Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards
Metallurgy and Reactor Fuels Subcommittee
Docket Number:
(n/a)
Location:
Rockville, Maryland
Date:
Wednesday, March 23, 2016
Work Order No.:
NRC-2249
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers
1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005
(202) 234-4433
Pages 1-493
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1
2
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4
DISCLAIMER
5
6
7
UNITED STATES NUCLEAR REGULATORY COMMISSION’S
8
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
9
10
11
The contents of this transcript of the
12
proceeding of the United States Nuclear Regulatory
13
Commission Advisory Committee on Reactor Safeguards,
14
as reported herein, is a record of the discussions
15
recorded at the meeting.
16
17
This transcript has not been reviewed,
18
corrected, and edited, and it may contain
19
inaccuracies.
20
21
22
23
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1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
+ + + + +
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
(ACRS)
+ + + + +
METALLURGY AND REACTOR FUELS SUBCOMMITTEE
+ + + + +
WEDNESDAY
MARCH 23, 2016
+ + + + +
ROCKVILLE, MARYLAND
+ + + + +
The
Subcommittee
met
at
the
Nuclear
Regulatory Commission, Two White Flint North, Room
T2B1, 11545 Rockville Pike, at 8:30 a.m., Ronald G.
Ballinger, Chairman, presiding.
COMMITTEE MEMBERS:
RONALD G. BALLINGER, Chairman
DENNIS C. BLEY, Member
CHARLES H. BROWN, JR. Member
DANA A. POWERS, Member
JOY REMPE, Member
PETER RICCARDELLA, Member-at-Large*
GORDON R. SKILLMAN, Member
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DESIGNATED FEDERAL OFFICIAL:
CHRISTOPHER L. BROWN
ALSO PRESENT:
HUDA AKHAVANNIK, NMSS
MICHELLE BALES, RES
KRISTINA BANOVAC, NMSS
JANA BERGMAN, Curtiss-Wright
DONALD CHUNG, NMSS
AL CSONTOS, NMSS
KRIS CUMMINGS, NEI
BOB EINZIGER, NWRTB
STEVE FRANTZ, MLB
DONNA GILMORE*
NICHOLAS HANSING, NRO
MATT HISER, RES
ANTHONY HSIA, NMSS
MATT KEENE, Duke Energy
SUZANNE LEBLANG, Entergy
MARVIN LEWIS
HAILE LINDSAY, NMSS
MARK LOMBARD, NMSS
KARAN MAUSKAR, Areva TN
ROD MCCULLEN, NEI
GREG OBERSON, RES
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TERRY PICKENS, Xcel Energy
PAUL PLANTE, 3 Yankees
MERAJ RAHIMI, NMSS
WENDY REED, NMSS
STEVE RUFFIN, NMSS
NORMA GARCIA SANTOS, NMSS
PATRICIA SILVA, NMSS
DAVID TANG, NMSS
JEREMY TAPP, NMSS
RICARDO TORRES, NMSS
BRIAN WAKEMAN, Dominion
KEITH WALDROP, EPRI
BERNARD WHITE, NMSS
JOHN WISE, NMSS
EMMA WONG, NMSS
JIM WOOD, Exelon
*Present via telephone
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CONTENTS
Opening Remarks....................................5
Staff Opening Remarks..............................7
Update on Storage Renewals........................78
Spent Fuel Retrievability........................118
Update on Storage and Transportation of
High Burnup Spent Fuel...........................141
Building a Risk Framework for Dry Storage........190
Industry Perspectives Ongoing Research
related to Storage and Transportation............260
Industry Perspectives on the Dry Storage
Regulatory Framework.............................278
Closing..........................................314
Public Comments..................................322
Adjourn
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1
P R O C E E D I N G S
2
8:31 a.m.
3
CHAIR BALLINGER:
Okay.
4
The meeting will now come to order.
5
hear myself.
6
Ready to go?
Boy, I can
This is the meeting of the Metallurgy
7
and Reactor Fuel Subcommittee.
8
Chairman of the Subcommittee.
9
ACRS
Stetkar
in
Dick
11
Charles Brown and Joy Rempe.
12
I believe, is going to be here on the phone, on the
13
bridge line.
spirit,
And Pete Riccardella,
MEMBER RICCARDELLA:
I'm on.
Can you
hear me?
16
17
John
attendance,
Skillman,
15
Powers,
in
10
14
Dana
members
I'm Ron Ballinger,
CHAIRMAN BALLINGER:
hear you great.
18
Oh, great.
We can
Thanks.
Chris Brown of the ACRS staff is the
19
designated federal official for this meeting.
20
purpose of this two-day, approximately, meeting is
21
to receive a briefing on the framework for storage
22
and transportation of spent fuel.
23
this has been ongoing for quite a while.
24
time.
25
The
I might add that
A long
In particular, we'll hear about the ISG
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1
on spent fuel retrievability, updates and licensing
2
of
3
transportation, as well as NUREG-1927 on renewals.
4
We'll also hear from EPRI and NEI on the subject
5
matter mentioned.
high
burnup
spent
fuel
and
storage
and
6
The rules for participation in today's
7
meeting were announced as part of the notice of
8
this
9
Register on March 8, 2016.
meeting
previously
published
in
the
Federal
We have received no
10
written comments or requests for time to make oral
11
statements
12
today's meeting.
from
13
A
members
of
the
public
regarding
transcribe
of
the
meeting
is
being
14
kept and will be made available as stated in the
15
Federal
16
that
17
microphones, myself included, throughout the room
18
when addressing the subcommittee.
Register
notice.
participants
19
in
Participants
speak
this
should
at
themselves
21
volume that can be readily heard.
22
all beepers.
request
use
first
sufficient
the
identify
clarity
and
Please silence
Thank you.
Since
we
with
we
meeting
20
23
and
Therefore,
have
today's
an
meeting
additional
is
bridge
open
to
line,
the
24
public,
Pete
25
Riccardella is on it, set up for folks who have
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1
requested a call in.
2
The phone line is in a listen-in mode
3
at
this
time
4
today's meeting and tomorrow's half-day meeting.
5
and
will
be
opened
at
the
end
of
Dr. Rempe has been identified as having
6
a
conflict
of
interest
7
participation, if that's possible, during certain
8
presentations.
9
We
have
and
will
scheduled
limit
a
spent
her
fuel
10
retrievability and NUREG-1927 for the April -- a
11
meeting
12
However, the subcommittee will determine if it is
13
necessary
to
go
14
topic
the
full
15
meeting.
on
to
NUREG-1927,
16
the
forward
April
with
committee
full
the
at
committee.
retrievability
the
end
of
this
We've had, as I said before, a couple
17
of
meetings
18
subcommittee on high burnup fuel on June 8th in
19
which
20
their work through the subcommittee.
we
21
on
provide
We
NUREG-1927
comments
will
now
on
April
back
proceed
to
8th
the
with
and
staff
the
a
on
meeting
22
and I'll call on Mark Lombard, Director, Division
23
of
24
introduction and introduce the speakers.
Spent
25
Fuel
Management,
MR. LOMBARD:
to
give
a
brief
I was trying to hide over
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1
on the side and Kris moved me up to the middle
2
here.
3
So,
we
appreciate
the
subcommittee's
4
time that you've set aside over this next day and a
5
half to talk about spent fuel issues.
6
We'd like to start off with an overview
7
of the spent fuel world.
8
we're
9
overview of some of the key topics.
just
going
to
It's a large world, but
--
I'm
going
to
provide
an
10
Some of the things we're going to talk
11
about in detail, but some other things that you may
12
or
13
storage and transportation, as well as radioactive
14
material
15
responsibilities
16
transportation business line.
may
17
not
be
aware
of
transportation
in
relative
which
spent
to
is
fuel
spent
part
fuel
of
storage
our
and
So, the agenda for today for my talk is
18
to go over roles and responsibilities.
The spent
19
fuel
a
20
pieces.
21
and some of them don't.
puzzle,
22
the
spent
fuel
world
has
lot
of
And some of them grow and shrink and move,
Seems
like
most
of
them
do
grow
and
23
shrink and move as we try to get our arms around
24
this puzzle.
25
picture is going to show over the long term, but
And we're not sure exactly what the
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1
we're trying to keep up with those puzzle pieces as
2
they do move.
3
We'll be talking about specific topics
4
today
which
I'll
5
touch
upon
them,
6
overview and then introduce the topics.
7
So,
go
over
but
I
we'll
and
I'll
want
to
talk
just
briefly
provide
about
that
roles
and
8
responsibilities as a business line, the work that
9
we do in the Division of Spent Fuel Management, but
10
we also have several partners around the NRC that
11
help us out, as well as national labs and other
12
consultants that help us.
13
Overview of what we do under Part 71
14
and 72.
15
The
16
paradigm shifts that have occurred over the last 15
17
to 20 years.
18
paradigm shift has been more recent.
19
little bit about that and how that's affected our
20
work
21
forward.
new
and
22
71 for transportation and 72 for storage.
paradigm.
There's
really
a
Some of them more recent.
the
way
we
approach
our
pair
of
A second
I'll talk a
work
going
A few words about interim consolidated
23
storage,
24
really that second paradigm shift that we've seen.
25
because
And
it
then
does
what
have
I
an
call
impact.
"The
It's
Perfect
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1
Storm," which is our workflow projections in the
2
FY16 through FY20 period.
3
that
4
approach to the work going forward.
5
ACRS topics, and then talk about successes that we
6
have had in this new paradigm.
7
MEMBER
8
are
affecting
us
There's a lot of things
and
it
SKILLMAN:
is
driving
our
Touch upon the
Mark,
before
you
change --
9
MR. LOMBARD:
10
Yes.
MEMBER SKILLMAN:
-- I would like to
11
ask this question, please.
