Dry Cask Storage License Renewal Implementation

January 24, 2018

Curt LindnerENERCON Services, Inc.

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Background

• 10 CFR 72 Subpart K – General License– 72.210 – Grants general license to power reactor

licensees (GL)– 72.212 – Specifies conditions of general license– 72.214 – Lists dry cask storage systems (DCSS)

approved for use under general license

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Background (cont)

• 10 CFR 72 Subpart L – Approval of Spent Fuel Storage Casks– 72.238 – Issuance of Certificate of Compliance (CoC)

• CoC issued for a term of up to 40 years

– 72.240 – Conditions for CoC Renewal• Renewal for term of up to 40 years• Application must include time-limited aging analyses (TLAA)

for systems, structures and components (SSCs) important to safety and an aging management program (AMP) for aging issues that could affect these SSCs.

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Background (cont)• ENERCON Experience

– 10 CFR 54 License Renewal Applications for 3 sites– 10 CFR 54 License Renewal Implementation support at 8

sites– Actively involved in NEI License Renewal Task Force and

several Working Groups– Currently authoring EPRI License Renewal Mechanical

and Structural Tools documents– Aging management requirements very similar between

reactor and dry cask storage– Currently working or in discussions for DCS license

renewal implementation support at 6 sites

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List of Approved Storage Casks Approaching Renewal

Model CoC # Approval Date

Expiration Date

Renewal Date

Standardized NUHOMS 1004 01/23/1995 01/23/2015 12/11/2017VSC-24 1007 05/07/1993 05/07/2013 09/20/2017HI-STAR 100 1008 10/04/1999 10/04/2019 TBDHI-STORM 100 1014 05/31/2000 05/31/2020 TBDNAC-UMS 1015 11/20/2000 11/20/2020 TBDTN-32 1021 04/19/2000 04/19/2020 TBDNAC-MPC 1025 04/10/2000 04/10/2020 TBDW-150 1026 02/15/2001 02/15/2021 TBDTN-68 1027 05/30/2000 05/30/2020 TBDAdvanced NUHOMS 1029 02/05/2003 02/05/2023 TBD

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DCSS CoC Renewal Guidance

• NRC Guidance Documents– NUREG-1927 – Standard Review Plan– NUREG-2214 – Managing Aging Processes in

Storage (MAPS) Report• Industry Guidance Documents

– NEI 14-03 – Format, Content and Implementation Guidance for DCSS Ops Based Aging Management

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MAPS Process for DCSS Vendors

• Scoping Evaluation• Aging Management Review

– Establish materials and environment– Evaluate aging mechanisms– Identify aging management activities

• Perform TLAA Evaluations • Develop AMPs

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AMP Elements• 10 CFR 72 AMP requirements defined in NUREG-1927. • Elements are effectively equivalent to that imposed on

Part 54 license renewals

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1. Scope 6. Acceptance Criteria2. Preventative Actions 7. Corrective Actions3. Parameters Monitored or

Inspected8. Confirmation Process

4. Detection of Aging Effects 9. Administrative Controls5. Monitoring and Trending 10. Operating Experience

DCSS Renewal Application Content

• NEI 14-03 provides format for CoC renewal applications recommended for consistency with NRC review guidance in NUREG-1927.

• Content of application follows MAPS process– identify affected materials– perform aging management reviews– perform TLAA evaluations– develops AMPs that address the 10 elements

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Tollgate Assessments• Defined in Sec. 3.6.5 of NEI 14-03 and addressed in

Rev. 1 of NUREG-1927– Intended a ”structured approach for assessing operating

experience (OE)” in the aging management process– Use of assessment process allows for “learning AMPs”

considering results of ongoing inspections of DCSS and OE from research and industry initiatives

• ISFSI Aging Management INPO Database (ISFSI AMID) created for aggregation and dissemination of OE to DCSS vendors and GLs

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Tollgate Assessments (cont)• Key elements of the tollgate concept addressed

in App A of NEI 14-03• GL perform tollgate assessments as required by

the DCSS UFSAR/CoC– Consider industry OE from INPO database and other

sources– Adjust aging management activities as necessary as

a result of OE– Share results of assessments with database and CoC

holder

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CoC Renewal Process• Cask vendors submit license amendment

request documenting information required by MAPS– Identification of SSCs important to safety– AMR of SSCs– TLAA of SSCs– AMP for cask system– AMP inspection requirements implementing the 10

elements– Tollgate assessments

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DCSS Renewal Impacts

• After renewal of the DCSS CoC, the GL must be prepared to address– AMP additions to the UFSAR– Revised CoC expiration date and conditions– Revised Tech Specs

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GL Implementation Activities

• Update the 72.212 Report for changes to UFSAR, CoCs, and Tech Specs

• Develop high-level AMP implementing document• Develop tollgate assessment procedure• Prepare AMP inspection procedures for each

required inspection

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GL Implementation Activities (cont)

• Prepare 72.48 evaluations for revised documentation

• Generate engineering change packages for LRI documentation

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Ongoing GL AMP Processes

• Perform required AMP inspections and tollgate assessments according to required schedules

• Repairs and corrective actions stemming from AMP inspections

• Modifications to AMPs resulting from inspection and tollgate findings made via 72.48 evaluations

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Potential AMP Implementation Issues

• Chloride-induced stress corrosion cracking (CISCC) applicability screening– GL may be able to perform air monitoring to exempt

from CISCC AMP• Access to pad and casks necessary to perform

VCC or canister lift• Equipment and qualified personnel needed to

perform inspections• Alkali-Silica Reactions (ASR) in concrete

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Other ISFSI Aging Management Issues

• Cask vendors typically only address important to safety SSCs that are a part of the cask

• Components of the ISFSI may also require coverage by the AMP– Concrete pad inspections (surface conditions and

potential subsurface degradation)– Groundwater chemistry monitoring

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Other ISFSI Aging Management Issues (cont)

• Preparation for NRC inspection of AMP activities– NRC plans to perform inspections using temporary

instructions at selected sites in advance of development of their inspection procedure

– NRC inspections to review GL implementation of the 10 elements of each AMP

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Implementation Timeline

• Schedule for implementation varies – NUREG-1927 – Section 3.6.3 indicates a 1

year schedule• Renewed CoC requirements

– VSC-24 – 1 year– Standardized NUHOMS – 180 days

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Implementation Timeline (cont)

• Near term actions– Revise 72.212 Report for CoC renewal and

AMP– Develop AMP descriptive document for

reference in 72.212– Prepare Tollgate procedure– Prepare 72.48 Evaluation– Implement ECN

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Implementation Timeline (cont)

• Long term actions (> 20 years in storage)– Develop AMP inspection procedures– Perform inspections– Perform Tollgate assessments

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Questions?

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