ML18346A520

Presentation Slides: Mccullum Reg Con 12 12

ML18346A520
Person / Time
Site:	Nuclear Energy Institute
Issue date:	12/12/2018
From:	Mccullum R Nuclear Energy Institute
To:	Haile Lindsay NRC/NMSS/DSFM/IOB
Lindsay H
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©2018 Nuclear Energy Institute Understanding Dry Storage Safety Margin Rod McCullum NRC REG CON December 12, 2018

©2018 Nuclear Energy Institute 2 Industry Strategic Focus NATIONAL NUCLEAR ENERGY STRATEGY Appropriately value nuclear generation Create sustainability via improved regulatory framework and reduced burden

Innovate, commercialize, and deploy new nuclear Compete globally PRESERVE SUSTAIN INNOVATE THRIVE

©2018 Nuclear Energy Institute 3 Graded Approach to Licensing Reviews (RIRP-I-16-01)

We expect this initiative to make the storage licensing process more effective. This effort would reduce the number of amendments needing NRC review and approval by adjusting the level of information included in the technical specifications. - Marc Dapas So the Fuel Qualifications Table can be placed in the SAR, and if the licensee wishes to do some changes to loading patterns or things like that need a modification to the Fuel Qualifications Table, they can do that on their own and not come in for an amendment. - Mike Layton Change Control We completed our review of the Nuclear Institute guidance document 12-04, entitled Guidelines for 10 CFR 72.48 implementation, Revision 1, and starting working on the draft regulatory guide that would endorse this guidance document. - Marc Dapas Regarding method of evaluation, weve had significant engagement with the industry to reach alignment on what is allowed, if you will, within the context of 72.48. - Marc Dapas

Aging Management We are now working through the process to consider endorsing an industry-proposed format and content guide for aging management, NEI 14-03. These process enhancements have already demonstrated increased efficiencies in the reduction of number of request for supplemental or additional information. For example, weve receive three license renewal applications which were accepted and docketed without any requests for supplemental information. - John McKirgan NMSS Commission Brief 10/11/18

©2018 Nuclear Energy Institute 4 Thermal Modeling I had the opportunity of course to see the cask demonstration project at North Annaand then attend a Used Fuel Working Group meetingwhere a presentation was provided that showed that the thermal models are conservative when you look at the comparison of what that model predicts relative to the actual parameters, the temperature measurements youre seeing at the demonstration project. - Marc Dapas And so its with a positive outlook that were going to be able to reduce the uncertainties here in using the models, will facilitate more efficient reviews of the licensing actions. - Marc Dapas NMSS Commission Brief 10/11/18

©2018 Nuclear Energy Institute 5 What the High-Burnup Demo tells us about Margin

©2018 Nuclear Energy Institute 6 Dry Storage Safety Margin Reality Model A Model B Established Limit or Criteria Where We Would Still Be Safe What we are debating

Change in Perceived Reactor Safety Margin NRC Safety Goal

?

Factor of 2-5 Factor of 2-5 Factor of 100 - 10,000 Margin to Safety Goal Severe Accident Research - Improving State of Knowledge 2005 1990 1995 2000 1985 2010 2015 NUREG-1150 - Severe Accident Risks Demonstrates that five representative nuclear powers plants are well within the Safety Goal NRC State-of-the-Art Severe Accident Consequence Analysis (SOARCA)

Applied state of the art modeling methods to assess consequences of reactor accidents

©2018 Nuclear Energy Institute 8 Thermal Conditions Radiation Levels Canister Integrity Where is the Margin in Dry Storage?

©2018 Nuclear Energy Institute 9 Develop a systematic approach to applying known margin to facilitate more efficient reviews of licensing actions and safety focused inspections Industry should propose a solution Industry must pre-align with NRC on submittal form and approval/endorsement path NEI/EPRI collaborative effort Industry volunteers needed to support Where do we go from here

Questions?

rxm@nei.org