ML21204A078
| ML21204A078 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/2021 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Brown, C, ACRS | |
| References | |
| NRC-1563 | |
| Download: ML21204A078 (116) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Radiation Protection and Nuclear Materials Docket Number:
(n/a)
Location:
Teleconference Date:
Wednesday, June 23, 2021 Work Order No.:
NRC-1563 Pages 1-94 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 SUBCOMMITTEE ON RADIATION PROTECTION &
7 NUCLEAR MATERIALS 8
+ + + + +
9 WEDNESDAY 10 JUNE 23, 2021 11
+ + + + +
12 The Subcommittee met via Teleconference, 13 at 2:30 p.m. EDT, Ronald G. Ballinger, Chair, 14 presiding.
15 16 COMMITTEE MEMBERS:
17 RONALD G. BALLINGER, Chair 18 VICKI M. BIER, Member 19 CHARLES H. BROWN, JR. Member 20 VESNA B. DIMITRIJEVIC, Member 21 GREGORY H. HALNON, Member 22 WALTER L. KIRCHNER, Member 23 JOSE MARCH-LEUBA, Member 24 DAVID A. PETTI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 JOY L. REMPE, Member 1
PETER RICCARDELLA, Member 2
MATTHEW W. SUNSERI, Member 3
4 ACRS CONSULTANT:
5 STEPHEN SCHULTZ 6
7 DESIGNATED FEDERAL OFFICIAL:
10 ALSO PRESENT:
11 KRISTINA BANOVAC, NRC/NMSS 12 THOMAS BOYCE, NRC/NMSS 13 DARRELL DUNN, NRC/NMSS 14 MERAJ RAHIMI, NRC/RES 15 CHRISTOPHER REGAN, NRC/NMSS 16 SCOTT MOORE, NRC/ACRS 17 ROD MCCULLUM, NEI 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 A G E N D A 1
Opening Remarks and Objectives 4
2 Staff Opening Remarks..............
7 3
NEI Presentation on NEI 14-03.......... 13 4
NRC Presentation on RG 3.76........... 35 5
Public Comments................. 77 6
Committee Discussion
.............. 77 7
Adjourn..................... 94 8
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4 P R O C E E D I N G S 1
2:30 p.m.
2 CHAIR BALLINGER: Okay, let's, it's 2:30, 3
let's get started. The meeting will now come to 4
order. This is a meeting of the Metallurgy and 5
Reactor Fuels and Radiation Protection and Nuclear 6
Materials Subcommittee of the Advisory Committee on 7
Reactor Safeguards.
8 I'm Ron Ballinger, chairman of today's 9
subcommittee meeting. ACRS members in attendance are 10 Vicki Bier, Charles Brown, Dave Petti, Greg Halnon, 11 Jose March-Leuba, Walt Kirchner, Joy Rempe, Matt 12 Sunseri, Vesna Dimitrijevic, and our consultant, 13 Stephen Schultz.
14 During today's meeting, the subcommittee 15 will review the staff's Regulatory Guide DG-3055, 16 Implementation of Aging Management Requirements for 17 Spent Fuel Storage Renewals. It's going to be the 18 proposed new Regulatory Guide 3.76, which endorses 19 with conditions NEI 14-03, Guidance for Operations 20 Based on Aging Management for Dry Cask Storage 21 Revision 2, dated December 2016.
22 The joint subcommittee will hear 23 presentations by and hold discussions with the NMSS 24 staff, NEI representatives, and other interested 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 persons regarding this matter.
1 The ACRS has previously commented on spent 2
fuel storage issues via letter after review of the 3
NUREG-1927 Revision 1, Standard Review Plan for 4
Renewal of Specific Licenses and Certificates of 5
Compliance for Dry Storage of Spent Nuclear Fuel, 6
dated April 20, 2016.
7 One of the recommendations in that letter 8
was a future revision should be undertaken that places 9
a priority on the development of a risk-informed 10
- approach, which includes analysis of event 11 consequences for aging management of dry storage 12 systems.
13 As far as we know, this recommendation has 14 not been acted on. It is likely that the consequences 15 of a leak caused by chloride stress corrosion cracking 16 would essentially be zero.
17 The rules for participation in all ACRS 18 meetings, including today's, were announced in the 19 Federal Register on June 13, 2019. The ACRS section 20 of the USNRC public website provides our charter, 21 bylaws, agendas, letter reports, and full transcripts 22 of all full and subcommittee meetings, including 23 slides presented there. The meeting notice and agenda 24 for this meeting were posted there.
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6 We have received no written statements or 1
requests to make an oral statement from the public.
2 The committee will gather information, 3
analyze relevant issues and facts, and formulate 4
proposed positions and actions as appropriate for 5
deliberation by the full committee.
6 The rules for participation in today's 7
meeting have been announced as part of the notice of 8
this meeting previously published in the Federal 9
Register. A transcript of the meeting is being kept 10 and will be made available as stated in the Federal 11 Register notice.
12 Due to the COVID pandemic, hopefully which 13 will be over soon, today's meeting is being held over 14 Microsoft Teams for ACRS, NRC staff, and NEI 15 attendees. There is also a telephone bridge line 16 allowing participation of the public over the phone.
17 When addressing the subcommittee, the 18 participants should first identify themselves and 19 speak with sufficient clarity and volume so that they 20 may be readily heard. When not speaking, we request 21 that participants mute your computer microphone or 22 phone.
23 We will now proceed with the meeting, and 24 I would like to call on, I think it's Chris Regan with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 NMSS staff for opening remarks. Chris? Chris Regan, 1
are you there?
2 MR. REGAN: I am here. Can you guys see 3
me and hear me?
4 CHAIR BALLINGER: I can certainly hear 5
you.
6 MR. REGAN: Okay, good.
7 CHAIR BALLINGER: And now, I can see you.
8 MR. REGAN: All right, very good. Thank 9
you very much. My name is Christopher Regan, I am the 10 deputy director for the Division of Fuel Management in 11 the Office of Nuclear Materials Safety and Safeguards.
12 Thank you, Mr. Chair and members of the 13 subcommittee. We're pleased to be here today. Staff 14 is going to present to you all our proposed final 15 guidance in Reg Guide 3.76 on Implementation of Aging 16 Management Requirements for Spent Fuel Storage 17 Renewals.
18 This Reg Guide endorses, with some 19 clarifications, the industry guidance in NEI 14-03 20 Revision 2, which is their Format, Content, and 21 Implementation Guidance for Dry Cask Storage 22 Operations Based Aging Management.
23 So, several years ago, staff began 24 updating our regulatory framework to look at lessons 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 learned from reviews of storage renewal applications 1
and to get ready for a wave of storage renewal 2
applications that we had forecast based on the 3
expiration dates of previous licenses.
4 As part of this work, we received quite a 5
bit of input from our stakeholders, including 6
industry, the public, our national and international 7
counterparts, and also you all from the ACRS.
8 We interacted with the ACRS as part of our 9
updates to the SRP and Revision 1 to NUREG-1927, which 10 is our SRP for renewal of specific licenses and 11 certificates of compliance for dry cask storage 12 systems.
13 And also, in 2016, on the issuance of 14 NUREG-2214, which was our MAPS report, the Managing 15 Aging Processes and Storage. And we did that in 2019.
16 Sorry, the NUREG-1927 was 2016 and the MAPS report was 17 2019.
18 So, these updates streamlined our reviews 19 of renewal applications and improved our regulatory 20 stability and predictability greatly.
21 However, as I mentioned, aging management 22 is an area where we continue to learn. Operating 23 experience has been accumulating over the years.
24 We've also had some research activities. And we'll 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 continue to use that as we update our regulatory 1
framework in this area.
2 As you pointed out to us, you sent us a 3
letter on NUREG-1927 that there are opportunities for 4
further risk-informing that framework as we gain 5
information and operating experience from our 6
inspection activities, as well as additional work in 7
research, when it comes to fruition and is completed.
8 So, this includes work on understanding 9
consequences and probability of the chloride-induced 10 stress corrosion cracking, which you referred to, the 11 CISCC, which staff will consider to risk-inform 12 canister inspections and the storage renewal 13 framework.
14 So, today, you'll hear from NEI. I see 15 Rod McCullum has flashed his camera on, so he's in hot 16 standby at the moment. You'll hear from us and NEI, 17 and another step in our ongoing updates to our storage 18 renewal framework.
19 So, NEI developed NEI 14-03 in parallel 20 with the staff's efforts to update NUREG-1927. And 21 I'd like to say that they complement each other and 22 provide specific guidance to industry on the format 23 and content of spent fuel storage renewal applications 24 on the implementation of their aging management 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 programs.
1 In addition, I should like to point out 2
that industry has developed an operating experience 3
database, hosted by INPO, called, I believe it's AMID, 4
this is the Aging Management INPO Database. We 5
support the industry's efforts in developing the 6
operating experience database and populating it using 7
experience from implementation of these programs and 8
inspection activities.
9 It's essential for us as a piece of our 10 operations-based learning on storage renewal 11 framework, to ensure we continue to store spent fuel 12 safely into extended periods of operations, which can 13 go as long as 40 years.
14 So, it's an important cornerstone of NEI 15 14-03, regarding operations based aging management, 16 through learning of the AMPs and sharing of operating 17 experience in the INPO database, which are included in 18 NUREG-1927.
19 However, to ensure our regulatory clarity 20 and predictability, staff has prepared a final Reg 21 Guide 3.76 to formally endorse the NEI guidance, as I 22 mentioned, with a few clarifications that you'll hear 23 from the staff's presentation.
24 So, we ask, as you take a look at our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 proposed final Reg Guide, please view it in the 1
context of our ongoing efforts to continuously 2
improve.
3 And because the industry guidance 4
complements 1927, that the staff previously discussed 5
with the ACRS, we don't feel we have a need for a 6
letter from the ACRS on this specific Reg Guide.
7 However, we do look forward to your input and your 8
feedback and the discussions today.
9 And with that, Mr. Chair, I will thank you 10 for the opportunity for the staff to present today and 11 I'll turn it back over to you. Thanks.
12 CHAIR BALLINGER: Thank you very much. I 13 think next up is Kristina.
14 MR. BROWN: Hello. Ron, it will be Rod 15 first.
16 CHAIR BALLINGER: Oh, I'm sorry. All 17 right.
18 MEMBER BROWN: Ron, can I ask a question 19 first?
20 CHAIR BALLINGER: Okay.
21 MEMBER BROWN: This is Charlie, could I 22 ask one question based on a comment he just made 23 during his warmup?
24 CHAIR BALLINGER: Sure enough.
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12 MEMBER BROWN: Yeah. You mentioned the 1
cask storage and this Reg Guide and all the management 2
programs and keeping it updated because these things 3
could be in storage for up to as long as 40 years.
4 Why did you calibrate that at 40 years? I didn't see 5
anything in the documents that talked about 40 years.
6 MR. REGAN: So, our regulatory framework 7
allows license renewals for that extended time period.
8 MEMBER BROWN: Okay, all right. So, 9
that's part of your -- is that in one of the, in 10 10 CFR 70, 42, or 24 or someplace like that?
11 MR. REGAN: Part 72.
12 MEMBER BROWN: Oh, 72, I'm sorry. Okay.
13 All right, thank you.
14 MR. REGAN: You're welcome.
15 CHAIR BALLINGER: This is Ron, a follow-up 16 on that. Am I correct in assuming there are words in 17 the document, actually in 1927 as well, which allows 18 for further renewals, right?
19 MS. BANOVAC: This is Kris Banovac from 20 the NRC. Yes, there's currently no limitation on the 21 number of renewal periods in our regulations, in Part 22
- 72. So, there could be subsequent renewal periods.
23 MR. REGAN: Thanks, Kris.
24 MS. BANOVAC: Thank you.
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13 MR. REGAN: I couldn't get off mute fast 1
enough.
2 MS. BANOVAC: Sorry.
3 CHAIR BALLINGER: A recognition of 4
reality, I guess.
5 MS. BANOVAC: Yes.
6 CHAIR BALLINGER: Okay. So, now, is it, 7
Kris, you're going to do the -- I'm confused about 8
who's going to go next, I guess.
9 MS. BANOVAC: Rod McCullum from NEI --
10 CHAIR BALLINGER: Okay.
11 MS. BANOVAC: -- will present next.
12 CHAIR BALLINGER: All right. Thank you.
13 MR. MCCULLUM: Thank you, Dr. Ballinger, 14 Kristina, and Chris. I agree wholeheartedly that NEI 15 14-03 is a complementary regulatory tool, guidance 16 tool for industry, that goes right along with Rev 1 of 17 NUREG-1927 and the MAPS report. I also think that the 18 key thing here is that this is about a learning 19 approach to aging management.
20 Referring to the recommendation Dr.
21 Ballinger mentioned at the outset about a consequence 22 analysis, there is a lot of work being done in this 23 area, but if we were to do a consequence analysis 24 today, we would base it on a lot of conservative 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 assumptions.
1 I agree with the likelihood that it would 2
show the consequences of CISCC, should it occur, would 3
be likely zero. Again, but conservative assumptions 4
would not necessarily validate that. And the one 5
thing that is true about CISCC is in 25 years of dry 6
storage experience, now including several inspections, 7
we simply haven't seen it yet.