12
and Part 72.
13
CFR as part of the complex of regulations.
14
I understand Part 71
I'm curious why you don't identify 49
I
ask
that
question
because
in
our
15
campaigns to shift the fuel from Three Mile Island,
16
we found ourselves confronted by 49 CFR issues that
17
we had never imagined and political issues dealing
18
with
19
transport through Chicago, the almost untangleable
20
knot of politics to ship that fuel on those rights-
21
of-way and it seems that that is an integral part
22
of what we should be talking about here in terms of
23
transportation.
Pennsylvania
to
Ohio,
Ohio
to
Indiana,
24
May I ask you to address that, please?
25
MR. LOMBARD:
Sure.
That's a very good
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1
point.
2
integral
3
picture.
Part 49 transportation regulations are an
part
4
of
the
overall
transportation
As you know under Part 71, we certify
5
the
packages,
6
Department
7
authority
8
really regulate the transportation piece of it.
9
the
of
transportation
Transportation
within
Now,
United
is
the
competent
States.
there's
an
interface
interface
is
not
The
So,
they
there
sometimes
11
line, but we do rely on them to do -- take care of
12
the transportation end of it although we have some
13
transportation security requirements within the 71
14
regulations and, in part, 73.
15
is really mostly in the DOT's ball -- most of their
16
ball to carry forward.
MEMBER SKILLMAN:
always
a
and
10
17
that
the
packages.
bright
But, again, that 49
How is that interface
18
integrated or harmonized as we talk about what we
19
are going to speak about for the next day and a
20
half?
21
MR. LOMBARD:
The next day and a half
22
is going to be focused on 72 on storage primarily
23
and
24
transportation side.
we
25
won't
really
get
MEMBER SKILLMAN:
into
Part
Okay.
71
on
the
Thanks, Mark.
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1
MR. LOMBARD:
Okay.
2
So, roles and responsibilities, what we
3
do.
4
under Part 71 and Part 72.
5
only
6
the
7
business
8
radioactive
9
certifications.
Thank you.
We do licensing, certification and inspection
spent
ones
fuel
that
transportation
are
line's
10
most
material
but
within
the
also
do
we
transportation
some
of
them
we
do
for
in
concert
Nuclear Security Administration, but that's a big
13
part
14
resources and about three-quarters of the cases we
15
do every year.
16
move a lot faster than the storage certifications.
17
It's
about
a
DOE
with
12
work.
the
package
DOT,
our
them
about
they're
11
of
of
packages,
talked
activities,
Again,
some
Part 71 includes not
National
third
of
our
And those certifications usually
Part 72, spent fuel storage facilities,
18
spent
fuel
dry
19
ISFSIs,
20
Installations, and the spent fuel dry ask storage
21
systems that are certified for use on those sites,
22
we look at those as well.
the
cask
storage
Independent
systems,
Spent
Fuel
both
the
Storage
23
And then as part of both the 71 and 72
24
activities and vendor, quality assurance and ISFSI
25
inspections, we provide regional resources for them
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1
to do the ISFSI inspections.
2
they request us to and respond to their technical
3
assistance
4
involved with there as well.
requests
and
We support wherever
other
activities
we
get
5
Vendor inspections, we have the three
6
main vendors making systems today not only in the
7
United
8
facilities overseas that they do fabrication.
9
it's a pretty wide range of activities there and
10
States,
but
overseas
they
have
some
So,
they've covered a lot of ground.
11
Our
vendor
inspectors
cover
a
lot
12
ground over a three-year period.
13
every three years, every one of those facilities.
14
We
coordinate
notably
They're inspected
with
DOT,
state
15
agencies.
16
about on the transportation side.
17
Most
of
as
we
and
just
federal
talked
Part 49 we have regular conversations
18
with DOT.
19
a
20
folks, but also EPA.
meeting,
21
They're coming up, I think, tomorrow for
an
all-day
meeting
with
some
of
our
EPA doesn't get involved in a lot of
22
our transportation storage activities.
Only when
23
we're working with ISFSIs we will interface with
24
them to make sure, again, there's a clear handoff
25
between our regulation and their regulation.
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1
Foreign
and
international
regulatory
2
agencies, the IAEA, we've very involved with the
3
IAEA
4
Transportation
5
have built an international set of regulations and
6
requirements
7
but requirements for transportation.
and
their
8
9
work
Safety
--
not
under
the
Standards
TRANSSC,
Committee.
necessarily
the
the
They
regulations,
We look at those standards every time
they're reissued.
We were looking at the 2009 --
10
we did the 2009 incorporated back into our Part 71
11
regulations and that was complete last year.
12
summer I think that changes to 71 went live.
13
Last
We're now looking at the SSR-6, which
14
is
the
15
regulations.
16
for some reason.
17
version again to see what needs to be pulled into
18
Part
19
appropriate
20
requirements.
71
new
It's
their
same
set
of
They just changed the name and number
to
21
TSR1.
make
And we're looking at the 2012
sure
conformance
our
regulations
with
the
are
in
international
Native American tribes, we had a lot of
22
interaction
with
23
communities.
We
24
renewal.
25
that
we
the
were
Prairie
Island
reviewing
their
Indian
ISFSI
for
And we have other Native American tribes
do
interface
with
on
a
fairly
regular
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1
basis.
2
The last one, the public outreach, it's
3
been
public
outreach
4
reach.
5
the last three years.
and
in-reach
and
sideways-
We've had so much public interaction over
It's amazing.
6
It
seems
7
Massachusetts,
8
are getting more and more interested in spent fuel
9
storage and that we're glad to have that interest
10
and we've spent a lot of our time interfacing with
11
them through our Category 3 public meetings, other
12
public
13
interaction
14
calls and that type of thing, but it has increased
15
tremendously over the last three years.
from
like
San
meetings.
16
Our
Onofre
And
with
them
from
we
through
division
California
to
Pilgrim,
also
get
emails
branches.
to
folks
direct
and
phone
We
have
17
primarily the top three are the technical review
18
branches
19
technical discipline that's involved in each one of
20
them; confinement, structural, thermal branch, or
21
CSTB;
22
assessment --
and
they're
criticality,
23
primarily
shielding,
MEMBER POWERS:
set
aside
dose
by
and
the
risk
Mark, I wonder if you
24
could speak a little more about the -- what I'm
25
interested
in
is
the
adequacy
of
expertise
in
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1
calculational
2
analyses.
3
4
tools
for
criticality,
You do primarily confirmatory analyses
there?
5
MR. LOMBARD:
That's -- it's --
6
glad you asked that question.
7
my last slide of things looking forward.
8
9
shielding
I'm
That was really on
We do some confirmatory analyses.
And
we do some review of the calculational methods that
10
are
used
by
the
11
that's something that we're looking at very closely
12
now going forward of are we doing the right amount
13
of
14
right tools?
15
from
16
areas.
confirmatory
the
17
applicants,
the
calculations?
vendors.
Are
we
And
using
the
Are we looking at the right margins
thermal
criticality
MEMBER
in
POWERS:
18
interested
19
expertise
20
tools that are readily used.
21
MR.
and
and
other
What
is
the
availability
the
availability
LOMBARD:
For
of
technical
I'm
of
most
adequate
calculational
criticality
we
use
22
the scale software and it's been readily available
23
and kept up to date.
24
Ridge; is that right, the scale system?
25
been
kind
of
our
I think it's based in Oak
go-to
tool
for
It has
criticality
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1
analyses.
2
MEMBER POWERS:
Well, it is for a lot
3
of people.
The question is not so much what the
4
tool is, but how useful is it?
5
amounts of manpower?
Because you have --
6
MR. LOMBARD:
7
MEMBER
8
complicated situations that --
9
MEMBER
Well,
POWERS:
--
12
availability
13
training and things like that.
14
here or that we can forecast, or not?
15
MR. LOMBARD:
17
CSRAB.
18
of
here,
primarily
and
that.
friend
but
talent
Meraj
MR.
with
somewhat
I'm
things
like
interested
the
right
kind
in
of
Are there problems
Well, if I could phone a
Rahimi
RAHIMI:
and
Yes.
11
16
And,
Limited resources.
POWERS:
MR. LOMBARD:
10
Is it taking huge
is
in
charge
Yes,
of
the
criticality,
19
shielding and risk assessment branch is my branch.
20
And in terms of the expertise, first of all, the
21
tools, scale, as Mark mentioned, is the codes that
22
in the late '70s it formed the entire development
23
of SCALE package by the NRC in the late '70s.
24
25
And NRC has been the major contributor
in
development
and
improvement
of
that
code.
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1
That's our main tool.
2
Of course my folks, you know, they also
3
--
we
use
MCNP
4
package
5
will try to use a different code and to cross-check
6
the results.
comes
7
as
in,
well,
you
And
we
in
terms
which
know,
they've
have
of
normally
been
if
used
SCALE,
funding
cross-section,
the
the
8
improvement
9
cross-section for the past, you know, many years.
10
30-40 years.
11
from the NRC part is about 700k a year.
12
updating
And roughly, you know, the funding
And
the
Laboratory
SCALE
Ridge
14
from
15
improvement of that tool is about, you know, two to
16
three million dollars a year.
the
funding
fronting
Oak
National
So,
gets
at
13
NNSA.
also
team
for
that
from
tool,
DOE,
the
17
And so, we are constantly improving and
18
very -- in this fiscal year we're trying to make a
19
tool -- what is called a template base to be very
20
easy to use and quick to use because when we get
21
application,
22
modeling.
23
fuel templates, cask templates, canister templates
24
for us.
25
tool and about a dozen of engineers, mainly nuclear
we
don't
have
that
much
time
for
So, Oak Ridge is developing templates,
So, it's constantly we're improving that
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1
engineers in my branch, and they are very versed
2
and very qualified and very capable.
