ML20282A299
| ML20282A299 | |
| Person / Time | |
|---|---|
| Issue date: | 12/04/2020 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| SJG1 | |
| Shared Package | |
| ML20282A290 | List: |
| References | |
| DG-3055 | |
| Download: ML20282A299 (5) | |
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REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-3055 Implementation of Aging Management Requirements for Spent Fuel Storage Renewals
- 1. Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering issuing a new regulatory guide (RG) to provide additional guidance to the industry for complying with and implementing the requirements for spent fuel storage renewals in Title 10 of the Code of Federal Regulations (10 CFR) Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste. This new guidance would address the format and content of renewal applications, and implementation of aging management programs (AMPs) associated with renewal of specific licenses for independent spent fuel storage installations (ISFSIs) and certificates of compliance (CoCs) for spent fuel storage cask designs in 10 CFR 72.42, Duration of license; renewal and 10 CFR 72.240, Conditions for spent fuel storage cask renewal, respectively.
Based on lessons learned from reviews of storage renewal applications and input received from the public and industry, the NRC identified a need for clear guidance on storage renewals. The NRC held public meetings with industry and other stakeholders to discuss NRC and industry plans to develop this guidance on April 23, 2014, July 14 and 15, 2014, and July 29, 2015. In response to stakeholder input, NRC developed NUREG-1927, Revision 1, Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel, in June 2016 (ADAMS Accession No. ML16179A148).
In parallel with NRC efforts, the Nuclear Energy Institute (NEI) developed industry guidance in NEI 14-03, Format, Content and Implementation Guidance for Dry Cask Storage Operations-Based Aging Management, to complement the NRC guidance in NUREG-1927 and provide specific guidance to industry in the preparation of storage renewal applications and implementation of AMPs.
Subsequently, the NRC proposed to develop a RG to endorse NEI 14-03, Revision 2 (ADAMS Accession No. ML16356A204), with clarifications. This RG would provide the industry with staff positions on the format and content of storage renewal applications and implementation of AMPs in order to comply with NRC regulations. NEI submitted a letter of support for the NRCs approach (ADAMS Accession No. ML19192A141).
- 2. Objective The objective of this regulatory action is to provide industry with guidance on the format and content of storage renewal applications and implementation of AMPs. The guidance would provide a method to demonstrate compliance with the requirements for spent fuel storage renewals in 10 CFR 72.42 and 10 CFR 72.240. This RG would endorse NEI 14-03, Revision 2, with clarifications. The NRC determined that this RG would provide acceptable guidance for industry use in preparing storage renewal applications and implementing AMPs.
The guidance would provide an operations-focused approach to storage aging management. Operating experience would be shared through an industry-developed database
called the ISFSI Aging Management Institute of Nuclear Power Operations Database (AMID).
The guidance also provides a framework for learning AMPs through the use of tollgates, which is a structured approach for assessing operating experience and data from applicable research and industry initiatives.
It is expected that the guidance would facilitate efforts by licensees and CoC holders to submit storage renewal applications that are reasonably consistent in format and content, thereby increasing the efficiency of NRCs reviews of the applications. In addition, the guidance would encourage licensees to share and assess operating experience through the use of AMID and provide flexibility for licensees to change AMPs over time to respond to operating experience, to ensure the effectiveness of aging management activities in the period of extended operation and continued safe storage of spent fuel.
- 3. Alternative Approaches The NRC considered the following alternative approaches:
- 1. Do not issue DG-3055.
- 2. Issue DG-3055.
Alternative 1: Do Not Issue DG-3055 Under this alternative, the NRC would not issue new guidance. This alternative is considered the no-action alternative and provides a baseline condition from which any other alternatives would be assessed. If NRC does not take action, there would not be any changes in costs or benefit to the public, licensees, CoC holders, or the NRC.
However, the no-action alternative would not address the identified need for clear NRC staff positions on the format and content of storage renewal applications and implementation of AMPs, including sharing and assessing aging operating experience to determine what changes are needed to AMPs so that they continue to be effective at managing aging effects on ISFSIs and spent fuel storage casks throughout the period of extended operation. Licensees and CoC holders would continue to prepare their storage renewal applications, per 10 CFR 72.42 or 10 CFR 72.240, respectively, and the NRC would continue to review the applications. However, the consistency in applications that the guidance would facilitate would not be fully realized to allow the benefit of efficiency gains in NRCs review.
Alternative 2: Issue DG-3055 Under this alternative, the NRC would issue DG-3055, which would provide a method to demonstrate compliance with the requirements for spent fuel storage renewal in 10 CFR 72.42 and 10 CFR 72.240. The guidance would endorse NEI 14-03, Revision 2, with clarifications.
DG-3055 would provide guidance for industry on the format and content of storage renewal applications and implementation of AMPs. The guidance would also discuss the operations-focused approach to storage aging management, where operating experience is shared through an industry database and continually assessed to determine what changes are needed to AMPs to ensure their effectiveness for managing effects of aging degradation throughout the period of extended operation. By doing so, the NRC would ensure that the industry has clear guidance available in this area.
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The staff anticipates the impact on the industry of implementing the new guidance would be minimal and would be the voluntary costs of reviewing the issued RG and the NEI 14-03, Revision 2 guidance. The impact to the NRC would be the costs associated with preparing and issuing the RG. The impact to the public would be the voluntary costs associated with reviewing and providing comments to NRC during the public comment period.