8 So, what we have constructed here is a set 9
of guidance, which is forward-looking. It is about 10 taking the information that we will get going forward 11 and maximizing our value and ensuring that we continue 12 to safely contain spent fuel.
13 I actually am taking the control of this 14 presentation, I thought I took control of the 15 presentation, yes, I did. And this, by the way, is 16 the first time -- I wasn't able to share my slides, 17 they shared my slides and taken control, first time 18 I've ever taken control of anything from the NRC, and 19 I promise I won't make it a habit.
20 But what we have here is quite a history 21 of successful containment. Again, we started this 22 journey back in 2013, when we realized that we were 23 going to be in the dry storage business for a lot 24 longer than we might have originally suspected. And 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 we've developed a lot of tools here that I'll allude 1
to.
2 We've already renewed site-specific 3
licenses and CoCs that cover 32 sites. These are 40-4 year renewal on top of 20-year initial licenses. The 5
rule Part 72 was changed in 2011 to allow that.
6 And NRC's continued storage rulemaking 7
concluded that the current systems would safe for at 8
least 100 years. They made the conservative 9
assumption in that Environmental Impact Statement 10 behind the continued storage rule that we did 11 repackage them every 100 years. They didn't say we 12 would have to, but they thought they would last at 13 least that long.
14 So, we have this substantial base of 15 experience with successful containment. What NEI 14-16 03 is all about is how do we build on what we learned 17 going forward?
18 And this really is risk-informed and it 19 really is, I think as Chris mentioned, a streamlined 20 approach, how do we take what we learned going forward 21 and continue to build this confidence in what we all 22 believe to be true, what the experience is so far 23 telling us to be true?
24 But in a regulatory context, that's not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 good enough. In a regulatory context, you need data.
1 In a regulatory context, you need a lot of 2
information. So, how do we gather it? What do we do 3
with it as we continue to renew these licenses?
4 I don't know how long it will take the 5
United States to develop a repository program, but I 6
don't think I need to, because I know that every 40 7
years, we can renew these. And we're going to have to 8
go through all the things that are spelled out in our 9
guidance to do it. It just doesn't happen 10 automatically.
11 And so, what we see here is, again, we 12 started this back in 2013. Yucca Mountain program had 13 been defunded. We were realizing we were facing much 14 longer term dry storage, and we started to put things 15 in place.
16 We've built on our experience. We had a 17 good regulation. I think Part 72 is a very strong 18 performance-based regulation. NUREG-1827, the review 19 plan, was updated as we were developing NEI 14-03.
20 It's important to note that NEI 14-03, 21 we've revised it twice, because we've been doing this 22 thing with the NRC where we work with them and they 23 work back with us, and it's been a
great 24 collaboration.
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17 We've engaged with the IAEA and others, 1
there's a lot of international experience out there.
2 And Kristina and I are currently part of an IAEA 3
collaborative research project that is compiling this 4
document, compiling some of this experience into 5
another international document that will reference 14-6 03, 1927, and all the experience we have in the United 7
States.
8 A lot of science has gone into this, all 9
the National Laboratories. We first looked at CISCC 10 when it first came to the forefront as the (audio 11 interference). Somebody's got a phone in the 12 background, so perhaps somebody needs to mute.
13 We engaged in a
Regulatory Issue 14 Resolution Protocol to address it, which informed the 15 development of these tools.
16 The tollgate concept, there's really two 17 key things that are laid out in NEI 14-03, the 18 tollgate concept and AMID. I think Chris talked about 19 AMID. This is the database we created, there's 20 already about three dozen entries in it as we continue 21 to do inspections and do renewals.
22 And I think one of the things that the 23 endorsement of 14-03 does is take AMID from something 24 that's nice to do and makes it part of the regulatory 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 framework. In an industry where we're trying to pare 1
down and become more efficient, doing just what we 2
need to do, making AMID part of the regulatory 3
framework is important.
4 The tollgate concept is not just about, 5
okay, we're going to look forward and we're going to 6
learn, we're going to apply what we're going to learn, 7
and, yes, eventually that will lead us to a 8
consequence analysis. Again, a lot of R&D going on at 9
the labs, at EPRI, elsewhere.
10 But these are commitments to specific 11 points in time, to looking at specific information 12 about specific aging management issues. It's really 13 a sense of making sure that we will always -- right 14 now, I'm very confident we're ahead of the rate at 15 which these canisters will age. This is all about 16 making the commitments at very specific points in time 17 to ensure we will be there.
18 And we've also developed an ASME code case 19 to guide our inspection program. So, all these pieces 20 are in place and they've been developed in parallel 21 with 14-03.
22 So, we're already putting tollgates in 23 place. I was just talking to one of my member 24 companies this morning and they were saying, hey, I'm 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 writing my first tollgate. Great.
1 And as I say, we already have entries in 2
AMID. These things are referred to in NUREG-1927.
3 The framework is already working, what you're really 4
doing by endorsing NEI 14-03 through Reg Guide 3.76 5
is, as this graphic illustrates, you're putting in 6
place the last piece of the puzzle.
7 This assures that what NRC sees from 8
industry will be consistent and will continue to be in 9
the philosophy and, really, the letter of this 10 learning approach that we've laid out.
11 It really, since 2014, and again, that's 12 why it's NEI 14-03, because we started it in 2014 and 13 here we are in 2021. It has been quite a journey and 14 has been a very successful journey.
15 So, I commend my counterparts at the NRC, 16 and I really think all the people in industry, EPRI, 17 the National Labs, who put this in place so that we 18 can continue to renew these licenses and the continued 19 safe containment of used nuclear fuel really stays a 20 no-nevermind.
21 So, I think Chris may have referred to the 22 cornerstones. First of all, consistent format and 23 content of license renewal applications. It's very 24 important that NRC knows what to expect. We know from 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 experience, but if we submit something completely 1
different, and when you're forward-looking, there's 2
always that possibility, hey, I'm going to look at the 3
future differently than the last guy, that you've 4
become inefficient. So, this is an important aspect 5
of it.
6 Again, we've talked about the learning 7
aging management, based on what we know, continue to 8
build on this experience, continue to incorporate it 9
into our renewal applications. And then, when we 10 actually find things through our corrective action 11 program, building back the mitigation and repair 12 strategies.
13 And then, learning from what we've done on 14 mitigation and repair, although, based on what we're 15 seeing so far, I've got to imagine it will be quite a 16 few years, many decades before we start to have 17 substantial mitigation and repair experience.
18 So, we put all this in AMID. And AMID is 19 unique. It was developed by INPO, it certainly meets 20 INPO standards. It is now run under contract by 21
- Certrec, but that's a
distinction without a
22 difference.
23 It's unique amongst databases. Normally, 24 when we enter operating experience, we're talking 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 about, okay, what went wrong and how did we fix it?
1 Here, we enter positive experience.
2 When we get an inspection that does not 3
find CISCC or when we open the used fuel demo cask and 4
we find that the fuel is in the same condition it went 5
into the cask, just as when we opened the first lower 6
burnup demonstration cask, we found that, we share the 7
positive experience.
8 We can share international experience. We 9
can share information we collect from scientific 10 efforts having nothing to do with used fuel or even 11 nuclear, but are relevant to our journey here. So, 12 all of this goes in there.
13 And, again, the tollgates are, you got to 14 pay for the road as you go along. And we will, and 15 there already are several tollgates in these renewals 16 and there will continue to be more. As I said, I just 17 heard this morning of one that's being written as we 18 speak.
19 And these are commitments that we're going 20 to say, okay, at this point in time, what did we learn 21 about CISCC? What did we learn about high burnup 22 fuel? We're going to build that back into not only 23 under the currently 40-year framework we've 24 established, but these things will also set up the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 next renewal, should they be needed, should we not 1
have a repository 40 years from now.
2 And I'm becoming more optimistic that we 3
might, but that's not the subject of this meeting.
4 So, moving on to the next slide.
5 MEMBER REMPE: Rod, this is Joy, could I 6
interrupt you for a minute?
7 MR. MCCULLUM: Sure.
8 MEMBER REMPE: It's been a while since we 9
talked about AMID and tollgates and I've forgotten 10 some of the details. I know that in the documentation 11 we were provided to this meeting, they said that AMID 12 would provide periodic reports --
13 MR. MCCULLUM: Right.
14 MEMBER REMPE: -- to the regulator. Does 15 the regulator need to request those reports to get 16 access to them?
17
- Likewise, what's the way that you 18 integrate or you interact with the regulator with the 19 tollgate assessments? Do they have to request them, 20 are they automatically submitted to the NRC, or how 21 does that interaction take place?
22 MR. MCCULLUM: Well, it is by request. We 23 very purposefully put AMID in the control of the CoC 24 holders, because there's a lot of proprietary 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 information. But, of course, NRC knows how to deal 1
with that.
2 I would view this as a forward-looking 3
element of NRC's inspection program. Certainly, if 4
NRC approves a license with a tollgate in it, when 5
that tollgate is reached, NRC should ask, well, okay, 6
was it performed? Some of the tollgates, by the way, 7
do indicate that information will be shared with NRC 8
at that point, information will be made public at that 9
point.
10 So, I would say, this is an innovative and 11 forward-looking part of the inspection program.
12 You're not just inspecting looking backwards, you're 13 inspecting our ability to look forward. And I look 14 forward to the continued engagement.
15 I see Kristina has come on board, so 16 perhaps she has something to say.
17 MS. BANOVAC: You got to it, Rod. I was 18 going to mention the NRC's inspection program. That's 19 really where we're going to look at AMID, what 20 licensees are entering into AMID, and making sure 21 they're considering the operating experience that's 22 getting reported and aggregated there, as they 23 implement their AMPs.
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24 in my presentation, but I think, Rod, you got to it, 1
so that's why I turned on my video there. So, I'll 2
let you get back to it.
3 MR. MCCULLUM: All right, no problem. And 4
this is one of the efficiencies we've gained overall 5
in dry storage, not just specific to renewal or aging 6
management, the idea, what information gets looked at 7
in the inspection program, what gets looked at at the 8
time of licensing?
9 And if everything has to be looked at as 10 part of the licensing review, well, then that becomes 11 very highly inefficient licensing process. If you 12 review a license application to make sure it's set up 13 to assure safety, then you inspect, and NRC's done a 14 great job of enhancing its inspection programs.
15 So, again, I think this is going to work 16 very well going forward. I should never, on behalf of 17 my industry, say, we look forward to being inspected, 18 but I think this really is the case here, because we 19 have consistent guidance on both sides, we have 20 consistent expectations, and we have a consistent 21 commitment to learning aging management.
22 So, here's the structure that 14-03 lays 23 out, the general information. What do we need to look 24 at to determine that we can continue to safely contain 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 used fuel? And then, what safety systems and 1
structures and components do we need to look at with 2
respect to that information.
3 And then, how would it potentially be 4
affected? Obviously, the big player here is how will 5
CISCC affect stainless steel canisters, and so, that 6
is definitely, I would say that's the lion share of 7
what we'll be looking at going forward, but we will be 8
looking at it in a very structured way.
9 Time limited aging analyses, these go for 10 40 years. Okay, what assumptions are you going to 11 make about what happens over those 40 years? Right 12 now, we're making very conservative assumptions.
13 To get to Dr. Ballinger's point at the 14 outset, I think over time, we'll be able to make less 15 conservative assumptions, we'll have more experience, 16 we'll have more data, and we will have evaluated that 17 through AMID and through our tollgates.
18 So, what assumptions, what consequences, 19 what conclusions do you draw? And, of course, if 20 you're going to go for a second renewal, so, right 21 now, the first renewals take us out to a total of 60 22 years, if you're going to go from 60 to 100, which, 23 again, I would hope we don't, but if we do, then 24 you're going to have to do another time limited aging 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 analysis that looks at the next 40 years.
1 The Appendix A
defines the aging 2
management program, it address the ten elements of 3
NUREG-1927 Section 3.6.1. And so, very consistent in 4
terms of we have to address all those things with our 5
programs. Are there exemptions in play? Is there 6
something in the license renewal application that 7
would result in a need to amend the license or CoC, 8
and/or supplement the UFSAR?
9 So, we're able to consistently, and I 10 think consistency is important in assuring we're 11 efficiently, we're able to consistently integrate the 12 information through this tool. And, again, NEI 14-03 13 was done as a complement to 1927 and they both evolved 14 along with the MAPS report and everything else in that 15 puzzle piece together.
16 So, then, that was Chapter 2 of NEI 14-03, 17 was the format and content. Chapters 3 and 4 are 18 summarized, really, here in one statement, it's 19 everything we've been talking about, which is the 20 ability to efficiently change your approaches based on 21 feedback from operating experience,
- research, 22 monitoring, inspections.
23 The research will continue. I'm going to 24 be leading an industry meeting with DOE coming up.
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27 Again, we do this annually, where industry says, 1
here's our dry storage research priorities, and DOE 2
says, here's what we're doing, and we make sure those 3
are the same thing.
4 Of course, EPRI has a very robust research 5
program. EPRI recently took in a number of full-sized 6
casks that they're going to be doing some research 7
with. Still to be determined what that is.
