ML23006A023

NEIs Presentation for the December 15, 2022 Spent Fuel Priorities Meeting with NEI

ML23006A023
Person / Time
Issue date:	12/15/2022
From:	Richter M Office of Nuclear Material Safety and Safeguards
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Download: ML23006A023 (17)

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NRC and NEI/Industry Spent Fuel Activities Prioritization Public Meeting (Observation Meeting)

Meeting with Nuclear Energy Institute and Members from the Spent Fuel Industry December 15, 2022 1

Agenda Topic Time Speakers Introduction 1:00 PM NRC & NEI NRC Presentation 1:10 PM NRC Industry Presentation 1:25 PM NEI Open Discussion 1:40 PM NRC & NEI Summary Review & Closing Remarks 2:40 PM NRC & NEI Opportunity for Public Comment 2:45 PM Public 2

Introductions/Opening Remarks Shana Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards Mark Richter, Technical Advisor Nuclear Energy Institute (NEI) 3

NRC Presentation 4

Background:

How We Got Here

• 2019 - NEI White Paper, Discussing spent fuel performance margins along with some recommendations to be implemented, November 2019 (ADAMS Accession No. ML19318D971)

• 2021 - Implementation of the Recommendations of Industrys November 8, 2019, White Paper, Defining Spent Fuel Performance Margins, January 2021 (ML21025A356)

• 2021 - Summary of April 13, 2021, Observation Public Workshop on Spent Fuel Performance Margins, June 2021, (ML21139A109) 5

NRC Priorities

• Maintain a highly qualified workforce through recruitment, hiring, qualification, and training activities as informed by Strategic Workforce Planning

• Safety, security, and environmental reviews of licensing applications for casks (including related rulemakings), independent spent fuel storage installation (ISFSIs) (including renewals), and consolidated interim storage facility (CISF)

• Safety and security reviews of transportation packages (including renewals and revalidations)

• Licensing accident tolerant and advanced fuels o Enhance the technical basis for review of transportation packages with batch quantities of fresh accident tolerant fuel (ATF) 6

NRC Priorities (continued)

• Continue risk-informed initiatives, including incorporating technical information into guidance for spent fuel licensing o Continued application of the Risk Tool, Be riskSMART, and other risk-informed tools

• Conduct oversight activities, including revision of inspection guidance, inspector training and qualification, aging management inspections, and safety inspections of ISFSI pad construction, dry-run operations, initial loading operations, and routine operations

• International engagement regarding storage and transportation activities to compare regulatory frameworks, share research information, and harmonize with international standards

• Closure on the ISFSI short-term operations issue 7

Phenomena Identification and Ranking Table (PIRTs)

• Used Fuel Cladding Performance PIRT (June 2020) https://www.epri.com/research/products/000000003002018439 o Evaluated state of knowledge as a basis for potential changes to criteria to prevent gross rupture

• Thermal Modeling PIRT (June 2020) https://www.epri.com/research/products/000000003002018441 o Identified and ranked opportunities to quantify and reduce uncertainty in cask thermal analyses through focused research and development (R&D) modeling

• Decay Heat PIRT (July 2020) https://www.epri.com/research/products/000000003002018440 o Identified, evaluated, and ranked the various parameters that affect the accurate prediction of decay heat

• Spent Fuel Cladding Gross Rupture PIRT (December 2021) https://www.epri.com/research/products/000000003002020929 o Basis for potential revision to definition of gross rupture (practical, safety-focused) 8

Accomplishments

• Regulatory Guide 3.72, "Guidance for Implementation of 10 CFR 72.48, Changes, Tests, and Experiments (Rev. 1 issued Sept. 2020)

(https://www.nrc.gov/docs/ML2022/ML20220A185.pdf) o Endorsed NEI 12-04, Guidelines for 10 CFR 72.48 implementation

• Evaluation of Increased Peak Temperatures for Spent Fuel Cladding Performance during Dry Storage, PNNL-30430 (July 2021) https://www.nrc.gov/docs/ML2027/ML20276A067.pdf/ML21176A031 o Enhance understanding of the safety margins associated with the peak cladding temperature (e.g., current 400°C threshold); input to Alternative Fuel Performance Metrics PIRT

• Approval of Thermal Topical Report (September 2021) https://www.nrc.gov/docs/ML2130/ML21302A147.pdf o Approved allowance of heat load patterns in two storage systems 9

Further Risk-informed Accomplishments

• COVID enforcement guidance memorandum, revised inspection guidance, and relief requests

- https://www.nrc.gov/about-nrc/covid-19/materials/index.html

• Enforcement Guidance Memorandum (EGM) 22-01, "Enforcement Discretion For Noncompliance of Tornado Hazards Protection Requirements at Independent Spent Fuel Storage Installations, April 2022 https://www.nrc.gov/docs/ML2208/ML22087A496.pdf o Recognized the low probability of tornado events in conjunction with formally documented administrative controls

• First-time use of the Very Low Safety Significance Issue Resolution (VLSSIR) Process in the materials arena Joseph M. Farley Nuclear Plant -

Integrated Inspection Report 05000348/2022002 And 05000364/2022002 o Closed an issue related to use of administrative controls when conducting cask transfer operations outside of the fuel handling building in a different configuration to those analyzed in the final safety analysis report (FSAR) 10

Current Activities

• Graded Approach (ADAMS Accession No. ML19353D337) o Completed the graded approach pilot in September 2020 o Served as a positive step forward in risk-informing the format and content of storage certificate of compliances (CoCs) and appendices o Variations have been used by some vendors in a few applications currently under review

• Risk Tool (ADAMS Accession No. ML20324A110) o Risk tool - serves to support staff in their dry cask storage reviews to determine the appropriate risk o The risk tool has been used in a few technical reviews o The risk tool is a living document 11

Current Activities (continued)

• Alternative Fuel Performance Metrics PIRT (To be issued in 2023) o Perspectives on whether/how current guidance on fuel drying may be revised (e.g., considering any margins in current 400°C threshold)

• Topical Reports o Shielding Topical Report (ADAMS Accession No. ML22038A943)

• Regulatory Guidance for the use of Administrative Controls during Short Term Operations (planned issuance in 2023) 12

NEI Presentation 13

Open Discussion Between NRC and NEI 14

Summary Review &

Closing Remarks 15

Opportunity for Public Comment 16

If You Have Additional Questions to Be Asked of NRC Staff, Contact Linda Howell, Special Assistant Division of Radiological Safety and Security Region IV Email: Linda.Howell@nrc.gov Phone: 817-200-1287 Haile K. Lindsay, Ph.D., Technical Assistant Division of Fuel Management Office of Nuclear Material Safety and Safeguards Email: Haile.Lindsay@nrc.gov Phone: 301-415-0616 17