3
MEMBER POWERS:
Well, I have no doubt
4
about that, but tell me about 2020.
5
going to have the same cadre of folks, or do you
6
have to improve, or what?
7
MR. RAHIMI:
Are you still
What's the situation?
There is same -- pretty
8
much I guess my unit, my branch, as far as I know.
9
The folks, they don't have any plans leaving.
And
10
we've got people with a lot of experience in there.
11
Maybe by 2020 we'll have one or two individuals
12
leaving,
13
people.
but
we're
constantly,
you
know,
hiring
14
I mean, about, I guess, two years ago
15
we got a Ph.D. from Penn State, you know, he was --
16
all his research was in cross-section development.
17
He joined our team.
18
ahead and --
19
So, we're constantly looking
MEMBER POWERS:
So, you don't see any
20
problems with the manpower and expertise in this
21
area?
22
MR.
RAHIMI:
I
don't
believe
so,
23
because we have a very good support from Oak Ridge
24
National Lab.
25
codes, you know, when we need to, we always go to
The people who have developed the
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1
them.
2
And in terms of any difficult issues,
3
problems or phenomena that we see from using the
4
codes, we have a very good support from Oak Ridge
5
National Laboratory.
6
MEMBER POWERS:
7
MEMBER SKILLMAN:
8
Powers' question.
9
knowledge retained?
Thank you.
Let me build on Dr.
Sir, how is the institutional
I mean, these are smart people
10
that they may retire or go someplace else and this
11
is a fairly sophisticated technology in of itself.
12
So, how is the institutional knowledge
13
maintained
14
benefit from all of the learning?
15
so
that
future
MR. RAHIMI:
certificate
Good question.
seekers
Two years
16
ago we instituted developing an in-house training
17
course in terms of the people who are new joining
18
our team, the knowledge is transferred from more
19
senior people.
20
So, we gave our first in-house training
21
course, which the staff will be working for the
22
past
23
Based
24
course and this was on the shielding side.
decade
on
25
on
their
doing
confirmatory
knowledge
they
put
calculation.
together
this
This April we are completing our second
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1
training module, which is the criticality safety,
2
which again the entire staff has put together the
3
course and that is going to be our tool to transfer
4
the knowledge from the more senior people to junior
5
people, the two in-house training courses.
6
MR. LOMBARD:
The other piece is when
7
you look at the documents, the deliverables that we
8
issue
9
approval, it's really in the SERs.
when
we
issue
a
certification
review
or
10
The SERs have a lot of that background
11
information of the basis for the finding and our
12
Office of General Counsel is very good at keeping
13
us honest from that standpoint and making sure we
14
have a solid basis for each finding that we make.
15
And
when
you
look
back
at
what
16
applicants used to look at in the future to try to
17
determine
18
going to do in a specific area, I really think the
19
SER can provide that, that feedback for them.
how
20
much
of
MR. RAHIMI:
an
in-depth
review
we're
I would like to add one
21
more thing that in addition to that, that -- over
22
the
23
committees.
24
committee in my branch.
25
Grand
past
several
years
we
have
formed
technical
And there are two specific technical
Criticality
We call them -- one is the
Council.
The
other
one,
Dose
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1
Busters.
2
These are the two technical teams that
3
they bring up the issue of the day.
4
has work on a case which is unique, they bring to
5
everybody.
6
get together both of these technical disciplines on
7
a monthly basis to share their experience/knowledge
8
from each different cases.
9
10
If one person
Everybody shares the knowledge and we
MR.
LOMBARD:
We
also
have
the
Sizzlers, don't we?
11
MR.
RAHIMI:
We
have
several
other
12
technical -- we have the Sizzlers.
13
Leakers.
These are all the technical groups we
14
form
get
15
knowledge and share the information.
to
16
together
MR.
LOMBARD:
Next
branch
19
FSME back in October 1st -- or October 6th of 2014,
20
when we merged together to create the new NMSS and
21
we
22
materials
23
changes.
25
branch
And
become
the
we
focal
is
really
set
up
point,
this
the
branch that really came out of our merging with
organizational
And
is
18
24
branch.
transfer
materials
some
renewals
discuss,
17
had
and
and
We have the
changes.
one
that
because
of
a
Renewals,
those
branch
as
is
to
you
large
really
look
at
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1
renewals
for
CoCs
and
ISFSIs
they're
really
2
materials focused.
3
take the lead, put our materials folks into that
4
branch, all of our expertise there, and then also
5
project managers.
So, we wanted that branch to
6
So, when we -- the next renewal that
7
comes in, the North Anna renewal which is coming
8
in, in May of this year, the Renewals Branch will
9
take care of that.
They'll project manage it, it
10
won't go to the Licensing Branch.
11
manage
12
within that same branch to move that forward and
13
take care of that review.
it
14
and
And
have
all
then
the
after
They'll project
technical
that,
expertise
the
project
15
managers will be -- are responsible for the rest of
16
the
17
transportation and the storage side and the primary
18
project managers with the branch chief.
licensing
19
actions
We
have
that
our
Oversight
do
fifth
both
branch
is
QA,
21
Inspections and Oversight Branch.
22
of the cats and dogs of the rulemaking process,
23
oversight
that
24
frequently
on,
25
regions.
interface
inspections
the
the
Inspection,
the
Rulemaking,
on
20
they
and
we
IOB,
They take care
with
going
the
on
regions
in
the
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1
They
do
the
vendor
inspections
and
2
other activities to all the assurance plan reviews
3
and that type of thing.
4
And there's a sixth branch within the
5
division now that didn't make it to this slide.
6
I'm sorry, I had an oversight.
It's the Long-Term
7
Spent Fuel Management Branch.
It's a branch that
8
we lost the branch chief last year, last December.
9
He took one of the early outs last December.
10
(Laughter.)
11
MR. LOMBARD:
He probably foresaw that.
12
I don't know.
13
care
14
transportation activities.
15
was initiated through an SRM back in the 2010 time
16
frame to look at storage periods of 120 years and
17
beyond, which means really 60 years of wet storage,
18
60
19
storage period beyond that second 60 years.
of
years
But that branch was set up to take
primarily
in
20
dry
extended
storage
storage
and
That's something that
and
then
look
at
that
We define it to be really the 120-year
21
to 300-year time frame.
22
job, and Kris Banovac and John Wise and Ricardo and
23
the rest of the team did such a good job building
24
this
25
found
new
regulatory
that
that
And as Al did such a good
framework
framework
is
for
renewals,
we
so
sustainable,
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1
predictable
and
reliable
going
2
didn't really need to focus our energies on those
3
extended storage and transportation issues, because
4
the renewals framework is taking care of those as
5
they go.
6
going forward.
that
we
It's a learning -- sustainable framework
7
Next slide, please.
8
MEMBER
9
forward
SKILLMAN:
I
need
to
ask
one
more question.
10
MR. LOMBARD:
11
MEMBER
at
SKILLMAN:
since
I
read
This
the
one
12
eating
13
particularly the comments from industry.
14
me
Yes, sir.
revised
has
been
ISG
and
You present here what are really review
15
branches
16
analytical approaches to this whole issue.
17
that
are
Who
fairly
gives
the
technicians, to the rad techs, to the people who
20
have
21
casks, who take the shield overpack off, unweld the
22
lid or reweld the lid or ensure the lid is put on
23
properly so it doesn't leak?
24
And
25
I'm
and
going
mechanics,
to
19
around
the
their
practical
hop
To
consideration
in
18
to
stuff?
sophisticated
deal
to
around
keep
through this whole presentation.
on
to
with
this
the
these
theme
I'm going to pour
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1
in
on
the
2
operational safety problems.
That's a new addition
3
to
least
4
brings up a whole host of practical issues.
ISG-2,
ability
I
5
think,
to
safely
but
at
remove
in
my
with
no
mind
it
For instance, you can have the greatest
6
shielding,
7
than 0.5, so you're very comfortable, you have no
8
criticality issue, but working the cask can be an
9
absolute nightmare because the lid is too small or
10
confirmation
that
k-effective
is
less
it's complicated.
11
And
if
get
a
container,
a
or
stuck
if
there's
there's
no
radiological
12
subcontainer
13
shielding
14
problem, but it's a situation where the cask is in
15
between and the whole operation at the site comes
16
to a halt because it's series process, is that an
17
operational safety problem?
18
caught
you
problem,
if
no
I'm not sure.
Hence, I can see comments from industry
19
raising that issue.
20
Which of these branches is really looking at the
21
practical stuff that really impacts the people who
22
own and operate these cask systems?
23
addressed?
24
25
MR.
question.
And so, I raise that here.
LOMBARD:
So,
Where is that
it's
a
great
It's something that we kind of fell upon
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1
over
the
last
few
2
inspection folks, we have four awesome inspectors,
3
at least one of them is here today in the back of
4
the room, and what we do during the reviews is get
5
them
6
possible.
involved
in
years.
reviews
And
to
the
the
IOB,
the
maximum
QA
extent
7
And at the same time, we're also trying
8
to get more of our reviewers out to actually see
9
these things during loading campaigns and dry runs
10
just to make sure that they don't just think it's a
11
piece of paper with a large drawing on it, that
12
these things are 150-ton massive structures sitting
13
out on the pad and that there's a lot that goes
14
into
15
loading and the drawing and vacuum drawing of these
16
systems and in the transfer, you know.
the
17
operation,
So,
it
a
is
lot
that
something
goes
that
into
we
the
were
18
sensitive to.
19
as we'd like to, but we have a thought, you know,
20
trying to get those inspectors involved in every
21
review that we can possibly going forward.
22
23
So,
there's
two
that
are
very
vocal,
right?