8 And, again, all of this stuff will inform 9
consequence analyses, will inform NRC's inspection 10 programs. It'll be visited through AMID and it'll be 11 visited through the tollgates.
12 So, you see in Chapters 3 and 4, really, 13 this idea of recognition, evaluation, and then, of 14 course, if we ever do find anything, then it goes back 15 through the corrective action program.
16 The idea that we would spell out now, 17 based on what we know in 2021, what we will do in 18 2087, when we find corrosion on a cask at Site X, 19 would then deny us the benefit of everything that's 20 learned in the intervening 76 years.
21 Certainly, had we tried to define that 22 stuff back in 2014, when we first started this 23 journey, we would have been disadvantaged in terms of 24 not having had the benefit of all the knowledge we've 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 gained since.
1 It really has been a very fulfilling 2
journey we've taken down this. You can talk about 3
what hasn't happened on the disposal front, but this 4
is a strong example of the triumph of science, 5
engineering, a strong regulator, and a determined 6
private sector in overcoming a problem that was not 7
anticipated when we first began discharging used fuel.
8 So, that's what we have. There's one 9
opportunity that we're leaving on the table here in 10 14-03, this notion of surrogate inspections.
11 Kristina noted, and I think she'll talk 12 about them, there's 13 clarifications in the Reg Guide 13 3.76, but most of these are just simply a useful 14 extension of the dialogue. NRC has come in and made 15 a point on top of the point we've made and they tend 16 to be complementary and reinforcing. So, we welcome 17 those clarifications.
18 And the one on surrogate inspections is a 19 thing where we have provisions in here, because we did 20 do a susceptibility analysis, EPRI did that, that we 21 do have the ability to say that this environment over 22 here is more corrosive than that environment, so if I 23 inspect the exact same canister here, shouldn't that 24 tell me something that I can take for the other one?
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29 I know, I've had the good fortune of being 1
able to spend most of the pandemic working remotely, 2
very close to the ocean, and I'm noticing a lot of 3
things in my life are corroding and rusting at rates 4
they didn't use to. Hopefully, my mind is not one of 5
them. But nothing stainless steel is in that 6
category. My appliances are fine and not as thick as 7
the casks. But that's a worthless digression.
8 The point there is, I think we will be 9
able to, at some point in the future, start using 10 surrogate inspection results. But NRC has in their 11 clarification that that's not something they're 12 endorsing. That's the main reason this is a partial 13 endorsement.
14 We exchanged letters back and forth, NEI 15 agrees with that, we're saying we are willing to 16 accept a partial endorsement at this time. And as we 17 gain more, as we learn more, we hope to perhaps, at 18 some point, whether it's five, ten, 15 years down the 19 road, re-engage on surrogate inspections.
20 But that's really, if your questions are 21 why is this a partial endorsement, that's really the 22 central reason. But I also think it's an opportunity 23 to get even smarter going forward. It certainly would 24 be informed by a consequence analysis as well, if the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 consequences are better understood.
1 CHAIR BALLINGER: I think we have, Greg 2
Halnon, you have a hand up?
3 MR. MCCULLUM: Oh, I just --
4 MEMBER HALNON: Yeah, I do.
5 MR. MCCULLUM: That's my last slide.
6 MEMBER HALNON: Thanks, Rod. It's good to 7
hear you, Rod, appreciate it. Hey, could you discuss 8
a little bit, and maybe you've already answered the 9
question, I just clicked in a little bit into the 10 conversation, about these tollgate assessments, 11 whether or not they'll be public. If not public, how 12 will they be informed?
13 I know it's through the inspection 14 process, but I can see a thirst for information from 15 both the shutdown plants that may have a long-term 16 CAP, like a Citizen Advisory Panel or something to 17 that effect, or even the operating plants for the 18 annual assessment meetings.
19 Did you have any internal discussion about 20 that and how that might work out?
21 MR. MCCULLUM: Yeah. I think they will be 22 open to the public. Again, I think you want to go 23 through the CoC holders, because of the proprietary 24 information considerations.
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31 But the fact that the tollgate inspections 1
are being done are public, because they're in the 2
license renewal application. So, I think it's a very 3
smart communication strategy that if you have 4
something you publicly committed to, you in fact 5
publicly announce what you find when you get there.
6 That's going to be incumbent on us. And, 7
certainly, NRC's inspection results also become 8
public. So, NRC will inspect those, that will become 9
public. But I think we need to be more proactive than 10 that and I think we've already got one great example 11 out there.
12 San Onofre, Southern California Edison, 13 they, in order to get California Coastal Commission 14 approval of the decommissioning of that site, they 15 committed to a monitoring, inspection, and repair 16 program, where they had to, well ahead of any 17 tollgates, they had to go ahead and demonstrate repair 18 technologies and mitigation technologies to the 19 satisfaction of the California Coastal Commission, 20 which voted ten-to-nothing to approve the plan that 21 would lead to decommissioning of the plant.
22 And so, I would cite that example as a 23 proactive way of getting this information out in the 24 public. But I think, Greg, you've also given me a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 challenge here, so that we need to continue to do 1
that.
2 I, for one, if I was a utility, would not 3
be happy with waiting for NRC inspection results to 4
come out, I would expect that I would be putting 5
things in AMID and I would be sharing that widely.
6 There are a number of industry venues, 7
including conferences, that could be open to the 8
public, where we talk about these lessons learned, 9
what's in AMID, and --
10 MEMBER HALNON: Right, I agree. I think 11 that it proactively is, you're right on on that. You 12 might consider the Citizen Advisory Panel charters 13 that your members have, maybe start discussing that 14 amongst those, that decommissioning group, to talk 15 about. It's not just decommissioning, obviously, I 16 know that there's some operating plants that will go 17 on beyond 40. So, anyway, just a thought, maybe put 18 that in the back of your head.
19 MR. MCCULLUM: Making a note of that now, 20 because, yeah, that sounds like another thing that 21 should be on. And I know you're very familiar with 22 this group, the decommissioning working group. So, 23 thank you for that.
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33 your hand up?
1 MEMBER KIRCHNER: Yes, thank you, Ron. It 2
took a while to find the mic. Rod, just a 3
clarification. This acronym AMA, is that really AMP?
4 Or what is the AMA?
5 MR. MCCULLUM: I think it means aging 6
management approaches. It probably should have been 7
-- well, it's broader than AMP, because it includes 8
the AMPs. This was --
9 MEMBER HALNON: I think the other A is 10 analysis, aging management analysis?
11 MR. MCCULLUM: Yeah, analyses, yeah, yeah.
12 MEMBER KIRCHNER: Okay, thank you.
13 MS. BANOVAC: Or activities?
14 MR. MCCULLUM: I think it -- well, the way 15 I said it, when I brought this slide back to life, it 16 was an old slide, I meant it to be all-encompassing.
17 MEMBER KIRCHNER: Yeah, yeah. Okay, fine.
18 I just wanted to make sure I didn't miss something.
19 But while I've got the microphone unmuted, I know 20 there's a focus on, always in the nuclear industry, 21 when you use stainless steel, there's always concerns 22 about chloride stress corrosion and cracking.
23 But put that aside for the moment. Are 24 there other likely things that should be inspected, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 like thermal fatigue of welds, or things like that, 1
with or without the presence of chlorides? Is that 2
part of these aging management activities --
3 MR. MCCULLUM: Yes. I mean, we're --
4 MEMBER KIRCHNER: -- or the inspection 5
programs? Yeah, so we're not looking just at one 6
single potential failure mechanism and obsessing on 7
it, but also looking that the cask is, over its 8
- lifetime, is actually meeting its performance 9
requirements?
10 MR. MCCULLUM: Yeah. The inspection 11 technologies that we've deployed already while bring 12 a comprehensive look. There's multiple corrosion or 13 degradation mechanisms and they've all been addressed 14 through various DOE gap analyses. And it keeps coming 15 back to CISCC is the one we focus on most. But these 16 are going to be comprehensive programs.
17 And if we learn new information about 18 something that we should be more concerned about than 19 we are, because we find something different than CISCC 20 that we want to learn more about, then this program 21 allows us to get that in a corrective action program, 22 address it, and get it out to industry.
23 MEMBER KIRCHNER: Good, thank you.
24 CHAIR BALLINGER: Okay. Are there any 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 other questions for Rod? Well, thank you, again. I 1
guess we now need to go to Kristina?
2 MS. BANOVAC: Okay.
3 CHAIR BALLINGER: There you are.
4 MS. BANOVAC: Thank you, Dr. Ballinger.
5 And please give me a moment to pull up my slides.
6 Okay. Can you all see that slide presentation?
7 MEMBER REMPE: Yes.
8 CHAIR BALLINGER: Yes.
9 MS. BANOVAC: Okay, great. And I will 10 say, before I get started, so when I do the slide 11 show, it takes up my full screen, so I can no longer 12 see the Teams link. And so, I can't see if somebody 13 has their hand raised.
14 So, I would just ask Dr. Ballinger to 15 please let me know if any of the members have any 16 questions, or if any of the members, please jump in at 17 any point during my presentation to ask your 18 questions.
19 So, thank you so much for the opportunity 20 to present to you today on the proposed final Reg 21 Guide 3.76. I'm happy to present this on behalf of 22 the NRC team that reviewed NEI 14-03 and prepared the 23 Regulatory Guide.
24 I'm now on Slide 2. Slide 2 provides an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 outline of my presentation. I'm going to give some 1
background information to get us started. I'm going 2
to talk a little bit about updates to the storage 3
renewal framework, both updates that we have completed 4
and also updates that are ongoing and work that is 5
ongoing.
6 I'll then get into NEI 14-03 and the Reg 7
Guide, which is the subject of the meeting today.
8 I'll talk about the public comment we received on the 9
Reg Guide.
10 And then, I'll wrap up by talking about 11 how the framework is flexible and risk-informed and 12 how we're going to continue to risk-inform the 13 framework going forward. And then, finally, our path 14 forward, both for the Reg Guide and for our storage 15 renewals framework.
16 I'm now on Slide 3. So, in terms of 17 background for storage renewal requirements, as we've 18 already discussed, the regulations in 10 CFR Part 72 19 do allow for us to renew specific licenses for 20 independent spent fuel storage installation and 21 certificates of compliance for dry storage system 22 designs, for a period not to exceed 40 years.
23 The regulations do specify that renewal 24 applications must include time limited aging analyses 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 and those consider the effects of aging on structures, 1
systems, and components, or SSCs, important to safety, 2
and the capability for those SSCs to continue to 3
perform their intended safety functions for the period 4
of extended operation.
5 Renewal applications must also include 6
- programs, and those are for 7
management of aging issues that could adversely affect 8
the performance of our structures, systems, and 9
components important to safety.
10 And so, in order for the NRC to approve a 11 storage renewal application, applicants must 12 demonstrate that any aging effects on our dry storage 13 systems can be addressed in the period of extended 14 operation, so that those systems continue to perform 15 safely.
16 Any questions on that slide before I go 17 on? Okay. I'm now on Slide 4.
18 A little bit more background on updates to 19 our storage renewal framework. You've already heard 20 from Chris and Rod a little bit about our experience 21 with the previous storage renewals. They did indicate 22 a need for some expanded guidance in the area of spent 23 fuel storage renewals and aging management.
24 We did have some inefficiencies in our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 past reviews. And also, as Chris alluded in his 1
opening remarks, we had this wave of storage renewal 2
applications that were coming, we were expecting 15 3
renewal applications over several years.
4 And so, we really wanted to be ready to 5
review those applications, and we wanted industry to 6
also prepare quality applications for us to review.
7 So, we did reflect on the lessons we learned from 8
those reviews.
9 We looked at the reactor renewal 10 experience. We looked at the research that had been 11 done, industry and DOE initiatives, research and 12 development. And we considered all those things as we 13 determined what we need to do and change in the 14 framework.
15 As Chris mentioned in his opening remarks, 16 we did receive extensive stakeholder feedback as we 17 went through this process from public, industry, ACRS, 18 our national and international counterparts. NRC did 19 not do this alone, it was really in collaboration with 20 all of our stakeholders, and we thank them for sharing 21 their perspectives over the years to help us get to 22 where we are today.
23 And as you've heard from Chris, and Rod 24 got into a little bit more detail, our focus was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 really ensuring this operations-focused aging 1
management and the idea that we're learning as we go.
2 So, as we conduct these AMP inspections, 3
as we get operating experience, as we do complete 4
additional research and develop new technologies, that 5
we learn from that and we update our aging management 6
programs as we go, to make sure that they continue to 7
be effective at managing those aging effects in the 8
period of extended operation.
9 I'm sorry, let me pause there. Any 10 questions on Slide 4 before I go on? Okay. I'll go 11 on to Slide 5.
12 So, in terms of updates that we've already 13 made to the storage renewal framework, we started our 14 work with the update to NUREG-1927, as you've already 15 heard, and, of course, discussed that with the ACRS 16 back in 2015 and 2016. We also met with the ACRS back 17 in 2016 on the draft MAPS report, the Managing Aging 18 Processes and Storage report.
