ML22047A142

NEI 22-02: Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations Presentation Slides

ML22047A142
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/17/2022
From:	Nuclear Energy Institute
To:	Office of Nuclear Material Safety and Safeguards
Tomeka Terry NMSS/DFM/IOB 301-415-1488
References
Download: ML22047A142 (9)

Text

NEI 22-02: GUIDELINES FOR WEATHER-RELATED ADMINISTRATIVE CONTROLS FOR SHORT DURATION OUTDOOR DRY CASK STORAGE OPERATIONS NRC Public Meeting: Independent Spent Fuel Storage Installation (ISFSI) Operations February 17, 2022 Nuclear Energy Institute

©2022 Nuclear Energy Institute

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Background===

NRC inspectors have questioned industry practices during short duration dry cask storage operations In a letter of 10/29/2021 NEI

• raised backfit concerns regarding these questions

• pointed out that this issue of very low safety significance had the potential to disrupt dry cask storage operations across the country

• proposed using the Very Low Safety Significance Issue Resolution Process to address the issue In an 11/9/2021 meeting there was a thorough discussion of the issue and the potential to resolve them using the VLSSIR process These discussions have not, yet, led to resolution

©2022 Nuclear Energy Institute 2

Overview Certificates of Compliance (CoCs) for dry storage systems (DSS) have been issued by NRC under Part 72 since the 1990s 72.122 requires DSS to withstand natural phenomena including tornado missiles 72.122 is broadly worded and does not specify how the analyses must be conducted CoCs include deterministic tornado analysis for fully loaded casks, but many short-duration operations were not required to be covered by those deterministic analyses For short-duration operations where deterministic analysis was not required, safety is ensured through admin controls - no loading takes place in inclement weather This issue is of very low safety significance Guidance on administrative controls may be useful to address NRC questions

©2022 Nuclear Energy Institute 3

VLSSIR and Principles of Good Regulation Very Low Safety Significance Issue Resolution (VLSSIR) Process has been used by the NRC 11 times in the reactor area It is designed to efficiently manage issues of very low safety significance when there is uncertainty in the licensing basis NRCs Principles of Good Regulation indicate:

Regulatory activities should be consistent with the degree of risk reduction they achieve.

Where several effective alternatives are available, the option which minimizes the use of resources should be adopted.

VLSSIR should be used to address the short-duration issue as it arises in NRC inspections NEI 22-02 is being proposed to align NRC and industry on appropriate use of administrative controls during short-duration operations

©2022 Nuclear Energy Institute 4

NEI 22-02 Introduction Scope of the Guidance Guidance References

©2022 Nuclear Energy Institute 5

NEI 22 Scope of the Guidance Overview of short-duration outdoor DCS activities Common examples of short-duration outdoor activities Industry experience Licensing bases and administrative controls

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NEI 22 Guidance Proactive administrative controls Reactive administrative controls Resources Use of severe weather alerts to guide decision-making Implementation

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Closing Remarks Expectation that tornado analyses address all short-term ISFSI operations unreasonable and outside of the licensing basis for general ISFSI licensees Issue is of very low safety significance VLSSIR process is a good fit for determining whether NRC and industry resources are best spent to resolve the STO issue as it arises in the context of NRC inspections Any inspection findings should be subject to backfit analysis NRC endorsement of NEI 22-02 would clarify appropriate use of administrative controls during STO, if needed

Discussion