ML22194A068

NEI Presentation for NEI 22-02 Rsi Response

ML22194A068
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/18/2022
From:	Nuclear Energy Institute
To:	Storage and Transportation Licensing Branch
JCNGYEN NMSS/DFM/STLB 3014150262
References
NEI 22-02
Download: ML22194A068 (10)

Text

NEI Response to NRCs Acceptance Review of NEI 22-02 - Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations NRC Public Meeting: July 18, 2022 Nuclear Energy Institute

©2022 Nuclear Energy Institute

Dry Cask Operations and Weather Administrative Controls have been reliably preventing severe weather disruptions of dry cask operations for 35+ years

• A safe and efficient alternative to tornado missile analyses of all operational configurations

• Consistent with severe weather considerations for other outdoor plant operations and maintenance

• NRC staff now questioning this practice for various site-specific configurations NEI 22-02 submitted (2/16/22) to clarify use of Administrative Controls

• Demonstrates Industry commitment to rigorous approach

• NRC endorsement would provide generic acceptance of Administrative Control use

• NRC Enforcement Guidance (4/15/22) provides time for agreement to be reached NRC Requested Supplemental Information (RSI) (4/29/22)

Industry submitted revision to NEI 22-02 (6/17/22)

• Bolsters industry commitment to sound practices in avoiding severe weather disruptions

• Enhances safety while preserving efficiency

©2022 Nuclear Energy Institute 2

NRC Requests for Supplemental Information Procedures

• Additional guidance and consistent approach requested Weather Resources

• Additional guidance on how industry uses these resources requested Duration

• Specifics on estimating time windows requested Compensatory Measures

• Acceptance criteria, site-specific information, staffing information, and malfunction contingencies requested Licensing and Inspection

• Guidance on incorporating Administrative Controls into Technical Specifications/Final Safety Analysis Report (FSAR)/72.212 report requested

©2022 Nuclear Energy Institute 3

Industry RSI Response - Procedures NEI 22-02 revised to recommend:

• CoC holders add generic severe weather info. to FSAR

• Licensees develop engineering evaluations as technical basis for site-specific administrative controls

• Licensee procedures include timing and frequency of weather forecast checks

• Recommend that Licensee procedures clearly specify compensatory actions, roles, and responsibilities NEI 22-02 revision does not include

• Recommendations for broad scope design review (out of scope)

• Recommendations for a graded response to weather conditions of varying severity

©2022 Nuclear Energy Institute 4

Industry RSI Response - Weather Resources NEI 22-02 revised to:

• Address the use of relevant onsite meteorological data

• Recommend licensees use radar projections

• Clarify that personnel address forecast changes during DCS operations if self-identified or if informed by control room

©2022 Nuclear Energy Institute 5

Industry RSI Response - Duration NEI 22-02 revised to:

• Add most of NRC suggested checklist for use as appropriate and recommend inclusion of estimated durations in FSAR

• Address malfunctions and delays

• Recommend that estimated durations be addressed in licensee specific engineering evaluations

©2022 Nuclear Energy Institute 6

Industry RSI Response - Comp. Measures NEI 22-02 revised to:

• Add a list of things to be considered in the development of Administrative Controls

©2022 Nuclear Energy Institute 7

Industry RSI Response - Licensing and Inspection NEI 22-02 revised to:

• Recommend that CoC holders reference NEI 22-02 in FSARs

• Recommend that CoC holders include generic guidance for Administrative Controls in the Operations Chapter of the FSAR

• Include new guidance clarifying roles and responsibilities between CoC holders and licensees NEI 22-02 revision does not include

• Guidance on including Administrative Controls in Technical Specifications

• Address nonconforming or degraded conditions

©2022 Nuclear Energy Institute 8

Conclusion Industrys commitment to rigorous dry storage operational practices has successfully protected public health and safety for 35+ years NEI 22-02 codifies that commitment w.r.t. severe weather NEI 22-02 Rev. 1 (response to NRC RSIs) makes that commitment stronger than ever 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

Discussion