19 And in addition to those two items that we 20 did coordinate with the ACRS, we also completed this 21 temporary instruction, or TI for short. And the TI 22 really focused on inspection of licensees' programs 23 and procedures to implement AMPs. And since issuance 24 of that TI in 2018, we have completed several 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 inspections under the TI.
1 And so, with that work that we have 2
already completed, we actually have realized 3
efficiencies in our review process, in terms of the 4
total time that it takes to review these renewal 5
applications, and also, the NRC staff resources that 6
we use in those reviews. So, we actually have already 7
seen some efficiencies with these updates that we've 8
made.
9 Any questions before I move on? Okay.
10 I'm now on Slide 6.
11 So, even though we have completed those 12 improvements and we've already seen some efficiencies, 13 our work is not done, so our work continues. And this 14 slide just lists some examples of our ongoing work to 15 continue to improve our framework going forward.
16 So, we're actually currently developing an 17 inspection procedure for licensees' AMP 18 implementation, some questions already came up in this 19 regard. As part of this inspection procedure, we'll 20 be looking at how licensees are inputting the 21 operating experience from their aging management 22 programs into AMID, and also, how they're using AMID 23 to learn from operating experience that other sites 24 and other licensees are gaining.
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41 We're also going to look, going forward, 1
the idea is to have a learning aging management 2
program that constantly responds to operating 3
experience and sort of evolves with time to be able to 4
make sure that that program remains effective.
5 We're also going to be looking at how 6
licensees change those aging management programs and 7
how they use their change control processes under 10 8
CFR 72.48 to make those changes to AMPs.
9 So, those are all things that we're going 10 to be looking at in that inspection procedure. And we 11 currently plan to issue that later this fall.
12 We're also planning a future update to Reg 13 Guide 1.147, and this would be to endorse the ASME 14 Code Case N-860. I think Rod already mentioned this 15 code case. This is for inspection of canisters and 16 the protocols for that.
17 So, we are planning a future update.
18 There is a current update to Reg Guide 1.147, we 19 didn't get a chance to get in that, we didn't have 20 enough time to get in that update, so that will be a 21 future update to that Reg Guide.
22 And in addition to those updates, we're 23 also continuing our active involvement in many other 24 areas. I think Rod alluded to some of these already.
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42 There's the Extended Storage Collaboration Program 1
that's coordinated by EPRI.
2 We're working with our international 3
counterparts. As Rod mentioned, there is some active 4
development of IAEA guidance on aging management for 5
dry storage systems, so we're actively involved in 6
that.
7 We're, of course, following the DOE and 8
industry initiatives and advancements in technologies 9
and techniques for inspections and, ultimately, repair 10 and mitigation if it's needed.
11 And also, research continues. So, we're 12 following the research, in terms of fuel performance, 13 degradation mechanisms. And also, there's currently 14 the high burnup fuel demonstration, led by DOE and 15 EPRI, that's ongoing, and so, we're continuing to 16 follow that.
17 And then, finally, I know this has come up 18 a few times already, based on the ACRS letter that we 19 received on NUREG-1927, but we continue to look at the 20 risk of aging effects on canisters.
21 And things that we're looking at, or that 22 industry is looking at, and I use the industry with a 23 capital I, we're looking to understand the deposits on 24 canisters. So, what's the chemical makeup of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 deposits on the canisters?
1 And to look at CISCC probability, take a 2
further look at that. And then, if cracking does 3
occur, looking at crack growth rates, understanding 4
those better and how the crack could propagate.
5 And then, as has been mentioned a few 6
times already, the consequence analysis. That work by 7
EPRI is ongoing. It will be coming, I believe a 8
couple more years still until there will be a report 9
that we can look at, but we know that work is ongoing 10 and we will follow that and welcome that.
11 Any questions on this slide before I go 12 on?
13 CHAIR BALLINGER: I think Steve Schultz 14 has his hand up. And --
15 MS. BANOVAC: Sure.
16 CHAIR BALLINGER: -- I think Walt as well.
17 DR. SCHULTZ: Kristina, this is --
18 CHAIR BALLINGER: Go ahead.
19 DR. SCHULTZ: -- Steve Schultz.
20 MS. BANOVAC: Hello.
21 DR. SCHULTZ: Hi, how are you? The 22 question I have is, you've mentioned a few times now 23 efficiency improvements that have been noted, I 24 presume efficiency and effectiveness. Could you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 provide some examples or some quantification of the 1
efficiencies that have been observed --
2 MS. BANOVAC: Absolutely.
3 DR. SCHULTZ: -- or some examples of 4
improvements that have been developed as a result of 5
the program and its oversight?
6 MS. BANOVAC: Yes, absolutely. So, in 7
terms of efficiencies, so what we've done is we've 8
looked at a baseline.
9 So, we looked at the hours that we spent, 10 which ultimately are dollars that are charged to our 11 applicants, for the renewal applications before we 12 made these improvements, so the issuance of NUREG-1927 13 and MAPS, and then, we looked at the renewals that 14 we've done since then. And so, we compared the 15 numbers. And we've actually cut our review costs in 16 half, so we've very happy to say that.
17 And also, the time, the total time to 18 review the applications, we've almost cut that in 19 half. I think it's from about 48 months to 26 months.
20 And as we continue with our renewals, we're learning 21 as we go, and so, that time is shrinking even more.
22 So, we actually have been able to cut both 23 the resources that are spent on those reviews and the 24 time in half. And so, we're happy to report that.
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45 In terms of effectiveness, I will say 1
effectiveness, I think going forward as we implement 2
the AMPs, we are going to make sure, and this is going 3
to be in our inspection program, that licensees are 4
responding to what they're finding, to the operating 5
experience, that they're changing their AMPs to 6
respond to it, to make sure those continue to be 7
effective.
8 So, in terms of effectiveness, that's 9
more, I think, a future goal is to make sure we remain 10 effective. But we're very pleased with the 11 efficiencies that we've realized so far.
12 DR. SCHULTZ: Are there consistencies in 13 the corrective action programs as you see it across 14 the industry that are associated with the spent fuel 15 storage?
16 MS. BANOVAC: So, that is a focus of our 17 inspection program. So, the corrective actions 18 programs and the quality assurance programs at 19 licensees, we do inspect those independently.
20 So, even besides the AMP implementation 21 and aging management, we do conduct our inspections to 22 make sure that those programs, the quality assurance 23 programs and corrective action
- programs, are 24 effective, that they are correcting issues as they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 arise.
1 And so, yes, we inspect that now and we 2
will continue to inspect that going forward.
3 DR. SCHULTZ: Rod, do you have a comment?
4 It looks like you might. If you're unmuted?
5 MR. MCCULLUM: I came on with my video, 6
but not my audio, isn't that stupid? But, yeah, no, 7
that is a specific feature of NEI 14-03, there is 8
guidance in there on how to enter aging management 9
findings into your corrective action program. And by 10 endorsing this, then NRC understands how we'll be 11 doing that and we should have a consistent and 12 effective process going forward.
13 DR.
SCHULTZ:
Yeah.
That's the 14 collaborative process that you mentioned earlier. I 15 appreciate that. Thank you.
16 CHAIR BALLINGER: Walt, you still have 17 your hand up --
18 MEMBER KIRCHNER: Yes.
19 CHAIR BALLINGER: -- I think?
20 MEMBER KIRCHNER: Yes, thanks, Ron.
21 Kristina, this is Walt Kirchner, good afternoon. With 22 regard to inspections, to date, without identifying 23 any sites or operators, have you found any significant 24 problems with dry cask storage that would perhaps 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 threaten the integrity and/or have there been 1
significant repairs of
- any, and when I
say 2
significant, a significant problem and hence, a 3
significant repair program, of dry casks? Have there 4
been any incidents such as that in the dry casks that 5
are deployed so far?
6 MS. BANOVAC: Good question. And I'll 7
kind of start with a response and I'll also invite my 8
NRC colleagues to jump in if they have anything they 9
want to add.
10 So, we have seen a couple things. We 11 actually published a information notice. We saw some 12 degradation because of environmental moisture with 13 cask seals. So, the sealing system for the metal 14 casks. And then, also, some freeze-thaw degradation 15 of concrete, of the horizontal storage modules for a 16 canister-based system.
17 And so, we actually did issue a generic 18 communication, it's in an information notice, the 19 number escapes me, a number that's coming into my 20 mind, I don't know if this is correct, I want to say 21 like 2017-20, but please don't quote me on that.
22 But we do have an information notice that 23 we did put out as a generic communication to alert 24 industry as to what we were seeing. But besides that, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 nothing else is coming to mind, in terms of 1
degradation and aging that we've seen.
2 And, of course, and I think a question 3
came up, I can't remember who asked that before, I 4
apologize, but a question came up, as we go forward 5
and we get this operating experience, we're going to 6
be doing these AMP inspections, we're going to be 7
learning a lot more about the condition of these 8
systems, how are we going to share that? How is that 9
information going to go out there?
10 And besides the things that Rod had 11 mentioned, in terms of AMID and the tollgate 12 assessments, NRC, we believe we absolutely have a role 13 to share operating experience, just as industry does, 14 NRC has its programs as well.
15 And so, just as we did with that 16 information notice on the environmental moisture and 17 some of the degradation that we were seeing because of 18 that, we would continue to do that going forward. So, 19 if we saw any issues or trends going forward, we have 20 our generic communications process.
21 And then, also we have, if there are any 22 issues with the licensee's implementation of AMPs, we 23 obviously have our inspection program and our 24 enforcement program as well.
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49 But that's what immediately comes to mind.
1 And I'll ask my NRC colleagues if anybody has anything 2
that they wanted to add to that?
3 MR. MCCULLUM: While we're waiting, I'll 4
just point out that information notice is 2013-7, and 5
that does pertain to bolted systems that represent 6
less than ten percent of the U.S. fleet.
7 MS. BANOVAC: Yeah. And then, it also has 8
the concrete degradation for --
9 (Simultaneous speaking.)
10 MR. MCCULLUM: Yeah.
11 MS. BANOVAC: Yeah, yeah. Thank you, Rod.
12 MR. DUNN: Yeah, this is Darrell Dunn.
13 Can you hear me?
14 MS. BANOVAC: Yes.
15 MR. DUNN: Yeah. So, you are correct 16 about the horizontal systems and the freeze-thaw 17 issues. There were also some vertical cask systems 18 that have had exposed concrete on the outside that 19 have had aging effects and necessitated repairs to 20 those systems.
21 And then, in addition to that, there has 22 been some coating-related issues for some of the 23 carbon steel components. For example, the inside of 24 the vertical cask that have a carbon steel shell on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 the inside of the concrete surface.
1 That was not necessarily evaluated as an 2
aging effect, but more as a coating application 3
problem, but it was still something that was 4
identified in an inspection and noted in the 5
inspection report.
6 And that's, in addition to the things you 7
said, that's about all the things I can think of.
8 Certainly, no indications of corrosion or chloride 9
induced stress corrosion cracking on any of the 10 stainless steel canister inspections that I am aware 11 of.
12 MEMBER KIRCHNER: Thank you very much, 13 that was a good survey, I appreciate it. And that you 14 do the information notices, thank you.
15 MS. BANOVAC: Thank you. Any further 16 questions on this slide before I move on? Okay. Now, 17 moving on to Slide 7.
18 So, with this slide, I'm not going to 19 spend much time here, I think you've already heard 20 this from Chris and Rod. We did include the key 21 aspects or cornerstones of NEI 14-03, we did already 22 reference those in NUREG-1927.
23 However, to have the regulatory stability 24 and predictability, and I'll even say a durable 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 guidance document going forward, we are making sure to 1
do the formal endorsement of NEI 14-03 through the Reg 2
Guide.
3 So, even though some of these ideas and 4
the important ideas from NEI 14-03, we already have 5
referenced in the SRP, we still feel it's important to 6
go through the process of the endorsement through the 7
Reg Guide.
8 And so, I'll stay there, I think we've 9
talked about that already. Now --
10 MEMBER REMPE: So, Kristina, I'm sorry, 11 this is Joy, again.
12 MS. BANOVAC: That's okay. Hi, Joy.
13 MEMBER REMPE: Hi. You mentioned you 14 would go a bit more into AMID and tollgates and how 15 the regulator interacts or gets access to the, I guess 16 they said they give periodic reports on AMID, what's 17 coming in. Do you --
18 MS. BANOVAC: Yes.
19 MEMBER REMPE: -- actually have -- I would 20 bet you don't have access to this database, or do you 21 actually get access to the full database or are you 22 limited to the reports?
23 MS. BANOVAC: That's a good question. And 24 our inspector, our main SME in this area, Marlone 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 Davis, he's actually on inspection this week, on an 1
AMP inspection looking at a
licensee's AMP 2
implementation, which is why he's not here. So, we 3
talked before the meeting.
4 He had mentioned that, currently, the plan 5
is that when we go to the sites to do the inspections 6
of the licensee's AMP implementation, we'll access 7
AMID through the site. So, we'll be there, we'll be 8
able to search on the database.
9 There's multiple tools to search on the 10 database and to find the information that you're 11 looking for based on materials, the type of system, 12 the aging effect. So, we'll have access to that when 13 we're at the site.