24
25
We haven't -- we don't do it as much
MR. RAHIMI:
Let me just add that we're
aware also that we don't want to be an impediment
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1
during operation, as well.
So, most -- as part of
2
the qualification process for technical reviewers
3
in the three different branches there, one of the -
4
- so, as part of the qualification process for the
5
technical reviewers in those three, they have to go
6
out to do some sort of inspection or some seed of
7
practicality that you're asking.
8
We tend to send them off to dry runs
9
for the campaigns, because we don't want -- I came
10
from an experience where I think it was somebody
11
from
12
remember which one, but to do an inspection of pipe
13
there
14
Several from the state, several from NRC and, you
15
know, we're aware of that.
an
Exelon
was
12
plant
16
in
people
Chicago
area.
overseeing
three
I
can't
people.
So, that's -- in this case, it's part
17
of
the
qualification
18
technical
19
and we send them out to these dry runs rather than
20
direct, you know, when you guys are -- when plants
21
are operating.
reviewer
22
MEMBER
process
for
the
SKILLMAN:
to
be
technical
So,
to
qualified
disciplines
repeat
back
23
what I think I just heard, there isn't any specific
24
discipline.
25
oversight of the process.
It
is
really
handled
through
the
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1
MR. RAHIMI:
It's in the IOB branch,
2
and the IOB branch reaches out, because they're the
3
ones that interface with the regions and with the
4
inspectors.
5
branches for the specific technical disciplines and
6
it's
7
person involved.
up
to
And they reach out to the technical
the
branch
chiefs
to
get
the
right
8
And we've had instances in the past and
9
we've had to deal with just exactly what you're
10
saying and looking at what the impact of doing some
11
sort of repair or replacement action.
12
we've probably about three or four, right, of them
13
and get the right people involved and look at the
14
total
15
safety for, you know, for everybody.
picture.
16
Not
just
MEMBER SKILLMAN:
compliance,
Last year
but
also
That seems to me that
17
-- and I'll hang onto this through the rest of the
18
meeting,
19
interpreting the ability to safely remove with no
20
operational safety problems.
21
people,
that's
22
language
needs
23
practical problem that is truly a non-safety issue
24
does not get interpreted to be a safety issue.
25
calibrating
where
to
the
the
connect
people
who
are
If those are the IOB
calibration
accurately
and
so
that
that
a
Because once it's interpreted to be a
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1
safety issue, that poor licensee is stuck.
2
there needs to be the recognition that sometimes a
3
sledgehammer to take a subcask out is sufficient
4
and appropriate and that is not a safety problem.
5
That's a practical issue that people at the plants
6
work with every day.
7
MR. LOMBARD:
8
MEMBER SKILLMAN:
9
Absolutely.
So, we'll talk about
that later on.
10
11
And so,
MR. LOMBARD:
And they're good at those
-- solving those operational problems.
12
MEMBER SKILLMAN:
13
MR. LOMBARD:
Okay.
Absolutely.
Thank you.
Many of us have come from
14
operational backgrounds and spend time at the plant
15
sites.
16
So, I appreciate you bringing that up.
So, we're very sensitive to that as well.
17
MEMBER SKILLMAN:
18
MR. LOMBARD:
radioactive
Part 71, transportation
19
of
20
certificates in compliance that we have right now.
21
We
material,
Thank you.
do
50
to
about
70
or
a
hundred
so
active
transportation
22
cases each year, including spent fuel, medical and
23
industrial applications, medical sources that are
24
used for cancer treatments, other sources used in
25
radiography
devices
and
well
loggers,
power
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1
research reactors, fuel cycle facilities.
2
So, it's a lot of the work that we do
3
every
year.
As
4
resources
5
radioactive material transportation.
are
6
I
said,
in
Part
about
71,
a
third
of
our
transportation
--
We work closely with DOT on Part 49 in
7
both
8
Issues come up with transportation packages.
9
typically
10
domestic
and
called
international
in
to
help
transportation.
DOT
assess
We're
in
any
issues that come up with transportation packages.
11
I
will
say
there's
the
Type
B
12
packages,
13
transportations
14
probably
15
actually in the back of a FedEx truck.
16
million
17
those
18
sources
19
world.
one
a
Type
year
We
21
Department
22
international
23
transportation
24
nuclear navy.
25
of
As
by
the
three
single
the
throughout
packages,
around
20
every
going
B
about
transportation
year.
building
the
which
are
States
coordinate
very
NNSA,
and
you
probably
now
States
around
and
of
medical
closely
states
but
right
moving
transportation,
requirements,
There's
About three
United
United
Energy,
million
the
with
IAEA
on
international
also
are
with
aware,
the
we've
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1
reviewed
2
Transportation
3
Enterprise is the M-290.
4
-- 220 some tons.
5
15 or 18 trucks on it.
6
actually did kind of a courtesy certification of
7
that system for the nuclear navy.
8
Part 72.
9
both
the
M-140
systems
for
and
spent
the
fuel
M-290.
from
the
It's a large 200 and some
Sits on a railcar with, I think,
It's very large and we
There is a picture of a HI-
STORM 100 storage system there on the right.
It's
10
a canistered system.
11
center and the concrete overpack on the outside and
12
the lid -- shielding lid going on the top.
13
You see the canister in the
About 12 active storage CoCs right now.
14
Again, three main vendors.
15
with active -- well, actually more than four with
16
active
17
outside.
CoCs,
because
Although, there's four
there's
some
storage
even
18
There are three main vendors right now,
19
you know, Holtec, NAC International and AREVA-TN.
20
There's
21
three sites.
22
and
23
there, but really 12 active storage CoCs right now.
another
there's
24
25
coordinate
one,
Energy
Solutions,
has
about
Their systems are at three sites now
one
or
two
other
cats
and
dogs
out
20 to 30 storage cases each year.
We
closely
if
with
DOE.
I
don't
know
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1
you're
aware,
you
2
Energy
3
organization that we deal with and we try to meet
4
with them on a quarterly basis.
there's
know,
really
but
two
within
legs
DOE
Nuclear
within
their
5
One is the project planning site, which
6
is looking at what does it take to deploy storage
7
sites
8
although their level of activity in both of those
9
areas is somewhat relative, but we deal with them
10
pretty much on at least a monthly basis in looking
11
at supporting to the extent that is reasonable for
12
us, their consent base signing activities that are
13
ongoing now at the meetings that they're planning
14
starting next week around the country.
and
15
repositories
The
other
with
side
is
United
the
and
17
They
18
development,
19
independent regulator, but we do work with them to
20
make sure that the dollars that taxpayers give both
21
of
22
development activities and we're solving the right
23
problems.
us
24
25
are
we
spent
we
research
development
research
Now,
States
16
do
organization.
the
and
development.
don't
promote,
appropriately
do
research.
We
don't
do
just
an
we're
on
research
and
We try to define the regulatory issues,
the
technical
issues
related
to
the
regulatory
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1
issues
that
2
those activities and, again, collaborate on those
3
activities going forward, make sure we're solving
4
the
5
outcome is clearly defined when we start off on a
6
research activity.
right
7
we
try
to
problems.
solve
And
at
Significant
8
stakeholders,
9
Massachusetts.
as
I
within
end
one
game,
from
actually
with
California
have
of
the
engagement
said,
We
the
each
a
lot
to
more
10
engagement with stakeholders around the country and
11
we expect that to continue going forward.
12
So, here's kind of our world at least
13
in
the
United
14
storage around the country.
15
have
16
license ISFSIs.
general
17
States,
license
There's
two
the
world
of
spent
fuel
60 reactor sites that
ISFSIs,
15
that
have
with
one
specific
of
each.
18
North Anna and Surry have one of each.
19
general and a specific ISFSI.
They're separated by
20
a fence between the two pads.
And it's interesting
21
-- I don't know if you've dug into Part 72, but
22
it's -- the way we define the difference between
23
generals
24
reactor Part 50 license for a reactor and you want
25
to start an ISFSI, essentially send us a letter.
and
specifics
if
you
have
They have a
an
operating
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1
You
your
pick
an
and
your
active
CoC
that
needs
for
your
matches
3
operation of considerations and you're ready to go
4
as soon as you build the ISFSI pad.
You
type
CoC,
2
5
fuel
a
build
it
in
accordance
with
your
6
requirements and your Part 50 license and any state
7
and local requirements that you have to meet and
8
you're good to start operating the pad after we do
9
inspection on the security and also the safety side
10
to make sure that you're complying with the Part 72
11
requirements.
12
The specific licensed ISFSI is a little
13
different.
You don't necessarily have to pick a
14
CoC.
15
system
16
And we would do it from scratch a review on the
17
safety, security and environmental aspects of your
18
ISFSI application.
You can start off from scratch with a new
that
19
again
meets
your
operational
needs.
Now, there's a couple different kinds
20
of
ISFSIs,
site-specific
21
different kinds.
22
both
23
general and a specific licensed ISFSI.
operating
ISFSIs.
Maybe
three
As I said, North Anna and Surry
nuclear
reactors.
They
have
a
24
There are other sites like the Yankees
25
that have -- they don't have -- they decommissioned
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1
and dismantled their reactor.
2
ISFSI
3
ISFSIs.
there
4
and
then
those
All they have is an
are
general
licensed
And then you have wave reactor ISFSIs.
5
Those
like
6
constructed
7
going to talk about in a few slides here, interim
8
consolidated
9
eventually planning to be away from reactor ISFSIs
10
under Part 72 and it would be specific licensed
11
ISFSIs.
