ML23321A132

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Letter Issuing NRC Endorsement of Risk-Informed Methodology for Project Pele
ML23321A132
Person / Time
Site: 07109396
Issue date: 08/05/2024
From: Yoira Diaz-Sanabria
Storage and Transportation Licensing Branch
To: Waksman J
US Dept of Defense (DOD)
Shared Package
ML23321A131 List:
References
EPID L-2022-NFN-0009
Download: ML23321A132 (1)


Text

Dr. Jeff Waksman Strategic Capabilities Office U.S. Department of Defense 4755 Meadow Wood Lane Chantilly, VA 20151

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION REVIEW OF THE RISK ASSESSMENT APPROACH FOR TRANSPORTATION PACKAGE APPROVAL OF THE PROJECT PELE TRANSPORTABLE NUCLEAR POWER PLANT FOR DOMESTIC HIGHWAY SHIPMENT

Dear Dr. Waksman:

By request dated February 20, 2023 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML23066A201), as supplemented on September 18, 2023 (ML23268A328), on behalf of the Strategic Capabilities Office (SCO) within the U.S. Department of Defense (DoD), Pacific Northwest National Laboratory (PNNL) asked the U.S. Nuclear Regulatory Commission (NRC) to review the PNNL document Development and Application of Risk Assessment Approach for Transportation Package Approval of a Transportable Nuclear Power Plant for Domestic Highway Shipment.

The NRC staff determined that the risk-informed methodology is generally acceptable for a future applicant to use in its application for transport approval of either the Project Pele demonstration transportable micro-reactor or a potential future DoD tri-structural isotropic-based micro-reactor to the extent specified and limited in this letter and in the enclosed evaluation of the risk-informed methodology. Specifically, the NRC review of the risk-informed methodology includes the frequency-consequence plots and the steps needed to determine accident frequency and their consequences (see items 1 through 5 in the Summary in the enclosure),

along with defense-in-depth and sensitivity analyses.

At this time, the NRC reviewed the risk-informed methodology consistent with the demonstration probabilistic risk assessment, for two transports one per year, one away from and one back to the Idaho National Laboratory (INL). The NRC review did not consider the risk associated with additional transports. Therefore, the NRC endorsement of the methodology is limited to scenarios with one transport per year, one away from and one back to specified location. The methodology may be able to be used in scenarios where there are multiple shipments per year, but it would require additional considerations and/or justifications to support the additional transports. If an application were to be submitted using the risk-informed methodology in the future, an independent peer review of the future applicants probabilistic risk assessment would be beneficial and make for a more efficient review.

August 5, 2024

J. Waksman In its letter dated April 15, 2024 (ML24113A069), SCO stated its reasons for discontinuation of work on the Project Pele transportation application and expressed its continued interest in the NRC endorsement of the risk-informed methodology. SCO, through its contractor PNNL, indicated that the future package application for a DoD transportable micro-reactor may include a request for exemptions from the dose rate and containment criteria in 10 CFR 71.51(a)(2) after being evaluated for tests for hypothetical accident conditions specified in 10 CFR 71.73, Hypothetical accident conditions. If the application for a future package application for a DoD transportable micro-reactor seeks exemptions, the package application would need to be accompanied by an environmental report, unless one of the categorical exclusions in 10 CFR 51.22(c) is applicable. Under the NRCs regulations, the categorical exclusion in 10 CFR 51.22(c)(13) for package designs for packages to be used for the transportation of licensed materials generally does not apply to packages that rely on exemptions from the specific package approval regulations. If the applicant only requests a review of the package application, without the NRC authorizing transportation, then an environmental report is not needed.

The NRC requests that SCO publish the risk-informed methodology as a PNNL document. In publishing the document, consider including an appendix in the PNNL document containing all historical review information (i.e., responses to the request for additional information and slides for the meetings with the Advisory Committee on Reactor Safeguards). After publication of the risk-informed methodology as a final PNNL document, the NRC will issue an endorsement of the PNNL document.

If you have any questions regarding this approval, please contact Bernard White of my staff at (301) 415-6577 or send an email to Bernard.White@nrc.gov.

Sincerely, Yoira Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9396 EPID No. L-2022-NFN-0009

Enclosure:

Risk-Informed Methodology Evaluation cc w/encl:

Steve Schilthelm, BWXT Harold Adkins, PNNL Steve Maheras, PNNL Jeff England, NAC International, Inc.

Signed by Diaz-Sanabria, Yoira on 08/05/24

ML23321A132 SECY-24-0062 (ML23320A124)

OFFICE NMSS/DFM NMSS/DFM NMSS/DFM QTE NMSS/DFM NAME BWhite BWagner DForsyth JDougherty WWheatley DATE 12/11/2023 12/14/2023 12/12/2023 12/01/2023 12/13/2023 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM OGC NMSS/DFM NAME DJohnson YDiaz-Sanabria SHelton TJones YDiaz-Sanabria DATE 12/14/2023 12/15/2023 12/19/2023 02/09/2024 08/05/2024