The value to NRC and applicants (licensees and CoC holders) would be the benefits associated with enhanced efficiency and effectiveness gained from using a common guidance document for format and content of storage renewal applications and implementation of aging management requirements. Consistency in format and content of applications would, in turn, result in a reduction in time and cost of the NRCs review of the storage renewal applications and ultimately would reduce cost to applicants as NRCs review costs are billed to applicants through the NRCs fee-billing structure. The NRC expects to gain efficiencies in terms of fewer staff requests for additional information, reduction in NRC staff application review hours, and less overall review time.
The NRC assessed the benefits and costs of this alternative to issue DG-3055. The NRC assessed the costs for applicants to prepare storage renewal applications and the associated costs of NRCs review of these applications, for applications expected to be submitted over the next 10 years. There are 14 renewal applications expected in this timeframe (10 CoC renewal applications, and 4 specific license renewal applications). The assessment includes costs of storage renewal applications under review and submitted in fiscal year 2020, which occurred in parallel with the development of DG-3055. These costs were included in the assessment, as the NRC staff had communicated to industry in 2019 its plans regarding endorsement of NEI 14-03.
The NRC estimated that the costs for applicants to prepare applications and the NRC hours spent reviewing applications would decrease by 20 percent. This estimate is based on staff experience with similar guidance for storage renewals and the renewal of power reactor licenses and reductions in NRC staff hours spent reviewing storage renewal applications since the issuance of NUREG-1927, Revision 1. Table 1 shows the net averted cost of issuing DG-3055 is $3.3 million, which is comprised of industry averted costs of $2.4 million and NRC averted costs of $911 thousand.
Table 1 Net Benefits (Costs) by Affected Entity of Issuing DG-3055 7 Percent Net Present Value Description (2020 dollars)
Industry NRC IMPLEMENTATION-Apply for Renewal Using DG-3055 Applicant Prepares Renewal Application for CoC and Respond to Staff Questions $1,770,000 NRC Costs of Reviewing Renewal Applications for CoCs $763,000 Licensee Prepares Renewal Application for Specific ISFSI License and Respond
$638,000 to Staff Questions NRC Costs of Reviewing Renewal Applications for Specific ISFSI Licensees $148,000 Implementation Total by Entity $2,408,000 $911,000 Net Benefits (Costs) $3,319,000 Because this analysis is based on estimates of values, the NRC conducted an uncertainty analysis to determine what variables have the largest impact on total costs and benefits.
Figure 1 identifies and ranks the key variables whose uncertainty has the largest impact on total Page 3
net benefits for this alternative. The three variables that contribute the most uncertainty in the expected benefits are as follows:
- The variable that causes the largest variation is the cost per applicant for renewal of a CoC of $1.6 million, which is the difference between $4.2 million and $2.6 million with a 90-percent confidence level.
- The variable with the second largest variation is the cost for the NRC hours to renew a CoC of $0.6 million, which is the difference between $3.6 million and $3.0 million.
- The variable with the third largest variation is the Cost Savings per Applicant for Renewal of a Specific ISFSI License (General Input) of $0.6 million (the difference between $3.6 million and $3.0 million).
Figure 1 Variables Contributing the Largest Cost Uncertainty for Issuing DG-3055 Cost per Applicant / Certificate Holder for Renewal of CoC / $2,589,032 $4,227,883 Input High NRC hours to Renew a CoC / General Input $3,037,884 $3,649,989 Input Low General Input $3,044,261 $3,647,841 Baseline = $3,318,082 2.40 2.60 2.80 3.00 3.20 3.40 3.60 3.80 4.00 4.20 4.40 Net of Benefits and (Costs) - 7%
Values in Millions ($)
Issuance of this guidance would also achieve additional qualitative benefits of maintaining the effectiveness of AMPs. In terms of effectiveness, the guidance would encourage licensees to share operating experience through the use of AMID and assess this operating experience and their AMPs over time through the use of periodic tollgate assessments. The structured tollgate assessment would provide for a licensees proactive review of the aggregate operating experience and its AMPs to determine if the AMPs continue to be effective at detecting and addressing degradation and aging, before these conditions affect the safety of the ISFSI or spent fuel storage cask. The licensees would have the flexibility to update their AMPs, within regulatory limits, over time to ensure their effectiveness in managing degradation and aging effects on ISFSIs and spent fuel storage casks throughout the period of extended operation. The AMID would provide operating experience information and a basis to support licensees future changes to AMPs. The uses of AMID and tollgates are considered key elements in ensuring the effectiveness of aging management activities in the period of extended operation and maintaining safe storage of spent fuel.
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The NRC notes that some applicants already are voluntarily using the guidance in NEI 14-03, Revision 2, to prepare their renewal applications. NRC endorsement in this RG would provide clear guidance and expectations for storage renewal applications and implementation of AMPs; the RG also may inform AMP inspections. This RG endorses guidance that describes an acceptable approach to aging management, thereby enhancing regulatory stability. The RG is not legally binding on the NRCs licensees or CoC holders and does not impose new requirements or change existing regulations.
Conclusion Based on this regulatory analysis, the NRC concludes that issuance of a new RG (Alternative 2) is warranted. This action would provide clear guidance and expectations for storage renewal applications and implementation of AMPs, including updating AMPs to respond to operating experience to ensure their effectiveness in managing effects of aging degradation throughout the period of extended operation and continued safe storage of spent fuel. The NRC estimates that issuing DG-3055 would lead to cost savings of $2.4 million for the industry by improving consistency in storage renewal applications and would result in $911 thousand in reduced application review costs for the NRC, with no reduction in safety.
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