ML19105B217

Memorandum to C. Regan Summary of March 20, 2019, Public Meeting to Discuss Request for Additional Information Issued in Connection with Nrc'S Review of the Interim Storage Partners Consolidated Isf Application (W/Enclosures 1 and 2)

ML19105B217
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	04/19/2019
From:	Janice Nguyen Spent Fuel Licensing Branch
To:	Christopher Regan Division of Spent Fuel Management
Nguyen J
References
CAC 001028, EPID: L-2017-NEW-0002
Download: ML19105B217 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 19, 2019 MEMORANDUM TO: Christopher M. Regan, Deputy Director Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards FROM: John-Chau Nguyen, Senior Project Manager Spent Fuel Licensing Branch /RA John McKirgan Acting for/

Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF MARCH 20, 2019, PUBLIC MEETING TO DISCUSS REQUEST FOR ADDITIONAL INFORMATION ISSUED IN CONNECTION WITH NRCS REVIEW OF THE INTERIM STORAGE PARTNERS CONSOLIDATED INTERIM STORAGE FACILITY APPLICATION FOR A FACILITY AT ANDREWS COUNTY, TEXAS PURPOSE:

For the U.S. Nuclear Regulatory Commission (NRC) staff and representatives from Interim Storage Partners (ISP) to discuss NRCs request for additional information (RAI) dated November 16, 2018 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML18320A184), issued in connection with its review of the license application (previously submitted by Waste Control Specialists) for the proposed ISP Consolidated Interim Storage Facility (CISF). The meeting was noticed on March 7, 2019 (ADAMS Accession No.

ML19066A273).

MEETING

SUMMARY

On March 20, 2019, NRC staff held a Category 1 public meeting with representatives from ISP at NRCs headquarters in Rockville, Maryland. Attendees included ISP and its contractors, NRC staff, and members of the public. The discussion followed the agenda provided in . NRC and ISP staff and contractors discussed the draft RAI responses, which were submitted to the NRC on March 12, 2019, and can be found in ADAMS at Accession No.

ML19073A272. Members of the public were given an opportunity to ask questions pertaining to the draft RAI responses following discussions between NRC and ISP. The list of meeting attendees is provided in Enclosure 2.

CONTACT: John-Chau Nguyen, NMSS/DSFM (301) 415-0262

C. Regan Following introductions and opening remarks, representatives from ISP discussed with NRC staff about its safety analysis associated with aircraft crash probability and impacts analysis.

RAI 2.2-1 requested an evaluation and aircraft crash probability impact analysis. ISP indicated that it had performed an aircraft hazards evaluation for the WCS CISF and added a summary of that evaluation in new SAR Section 2.2.1, Aircraft Hazard Evaluation. NRC staff inquired as to how the area for crash evaluation was determined. Following discussion between NRC staff and ISP, NRC staff emphasized that the applicant should seek to follow NRC guidance as it relates to this analysis.

RAI 2.2-2 requested the locations of nearby industrial, transportation, military, and nuclear installations, and to describe potential hazards to the proposed WCS CISF from activities or materials at those facilities. NRC staff noted that the applicant had evaluated the hazards associated with such facilities and installations, but observed that results and other details of the analyses were presented inconsistently within the response to the RAI and hence, the SAR.

NRC staff encouraged the applicant be more consistent with regard to these and other sections of the SAR relative to accident and hazard analyses and scenarios.

RAI EP-4 requested clarification of statements in SAR Section 3.1, Classifications of Accidents, of the proposed consolidated emergency response plan (CERP), which refer to classification of accidents at the proposed CISF for both an Alert and Site Area Emergency declarations; and RAI EP-19 sought justification as to why the most recent version of the NRC endorsed methodology for the development of emergency action levels (EALs) was not used in the development of the EALs for the WCS CERP specific to the CISF. ISP indicated that it had revised Section 3.1 of the draft CERP to clarify which classifications of accidents are specific to each facility (the existing Waste Control Specialists SP&D facilities or WCS CISF). ISP also indicated that newly added Appendix D of the CERP WCS CISF Facility Emergency Action Levels had been incorporated, using as guidance NEI 99-01 Development of Emergency Action Levels for Non Passive Reactors, Revision 6, dated November 2012 to develop EALs applicable to the WCS CISF.

NRC staff indicated that there were some discrepancies among the tables in the SAR regarding emergency action levels, and that those discrepancies were to be addressed, or modifications made to the EALs and EAL classifications. Finally, staff noted that there existed inconsistencies with regard to unusual events vs. alerts and that these inconsistencies in the CERP were to be further addressed by the applicant.

