ML21036A161
| ML21036A161 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/2021 |
| From: | NRC/OCM |
| To: | |
| References | |
| M210211 | |
| Download: ML21036A161 (13) | |
Text
Presentation of Wayne Norton 3 Yankee Companies and on behalf of the DPC:
Matters of Interest related to dry cask storage at sites that have Decommissioned or are in the process of Decommissioning
I am the President & CEO of both YA & CY and the CNO of MY - three New England single asset nuclear power companies that permanently shutdown their power plants in the 1990s and were decommissioned over the next decade.
I am also the Chairman of the Decommissioning Plant Coalition (DPC) Steering Committee.
My background includes managing all three companies in the decommissioning of their shutdown plants; transition to ISFSI only; site remediation; and ongoing ISFSI dry storage operation and maintenance.
Permanently & Announced Shutdown Nuclear Plant Sites
4 Yankee Rowe Maine Yankee Connecticut Yankee 3 Yankees Former Plant Sites
3 Yankees ISFSIs Maine Yankee ISFSI 60 Spent Fuel Dry Casks 4 GTCC Dry Casks NAC UMS System CoC Expired November 20, 2020 (timely renewal submitted)
Yankee Rowe ISFSI 15 Spent Fuel Dry Casks 1 GTCC Dry Cask NAC MPC System CoC Expired April 10, 2020 (timely renewal submitted)
Connecticut Yankee Yankee Rowe Maine Yankee Connecticut Yankee ISFSI 40 Spent Fuel Dry Casks 3 GTCC Dry Casks NAC MPC System CoC Expired April 10, 2020 (timely renewal submitted) 5
Decommissioning Risk Informed Regulation Dry Cask Storage & Aging Management NRC Inspections COVID Response
The 3 Yankee sites were shut down in the 1990s and safely decommissioned under the current and previous decommissioning rules. The Yankee experience demonstrated a successful risk informed process that resulted in exemptions based on safety significance. Generally, these exemptions are being considered in the current rulemaking for decommissioning.
The NRCs Decommissioning Rule should focus on the regulatory requirements involved with the transition from shutdown through decommissioning and reflect the significantly reduced levels of risk involved.
The Commission should ensure that as sites that are or will undergo decommissioning reach Stand-alone ISFSI status that their regulatory bases be the same as those that have previously reached that status.
When a Part 50 general licensed site has decommissioned and all that remains is the stand-alone ISFSI, the continued application of Part 50 regulations is inefficient and should be addressed to align appropriate provisions of Part 72 and Part 73 as it relates to ISFSIs.
- Efficiency in the dry cask storage and transportation processes is assured by consistent, predictable, and safety-based/risk informed regulation.
- Decades of experience and research studies undertaken to date confirm the safety and low risks of the spent fuel in storage and during transportation.
- Accordingly, the Commission should assure that any new rule or guidance reflect the low risk to the health and safety of the public.
New inspection tools and AMPs have been successfully integrated into CofC and site-specific relicensing.
We have applied those tools and programs at the 3 Yankee sites.
The Draft Regulatory Guide DG-3055 process that endorsed NEI-14-03 is a recent positive step of risk informed regulation.
We look forward to the issuance of the inspection process for AMPs at ISFSIs.
The NRC ISFSI Inspection Program Enhancement Working Group effort recognized the lower risk at ISFSI sites.
NRC should ensure that traditional inspections and enforcement at ISFSIs be better risk informed.
The practices and experience of the remote inspections of operating reactors during the pandemic could lead to more efficient and cost-effective inspection practices for our sites as well.
I want to take the opportunity to thank in person DFM, DDUR&WP, NSIR and Region 1 staff for their efforts.
The process was timely, efficient and effective without compromising the safety and security of our facilities.
The effort to quickly develop regulatory compliance strategies and processes was extremely important in ensuring our sites could meet the numerous challenges presented.
The several NRC public meetings associated with those efforts also helped reassure our communities and Community Advisory Panels that those challenges were being met.
The recent steps taken in risk informing the NRC regulatory programs for dry cask storage & transportation have enhanced efficiencies without diminishing safety margins.
We urge the Commission to continue to reflect the low safety significance involving these programs in its future rulemakings and guidance documents.
In particular with regard to the requirements involving aging management programs, the ISFSI inspection process for AMPs, and CofC renewals.
Industry has demonstrated that the existing regulation, coupled with compliant execution and routine NRC inspections results in safe and secure decommissioning and SNF storage. Regulatory changes should be thoughtful, risk informed and geared toward efficiency.
Questions?