ML22215A260

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071822 NRC-NEI-22-02 Meeting Summary to Discuss Rsi Response
ML22215A260
Person / Time
Issue date: 08/05/2022
From: Janice Nguyen
Storage and Transportation Licensing Branch
To: Linda Howell
Division of Fuel Management
JC NGUYEN NMSS/DFM/STLB 3014150262
Shared Package
ML22215A259 List:
References
CAC A33009, EPID L-2022-NFO-0008, NEI-22-02
Download: ML22215A260 (3)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 5, 2022 MEMORANDUM TO: Linda Howell, Deputy Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM: John-Chau Nguyen, Senior Project Manager Storage and Transportation Licensing Branch Chau N. Digitally signed by Chau N. Nguyen Nguyen 12:22:47 -04'00' Date: 2022.08.05 Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUBJECT:

SUMMARY

OF JULY 18, 2022, PUBLIC MEETING TO DISCUSS THE NUCLEAR ENERGY INSTITUTE RESPONSES TO REQUESTS FOR SUPPLEMENTAL INFORMATION, DATED APRIL 29, 2022, ISSUED IN CONNECTION WITH NRC ACCEPTANCE REVIEW OF THE NEI-22-02 GUIDELINES FOR WEATHER-RELATED ADMINISTRATIVE CONTROLS FOR SHORT DURATION OUTDOOR DRY CASK STORAGE OPERATIONS PURPOSE:

For the U.S. Nuclear Regulatory Commission (NRC) staff and representatives from the Nuclear Energy Institute (NEI) to discuss NEIs response, dated June 22, 2022, to the NRC staffs request for supplemental information (RSI) dated April 29, 2022 (Agencywide Documents Access and Management System {ADAMS} Accession Nos. ML22168A135 and ML22111A272, respectively), issued in connection with its acceptance review of NEI 22 Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations. The meeting was noticed on June 30, 2022 (ADAMS Accession No. ML22181B064).

MEETING

SUMMARY

On July 18, 2022, NRC staff held an observation public meeting with representatives from NEI at NRCs headquarters in Rockville, Maryland. Attendees included NEI staff and its members, NRC staff, and members of the public. The discussion followed the agenda provided in . The list of meeting attendees is provided in Enclosure 2. NRC and NEI presentation slides presented during the meeting can be found in ADAMS at Accession Nos.

ML22196A085 and ML22194A068, respectively.

CONTACT: John-Chau Nguyen, NMSS/DFM 301-415-0262

L. Howell 2 Following introductions and opening remarks, NEI staff discussed the RSI issued by the NRC, which addressed the procedures, weather resources, duration, compensatory measures, and licensing and inspection activities relating to the NEI-22-02 guidance. NEI staff then discussed their response for each RSI along with changes they incorporated in revision 1 of the guidance.

NEI staff also pointed out what they did not include in the revision. NEI concluded its presentation by stating that the industry is committed to rigorous dry storage operation practices and that NEI-22-02 codifies that commitment with respect to severe weather and that revision 1 of the guidance makes that commitment stronger. NEI also stated that generic agreement on acceptable use of administrative controls to protect short duration dry storage operations is needed to preserve regulatory efficiency consistent with NRC principles of good regulation.

Following the NEI presentation, NRC staff presented information describing methods that the NRC staff considers acceptable to meet the regulations and highlighting applicable regulations for licensees and CoC holders to follow. NRC staff then provided an initial assessment of the RSI responses, which included (1) the NEI 22-02 guidance document should provide more detailed guidance to licensees and CoC holders on how to establish and implement administrative controls that would meet regulatory requirements including potential risk base discussions, (2) the introduction of engineering evaluations for CoC holders and licensees adds another layer of review and inspection instead of having the guidance document provide the necessary technical basis for the development of the administrative controls, and (3) the NEI 22-02 guidance document could provide templates for the incorporation into the technical specification, final safety analysis report, and/or 10 CFR 72.212 evaluation reports. A standard template would make it easier to incorporate versus having different versions with the engineering evaluations described in revision 1 of NEI-22-02. In addition, NRC staff provided examples of additional guidance needed for NEI-22-02.

Following the presentations and discussions, NEI staff advised that it would consider the use of engineering evaluations and the addition of templates but felt that further clarification from NRC was needed in order to provide additional detail in the guidance. NRC staff advised that it would consider appropriate next steps in its acceptance review of the guidance.

After the business portion of the meeting, members of the public participating by phone/webinar were given the opportunity to ask questions and make comments to the NRC staff. There were no comments from members of the public.

The meeting was adjourned at 3:00 p.m. No regulatory decisions were made at the meeting.

CAC/EPID No. A33009/ /L-2022-NFO-0008

Enclosures:

1. Meeting Agenda and Attendance List

L. Howell 3

SUBJECT:

SUMMARY

OF JULY 18, 2022, PUBLIC MEETING TO DISCUSS THE NUCLEAR ENERGY INSTITUTE RESPONSES TO REQUESTS FOR SUPPLEMENTAL INFORMATION, DATED APRIL 29, 2022, ISSUED IN CONNECTION WITH NRC ACCEPTANCE REVIEW OF THE NEI-22-02 GUIDELINES FOR WEATHER-RELATED ADMINISTRATIVE CONTROLS FOR SHORT DURATION OUTDOOR DRY CASK STORAGE OPERATIONS DOCUMENT DATE: August 5, 2022 Distribution:

NRC Attendees ADAMS ML22215A259 (PKG) ML22215A260 (LTR) ML22215A261 (ENC)

OFFICE: NMSS/DFM NMSS/DFM NMSS/DFM NAME: J C. Nguyen W.Wheatley Y Diaz-Sanabria DATE: 7/26/22 7/27/2022 8/2/2022 OFFICIAL RECORD COPY