RAI EP-6 sought clarification about responsible individuals (designated emergency response organization (ERO) position) on site at all times (24-hour per day, 7 days per week) with the authority and responsibility to accurately and timely perform emergency classification, and notify offsite agencies and the NRC. The applicant indicated that it had revised the CERP to address this issue. NRC staff and ISP also discussed the need to articulate in the CERP, timely emergency communications, and the issue of prompt notification and incident response coordination, and identification of personnel performing those functions.

RAI EP-13 sought to have the applicant revise the threshold limits in Section 5.5, Exposure Control, and Table B, Protective Action Guidance, of the proposed CERP to ensure consistency with the latest version of the U.S. Environmental Protection Agency (EPA)

Protective Action Guide (PAG) Manual for early phase PAGs. NRC staff reiterated the need for consistency for all dry cask storage emergency preparedness plans and activities.

C. Regan ISP indicated that it had revised the table in CERP Section 5.5 and designated the table as Table C to ensure consistency with the latest version of the U.S. EPAPAG Manual for early phase PAGs. ISP indicated that the recommended actions listed in Table C are now consistent with the PAG but are worded slightly different to more closely match the WCS facilities.

The meeting adjourned at 1:15 p.m. The public asked no questions following the business portion of the meeting. No regulatory decisions were made at the meeting.

Docket No.: 72-1050 CAC/EPID No.: 001028/L-2017-NEW-0002

Enclosures:

1. Meeting Agenda

2. Attendance list

C. Regan

SUMMARY

OF MARCH 20, 2019, PUBLIC MEETING TO DISCUSS REQUEST FOR ADDITIONAL INFORMATION ISSUED IN CONNECTION WITH NRCS REVIEW OF THE INTERIM STORAGE PARTNERS CONSOLIDATED INTERIM STORAGE FACILITY APPLICATION FOR A FACILITY AT ANDREWS COUNTY, TEXAS, DOCUMENT DATE: April 19, 2019 DISTRIBUTION:

DSFM r/f NRC Attendees Filename: G:\SFST\Nguyen\Casework\WCS\03202019 Public Meeting to discuss RAIs/Final for Publication MTNG

SUMMARY

03202019.docx Memo: ML19105B217 ISP Meeting Information: ML19073A272 C=Without attachment/enclosure E=With attachment/enclosure N=No copy OFFICE: SFM SFM SFM SFM NAME: RTurtil JNguyen WWheatley JMcKirgan DATE: 4/12/2019 4/15/2019 4/15/2019 4/19/2019 OFFICIAL RECORD COPY

AGENDA Public Meeting between Interim Storage Partners, LLC (ISP), and the Nuclear Regulatory Commission (NRC)

March 20, 2019 12:30 p.m. - 3:30 p.m. (Eastern Standard Time)

Room: 3WFN-8A28

Purpose:

To discuss NRCs request for additional information, dated November 16, 2018, issued in connection with NRCs review of the license application for the proposed ISP Consolidated Interim Storage Facility at Andrews County, TX.

12:30 p.m. - 12:35 p.m. Introductions / Opening Remarks NRC/ISP 12:35 p.m. - 12:55 p.m. Discussion of Site Characteristic-related ISP/NRC request for additional information (RAIs) 2.2-1 and 2.2-2 12:55 p.m. - 3:15 p.m. Discussion of Emergency Response ISP/NRC Plan-related RAIs EP-1 through EP-20 3:15 p.m. - 3:30 p.m. Opportunity for Public Questions and NRC/Public Comments for NRC staff 3:30 p.m. Adjourn Enclosure 1

MEETING ATTENDEES

Participants:

ISP and the Nuclear Regulatory Commission Date: March 20, 2019, 12:30 P.M. - 3:30 P.M.

Location: Three White Flint North, Room 1C03 NAME AFFILIATION Ilka Berrios NRC John-Chau Nguyen NRC Michael Norris NRC Richard Turtil NRC Seshagiri Tammara NRC Joseph Anderson NRC Richard Turtil NRC Alana Wase NRC Kara McCullough NRC Jeff Isakson ISP Elicia Sanchez ISP Jack Boshoven ISP Timothy Matthews Morgan Lewis Stephen Burdick Morgan Lewis Earl Easton ISP Renee Murdock / call-in ISP Ben Mason ISP Annette Haynes / call-in ISP Jay Cartwright ISP Jay Britten ISP Enclosure 2

NAME AFFILIATION Paul Romo / call-in ISP Wren Fowler / call-in NAC Jenny Caldwell / call-in ISP Donna Gilmore / call-in Public Carlyn Greene / call-in UxC Veena Gubbi/call in New Jersey State Government Michael Keegan/call in Public/Dont Waste Michigan Nuclear Information and Resource Diane DArrigo/call in Service Lane Howard / call-in SWRI Anthony Leshinskie /call in State of Vermont Laura Schwartz/call in Intl. Technology and Trade Association