12
PFS
that's
been
or
operated
and
storage
So,
fuel
what
a
couple
facilities
is
new
that
we're
that
would
paradigm?
envisioned
15
think the time frame was 1998 we thought that Yucca
16
Mountain would be taking spent fuel and putting it
17
in the repository there.
a
very
envisioned,
When
14
be
first
never
spent
to
was
the
but
13
18
storage
licensed,
short
duration
it
by
That hasn't worked out as planned.
was
--
I
So,
19
the first paradigm shift was longer storage periods
20
much longer than the initial 20 years.
21
first
22
license them only up to 20 years.
started
23
licensing
storage
When we
systems,
we
did
The second paradigm shift was now as a
24
potential
interim
consolidated
storage,
25
potential sites in the United States.
two
Now, we're
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1
looking at the paradigm of the 72-71-72 paradigm
2
meaning
3
followed by storage.
storage
4
followed
And
then
if
by
the
71
transportation,
Department
of
Energy
5
implements its entire strategy that they issued in
6
January of 2013, there would be a repository into
7
that
8
transportation and then storage interim repository.
as
well
9
with
The
DOE
TSAR,
topical
DOE
is
Part
thinking
consolidated
12
heard from DOE is that more is better, more storage
13
sites are better and they intend to submit that to
14
us in the near future for our review and approval.
think
the
report
about
11
I
analysis
71
building
storage.
safety
another
10
15
a
potentially
quotes
for
I've
It would be, again, a generic topical
16
analysis
17
specific, but provides some bounding considerations
18
that would be part of the topical safety analysis
19
report.
20
report.
Nothing
MEMBER POWERS:
specific,
nothing
site
You're not responsible
21
for the proposal of interim consolidated storage,
22
but it seems -- it always seems remarkable to me
23
you
24
responsible for and now somebody wants to create
25
the megasites.
do
have
all
these
sites
that
you
are
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1
Do you have any views on that?
2
MR. LOMBARD:
3
We have a lot of views on
interim consolidated storage, which could take --
4
(Laughter.)
5
MEMBER POWERS:
6
you'd care to share with us?
7
(Laughter.)
8
MR. LOMBARD:
9
Do you have any views
It's, you know, from our
standpoint, from a safety and security standpoint
10
it
doesn't
11
interim consolidated storage facilities, the 75 or
12
so
13
consolidated
14
long
15
doesn't matter to us.
sites
as
matter
that
whether
you
are
out
storage,
they
still
meet
the
they
still
have
there,
distributed
or
meet
you
the
have
--
as
requirements,
it
16
As a taxpayer, it seems like there are
17
some economies of scale that could be appreciated
18
if you do the consolidated storage, but again it
19
depends on what is that end game?
20
after that point?
21
22
What happens
Where is it going from there?
Because we know what we hear are about
the communities are interested in having --
23
MEMBER POWERS:
Well, I mean, it seems
24
to -- just offhand to me, I mean, you've got places
25
to store fuel.
Now, you want to pack it up and
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1
ship
it
to
another
2
unnecessary
3
involves some risk.
shipping
step
4
MR. LOMBARD:
5
MEMBER
which
seems
necessarily
It's very, very small.
Yes,
risk
is
assured
very, very small, but it's risk, nevertheless.
LOMBARD:
that
we're
7
9
that
Now,
regularly
MR.
an
Yes.
POWERS:
seems
That
6
8
it
place.
and
truthfully
you're
right.
We were here before you, I
10
think, two years ago to talk about the spent fuel
11
transportation risk assessment showing that he risk
12
of transportation is less than that that you would
13
get from background radiation.
14
So, it is very small, but, yes, you're
15
right, there is an increase in risk when you start
16
to transport.
17
And it's -- there's a lot involved in
18
the transportation.
19
might be if you had a consolidated storage site
20
that's very close, if not right on the same site
21
that you're going to use as a repository, but that
22
doesn't
23
potentially submit applications in.
24
25
seem
to
So,
Right
on
cue.
So, the -- the best solution
be
the
interim
We
have
case
with
the
consolidated
received
two
two
that
storage.
letters
of
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1
intent, one from Waste Control Specialists and one
2
from
3
applications in 2016.
Holtec/Eddy
Lea
Alliance,
to
submit
4
We actually a week ago Monday, we went
5
up to Columbia, AREVA-TN's offices there, and took
6
a
7
application for consolidated storage just to do an
8
audit, as you're very familiar with the new reactor
9
operations.
10
look
at
the
draft
Waste
Control
Specialists'
They do look -- they do audits on --
pre-application audits of different applications.
11
We took a cue from them and did the
12
same thing just for several reasons.
13
our eyes on the application and get a feel for, you
14
know, is it a 15-volume reactor application, or is
15
it a couple of volume, you know, application for
16
consolidated
17
volume size.
18
What kinds of things is this going to contain?
19
storage?
And
it's
One, to get
more
the
two-
And also to get familiar with it.
Not many folks, I don't think anybody
20
is
around
21
application in the mid-'90s.
So, we're starting
22
from
curve,
23
management curve, although we have interfaced with
24
at least one of the project managers that was on
25
the
scratch
PFS
that
actually
from
review
a
and
reviewed
learning
trying
to
kind
the
a
of
PFS
knowledge
drain
his
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1
brain a little bit of some of things they looked
2
at, what are the challenges, what are the things
3
that we could learn from him in the review of that
4
PFS application going forward.
5
We also have a lessons learned document
6
that was put together soon after PFS was approved.
7
And we've taken a look at that and that's helping
8
us
9
with the two applications.
10
As
to
define
will
our
project
mentioned,
be
a
strategy
a
generic
going
potential
DOE
TSAR,
11
which
defined,
this
12
generic storage -- consolidated storage site.
It's
13
not
some
14
bounding for the environmental conditions and the
15
seismic conditions for that site in a couple years
16
in the future for another entity who would want to
17
submit an application for consolidated storage.
site-specific.
18
system
forward
Hopefully
we'll
provide
Part 72, this is a question that came
19
up a lot a couple years ago.
20
facilities
21
written for storage and packaging.
22
under
Folks
Part
have
23
repackaging?
24
just packaging again.
25
packaging adequately.
72?
asked
Can you license these
It
is
is
it
adequate
adequate
as
for
And when we look at repackaging, it's
So, yes, Part 72 does cover
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1
We continue to monitor and coordinate
2
as appropriate with DOE and industry.
3
have those quarterly meetings with the DOE project
4
planning side who's responsible for development of
5
the TSAR.
6
We
have
a
little
bit
Again, we
of
a
tricky
7
relationship there as they get to the point where
8
they
9
developing
actually
a
start
developing
TSAR.
Then
an
we
application
switch
over
or
from
10
government-to-government to government-to-licensee.
11
Feature
12
relationship
13
change and we would start having public meetings on
14
that specific topic and move forward on that.
15
potential
for
And
licensees
that
in
so
specific
industry,
we
that
activity
our
would
participate
with
16
NEI and other industry members directly, licensees
17
directly in many different situations, topics and
18
issues on a very frequent basis.
19
So, the perfect storm.
20
that we started working on a few years ago.
21
actually, I felt that what -- our ship there in the
22
middle that's raging along in the high seas, it
23
really
24
battleship a few years ago.
25
looked
more
like
an
old
It's something
World
War
We
II
We had a lot of things that we have
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1
changed
in
2
approaches, and we feel that we're a little more
3
sleek than we used to be.
4
baggage, little less weight than we were carrying
5
before.
6
our
process,
in
our
technical
We have a little less
And you see our normal workload there
7
on
the
top
8
hurricane that it's always, always there.
9
left
The
and
DOE
that
TSAR,
continues
we
10
when that will be submitted.
11
probably
12
gotten far enough long on --
13
14
in
the
'17
time
don't
be
know
the
exactly
We're thinking it's
frame,
MEMBER POWERS:
to
but
DOE
hasn't
Where is your biggest
man-hour burden?
15
MR.
LOMBARD:
The
biggest
man-hour
16
burden, most of our resources are in the storage
17
side -- on the storage side, storage application
18
reviews.
19
20
MEMBER POWERS:
In the reviews or the
monitoring and --
21
MR.
LOMBARD:
Mostly
on
the
reviews.
22
The monitoring, the oversight is not as big as our
23
reviews,
24
applications, they're getting more complex as we go
25
forward.
for
sure.
They're
It
getting
takes
--
they
--
storage
systems
are
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1
bigger, the higher heat loads.
2
wouldn't
3
guess I would say exotic materials in some cases
4
that have been used for basket materials and other
5
materials of construction.
call
them
There are some -- I
necessarily
--
well,
yeah,
I
6
So, it's caused us to really sit back
7
and really learn what are those materials, what are
8
the
9
change over time over the license period for that
10
material
properties,
how
are
they
going
to
system?
11
So,
yeah,
12
complex.
13
time
14
application in general.
they
have
gotten
more
So, we are making -- we're spending more
as
15
we
go
forward
CHAIRMAN
on
each
BALLINGER:
individual
So,
are
you
16
spending time -- to follow through on that, what
17
you're
18
staff to become more educated on these materials
19
and
20
review?
saying
other
21
is
things
MR.
you're
so
spending
that
LOMBARD:
they
time
can
do
Absolutely.
allowing
a
proper
Friction
22
stir welding is a great example.
And how did we do
23
that?
24
friction stir welding, get very familiar with the
25
materials,
Well, we sent them over to the site to watch
the
process
and
made
sure
that
they
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1
understood everything that we needed to understand
2
to
3
operation.
make
a
safety
4
5
finding
on
that
particular
So, we try to do the hands on, get your
eyes on it and see what actually goes on there.
6
MEMBER POWERS:
7
improvements
8
could
9
area?
in
reduce
10
software,
your
MR.
Are there technological
things
man-hour
LOMBARD:
like
that
requirements
That
that
man-hour
11
requirements?
12
When
13
tremendously
14
from
15
dimensional modeling now.
