graded approach to dry storage cask and isfsi licensing
TRANSCRIPT
![Page 1: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/1.jpg)
Graded Approach to Dry Storage Cask and ISFSI Licensing
Brian Gutherman for the Nuclear Energy Institute
October 28, 2016 • Rockville, MD
![Page 2: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/2.jpg)
Overview
• RIRP I-16-01 purpose: Document NRC/Industry agreement that the Part 72 regulatory framework would benefit from implementation of a graded approach to better focus resources on nuclear safety and provide a plan to accomplish this
- Part 72 licenses and CoCs currently contain a level of detail not commensurate with the associated risk
- Currently there is little guidance governing what information is included in the licenses and CoCs
- NRC’s inspection program should have a bigger role
![Page 3: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/3.jpg)
CoC Content
• Unnecessary CoC content is costly - CoC amendments and revisions – both number and
scope • Preparation (CoC holder)
• Review fees (CoC holder)
• Implementation (Licensee)
- Fuel selection package complexity
- 72.212 Report complexity, revisions • Every applicable CoC requirement needs to be addressed in
the site 72.212 Report
• Requirements invoking other rules seem innocuous, but are not; each one needs to be addressed in the 212 Report
![Page 4: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/4.jpg)
Precedents
• Industry submitted a petition for rulemaking in 2012 in an effort to codify improvements to the Part 72 licensing framework (PRM 72-7)
- Founded on 1993 NRC policy statement on Improved Technical Specifications (ITS) for power reactors
- ITS successfully sharpened power reactor safety focus
- The fundamental principles of the policy statement transcend just power reactors
![Page 5: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/5.jpg)
Part 50 Improved Tech Spec History
• From the NRC’s 1993 Policy Statement on Improved Technical Specifications (ITS):
![Page 6: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/6.jpg)
Part 50 ITS History (cont’d) • Further from the ITS Policy Statement:
![Page 7: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/7.jpg)
RIRP Problem Statement
• NRC and Industry agree • Industry believes we can use the work done in support of
the PRM to establish the graded approach
![Page 8: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/8.jpg)
Graded Approach to Part 72 Regulatory Framework
• PRM 72-7 provides a strong foundation on which development of a graded approach to improving the license framework and having the correct information in the licenses and CoCs can be built - Includes selection criteria which should be applied
• Documenting a split of important-to-safety (ITS) and not-important-to-safety (NITS) structures, systems, and components (SSCs) is not the right place to start
• Consistent with NRC Part 50 policy and practice, content of dry storage licenses and CoCs should be based on SSC function, not safety classification
![Page 9: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/9.jpg)
Graded Approach to Part 72 Regulatory Framework
• SSCs included in operating plant TS are based on the detection, initial conditions, and mitigation of design basis accidents described in the SAR, plus risk significant items
• PRM 72-7 describes selection criteria based on these principles, modified appropriately for casks
- Accident mitigation excluded based on passive design
- Additional, unique criteria proposed for cask contents
![Page 10: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/10.jpg)
Graded Approach to Part 72 Regulatory Framework
• In addition to accident-related SSC function, control of the SSC should relate to “immediate concern to the health and safety of the public” - i.e., protection of the fission product
boundaries • Confinement boundary
• Fuel cladding
![Page 11: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/11.jpg)
Proposed SSC Selection Criteria
• Criterion S1: Installed instrumentation that is used to detect, and indicate a significant abnormal degradation of the cask confinement boundary;
• Criterion S2: An initial condition of a design basis accident that either assumes the failure of or presents a challenge to the integrity of a fission product barrier;
• Criterion S3: A structure, system, or component which operating experience or risk considerations have been shown to be significant to public health and safety.
![Page 12: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/12.jpg)
Proposed Approved Contents Selection Criteria
• Criterion C1: The characteristic or parameter is identified in 10 CFR 72.236(a);
• Criterion C2: A characteristic or parameter for which verification is a necessary condition to provide reasonable assurance that the cask safety functions of confinement, sub-criticality, and shielding will be performed;
• Criterion C3: A characteristic or parameter which operating experience or risk considerations have been shown to be significant to ensure public health and safety.
![Page 13: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/13.jpg)
SSC Example
• SSC in a CoC not meeting proposed SSC selection criteria - Standardized NUHOMS®, Attachment A, TS 5.3.3 - TC Alignment with HSM or HSM-H
• Includes a +/- 1/8-inch tolerance for alignment during DSC transfer to and from the HSM
• Not used to detect confinement boundary degradation • Not an initial condition for a DBA • Not risk-significant for storage operations or retrievability
- TC alignment is an operational parameter that should be managed by the licensee and available for adjustment under 72.48, if needed
![Page 14: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/14.jpg)
Contents Example
• Contents in a CoC not meeting proposed SSC selection criteria - HI-STORM 100, Appendix B, TS 2.4 - Individual fuel storage locations have limits on decay
heat - With individual fuel assembly limits on burnup and
cooling time, heat load is already defined - Non-fuel hardware also has burnup and cooling time
limits - Maximum heat load for the cask is what 72.236(a)
specifies, not individual fuel assembly
![Page 15: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/15.jpg)
Other Issues of Concern
• Repeating Regulations in the CoC
• Items subject to QA program requirements
• Items governed by other programs
![Page 16: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/16.jpg)
Example of CoC Content Repeating Regulations
• CoC 1004, Amendment 13, Attachment A, Section 5.2.4.a:
![Page 17: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/17.jpg)
Repeating Regulations Example (cont’d)
• Because they are part of the CoC, licensees must separately address both of these requirements in the 72.212 Report
- Analyses to demonstrate compliance with 72.104 are already required and documented in the 212 Report
- Part 20 is not a regulation for which compliance is demonstrated by analysis – it’s performance-based
- Additional, site-specific dose assessments for these events by general licensees are contrary to the GL concept
![Page 18: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/18.jpg)
Examples of Other Issues
• QA program scope
- Neutron absorber manufacturing and testing
- Canister helium leak testing
- ASME Code compliance/alternatives
• Training
• Radiation protection/ALARA
![Page 19: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/19.jpg)
Industry Summary of Graded Approach
• Based on design functions as described in the ISFSI or cask FSAR, SSCs should be evaluated for inclusion in the CoC/TS against the “S” criteria, irrespective of ITS classification
• Approved contents’ characteristics or parameters should be evaluated for inclusion in the CoC/TS against the “C” criteria, irrespective of ITS classification
• Other license and CoC requirements should be governed by the regulations and licensee programs
![Page 20: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/20.jpg)
Industry Proposed Changes to RIRP Screen
![Page 21: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/21.jpg)
Industry Proposed Changes to Action Plan
![Page 22: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/22.jpg)
Industry-Proposed Changes to Action Plan
![Page 23: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/23.jpg)
Path Forward
• Finalize RIRP documents
• Industry and NRC discuss and refine selection criteria given what we have learned since PRM submittal
• Agree upon appropriate selection criteria
• Use the pilot CoC amendment to test implementation of the selection criteria
• Modify selection criteria per lessons learned from the pilot
• Develop industry guidance for NRC endorsement
![Page 24: Graded Approach to Dry Storage Cask and ISFSI Licensing](https://reader031.vdocuments.net/reader031/viewer/2022013000/61c9cd3051141e35b54cdd29/html5/thumbnails/24.jpg)
QUESTIONS?