14 And, also, I do know that some of our --
15 early on, it was possible for the NRC to be able to 16 also get access to the AMID. And I think, for that to 17 have, I'll say access at NRC headquarters rather than 18 through the licensees, we just need to make sure that 19 we have the infrastructure in place there, so in terms 20 of nondisclosure of proprietary information and things 21 like that.
22 So, we would just want to make sure that 23 we had that framework in place with INPO to be able to 24 access that. But, absolutely, our inspector, as we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 speak, is access AMID at a licensee's site, to see the 1
operating experience.
2 And then, also, the tollgate reports or 3
assessments, I believe this is discussed in NEI 14-03, 4
where that assessment itself, so this will be 5
something that's going to be recorded, summarized, and 6
then, that tollgate assessment and report itself will 7
also be entered into AMID. So, once again, that would 8
be available for industry use.
9 Does that address your question, Joy?
10 MEMBER REMPE: That helps a whole lot. It 11 wasn't clear to me, and, again, I know we discussed 12 this a lot several years ago and I probably have just 13 forgotten that you had access to the actual database, 14 so that's great.
15 And then, I assume that the inspectors are 16 well-versed, so they know to request these tollgate 17 assessments, that it's a system that's been working.
18 Since some of these assessments are being done, that 19 has happened and there's not a chance for the 20 inspector to miss that they need to request that.
21 MS. BANOVAC: Correct. And, actually, in 22 the AMP itself, and with the renewal applications that 23 we've approved so far with the tollgates, so there 24 will actually be something in the aging management 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 program itself that says when those tollgate 1
assessments will be conducted.
2 And so, that's making its way, it's in the 3
aging management program that's ultimately approved as 4
part of NRC's issuance of that renewal. And then, 5
that's ported over into the licensee's programs and 6
procedures, to actually implement that aging 7
management program.
8 And so, the inspectors will have access to 9
the aging management program itself, and then, also to 10 the licensee's procedures for the AMP implementation.
11 And so, they'll be able to review those procedures, 12 see, okay, oh, you've had a tollgate assessment that 13 you conducted last year, please show me the results of 14 that and, essentially, how you responded to what you 15 found.
16 So, that is absolutely the thought for how 17 we're going to address that in inspection.
18 MEMBER REMPE: Great. Thank you very 19 much.
20 MS. BANOVAC: Thank you. Any other 21 questions on this slide before I move on? Okay. I'm 22 going to move on to Slide, I'm on Slide Number 8 now.
23 So, in terms of what's in Reg Guide 3.76, 24 so you've heard, we do make some clarifications to NEI 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 14-03 in the Reg Guide. And I just provide a couple 1
examples here on this slide to illustrate.
2 I think the one that you've heard about 3
already, it's sort of the big one, I think, the 4
surrogate inspections. And this is the idea that a 5
licensee, instead of conducting their own AMP 6
inspection, they would rely on another site's 7
inspection results to sort of use as their own.
8 And the staff's position on surrogates was 9
originally presented in NUREG-1927, where we said you 10 can use surrogates as long as you have some operating 11 experience to back it up and provide a basis for their 12 use.
13 And NEI 14-03 did a nice job of expanding 14 on this area, thinking ahead to how would we use 15 surrogates, how could this be done appropriately and 16 safely going forward?
17 NEI 14-03 did reference the work that EPRI 18 had done, industry and NRC had done, through the 19 Regulatory Issue Resolution Protocol on CISCC, and 20 that resulted in EPRI's development of susceptibility 21 criteria and rankings for sites. And so, NEI 14-03 22 does go into that.
23 And so, the clarification that we provide 24 in the Reg Guide was that we need to understand, at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 this point, we're starting to get the operating 1
experience, it's starting to come in, but we really 2
need to understand what the inspection results, the 3
canister inspection results look like for those 4
difference susceptibility rankings, to be able to 5
compare, to see, okay, who can rely on whose 6
inspection?
7 And so, really understanding how that 8
susceptibility assessment is applied across the ISFSI 9
fleet, that's what we think we need to work on next.
10 As Rod had mentioned in his presentation, 11 industry is absolutely looking forward to re-engaging, 12 once we have that understanding of how the inspection 13 results are comparing for the different susceptibility 14 rankings, to be able to re-engage and apply this 15 condition of surrogates going forward. So, we did 16 make that clarification in the guidance.
17 And then, also, with this second bullet 18 here under surrogate inspections, there was also a 19 mention in NEI 14-03 that the concept of surrogates, 20 as it was laid out in NEI 14-03, for how you can use 21 that for canister inspections, there was a mention 22 that this could be used for other SSCs and materials, 23 such as concrete.
24 And so, we did want to make a
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57 clarification in the Reg Guide that if surrogates are 1
to be used for SSCs and materials other than stainless 2
steel canisters, there would just need to be a 3
methodology and some guidance for how you would do 4
that.
5 With the canister inspections, we had all 6
this really nice work we could rely on, that happened 7
through the CISCC RIRP, we had those susceptibility 8
rankings and assessments, we had that work that was 9
done by industry, and it laid out the methodology for 10 how you could do a canister surrogate going forward.
11 And so, if industry wanted to apply that 12 to other materials and components, NRC wanted to make 13 the clarification in the Reg Guide that there would 14 need to be a methodology for how to do that before we 15 apply surrogates. So, just something that we wanted 16 to make clear in the Reg Guide in terms of surrogates.
17 MEMBER KIRCHNER: Kristina?
18 MS. BANOVAC: Yes?
19 MEMBER KIRCHNER: This is Walt Kirchner, 20 again. On the surrogate inspection, could you just 21 give us a feeling for roughly the number of different 22 design type canisters that are certified out there and 23 in service?
24 MS. BANOVAC: By number, like --
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58 MEMBER KIRCHNER: I mean --
1 MS. BANOVAC: -- the number of designs?
2 MEMBER KIRCHNER: Where I'm going with 3
this is, it would seem to me surrogate inspections 4
would make sense for the same vendor canister. So, 5
I'm just curious, how many different canister types 6
are out there and vendors?
7 MS. BANOVAC: Yeah, so, and that's a great 8
question. So, it's really -- and, actually, this was 9
part of our second clarification that we made there.
10 If you're going to apply surrogates, you absolutely 11 have to understand variability.
12 It kind of comes down to the material, 13 I'll say the material and the service environment that 14 it's in, as the first piece. So, the variability in 15 the materials and the service environment it's in, and 16 also, if there's any operating parameters.
17 So,
- concrete, I
think of concrete 18 sometimes, I think that would be a tough one to do 19 surrogates on, just because there is, I think, a lot 20 of variability in terms of concrete, because it 21 depends on the aggregate that's used, which is usually 22 a local product, the water that's used.
23 And so, we really need to consider the 24 variability, I think, in the materials of construction 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 and also, differences in environmental and operational 1
parameters to use the surrogate. So, I --
2 MEMBER KIRCHNER: Well, my --
3 MS. BANOVAC: -- don't know if that really 4
answers your question, but that's the caution there.
5 MEMBER KIRCHNER:
I specific said 6
canisters, because my intuition would be just what you 7
said about concrete and local environmental conditions 8
and such being a lot more variability there. But 9
going back to the canisters themselves, it would seem 10 to me that there would be an order of magnitude less 11 variability. I think Rod's trying to make a comment.
12 MR. MCCULLUM: Yeah, just want to confirm, 13 there are 16 specific certificates of compliance out 14 there that cover 90 percent or over 2,700 canisters.
15 For example, standardized NUHOMS, there's 725 of 16 those, HI-STORM, there's 1,000 of those. Actually, 17 2,800 are covered under the CoCs.
18 So, yeah, there are opportunities where 19 you have hundreds, if not a thousand or more, of very 20 similar canisters. Some of the site-specific licenses 21 have some of the same canisters that are under the 22 CoCs too, they were just licensed site-specifically.
23 And I agree, concrete is extremely local, 24 but in terms of the stainless steel canisters that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 make up the bulk of the fleet, we do think there's a 1
significant potential for the use of surrogates. It's 2
really only a handful of designs out there right now.
3 CHAIR BALLINGER: This is Ron Ballinger.
4 I think that caution with respect to surrogates is 5
probably quite
- prudent, because while the 6
susceptibility criteria, environmental susceptibility 7
criteria are pretty easy to get a handle on, the 8
residual stresses in welds are not.
9 And so, you may have comparable 10 environment in one site or another, where you can use 11 surrogates in that respect, but the welding processes, 12 residual stresses, repair welds, and even the amount 13 of a canister that's inspectable might mask areas of 14 very high residual stress.
15 And so, that introduces a
lot of 16 variability and I think caution is important here, 17 with respect to that variable.
18 MR. MCCULLUM: I agree 100 percent, it 19 would be a very complicated analysis that would have 20 to consider all of the factors that lead to CISCC. I 21 think we do have a lot of design information on these 22 systems and a lot of information on the manufacturing 23 processes that were used, they come out of the same 24 factories. But, absolutely, we would have to consider 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 all of that.
1 CHAIR BALLINGER: Yeah, a lot of these 2
older canisters, where weld repairs were made, where 3
actually nobody knows.
4 MR. MCCULLUM: Right, those wouldn't be 5
good surrogates. But that's why we are not moving 6
forward with the surrogate thing at this time, there's 7
a lot more to learn on that. We have to figure out 8
how to do this.
9 CHAIR BALLINGER: Okay. We've got a five-10 second rule, you can continue.
11 MS. BANOVAC: All right. And, yeah, so, 12 that's sort of, I think, the big one in Reg Guide 13 3.76. And then, there are some other minor 14 clarifications. Several of them actually fall under 15 the umbrella of renewal application format and 16 content.
17 So, essentially, just since we've issued 18 NUREG-1927 and since NEI 14-03 Rev 2 came out, we have 19 gone through reviews of several storage renewal 20 applications. So, we've just learned a few things in 21 the last handful of years.
22 And so, most of our clarifications in that 23 area just reflect the passage of time and what we've 24 learned since the issuance of NEI 14-03 Rev 2. So, I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 would put them in the camp of fairly mild 1
clarifications, but it was a nice opportunity, I'll 2
say, in the Reg Guide, to be able to provide some of 3
those updates that we learned as we continued our 4
reviews.
5 So, I'll pause here again to see if 6
there's any questions on this slide before I advance.
7 Okay. So, I'm now on Slide Number 9.
8 So, in terms of public comments on the 9
draft Regulatory Guides, which was published as DG-10 3055, we only received one public comment on the draft 11 Reg Guide, it was from NEI. And in the comment, NEI 12 mentioned that they agreed to the approach to 13 surrogates, as you heard from Rod today, they know 14 that they'll re-engage in the future as we gain more 15 information, as we become more comfortable with the 16 use of that idea.
17 And they also encouraged the industry use 18 of the AMID database, which we absolutely agree. And 19 then, there was a specific comment that NEI made on 20 the supplement in the license renewal application.
21 So, in the license renewal application, there's a 22 FSAR, Final Safety Analysis Report, supplement that's 23 included as part of the renewal application.
24 In the draft guide, the NRC made a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 clarification that we wanted to see the actual 1
proposed FSAR changes, and the comment from NEI said 2
that that wasn't really needed, as long as it was very 3
clear what aging management information is ultimately 4
going to go into the FSAR after the renewal and that 5
will be recorded as part of the design basis.
6 And so, we ultimately agreed with that, we 7
recognize that having FSAR page changes is actually 8
very nice, because it's very clear what the applicant 9
will be putting in the FSAR after we issue the 10 renewal.
11 However, as long as the NRC has sufficient 12 information to understand what aging management 13 details are going to get recorded in the FSAR, are 14 going to get recorded in the design basis, to make 15 sure that that information that we based our renewal 16 on, that formed the basis of our approval, that that 17 gets recorded in the design basis.
18 As long as that is clear to us, then we 19 were okay with not having the actual FSAR proposed 20 changes. So, we did make a revision to the proposed 21 final Reg Guide to address that comment.
22 And one final thing I'll mention on this 23 slide before I see if anybody has questions, I will 24 note that even though we only received the one public 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 comment on the Reg Guide, we're continuing to monitor 1
the public interest.
2 I
think it came up
- already, our 3
involvement in community engagement panels. So, we're 4
going to continue to do that. So, even though we 5
received the one comment, we're going to keep our ears 6
open to public input in aging management as we go 7
forward.
8 So, let me pause there and see if there 9
are any questions. Okay. Hearing none, let me 10 advance here, I'm now going to Slide 10.
11 So, this is almost a conclusion slide, I 12 think. We've heard a lot so far about what we've 13 already done to the framework, what we're planning to 14 do going forward, and this slide kind of touches on 15 how our framework, in a way, is risk-informed and how 16 it's flexible going forward, so that we can continue 17 to risk-inform it.
18 So, the first thing to mention here is 19 that the focus of our renewals, it's really on the 20 continuation of the approved design basis and the 21 continued performs of those SSCs important to safety.
22 So, at its nature, we're focusing on the important to 23 safety aspects of the system in the renewal.
24 The AMPs are summarized in the Final 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 Safety Analysis Report, so that is under a licensee's 1
change control process. Licensees can change those 2
AMPs and aspects of the AMPs without NRC approval, as 3
long as they meet the criteria in 10 CFR 72.48, which 4
is the change control regulation of Part 72.