16
some time to get familiar with modeling strategy
17
and to understand what kind of result it's going to
18
give you.
you
the
Initially, no.
reduce
in
that
look
at
But long-term, yes.
modeling,
improved
over
two-dimensional
CFD
the
modeling
years,
modeling
you
to
has
know,
three-
And you -- it takes you
19
But in the long-term, they're giving us
20
better results, I think, and helping us to look at
21
can we now slim down those margins that we've been
22
using in the past to --
23
MEMBER POWERS:
Yeah, I'm just looking
24
to, you know, how can we -- can we use technology
25
to -- in the place of man-hours?
In this sort of
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1
thing are there expert systems that would assist?
2
Anything you can do to cut down on your man-hour
3
requirements because, I mean, quite frankly, man-
4
hours are expensive.
5
MR. LOMBARD:
Yes.
Absolutely.
And
6
that's a good point.
7
love to hear them.
8
play, but if you have any other ideas we'd like to
9
hear them, too.
10
If you have any ideas, we'd
We have a few that we have in
MEMBER POWERS:
I don't, but, I mean,
11
it seems like -- it seems like that's where I would
12
focus my attentions where you're expending the most
13
man-hours --
14
MR. LOMBARD:
15
MEMBER
Right.
POWERS:
--
because
small
--
16
relatively small improvements can make big dollar
17
changes.
18
MR. LOMBARD:
19
CoC
and
Yes.
ISFSI
Absolutely.
renewals,
you'll
see
a
20
graph here in another slide or two that will talk
21
about
22
renewals going forward.
23
storms there, WCS and Holtec.
the
24
25
timing
of
the
ISFSI
renewals
and
CoC
And then you see the twin
We didn't have in our FY16 budget, we
did
not
budget
for
review
of
two
consolidated
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1
storage
facility
2
reprioritizing our work going forward to make sure
3
we have the resources available for that purpose.
4
So,
applications.
our
topics,
So,
our
we're
meeting
topics
5
today, there's a lot of pieces to this puzzle and
6
only a few of them are shown here.
7
are rimmed in black, black borders, are the ones
8
we're
9
tomorrow morning.
going
10
to
talk
about
with
The ones that
you
today
and
But if you look at storage on the left,
11
things
on
the
12
performance, extended storage, as I said earlier,
13
we're looking to start to close those out, those
14
activities
15
sending a memo up to the Commission in the May --
16
by end of May telling them that we're essentially
17
closing
out
18
forward
because
19
framework that he built for the renewal, so ISFSIs
20
and CoCs going forward, which is a good thing.
out
bottom,
this
year
extended
Al
dry
and
storage
we're
storage
system
going
to
activities
overachieved
on
his
be
going
renewal
21
Initial storage terms, again, we were
22
at 20 years initially when we thought that there
23
would
24
changed the requirements.
25
term up to 40 years or even initial term up to 40
be
a
repository
available.
We
eventually
They could get a renewal
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1
years.
So, we're learning as we go forward and
2
changing our approaches.
3
The
and
top
three,
renewals
risk
you'll
informed,
hear
fuel
4
performance
about
this
5
morning and a little bit more on renewals tomorrow.
6
Retrievability is really the link that
7
links storage and transportation together and then
8
obviously
9
storage, but in transportation as well.
have
10
fuel
performance
not
only
So, the first one is renewals.
And you
11
see our little graph there on the top right.
12
see
13
application.
14
the
15
certificates of compliance.
for
the
few
years
we
have
a
You
single
The dark blues are the site-specific,
ISFSIs,
16
first
in
and
the
light
blues
are
the
CoCs,
And this year we have one coming in,
17
and that is North Anna.
Two coming in next year.
18
When you see in 2020, we hit a large peak.
19
four -- one, two, three, four, five, five CoCs and
20
one ISFSI renewal in 2020.
There's
21
So, we looked at -- luckily we looked
22
at this a couple years ago and said there's a bow
23
wave coming.
24
How are we going to handle this within our resource
25
constraints?
We've got to do something about it.
Because
everybody
has
resource
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1
constraints.
2
And we thought about what are the --
3
what are the key aspects of renewals that we really
4
need
5
time-limited
6
Part
7
management programs is the area that we felt we
8
should focus on because they're materials driven.
to
focus
72
on
and
aging
aging
analyses
requirements
9
management
are
for
programs,
required
in
renewals.
the
Aging
So, we built an operations-based system
10
for
aging
11
NUREG-1927
12
forward.
It's going to feed other documents that
13
we
going
14
Management of Aging -- I always have trouble with
15
the P -- Management of Aging Process for Storage.
have
16
management
Rev
We
1
is
programs
a
key
forward,
almost
SAM
MAPS
is
a
just
that
going
report,
storage
didn't
the
aging
management
18
didn't want people to get confused with SAMGs as
19
going forward.
21
but
of
forward.
17
20
program,
piece
the
called
going
--
we
So, we --
MEMBER
POWERS:
Our
former
chairman
would have loved it.
22
(Laughter.)
23
MR. LOMBARD:
So, part of this, again,
24
the focus or renewals is aging management programs.
25
The
focus
of
aging
management
programs
are
the
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1
inspections that have to be conducted under that
2
aging management program.
3
the
4
techniques and time frames.
5
And
appropriate
We looked at what are
monitoring
as
you
necessarily
can
and
imagine,
7
So,
8
industry, we're encouraging them and pushing them
9
in many cases to develop better techniques, better
techniques
we
for
are
that
systems
weren't
industry,
for
the
6
the
designed
inspection
promoting
monitoring
up
front.
within
10
ND
11
systems, for example, monitoring the surface of a
12
canister,
13
the welds on those canister, how can you detect
14
cracks, how can you detect the depth of cracks.
15
And those are the types of things we want to see
16
and those utilized as part of the aging management
17
program inspections going forward.
monitoring
18
And
then
and
the
storage
the
heat
also
canistered
effective
zones
assessment
monitoring
data
20
acceptance
criteria.
21
trending
22
can imagine, we, the collective we, and I mean us
23
in
24
operating
25
have been collecting over these last 20 plus years
industry,
operating
haven't
experience
findings
the
19
of
inspection
of
of
against
Reporting,
aggregating
and
experience,
because
you
really
collected
information
that
as
all
we
the
should
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1
of storage.
2
So, as part of the renewal framework,
3
it requires operating experience to be collected.
4
And
5
worked with INPO and they have an agreement now
6
within -- with the four main vendors of actually
7
they're building a program.
8
actually feeding information to it that will have
9
some
I
give
the
access
to,
10
individual
11
going forward.
level
vendors
12
13
industry
will
because
they've
They're going to start
of
access
have
MEMBER SKILLMAN:
to,
access
and
to
as
the
well
Mark, wouldn't the --
excuse me.
14
MR. LOMBARD:
15
MEMBER
16
kudos,
Go ahead.
SKILLMAN:
Mark,
wouldn't
the
corrective action programs --
17
MR. LOMBARD:
18
MEMBER
decades
Absolutely.
SKILLMAN:
past
20
information?
21
provide at least a pointer to we've got a leak, or
22
we've got a crack, or we've found something.
well,
in
25
canisters.
treasure
the
couple
24
a
from
19
23
provide
--
chest
of
I would think reporting on site would
MR.
CSONTOS:
the
past
they
So
far
those
haven't
don't
expected
-the
So, that's the only thing that we would
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1
find out about is whether or not there was a nest
2
in one of the thermal vents, you know.
3
take those out.
Was there any dosimeters around
4
the
the
5
there?
periphery
6
of
pad
would
They would
something
happen
But, you know, in this case we do have
7
some
OpE
for
certain
8
canister
9
different animal.
10
North
that
have
types
an
Anna,
of
tasks.
overpack
for
on
example,
But
a
is
a
the
pinks
their
11
casks.
Their casks are carbon steel, not stainless
12
steel.
And so, you can easily see a rust spot and
13
they
14
corrective
15
repaired those locations.
--
we
16
17
have
--
actions
we
have
they've
heard
done
about
the
there.
They
Those are easy to get, but the other
ones looking inside a canister, that's fairly new.
18
MEMBER SKILLMAN:
19
CHAIRMAN BALLINGER:
of
the
all
21
talked about many times.
22
you've explored more global inspection techniques
23
that
24
inside and look for cracks and things like that.
25
inspection
I can understand
20
don't
local
Thank you.
require
a
things
that
we've
I'm curious as to whether
lot
of
effort
to
go
down
Have you explored techniques that would
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1
tell you that you need to focus more carefully on
2
one
3
perspective so that you can reduce the burden and
4
workload of having to do a lot of inspections on
5
casks?
particular
6
cask,
Maybe
I'm
but
not
from
a
wording
more
it
global
right,
but
7
simple -- very simple things that you can measure
8
with respect to these casks that tell you that you
9
maybe should go a little bit more carefully rather
10
than sort of just inspecting everything.
11
MR.
LOMBARD:
There's
you
strategy
don't
inspect
12
every
one.
13
that,
a
14
anomalies, then you increase your sample just like
15
you do in the corrective action program for any
16
other issues.
sampling
a
And
strategy.
17
CHAIRMAN
BALLINGER:
18
doesn't necessarily mean a leak.
19
MR. LOMBARD:
20
CHAIRMAN BALLINGER:
21
MR. LOMBARD:
associated
If
you
But
an
with
identify
anomaly
Absolutely.
Okay.
But we want to identify
22
the precursors.
23
canister, then that would implement -- you go to
24
the next step and --
25
If there's general corrosion on a
MR. CSONTOS:
So, what are you asking
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1
about?
Are
2
relative humidity, all those --
3
4
you
CHAIR
asking
about
the
BALLINGER:
temperature,
Those
kinds
of
things.
