensing Reviews 3:40p.m. - 3:55 p.m. Opportunity for Public to Comment All 3:55 p.m. - 4:00 p.m. Summary and Closing Remarks NRC/NEI Enclosure 1

LIST OF PARTICIPANTS CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS September 9, 2020 Name Affiliation Christian Araguas Nuclear Regulatory Commission (NRC)

Andrew Barto NRC Alana Bell NRC Tanner Boone NRC Michel Call NRC Richard Chang NRC Donald Chung NRC Christian Jacobs NRC Paul Kallan NRC Andrea Kock NRC Zhian Li NRC Tilda Liu NRC Timothy McCartin NRC John McKirgan NRC Christopher Regan NRC Jeremy Smith NRC Alexis Sotomayor-Rivera NRC Ricardo Torres NRC Veronica Wilson NRC Aladar Csontos Electric Power Research Institute Stefan Anton Holtec International Sven Bader Public George Carver Public Glenn Schwartz PSEG Nuclear Kim Manzione Public Zita Martin Tennessee Valley Authority - Holtec Rodney McCullum Nuclear Energy Institute (NEI)

Rick Migliore Public Robert Quinn Public Mark Richter NEI Tom Tramm Centrec/IUG Keith Waldrop Public Enclosure 2

MEETING

SUMMARY

CATEGORY 1 PUBLIC WORKSHOP ON SPENT FUEL PERFORMANCE MARGINS September 9, 2020 On September 9, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 1 remote public workshop with the Nuclear Energy Institute (NEI) and other industry representatives to continue dialogue on recommendations contained in the NEIs white paper on Spent Fuel Performance Margins dated November 8, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971). This workshop built upon previous held meetings and workshops including those conducted on January 22, 2020 (ADAMS Accession No. ML20028F277), March 25-26, 2020 (ADAMS Accession No. ML20106F135), April 15-16, 2020 (ADAMS Accession No. ML20126G388), June 11, 2020 (ADAMS Accession No. ML20170A355), June 23 (ADAMS Accession No. ML20197A299), and July 28, 2020 (ADAMS Accession No. ML20223A352), respectively.

During the September 9, 2020, workshop, the NRC staff and the industry discussed two NRC staff led initiatives for transforming spent fuel licensing reviews: (1) a method of evaluation in lieu of having detailed content specifications to demonstrate that a shielding design would meet the pertinent regulatory requirements, and (2) a draft internal procedure in applying risk tool for reviewing license application requests. The staff and industry continued to refine project plans and identify next steps for enhancing spent fuel storage licensing. As a result of the workshop, the participants aligned on detailed problem statements for the associated recommendations, planned regulatory products, and next steps.

After the opening remarks, the NRC staff shared a draft document entitled, An Alternative Approach for Licensing Spent Fuel Dry Storage Systems (DSS): Shielding Method of Evaluation (MOE), with the industry, for information and discussion purposes. The NRC staff expressed that it is considering the possibility of accepting an MOE in demonstrating that a spent fuel dry storage system shielding design meets 10 CFR 72.236(a) and (d), in lieu of having detailed contents specifications in technical specifications. In particular, following the risk-informed regulatory guidance provided by the Commission, the NRC staff is looking into if and how an MOE could be specified so that there is a balance between adequate design control and flexibility for the certificate holder and general licensee to make changes following the rules of 10 CFR 72.48. The NRC staff emphasized that the information provided in the subject draft document was solely for the purpose of further exploring the feasibility of an MOE approach, and outlined a number of MOE related considerations including required documentations for supporting design certification(s).

In response, the industry shared its inputs with the NRC staff, including its understanding of the proposal on the MOE approach related to shielding, and the associated graded acceptance review process involving license application requests. Specifically, the NEI expressed that a clearer description and characterization of the anticipated review process involving an MOE would support its ability to provide meaningful examples, and to test them in a walk-through or table-top scenario. In addition, the industry highlighted its understanding of the NRCs grading review process, which assigns varying levels of a license application review, based on risk insights, from the time it is initially received. The NEI further indicated that the proposed review process would provide an opportunity for the industry to pre-screen the license application Enclosure 3

based on the review process and suggest an initial grade to the NRC to inform consistent understanding of the license application.

As previously discussed during the July 28, 2020, workshop, the NRC staff and NEI plan to conduct joint tabletop exercises by utilizing industry-provided examples to evaluate the effectiveness and efficiency of the new processes. During the September 9, 2020, workshop, in preparation for the upcoming joint tabletop efforts between the NRC staff and the industry, NEI mentioned that it plans to provide the NRC with an example application to facilitate the staffs review of the MOE approach. Furthermore, the industry pointed that it plans to observe the NRCs use of the new review process, participate in comparisons of the relevant results, and inform its revisions to the review processes prior to the final implementation currently scheduled for 2021.

Finally, the NRC staff summarized the September 9, 2020, workshop on Spent Fuel Performance Margins by sharing a detailed listing of technical topics related to the NEIs November 8, 2019, white paper. The summary chart listed requested regulatory products, and associated milestones for the NRC and the industry. The staff and industry continued to refine project plans and identify next steps for enhancing spent fuel storage licensing.

At the end of the workshop, the NRC staff provided an opportunity for the members of the public to comment or ask questions regarding NRCs regulatory process related to the topics discussed, and there was one question raised by a member of the public during this comment period. Because the question topic raised by the respective member of the public was outside the scope of the meeting, and the staff experts were not present to address the question, the NRC staff requested the member of the public email the request for an NRC response.

More than 30 individuals from industry, vendor groups, public citizens, and NRC staff attended the workshop (some participating in portions only) via Skype and telephone bridge line. The NRC staff is planning future workshops to continue efforts on the NEI white paper recommendations.

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