5 The guidance does not specify corrective 6
actions for aging management programs. We do, as we 7
discussed, we rely on the quality assurance programs 8
and the corrective action programs at the licensee's 9
site.
10 And, really, when we review the aging 11 management programs, we focus on the acceptance 12 criteria to make sure that we have acceptance criteria 13 that are essentially based on the aging effects and 14 when those can occur and what they would do, and 15 setting those acceptance criteria as a very low 16 threshold, so if you trigger those, as soon as you 17 trigger those, you're immediately into the corrective 18 actions program.
19 And we also feel that it's more sound to 20 rely on the corrective actions program, because there 21 is a wide range of, we expect a wide range of 22 inspection findings. You have some variability in the 23 storage system designs.
24 And then, also, we expect there to be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 continued development of inspection and repair 1
technologies. And so, that allows us the flexibility 2
to take advantage of those in the future.
3 One other thing to mention here, of 4
course, as we've been talking about, the framework 5
does allow licensees to change those aging management 6
programs to respond to operating experience, and that 7
really ensures that those aging management programs 8
remain effective throughout the period of extended 9
operation.
10 As you've heard, these periods can go up 11 to 40 years, so we want to make sure that those AMPs 12 are dynamic, that they're not static and they're not 13 frozen at the time of the issuance of the renewal, but 14 that they continue to change and learn as we learn.
15 And I'll mention also that, although we 16 believe we have the sustainable framework here and a 17 risk-informed framework, our work continues. I know 18 you've heard this message, I think, a few times, so 19 our work continues, which I'll get into on the next 20 slide on path forward.
21 But let me just pause there to see if 22 there's any questions. Okay. So, I'll now go to my 23 final slide here. I'm now on Slide 11 for those folks 24 on the phone.
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67 So, this is our path forward. So, for Reg 1
Guide 3.76 itself, after ACRS consideration and any 2
comments and input that we get from ACRS, we will 3
publish the Reg Guide after that. So, we look forward 4
to doing that in the future.
5 And in terms of the larger storage renewal 6
framework, we're going to complete those ongoing 7
framework updates that I talked about earlier in my 8
presentation. We're going to continue to risk-inform 9
our framework and revise our guidance as needed, as we 10 gain that information, as we gain the operating 11 experience from AMP inspections.
12 And as additional work is completed, 13 which, as we discussed a few times now, that work 14 continues in understanding the probability and the 15 consequences of stress corrosion cracking, and so, as 16 we learn more, we're going to continue to risk-inform 17 our framework and update our guidance as needed.
18 Of course, licensees, as they enter the 19 period of extended operation, they will be 20 implementing their aging management programs, they're 21 going to be entering their operating experience into 22 AMID, and, ultimately, making adjustments to the AMPs 23 going forward, to make sure that they're responding to 24 the operating experience and everything that we're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 learning in terms of aging management.
1 NRC will inspect the licensees' 2
implementations of AMPs, as we've discussed. We're 3
going to look at how they're using AMID, how they're 4
reporting to AMID, how they're learning from AMID, 5
and, ultimately, how they're using their change 6
control processes to change the AMPs to respond to the 7
operating experience and the knowledge that's being 8
gained.
9 We feel that this framework is 10 sustainable, flexible, and that it will ensure 11 continued safe storage for the period of extended 12 operation. And we appreciate the opportunity to 13 present today. And so, with that, I'm going to see if 14 there's any questions on my presentation from the 15 subcommittee members.
16 CHAIR BALLINGER: This is Ron. I guess 17 this is the time for me to chime in. This is now my 18 personal opinion. What you've done is excellent, a 19 very excellent program that will result in 20 satisfactory performance with one exception, possibly.
21 And that is the element of surprise.
22 The problem with some of these inspection 23 is that there's a significant fraction of these 24 canisters that can't be inspected, either because of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 the way they're installed or just not being able to 1
get at areas.
2 And I've mentioned residual stresses in 3
welds. Those residual stresses in welds are quite 4
unpredictable. And so, even for the best welding 5
techniques, you're going to get residual stresses that 6
are going to be highly variable.
7 And so, that means, at least to me, that 8
the possibility of you getting a surprise -- what I 9
mean by surprise is, you've identified a canister that 10 you think needs to be inspected because of it meeting 11 certain criteria and then, only to discover that 12 another canister actually has a leak, a canister that 13 you deemed not as susceptible as the ones that you've 14 chosen.
15 And so, that is what I mean by surprise.
16 And that leads me back to what I've been harping on 17 from the beginning. And that is, I think we've gotten 18 the cart before the horse a bit.
19 Because if we had done and we do a proper 20 consequence analysis, we will discover, as I think 21 most people expect, that the consequences of a stress 22 corrosion cracking leak or through-wall stress 23 corrosion crack are essentially zero. No consequences 24 to the health of public or safety.
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70 And if we had done that to start with, it 1
might have made the whole process that you've gone 2
through -- very well, by the way -- much simpler, 3
because if we get up front the consequences being 4
very, very, very low or zero, then some of the 5
inspections and other kinds of things that we're doing 6
now as a result of this program may not have been 7
necessary, or at least not as frequent.
8 So, that's the reason I've been harping on 9
the consequence analysis. And it's ongoing, but it's 10 been ongoing for a very, very long time. I mean, a 11 very long time. So, I would encourage somebody to, I 12 don't know, somehow accelerate this consequence 13 analysis so that you can factor it into your ongoing 14 updates for this. So, that's my story and I'm 15 sticking to it.
16 MS. BANOVAC: Thank you, Dr. Ballinger.
17 And I think all I'll say is, we agree, we look forward 18 to the consequence analysis work. Of course, as I 19 have mentioned previous, we continue work and, also, 20 understanding better the probability, where chloride 21 induced stress corrosion cracking can actually occur.
22 And so, the work continues, our work is not doing.
23 CHAIR BALLINGER: But you don't have to 24 have a probability. You can assume that there's a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 stress corrosion cracking through-wall crack and then, 1
analyze the consequences.
2 Because I think stress corrosion cracking 3
in this respect, well, in this case, with the residual 4
stress uncertainty and the
- like, is almost 5
unpredictable. I'm sure --
6 MR. MCCULLUM: I'm just onscreen to say, 7
I'm going to take your encouragement back into all the 8
meetings I have with industry, with EPRI, with the 9
scientific team at DOE.
10 We continue to have these discussions that 11 a consequence analysis built on overly conservative 12 assumptions would not be very useful. So, in order to 13 overcome that, we need more science, we need more 14 information.
15 And I can only say, I agree with you and 16 I will take your words and continue to push harder to 17 bring that information to bear for exactly the reason 18 you mentioned.
19 MEMBER RICCARDELLA: Yeah. This is Pete 20 Riccardella. I would say that there are different 21 types of consequences. There are safety consequences, 22 but then, there's also public relations consequences 23 that have to be addressed.
24 I mean, if someone reports, oh, spent fuel 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 casks are leaking at such-and-such a site, that could 1
have some serious consequences, even though there are 2
no real safety consequences.
3 CHAIR BALLINGER: Well, we can turn that 4
around and say that if we say that there isn't going 5
to be a leak in these canisters and all of a sudden we 6
have one --
7 MEMBER RICCARDELLA: Yeah.
8 CHAIR BALLINGER: -- that's a public issue 9
as well.
10 MEMBER RICCARDELLA: Yeah.
11 MS. BANOVAC: And this is Kris Banovac, 12 let me add one thing, because I don't want to miss the 13 chance to say this. Of course, consequences for 14 storage are one thing.
15 I do want to recognize that storage is not 16 the final step, there will be transportation after 17 storage. There's the possibility of a second storage 18 period at a different site. Ultimately, geologic 19 disposal at some point in the future. But they are 20 next steps.
21 So, absolutely, transportation, possibly 22 a second storage stage, and, ultimately, disposal.
23 And so, I think, I would just say that, of course, 24 consider the storage consequences is important, but we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 also can't forget the next steps.
1 So, even if the consequence is small for 2
storage, we'd want to make sure that it would be small 3
going forward. If the canister is relied on for 4
confinement in the transportation package, then the 5
robustness of the canister is, obviously, important.
6 So, I just wanted to throw out that idea 7
and just make sure that we didn't forget about those 8
next steps.
9 CHAIR BALLINGER: Yeah, that's true, but 10 when you start to do transportation, that is, in 11 effect, another tollgate. That's a place where you 12 can fully inspect the canister to make sure that it's 13 sound, prior to transportation. So, those are cases 14 where you can verify the canister integrity before 15 transportation, for example, or storage.
16 MR. BOYCE: Can I add something here? Can 17 you hear me? Assuming you can, I'm Tom Boyce, I'm the 18 branch chief --
19 CHAIR BALLINGER: Yeah.
20 MR. BOYCE: -- in NMSS for the Materials 21 and Structural Branch. We don't disagree that the 22 consequences are potentially low. We are following, 23 with great interest, the efforts that industry is 24 pursuing on these. And I think Rod mentioned several 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 of them, and I think Kristina has them in her slides.
1 But just to prove we're not just following 2
them, we actually reached out and put in, to our 3
colleagues in research, and put in place a user need 4
request with a specific task to assess and risk-inform 5
chloride induced stress corrosion cracking, including 6
the consequence analysis.
7 So, we're expecting a scoping report in 8
about November of next year, with a final report that 9
would include the efforts that industry has made to 10 date in about September of 2023. So, we are taking 11 what you're saying seriously, is my point.
12 CHAIR BALLINGER: Thank you. Are there 13 other comments from members?
14 MEMBER BIER: Yeah. This is Vicki Bier, 15 I just had a quick question of clarification for 16 Kristina. When you talk about reviewing the 17 implementation of the AMPs, the use of AMID, and the 18 adjustments to the AMPs, is that against a fixed set 19 of criteria that need to be met or is it just kind of 20 common sense, does the inspector agree that this was 21 done in a reasonable manner?
22 MS. BANOVAC: Yeah. So, the inspectors, 23 so they will actually be using the AMPs that were 24 approved as part of the renewal for that site or for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 the CoC that that site might be using.
1 They'll actually use the aging management 2
programs that were approved as part of the renewal and 3
make sure that the licensee is implementing those 4
programs as appropriate. So, they're ultimately going 5
back to what was approved as part of the renewal and 6
making sure that the licensee is implementing that 7
correctly and appropriately.
8 MEMBER BIER: Okay. So, it is a 9
compliance check, not just kind of a reasonableness 10 check?
11 MS. BANOVAC: Yes.
12 MEMBER BIER: Thanks.
13 MEMBER KIRCHNER: Ron, this is Walt. This 14 is --
15 CHAIR BALLINGER: Yes, sir.
16 MEMBER KIRCHNER: -- more a personal 17 comment than a technical one. But I don't see any 18 value in going further in risk-informing this, in 19 terms of consequence analysis. I agree with your 20 assessment, that the result of that would be a very, 21 potentially very low risk to the public.
22 I would think that, going forward, since 23 Kristina mentioned they were thinking about potential 24 next steps if there's interim storage, again, this is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 a personal opinion, interim storage is like when your 1
mother tells you to clean up your room, you don't put 2
things on a chair, that's what interim storage is, you 3
put them away where they belong.
4 So, until there's a geologic repository, 5
my own opinion is that the consequence of risk to the 6
public is minimized by having a bulletproof program on 7
this dry cask storage. And that leads the political 8
pressure distributed to solve the problem correctly, 9
which is a geologic repository.
10 There's certainly much more risk in moving 11 the casks or opening them, et cetera, et cetera, at an 12 interim site and then, picking them up and moving them 13 again. So, that's just one member's opinion.
14 But I don't think there's much value in 15 chasing consequence analysis for these dry cask 16 storage installations. I know that was our 17 recommendation, so I'm perhaps dissenting four years 18 later from a previous ACRS letter.
19 But I think what we've been presented is 20 a very good program and it addresses what Pete brought 21 up, which is not just public protection and safety, 22 but also, confidence. And so, I applaud and thank the 23 presenters.
24 CHAIR BALLINGER: Okay. I don't hear --
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77 we need to go around amongst the members one more 1
time, but can we get the public line open? Is it 2
open?
3 MR. DASHIELL: Public bridge line is open 4
for comment.
5 CHAIR BALLINGER: Thank you. Are there 6
any members of the public that would wish to make a 7
comment? If so, please identify yourself and then, 8
make your comment. With some fear and trepidation, I 9
guess we should close the public line.
10 MR. DASHIELL: Public line is closing.
11 CHAIR BALLINGER: Thank you. Okay. The 12 staff indicated in the beginning that a letter was not 13 required, but it's up to us whether we would like to 14 produce a letter. So, I'd like to go around to the 15 members and get your opinion on that topic.
16 My personal opinion is that we should have 17 a letter, and the reason is, not because we might have 18 some major suggestion, but this is the penultimate Reg 19 Guide, which is the sort of top of the heap, if you 20 will, in that it unifies everything.
21 So, I'm thinking that my personal opinion 22 is that a letter, however short it might be, to 23 provide an end point, is worth doing. But I'm just 24 one member, so I'm interested in everybody else's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 opinion.