5
MR. CSONTOS:
Yeah, so EPRI -- and EPRI
6
can discuss this when they're up here.
7
questions,
8
susceptibility report that they just published, I
9
think, September of last year or last fall.
but
there's
a
You can ask
chloride
SCC
And
10
what it goes into, it goes into all those different
11
parameters.
12
And
for
the
--
and
we
just
wrote
13
letter, gave comments back to EPRI.
14
be closing out the chloride SCC RIRP program.
15
think
16
Resolution
17
right.
it's
regulatory
Protocol.
--
18
CHAIR BALLINGER:
19
MR. LOMBARD:
20
MR. CUMMINGS:
We're going to
Regulatory
That's
a
the
NEI
I
Issue
protocol,
That M-10?
Correct.
Yeah.
Kris Cummings, NEI.
So,
21
yeah, a lot of questions that you're asking we'll
22
be able to address either in my presentation or
23
Keith
24
things the industry has been doing working with the
25
NRC, proposing some things.
Waldrop's
presentation
from
EPRI
on
the
You talked about the
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1
aging
management
INPO
2
collecting that information.
3
One
of
the
database.
things
to
We'll
your
be
question,
4
Gordon, about the previous OE catch programs is we
5
will
6
into that database as we get it up and running and
7
collecting new information.
be
looking
8
to
entering
CHAIR BALLINGER:
in
that
information
Because this is the
9
first presentation that I've seen here in two years
10
with the words risk-informed are actually on one of
11
the slides.
12
MR. CSONTOS:
the
know,
14
going to -- the criteria for how to inspect, which
15
ones
16
ongoing through the ASME code because of -- we're
17
not operations folks, you know.
inspect,
of
condition,
how
many
to
you
This is, you
13
to
extent
Oh, yeah.
know,
inspect,
we're
that's
18
So, what we did is we asked the ASME
19
code, because we brought in all the vendors, the
20
licensees, the people who are doing this work to
21
come up and help us with let's focus what we need
22
to do in terms of inspections.
23
So,
it's
ongoing
right
now,
but
the
24
point is, is that we have criteria that we can do
25
to focus onto one or two canisters at a site.
And
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1
then from there if we do find something on those
2
higher
3
extended conditions corrective actions.
4
all
5
oversight to those processes, but that's primarily
6
what we're doing is we're giving the tools back to
7
the licensees to go ahead and figure out what those
8
steps are and start off with an initial set going
9
into a larger set if need be.
10
CHAIR
11
risk
licensee-driven,
we
then
will
have
to
I'll
at
And that's
oversight
BALLINGER:
look
--
keep
give
bringing
that up.
12
13
canisters,
MR. LOMBARD:
Sure.
Please do.
That's
a good point.
14
MEMBER REMPE:
Talk a little bit about
15
orphan sites and what happens with the license when
16
it
17
plant.
goes
from
18
19
an
Are
operating
any
of
the
plant
ones
to
on
a
your
shutdown
earlier
map, orphan sites?
20
MR. LOMBARD:
21
MEMBER
like
Yes.
REMPE:
they're
Are
got
there
to
minimum
22
requirements
maintain
the
23
capability for repackaging required for an orphan
24
site, or is there anything -- what happens with
25
orphan sites?
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1
MR.
LOMBARD:
They
don't
2
maintain the capability for transfer.
3
required.
4
MEMBER REMPE:
5
that's
required
6
operating the plant?
7
the stuff offsite?
8
9
of
the
require
to
It is not
But isn't that something
utility
when
they
were
They have to be able to ship
MR. LOMBARD:
It depends on the system.
There are some system tech specs that have that
10
requirement
to
maintain
11
repackage, but it was something that wasn't put in
12
for -- due to a safety concern.
13
MEMBER REMPE:
14
MR.
that
to
Okay.
LOMBARD:
And,
some
actually,
actually
16
amendments now to take that requirement out of the
17
tech specs.
MEMBER REMPE:
revisions
Okay.
to
we're
15
18
processing
capability
those
And the renewal
19
when it goes from an operating plant to a shutdown
20
site, there's nothing that changes the ISFSI and
21
the
22
regular renewal?
licensing
23
24
on
MR.
that
LOMBARD:
until
it
Only
comes
the
up
for
imposition
a
of
aging management requirements.
25
MEMBER REMPE:
Okay.
Thank you.
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1
MR. LOMBARD:
You're welcome.
2
So, moving on to fuel performance, this
3
is one of my favorite topics.
4
I was referring to at North Anna is a TN-32, just
5
so
6
exterior vertical system.
you
know.
7
It's
a
And the system that
TN-32
metal
system,
metal
And they also have -- that's if they're
8
a
specific-licensed
9
general-licensed
ISFSI.
ISFSI,
And
they
if
have
they're
the
a
NUHOMS
10
System, which our canistered system -- just to be
11
clear on what they have at North Anna.
12
NUHOMS are the horizontal systems.
13
And the
So, fuel performance, we spent a lot of
14
time
talking
15
performance as part of our reviews of each system,
16
transportation and storage system that we look at.
17
about
Two
it
main
and
looking
aspects.
project,
One
DOE
fuel
is
a
18
demonstration
19
demonstration project.
20
microscopic views of fuel clad hydrides.
21
left is a circumferential hydride that -- for high
22
burn-up fuels.
23
uptake
industry
24
subjected
25
drying.
You see there on the right,
The top
You'll -- depending on the hydrogen
capability
to
the
at
of
high
the
cladding,
temperatures
those
during
are
vacuum
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1
Those
circumferential
hydrides
can
2
reorient to radiohydrides and can create a design -
3
- DBTT, ductile-to-brittle transition temperature,
4
which would be more -- actually be more accurate to
5
call
6
It's not necessarily ductile-to-brittle transition
7
temperature.
8
you'll see there that's the mechanism that we're
9
concerned about when we look at these.
it
a
less
ductile
It's
transition
somewhat
of
a
temperature.
misnomer,
but
10
Now, our position is -- our position is
11
that long-term storage and eventual transportation
12
of all cladding types we've reviewed and approved
13
to date is safe.
14
We've never identified a safety issue
15
with those that caused us to not be able to approve
16
the systems that we have put into play.
17
The
demonstration
project
is
intended
18
to take four fuel cladding types for North Anna.
19
And North Anna has submitted a license amendment
20
request for this TN-32 system that will be used to
21
actually
22
And we're -- that's an active amendment that we're
23
looking
24
aspect of it, but just the science piece is the
25
actual
house
at
fuel
now.
this,
the
So,
itself,
we
four
demonstration
can't
talk
different
project.
about
fuel
that
cladding
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1
types placed into this TN-32.
2
It
will
be
monitored,
pretty
much
3
online monitoring of temperature, and off gas will
4
be monitored every, I think, two to three times
5
during the ten-year planned storage period of the
6
system.
7
At the end of that time, the plant is
8
to send that cask to an area that has a hot cell
9
that
10
can
remove
the
fuel
and
do
some
material
property testing of the fuel itself.
11
Now, fuel pins have been removed from
12
the assemblies already.
13
Oak Ridge, right?
14
tested to set up some baseline material properties
15
for those -- the four different cladding types.
16
We're
They've been shipped to
Oak Ridge.
closely
And those will be
monitoring
it.
We
did
17
make comments on the test plan and reviewing, as I
18
said,
19
itself.
20
storage
21
including high burnup fuel, is safe.
22
being
23
doing at the Oak Ridge National Lab taking some
24
high burnup fuel samples from H.B. Robinson plant,
25
putting them into a CRIFT, I think it is, which is
the
license
amendment
for
the
demo
cask
But, again, our position is that long-term
and
demonstration
further
demonstrated
of
all
by
cladding
the
types,
And that's
testing
we're
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1
a
device
that
provides
2
itself, actual sample of the fuel assembly or the
3
fuel rod or fuel pin and subject it to a higher
4
than the loads that we would expect to see during
5
normal
6
seeing
7
going forward.
conditions
some
very
of
good
a
moment
on
transportation
results
from
the
sample
and
that
we're
testing
8
We issued the Phase 1 test report last
9
summer and we're going through the Phase 2 testing
10
now.
11
MEMBER POWERS:
How do you know what
12
normal loads are?
13
pretty spectacular in this country.
14
roads are excellent.
15
what the normal loads are?
16
I mean, some of the roads are
Some of the
And, I mean, how do you know
MR. LOMBARD:
Lucky for us DOE's done
17
some testing of that.
18
assembly, not an actual fuel assembly, but a dummy
19
fuel assembly and they've measured the loading that
20
you would see during some pretty crummy roads, I
21
think, there in New Mexico.
22
idea of --
23
24
They've taken a dummy fuel
MEMBER POWERS:
So, they have some
All of the roads in New
Mexico are pretty --
25
(Laughter.)
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1
2
MEMBER
POWERS:
here
to
testify.
And we all drive very fast.
3
(Laughter.)
4
MEMBER POWERS:
5
MR. LOMBARD:
6
I'm
And long distances.
So, we do have some feel
for what the normal loads are.
7
CHAIRMAN BALLINGER:
I mean, don't most
8
transportation vehicles that are related to nuclear
9
have accelerometers and all kinds of stuff on their
10
packages anyway?
11
the roads are like.
12
So, they pretty much know what
They actually have a recording for --
13
if
you're
14
recording of all of the various things that go on
15
in transportation between the site -- between the
16
fabrication facility and the site, right?
17
18
delivering
fuel,
MEMBER POWERS:
driven past my house.
they
have
a
I suspect they haven't
You would be more terrified.
19
(Laughter.)
20
CHAIRMAN BALLINGER:
21
MEMBER
22
actually
POWERS:
By the sandbags.
Sandbags?
How
about
deep pits.
23
MR.
