ML21218A073

Summary of July 7, 2021, Public Meeting Webinar Related to Extreme Environmental Phenomena During Short Term Operations within 10 CFR Part 72 Jurisdiction

ML21218A073
Person / Time
Issue date:	08/06/2021
From:	Tomeka Terry NRC/NMSS/DFM/IOB
To:	Christopher Regan Division of Fuel Management
TLTerry NMSS/DFM/IOB 301.415.1488
References
Download: ML21218A073 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 6, 2021 MEMORANDUM TO: Christopher Regan, Deputy Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards THRU: Francis Paul Peduzzi, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM: Tomeka Terry, Project Manager Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF THE JULY 7, 2021, PUBLIC MEETING WEBINAR RELATED TO EXTREME ENVIRONMENTAL PHENOMENA DURING SHORT TERM OPERATIONS WITHIN 10 CFR PART 72 JURISDICTION On July 7, 2021, the staff of the U.S. Nuclear Regulation Commission (NRC) conducted a virtual public meeting webinar with representatives from Holtec International (Holtec), the nuclear industry, and members of the public. The purpose of this meeting was to discuss in greater context a letter Holtec submitted to the NRC on May 12, 2021. The Holtec letter requested the NRC to provide clarification on the consideration of extreme environmental phenomena (EEP) related to tornado missile protection, during short-term operations and transient loading operations during a dry cask storage loading campaign. The Holtec letter, public meeting notice and agenda topics are available in the Agencywide Documents Access and Management System (ADAMS) under Accession Nos. ML21132A298 and ML21188A203, respectively. The enclosure to this document contains the webinar attendance list. Additionally, there were no regulatory decisions or commitments made by the NRC staff during the meeting.

During the public meeting webinar, Holtec presented an overview of their position regarding the treatment of a EEP for transient or transitional evolutions that occur during short-term operations.

The NRC staff followed with a presentation on the existing regulations and guidance documents regarding EEP specific to tornado missile protection. Both presentations are available in ADAMS under Accession Nos. ML21188A044 and ML21188A047, respectively.

CONTACT: Tomeka Terry, NMSS/DFM 301-415-1488

C. Regan Discussion The webinar promoted an open dialogue with representatives from Holtec, the nuclear industry, and members of the public. There were over 100 participants including the NRC staff. As discussed and presented in the Holtec presentation, Holtec wanted to use a probabilistic assessment or risk-informed approach to meet their design basis and wanted to consider the probability of tornado wind, pressure, and missile accidents during short term operations to be non-credible. Additionally, Holtec wanted to utilize administrative controls such as checking the weather and historical meteorological data to manage and reduce the risk of these events prior to conducting these short term operations to avoid environmental phenomena impacts without the need to explicitly analyze the transitional evolutions as designated in the regulations. The NRC staff asked clarifying questions, provided its perspective, and indicated that the staff will continue to review and discuss internally to determine a path forward.

During the NRCs staff presentation, the staff presented the existing regulatory requirements and guidance documents such as the General Design Criteria captured in Title 10 of the Code of Federal Regulations (CFR) 72.122(b), Protection against environmental conditions and natural phenomena, and the NUREG 2215, Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities, which provides the requirements and guidance for licensees and certificate of compliance holders. The NRC noted that the information provided in those documents establish that important-to-safety components shall and should always be protected and does not distinguish between what is considered a short-term operation.

Holtec is seeking alignment from the NRC on the need for guidelines on transient configurations.

The NRC staff acknowledged the request from Holtec and industry representatives. The NRC also asked if industry would be proactive in recommending a solution and establishing a clear problem statement and overall expectations. The Holtec Users Group committed to initiating a follow-up discussion with Holtec and to provide a response to clarify what the industry is asking.

The NRC Senior Level Advisor for Risk Assessment apprised Holtec that design basis analysis is used to bound consequences of an event. In the case of tornado missiles being generated, industry must recognize at lower magnitudes tornadoes, theres a higher frequency in generating tornado missiles that needs to be considered. As such, the consequence versus frequency needs to be bounded.

The NRC doesnt consider current industry practice as a means for holding up a loading campaign because of a lack of clarity on this issue. The current regulatory framework is sufficient to allow for a loading campaign to move forward.

Action Items/Next Steps The NRC staff recognizes that the existing regulatory requirements and guidance within 10 CFR Part 72 do not account for the treatment of an EEP during transient or transitional evolution that occur in course of short-term operations. The use of a probabilistic risk or risk-informed approach as a standalone basis combined with administrative controls without a licensing action could result in uncertainty for meeting regulatory requirements. The NRC staff will assess the industrys concerns to determine a path forward.

C. Regan The meeting also provided members of the public the opportunity to ask questions and provide comments to the NRC staff. The NRC staff received two comments from the public and responded to the comments for noticing the public meeting.

Enclosure:

List of Attendees

ML21218A073

• via email OFFICE DFM DFM DFM DFM NAME TTerry* WWheatley* ELove* Earl Love for/

PPeduzzi*

DATE 08/05/2021 08/05/2021 08/06/2021 08/06/2021 LIST OF ATTENDEES JULY 7, 2021, PUBLIC MEETING REGARDING EXTREME ENVIRONMENTAL PHENOMENA DURING SHORT TERM OPERATIONS WITHIN 10 CFR PART 72 JURISDICTION Name Affiliation Shana Helton Nuclear Regulation Commission (NRC)

Chris Regan NRC Yoira Diaz Sanabria NRC Earl Love NRC Marlone Davis NRC Matt Learn NRC Tom Boyce NRC John McKirgan NRC Tomeka Terry NRC Donnie Harrison NRC Ray Kellar NRC Pravin Patel NRC Ricardo Rodriguez NRC Stefan Anton Holtec International (Holtec)

Kim Manzione Holtec Chuck Bullard Holtec Matt Block Holtec Debu Mitra-Majumdar Holtec Brian DiPaolo Holtec Venkat Prabhala Holtec Rob Tindal Holtec Brian Gutherman Gutherman Technical Service, LLC Don Shaw Orano TN Zachary Kitts Tennessee Valley Authority Mark Oswald STP Nuclear Operating Company Richard Hagler Pacific Gas & Electric Company Doug Yate Abhijit Honrao Exelon Nuclear Abbas Abady Exelon Nuclear Benjamin Day Exelon Nuclear George Budock Exelon Nuclear Michael Cazzolli Exelon Nuclear Glenn Stewart Exelon Nuclear anonymous callers*

• Not all meeting attendees were identified by name, in some cases the only identifying information available was a phone number.

Enclosure