1 MEMBER REMPE: Ron, if we were to do this, 2
are you going -- I mean, isn't it too late to put it 3
in the July meeting --
4 CHAIR BALLINGER: Yeah, I --
5 MEMBER REMPE: -- since it's already been 6
posted?
7 CHAIR BALLINGER: Yeah, I think it's 8
probably too late, but --
9 MEMBER REMPE: So, then, we're into 10 September --
11 CHAIR BALLINGER: Yeah, yeah.
12 MEMBER REMPE: -- and how does that impact 13 the staff's schedule, if they have to wait until 14 September? Is that a problem?
15 CHAIR BALLINGER: I do not know.
16 MEMBER REMPE: Before we go around the 17 table, I want to make sure I understand the impact of 18 such a decision. And perhaps the staff could comment 19 on, do they mind waiting until September.
20 MS. BANOVAC: This is Kris Banovac, is it 21 okay if I --
22 CHAIR BALLINGER: Yeah, sure.
23 MS. BANOVAC: -- answer that? And I'll --
24 CHAIR BALLINGER: Very good, yeah.
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79 MS. BANOVAC: So, obviously, this Reg 1
Guide is a long time coming. NEI 14-03 has been out 2
for some time. We're excited to finally get to this 3
point, I mean, we obviously had some competing 4
priorities, which is why it did take us so long to 5
finally get to the formal endorsement of the Reg 6
Guide.
7 So, but that said, and I know we've 8
mentioned a few times during the meeting, we do have 9
the guidance. We referenced this guidance in NUREG-10 1927, I think Rod mentioned this.
11 We've been very pleased to see, even 12 though we don't have the formal endorsement yet in the 13 Reg Guide, we've been very pleased to see that 14 applicants are referencing NEI 14-03 in their renewal 15 applications, they are using it, they're mentioning 16 AMID, the tollgates.
17 And so, even though there isn't a formal 18 endorsement yet, everybody's already using it, which 19 we're very thankful to industry for that. So, I think 20 there, and please, Chris Regan jump in, or anybody 21 else, I don't think there's a rush to get the Reg 22 Guide on the street, since we've already waited this 23 long.
24 Obviously, as the project manager on it, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 I'm anxious now that we're close to the end to get 1
done. But, really, I don't see any pressing need to 2
get it done. But I'll let Chris Regan add to that, 3
please, Chris?
4 CHAIR BALLINGER: But NUREG-1927 is on the 5
street also.
6 MS. BANOVAC: Yes, NUREG-1927 --
7 CHAIR BALLINGER: And that --
8 MS. BANOVAC: -- that's been out since 9
2016, yeah.
10 CHAIR BALLINGER: Yeah, that's really the 11 sort of heavy lifting.
12 MS. BANOVAC: Correct.
13 (Simultaneous speaking.)
14 MS. BANOVAC: Yeah, or it's kind of like 15 the sister, I think of them as kind of the sister to 16 NEI 14-03, the NRC side of the house and industry side 17 of the house. But I'll stop there, I've been talking 18 a lot.
19 MR. REGAN: Yeah. The SRP, we see as, 20 like, guidance for the staff. The Reg Guide is 21 essentially guidance for industry, and the industry 22 has their guidance already. So, the two are 23 complementary.
24 I think in the big picture, obviously, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 we're always interested in getting stuff finalized so 1
we can move on as quickly as we can.
2 I would caveat my response with, I don't 3
think September or a delay would be a significant 4
impact, barring if there was any suggestion or any 5
recommendation in the letter for the staff to initiate 6
or take any particular action or pursue any particular 7
issue.
8 So, I'll just caveat that response in 9
saying, yeah, it's fine if there was additional time 10 needed.
11 MS. BANOVAC: And, Dr. Ballinger, may I 12 ask also that I would like to hear Rod's perspective 13 on it as well, as the industry representative? Is 14 that okay?
15 CHAIR BALLINGER: Sure.
16 MR. MCCULLUM: Yeah, I'm back on. I think 17 that would be, to put it frankly, a little bit 18 disheartening for industry. If there's a need for a 19 delay, if there's something that needs to be 20 addressed, but if we simply -- industry is looking 21 forward to this, we're already doing things that are 22 in it now.
23 And I just think, if I have to tell my 24 industry, well, we've got to wait another three months 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 to get this endorsed -- we're looking to be more 1
efficient here, Kristina talked about how we've 2
shortened review times, we're looking for interactions 3
with the regulator that get us to reasonable outcomes 4
and more reasonable points in time.
5 So, I would have some work to do with my 6
industry to explain another delay at this point, since 7
we think we've closed all the substantive issues. I 8
could do that, I guess, but I'll really rather not to.
9 That's my perspective.
10 CHAIR BALLINGER: Okay, thank you. I 11 think what we need to do is to get members' opinions 12 and see what people think. So, we have almost all of 13 the members here. So, let me just, at this point, go 14 down the list that I have. Vicki, what do you think?
15 MEMBER REMPE: Wait a second, Ron. Didn't 16 you want to get public comments before you went around 17 with the members?
18 CHAIR BALLINGER: I did.
19 MEMBER REMPE: Oh, I'm sorry, I guess I 20 forgot, I apologize, I --
21 CHAIR BALLINGER: Yeah, there were --
22 MEMBER REMPE: -- was distracted for a 23 minute 24 CHAIR BALLINGER: We got silence. So, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 Vicki?
1 MEMBER BIER: I'm reasonable satisfied 2
with what I've heard here. I feel like I'm new enough 3
to the committee that I don't have a deep sense of the 4
political pluses and minuses of having a letter versus 5
just informally saying, yeah, we don't need to do 6
anything more on this. So, I will abstain on that 7
side.
8 CHAIR BALLINGER: Oh, abstain.
9 (Laughter.)
10 CHAIR BALLINGER: Charlie?
11 MEMBER BROWN: I guess I would, in spite 12 of industry's concern about the delay, I think there's 13 at least three points that I took out of the Reg 14 Guide, the use of surrogates and the clarifications 15 relative to them, the endorsement of the tollgate 16 approach to doing business, and the database that's 17 being built with the AMID approach, that I personally 18 think it's a good idea to get the committee's Betty 19 Crocker, Good Housekeeping stamp of agreement. That's 20 my personal opinion. So, I would write a letter.
21 CHAIR BALLINGER: Okay. Dave?
22 MEMBER PETTI: I'm agnostic, I could go 23 either way. So, I'll just go with what the most of 24 the committee think. I mean, it's a grey area, I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 think, at this point.
1 CHAIR BALLINGER: Okay, you're amongst the 2
nones. Okay. Greg?
3 MEMBER HALNON: Hold on just a second.
4 Whoops, I'm sorry. I'm good with no letter, unless 5
you want to put a placeholder for the surrogate 6
conversation going forward. But from what I heard, I 7
didn't hear a need for it.
8 CHAIR BALLINGER: Okay. Jose?
9 MEMBER MARCH-LEUBA: Yes, I'm here.
10 Again, I'm either way. As a rule of thumb, I think 11 positive letters have almost as much value as negative 12 letters. So, if I have to lean one way, I would issue 13 a letter, with a positive outcome.
14 CHAIR BALLINGER: Walt?
15 MEMBER KIRCHNER: Concurring with Jose, I 16 don't like to confine our letters to finding problems 17 or identifying new ones. If something makes sense, we 18 should recognize that good work done and the letter 19 can be very brief, but I would lean in favor of a 20 letter.
21 And procedurally, I would point out, we 22 could always have a short special meeting of the ACRS 23 just to write this letter, if we want to consider the 24 schedule aspect. Thank you.
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85 CHAIR BALLINGER: Joy?
1 MEMBER REMPE: So, I was going to say, I 2
don't see a need for a letter, but in thinking about 3
our last letter, where that risk approach was 4
emphasized, it might be valuable to say something 5
about that our current perspective has changed and we 6
support this program. And so, I guess that might be 7
a reason. The surrogate inspections might be a reason 8
also to go ahead and do a letter.
9 I like what Walt said about maybe just go 10 ahead and do something virtually in August to get the 11 letter on out the door, so we don't hold up things 12 unnecessarily. But we can discuss that later if 13 everyone agrees to do a letter.
14 CHAIR BALLINGER: Okay. Pete?
15 MEMBER RICCARDELLA: Yeah, well, I agree 16 with the comments about a letter would be valuable, 17 but if it has the effect of delaying publication of 18 the Reg Guide, then I'd be opposed to it.
19 CHAIR BALLINGER: Well, you got to come 20 down on something.
21 MEMBER RICCARDELLA: If we can do as Joy 22 just said and get the letter out in time that it 23 doesn't impact the Reg Guide, then I would say go 24 ahead and do it.
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86 CHAIR BALLINGER:
Yeah.
I
- mean, 1
personally, I think if the letter is worth doing, the 2
schedule should not be an issue. I mean, if we don't 3
need a letter, we don't need a letter, regardless.
4 MEMBER RICCARDELLA: Yeah.
5 CHAIR BALLINGER: Matt?
6 MEMBER SUNSERI: So, I'm in the position 7
of thinking that we don't need a letter on this, and 8
I do appreciate the fact that writing positive letters 9
is of value, but when the value is consumed by the 10 cost, I don't agree with that.
11 It sounds like the industry has got 12 everything they need, sounds like staff doesn't need 13 anything, I don't see the need to wrap up from our 14 previous position, because, I mean, we're really not 15 changing anything.
16 But I am, behind the scene here, been 17 trying to figure out, if we choose to write a letter, 18 when we could do it, and I haven't reached a 19 conclusion on that yet. But working on trying to make 20 it available earlier than September, if that's what we 21 decide to do.
22 CHAIR BALLINGER: Okay.
23 MEMBER SUNSERI: But just to be clear, I'm 24 voting no, for no letter.
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87 CHAIR BALLINGER: So, you're voting no, is 1
that it?
2 MEMBER SUNSERI: Yes, regardless of if we 3
could write it or not, I don't think we need to.
4 CHAIR BALLINGER: Vesna?
5 MEMBER DIMITRIJEVIC: Yeah, well, my 6
position from the beginning was, I mean, after 7
discussion started, if we can do it fast to recognize 8
good work.
9 And I just want to say this was an 10 excellent presentation, which I really enjoyed, and 11 obviously reflects really good work. I mean, if we 12 are going to delay things to recognize this good work, 13 that doesn't make sense.
14 So, what I was going to say, if we can do 15 it faster, then yes, if we cannot, then no. But now, 16 I just, because not to complicate it, I would vote no, 17 if it comes to that. That's it.
18 CHAIR BALLINGER: Okay. Well, I thought 19 it would be a lot easier than this, but it actually is 20 coming out, with all the abstentions, no. So, absent 21 further discussion, which we, of course, can have, I 22 think the noes have it. So, I --
23 MEMBER SUNSERI: Ron, this is Matt. Just 24 let me throw out one more alternative here, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 probably folks don't like this, but we could say, 1
based on this discussion, we don't see any need to 2
hold up the issuance of the Reg Guide and then, just 3
write a letter after the fact praising it or providing 4
whatever positive comments we feel, and if we feel the 5
need to wrap up to our previous letter, then that 6
would take care of this, but not have anything to do 7
with the issuance of the Reg Guide.
8 CHAIR BALLINGER: Do we --
9 MEMBER SUNSERI: So, that's --
10 CHAIR BALLINGER: Do we have a precedent 11 for that anywhere? Have we done that before?
12 MEMBER KIRCHNER: I don't think that, from 13 a parliamentarian standpoint, I don't think, Matt, we 14 can do that. We only speak through our letters.
15 CHAIR BALLINGER: Wait, wait, what --
16 okay. So, explain why that wouldn't be, because I 17 completely would not understand that from a
18 parliamentary standpoint.
19 MEMBER KIRCHNER: Well, we only speak 20 through our letters. You're saying, go ahead and 21 issue the Reg Guide and we'll follow up later, we 22 can't say that from a subcommittee.
23 MR. MOORE: This is --
24 MEMBER KIRCHNER: The subcommittee makes 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 recommendations to the full committee.
1 MR. MOORE: May I --
2 MEMBER KIRCHNER: But if --
3 MR. MOORE: May I comment --
4 MEMBER KIRCHNER: -- it helps -- one more 5
thing, Scott, if I might. If it helps give you the 6
kind of majority you need, Ron, I'll change my vote to 7
no letter.
8 CHAIR BALLINGER: Okay. I mean, I think, 9
it's really up to the full committee whether we have 10 a letter. And so, that would -- what the subcommittee 11 would be doing at a full committee meeting is 12 recommending not doing a letter, I think that's the 13 correct path. And so, I guess, if you change your 14 vote, then we're saying, in effect, we don't need a 15 letter.
16 Now, the question is, do we want a full 17 committee presentation? I think we have to, where we 18 recommend not doing a letter, am I correct, Mr.
19 Parliamentarian?
20 MEMBER KIRCHNER: No, you're --
21 CHAIR BALLINGER: Oh.
22 MEMBER KIRCHNER: -- not correct.
23 CHAIR BALLINGER: Okay.
24 MEMBER KIRCHNER: In P&P, we can discuss 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 in this full P&P and the recommendation can be 1
advanced from the subcommittee that no letter is 2
needed. And the committee as a whole then can vote in 3
P&P yes or no.
4 CHAIR BALLINGER: Oh, okay.
5 (Simultaneous speaking.)
6 MEMBER BROWN: Ron?
7 CHAIR BALLINGER: Yeah?
8 MEMBER BROWN: This is Charlie. Walt's on 9
the money, I've done that at a couple of subcommittee 10 11 CHAIR BALLINGER: Okay.
12 MEMBER BROWN: -- meetings in the I&C 13 world --
14 CHAIR BALLINGER: Okay.
15 MEMBER BROWN: -- several years ago. We 16 can make a decision that a letter is not made, we've 17 done that several times in the past --
18 CHAIR BALLINGER: Okay, I stand --
19 MEMBER BROWN:
in my personal 20 experience.
21 CHAIR BALLINGER: Okay, I stand corrected.
22 That makes life a little bit easier. So --
23 MEMBER MARCH-LEUBA: This is Jose.
24 Couldn't P&P also issue a recommendation or, I mean, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 a vote asking the executive director, Scott, to send 1
them a memo to the staff saying that everything looks 2
good, therefore, we're not writing a letter? And we 3
4 CHAIR BALLINGER: I mean, that's the 5
general --
6 MEMBER MARCH-LEUBA: -- can do that?
7 CHAIR BALLINGER: That's what usually 8
happens, right?
9 MEMBER MARCH-LEUBA: No, usually, we vote 10 and then, we just drop it --
11 CHAIR BALLINGER: Okay.
12 MEMBER MARCH-LEUBA: -- if there is no 13 documentation.
14 CHAIR BALLINGER: Okay. That's an 15 administrative thing, I think. I think --
16 MEMBER MARCH-LEUBA: Yeah, but that would 17 take the place of a positive letter, saying --
18 CHAIR BALLINGER: Well, but again, Walt 19 would say that we only speak through our letters.
20 MEMBER MARCH-LEUBA: But we have, I mean, 21 that would be a P&P outcome where we have voted and we 22 ask the executive director to inform NRR that we like 23 the approach and we don't see the need for a letter.
24 CHAIR BALLINGER: Scott, are you on?
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 MR. MOORE: Yes, I am.
1 CHAIR BALLINGER: Is that a reasonable 2
path?
3 MR. MOORE: I mean, the committee can 4
direct me to write the staff and let the staff know 5
that the committee doesn't see the need for a letter, 6
yes.
7 CHAIR BALLINGER: Okay.
8 MR. MOORE: The other thing I will say is, 9
there have been instances, even in the two years that 10 I've been with the committee, where the staff has gone 11 ahead and issued a document based on the briefing to 12 the committee ahead of getting the committee's 13 response.
14 So, I don't know that the committee was 15 aware of that, but we saw the document go out before 16 the staff had the committee's response. So, I think 17 it depends on what the committee's going to say in its 18 recommendations.
19 CHAIR BALLINGER: Okay. I mean, I think 20 we've pretty much settled on not doing a letter, 21 unless I hear something, strong arguments the 22 contrary. That being the case, we can have the 23 discussion at P&P and that's it, right?
24 MR. MOORE: That's correct.
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93 CHAIR BALLINGER: Okay. Are there other 1
folks that would like to chime in and add to the 2
discussion?
3 MR. RAHIMI: I have a question.
4 CHAIR BALLINGER: Who are you?
5 MR. RAHIMI: This is Meraj --
6 CHAIR BALLINGER: Oh, okay.
7 MR. RAHIMI: This is Meraj Rahimi, branch 8
chief of Regulatory Guides in the Office of Research.
9 And I guess my question is, do we need, because within 10 our branch, we're trying to hit a metric in terms of 11 issuing the final Reg Guide, do we need to wait until, 12 I guess, the subcommittee or the full committee, they 13 have their meeting before we can issue the Reg Guide, 14 now that it's been decided no letter is needed?
15 MR. MOORE: Meraj, this is Scott. The 16 full committee's in two weeks, when we have P&P.
17 MR. RAHIMI: Okay, good. Okay, yeah, two 18 weeks.
19 MEMBER REMPE: And the answer to his 20 question is, yeah, you need to wait until that P&P 21 discussion is over, right, Scott?
22 MR. MOORE: You should, yes.
23 CHAIR BALLINGER: Okay.
24 MR. RAHIMI: Okay.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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94 CHAIR BALLINGER: So, now, we're homing in 1
on it. We've got no letter and we'll have the 2
discussion at P&P and go from there. Last, but not 3
least, for sure, Steve Schultz, do you have anything?
4 DR. SCHULTZ: I have no further comments, 5
Ron, except what's been said by the members reflecting 6
the good work that has been done. And I do appreciate 7
the collaboration between industry and the staff in 8
working toward this resolution.
9 The industry's response really is one that 10 pulls together a lot of experience associated with 11 aging management and brings it together for the 12 application of this purpose. And so, I'm very glad to 13 see that.
14 CHAIR BALLINGER: Great. Okay. So, I 15 think, barring other comments, I think we're done for 16 the day. And, again, I'll speak again for the 17 committee as a whole and myself that this was a great 18 job that's been done up to this point and we're 19 looking forward to updates, as needed, as you go 20 forward. And with that being said, I think the 21 meeting is adjourned.
22 (Whereupon, the above-entitled matter went 23 off the record at 4:23 p.m.)
24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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©2021 Nuclear Energy Institute RG 3.76 / NEI 14-03 Completing the Regulatory Framework for Long-term Spent Nuclear Fuel Storage Rod McCullum Nuclear Energy Institute NRC ACRS June 23, 2021
©2021 Nuclear Energy Institute
© 2021 Nuclear Energy Institute 2 Used fuel inventory*
Approximately 86,000 MTU Increases 2 - 2.4k MTU annually ISFSI** storage 148,646 assemblies 41,000 MTU (48%)
3,370 casks/modules loaded 73 Operating dry storage ISFSIs Eventual deployment at 76 sites (119 reactors) 19 sites where reactor operations have ceased Long-term commitment First Casks Loaded in 1986 Licenses being extended to 60 years Licenses extensions approved at 32 sites Licenses renewable for additional 40 yr. periods NRC determined casks safe for at least 100 yrs Dry Cask Storage of US Spent Nuclear Fuel
- As of December 2021
- ISFSI = Independent Spent Fuel Storage Installation
©2021 Nuclear Energy Institute Long Term Dry Storage Framework NUREG 1927 MAPS RG 3.76 NEI 14-03 AMID Tollgates 10CFR72 ASME Code Case N-860 35 yrs.
Operating Experience Science NRC Inspections NEI RIRP (CISCC)
International Engagement
©2021 Nuclear Energy Institute Consistent format and content of license renewal applications (LRAs)
Operations-based aging management through learning aging management programs Sharing of operating experience related to aging management - AMID Periodic tollgate safety assessments NEI 14-03 Cornerstones
©2021 Nuclear Energy Institute LRA Format and Content Section 1: General Information Section 2: Scoping Evaluation Section 3: Aging Management Review Section 4: Time Limited Aging Analysis (TLAAs)
App. A: Aging Management Programs App. B: Granted Exemptions App. C: License/CoC Changes App. D: UFSAR Supplement Additional appendices as needed (environmental report supplement, financial qualification, etc.)
5
©2021 Nuclear Energy Institute Operations Based Aging-Management Effective licensee implementation of an operations-based DCS aging management program will require the ability to efficiently change AMAs based on feedback from operating experience, research, monitoring, and inspections 6
©2021 Nuclear Energy Institute Opportunity going forward As industry gains additional experience applying operations-based aging management, we envision reaching a future point at which it would be appropriate to re-engage in the dialogue relative to the use of surrogate inspection results.
- Feb. 1 2019 NEI letter to NRC
Proposed Final RG 3.76 Implementation of Aging Management Requirements for Spent Fuel Storage Renewals Kristina Banovac, Marlone Davis, Darrell Dunn, Ricardo Torres, John Wise Office of Nuclear Material Safety and Safeguards Division of Fuel Management Meeting with Advisory Committee on Reactor Safeguards Subcommittee on Metallurgy & Reactor Fuels and Subcommittee on Radiation Protection & Nuclear Materials June 23, 2021
Outline
- Background
- Updates to storage renewal framework -
completed and ongoing
- Public comment on draft RG 3.76 (DG-3055)
- Flexible and risk-informed framework
- Path forward 2
Background - Storage Renewal Requirements
- Renewal of Independent Spent Fuel Storage Installation specific licenses and Certificates of Compliance for dry storage system designs, for a period not to exceed 40 years
- 10 CFR §72.42 and §72.240
- Maintain intended functions in the period of extended operation (PEO)
- Time-limited aging analyses
- Aging management programs (AMPs) 3
Background - Update Storage Renewal Framework
- NRC staff experience with the renewal of storage licenses and certificates of compliance revealed a need for expanded guidance
- 15 storage renewal applications were expected to be submitted over several years
- NRC team assessed current regulatory framework to determine what changes were needed 4
Updates to the storage renewal framework - Completed
- NUREG-1927, Rev. 1 (Standard Review Plan for storage renewals), issued 2016
- Discussed with ACRS in 2015 and 2016. ACRS issued letter.
- NUREG-2214 (Managing Aging Processes in Storage (MAPS)), issued 2019
- Discussed draft MAPS with ACRS subcommittee in 2016
- Temporary Instruction 2690/011, issued 2018 5
Updates to the storage renewal framework - Ongoing
- Inspection Procedure for inspection of licensees AMP implementation
- Endorsement of ASME Code Case N-860 in RG 1.147
- Continue involvement with:
- Extended Storage Collaboration Program
- International counterparts (development of IAEA guidance on storage aging management)
- DOE/industry advancements in techniques for inspection, repair, and mitigation
- Research in fuel performance, degradation mechanisms; DOE/EPRI high-burnup fuel demonstration
- Risk assessment of canister aging mechanisms and effects (deposition chemistry, CISCC probability, crack growth rates, and consequence analysis) 6
- NEI 14-03 complements NRC staff guidance in NUREG-1927, Rev. 1
- 2 key aspects of NEI 14-03 included in NUREG-1927, Rev. 1
- Aggregation and dissemination of operating experience in Aging Management INPO Database (AMID)
- Learning AMPs and use of tollgates (periodic assessments of operating experience)
- Surrogate inspections
- Surrogate inspections for stainless steel canisters can be used when there is sufficient operating experience from canister examinations for various CISCC susceptibility rankings
- For other SSCs/materials, there is no guidance yet for determining what other SSCs may be appropriate for surrogate inspections
- Renewal application format and content
- Reflects lessons learned from reviews of renewal applications since issuance of NUREG-1927, Rev. 1 8
Public Comment on DG-3055
- Received one public comment from NEI on DG-3055
- NEI agrees with approach to surrogates and notes that industry will reengage with NRC on surrogates as operating experience is gained, encourages industry use of AMID
- Comment that specific proposed changes to the final safety analysis report (FSAR) are not needed in the renewal application
- NRC agrees with the comment; made a revision in the proposed final RG 3.76 to address the comment 9
Flexible and risk-informed framework
- Focus of renewal is on the continuation of the approved design bases and continued performance of SSCs important to safety
- AMPs are summarized in FSAR and under licensee change control; licensees may change AMPs without NRC approval if they meet 10 CFR 72.48
- Guidance does not specify corrective actions; rely on licensee quality assurance and corrective action programs
- Framework allows licensees to change AMPs to respond to operating experience and to ensure AMPs remain effective at managing aging effects in the PEO 10
Path Forward
- Storage renewals framework:
- Complete ongoing framework updates
- NRC revises guidance to respond to future operating experience, research, and development
- e.g., risk-inform canister inspections
- Licensees implement AMPs, enter operating experience into AMID, and make adjustments to AMPs to respond to operating experience
- NRC inspects licensees implementation of AMPs
- Ensure continued safe storage of spent fuel in the PEO 11
References 10 CFR Part 72, https://www.nrc.gov/reading-rm/doc-collections/cfr/part072/index.html NUREG-1927, Rev. 1, https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1927/index.html ACRS letter on NUREG-1927 (ML16102A167) and staff response (ML16132A170)
NUREG-2214, MAPS, https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2214/index.html Temporary Instruction 2690/011, ML20023A016 NEI 14-03, Rev. 2, ML16356A204 DG-3055, ML20282A298 Response to comment on DG-3055, ML21098A024 Proposed final RG 3.76, ML21158A061 12
Acronyms ACRS: Advisory Committee on Reactor Safeguards AMID: Independent Spent Fuel Storage Installation Aging Management Institute of Nuclear Power Operations Database AMP: aging management program ASME: American Society of Mechanical Engineers CFR: Code of Federal Regulations CISCC: chloride-induced stress corrosion cracking DOE: U.S. Department of Energy EPRI: Electric Power Research Institute FSAR: final safety analysis report IAEA: International Atomic Energy Agency NEI: Nuclear Energy Institute PEO: period of extended operation RG: Regulatory Guide SSC: structure, system and component 13