LOMBARD:
Meraj
Rahimi
will
be
24
talking more about that in fuel performance going
25
forward.
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1
So,
so
far,
this
I
is
Dr.
think,
Ballinger's
risk-informed
favorite
2
slide
regulatory
3
framework.
4
to do.
5
at the NRC in a world of spent fuel, we knew we had
6
to start looking at risk-informed.
This is something that we knew we had
As we looked at our environment, our world
7
And,
actually,
the
RMRF,
the
risk
8
management regulatory framework folks put together
9
the document NUREG-2150, I think, is the number.
10
And spent fuel, transportation spent fuel storage
11
were parts of that document that was issued and had
12
some recommendations for us to consider in a spent
13
fuel world.
14
So,
we've
taken
those
recommendations
15
to heart, we've built an approach and we're off and
16
running to implement that approach and to find for
17
storage at least initially, to find a regulatory
18
framework
19
inform our decision going forward with the focus on
20
safety and security, obviously, going forward, but
21
to be more effective in the decisions that we make
22
to be more sensitive to the fact that these are
23
very large, robust systems.
24
25
that
we
could
use
that
would
better
And there were two pilot PRAs done some
years ago.
One done by the NRC, one done by EPRI,
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1
Electric Power Research Institute.
2
They looked at latent cancer fatality
3
risk
over
the
first
4
included
5
sitting on the pad for about a year.
6
out with about a 10 to the minus 12, 10 to the
7
minus 14 range of latent cancer fatality risk.
loading
year
and
of
transfer
operation,
to
the
which
pad
and
And they came
8
We're very cognizant of the fact that
9
those two pilot PRAs came up with low risk of spent
10
fuel storage, but I think part of that is because
11
the systems are so robust.
12
And in this world of when you look at -
13
- I guess I keep thinking from a risk informing
14
standpoint you look at a curve and the operating
15
experience is something that as we go over time and
16
build more and more documented operating experience
17
while there is some operating experience out there
18
now that we can tap into, but as you build that
19
database
and
learn
more
20
systems,
the
risk
that's
21
experience goes down.
22
But as you go forward in time to longer and longer
23
storage
24
degradation
25
well.
periods,
more
defined
about
by
these
operating
Your known risk goes down.
your
mechanisms
and
can
potential
potentially
material
go
up
as
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1
So, you've got some -- and those aren't
2
the only two considerations to be thought of, but
3
you have some potentially competing consideration
4
from a risk standpoint and we want to come up with
5
this risk framework that puts that in on a piece of
6
paper so we can all point to that and say this is
7
the process we use going forward.
8
9
CHAIRMAN BALLINGER:
Have you -- this
is a real issue for me, because 10 to the minus 12,
10
10
to
the
11
counting?
minus
13,
10
12
MR. LOMBARD:
13
CHAIRMAN
magnitude
the
minus
14,
It's
still
who's
Right.
BALLINGER:
below
orders
15
about and have you thought about what the increase
16
in risk is for a leaking canister?
MR. LOMBARD:
anything
that
we
six
14
17
of
to
care
For risk, and what's your
18
safety goal?
19
now defining a safety goal.
20
fatality, is it breach frequency?
21
right?
22
trying to look at the qualitative health objectives
23
and come up with a reasonable safety goal --
24
25
And that's -- we're in the process
Is it latent cancer
It's not CDF,
It's not core damage frequency.
CHAIR
BALLINGER:
Because
So, we're
there's
a
site boundary limit, 25 MR, right?
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1
MR. LOMBARD:
Right.
2
CHAIR BALLINGER:
So, have you thought
3
about an overall program to minimize the workload
4
and the -- of a lot of inspections and stuff like
5
that because if the canister actually does leak and
6
you
7
detect it if it leaks, but does that affect the 25
8
MR boundary limit?
have
9
10
to
take
action,
course
you
have
to
In other words, does a leaky canister
make a difference?
11
MR. LOMBARD:
12
CHAIRMAN
13
of
And you --
BALLINGER:
Other
than
a
political difference, does it make a difference?
14
MR.
LOMBARD:
That's
exactly
right.
15
You're asking a great question and we've thought
16
about it and talked about it several times and we
17
know that we want to do a consequence analysis.
18
But when you think of dry cask storage, what's the
19
driving force?
20
It's not a LOCA, right?
You've
got
--
It's not a
21
core-to-floor.
what's
going
to
22
happen?
23
if one starts, you'll get a crack, you'll leak a
24
few molecules a second over time.
25
helium over pressure will be gone, but that's --
What will happen is you'll get a crack --
Pretty soon that
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1
that's over time and then what happens?
2
have no driving force.
3
Then you
If there were any radioactive material
4
inside
the
5
system, what would happen?
6
for normal situations, you would detect it at the
7
site boundary.
8
canister
or
in
MR. CSONTOS:
a
dry
cask
storage
I don't believe you,
And I think we have to
9
take a look at it on an even bigger scale than that
10
just not from the public health and safety, you
11
know, issues.
12
I mean.
13
It's also looking at -- for storage,
But if you're taking a look at cracked
14
canisters, we look at one.
15
has 200 or 300?
16
Storage, it could be a lot more, okay.
17
So,
What about if a site
Or in the case of Consolidated
you
have
individual,
you
have
18
aggregate considerations to think about.
19
have to think about what that -- that that impacts
20
operations.
21
acceptable for you to be able to pick up, move,
22
handle.
23
-- these are all things that we're considering in
24
terms of risk informing.
25
public, but risk for the whole site and aggregate.
What
state
of
degraded
You also
conditions
What is the dose to the workers?
is
What are
It's not just risk to the
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1
CHAIRMAN
BALLINGER:
2
with 10 to the minus 12.
3
MR. CSONTOS:
4
CHAIRMAN BALLINGER:
5
you
started
Correct.
Let's say you go
up.
6
7
And
MR. CSONTOS:
We know that.
We are
well aware of that, yes.
8
CHAIRMAN BALLINGER:
9
MR. LOMBARD:
Okay.
Absolutely.
And Donald
10
Chung will be giving you that presentation later on
11
this morning.
We look forward to it, because this
12
is
where
13
straightforward to move forward.
something
it's
not
easy.
It's
not
14
We define defense-in-depth criteria and
15
built some matrices of what defense-in-depth means
16
to
17
you would apply them.
the
different
important
safety
functions,
how
18
But in the end when you get through all
19
those criteria, in the end you still have emergency
20
planning at the end of it.
21
mitigating
22
situation
23
which I don't think it would.
strategy
it
would
if
end
That's part of your
you
up
in
have
dry
such
cask
a
bad
storage,
24
And, again, we plan to do a consequence
25
analysis over the next year or two to help support
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1
our risk informing framework going forward.
2
Retrievability. So, this is one of my
3
favorites
4
favorites, too.
5
defined retrievability on a fuel assembly basis.
6
as
well.
It's
of
the
industry
It's something back in 2001 we
And it was a different environment back
7
then in 2001.
8
we're into a new century.
9
repository.
10
one
The '90s were just finishing up and
We
were
And we were thinking of
thinking
of
what
are
the
operational considerations.
11
But in reality when you look at what
12
are the safety considerations that need to be taken
13
care
14
retrievability in a fuel assembly basis in light of
15
the new paradigm, the pair of paradigm shifts that
16
have occurred, didn't really seem to be practical.
of
in
dry
cask
storage,
defining
17
Part of that is because that definition
18
could drive people to think that you are going to
19
be requiring actual fuel inspections.
20
want to drive fuel inspections.
21
based on the information we have -- and if you look
22
at -- if you look at the environment in a reactor
23
versus a -- that fuel would experience inside a
24
reactor versus what it would experience in dry cask
25
storage, they're very different.
And we don't
We don't think
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1
The
environment
in
a
reactor
is
much
2
more severe especially if you talk about accident
3
conditions, than what you're going to see in dry
4
cask storage.
5
information we have from fuel reliability in the
6
reactor, information we're receiving that we have
7
conducted in our research activities, and research
8
and development that the DOE has done at different
9
national labs and the work we continue to do, the
10
industry continues to do in confirming that really
11
the robust nature of cladding is very good.
12
very good performance going forward.
13
So, we are confident based on the
When
It's
we linked all the information and
14
wrapped it together, we said we really need to look
15
at ISG-2 and provide a broadened definition in ISG-
16
2 to give an option.
17
If an applicant wanted to come in and
18
use
the
retrievability
19
basis, we would give them that option in ISG-2.
20
Now,
it
definition
doesn't
come
on
a
system
without
some
21
baggage.
And if you -- I'm sure you've read ISG-2
22
in detail.
23
at aging management from day one to make sure that
24
that
25
functions going forward, but it does allow options
system
It also have some requirements to look
is
maintaining
its
important
safety
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1
to the approach and Emma will be giving you that
2
talk a little bit later on this morning.
3
expert on retrievability.
4
5
MEMBER SKILLMAN:
She's our
Mark, let's back up
just for a second.
6
MR. LOMBARD:
7
MEMBER
Sure.
SKILLMAN:
I
understand
what
8
you've just said and I generally agree with your
9
comment.
Fuel
in
10
environment
11
storage status.
a
reactor
is
than
fuel
different
definitely
in
a
in
dry
an
cask
12
So, in one case we've got temperature,
13
we've got neutron flux, we've got gamma flux, we've
14
got
15
debris issues that are part and parcel of operating
16
fuel at power.
all
of
the
water
chemistry
issues
and
the
17
When you remove the fuel, you attempt
18
to dry it out and put it in a can, but now what
19
we're talking about is not only the condition of
20
that
21
burnup
22
physical
23
which the fuel is resident.
cladding,
fuel,
24
25
whether
but
different
we're
condition
And
things
it's
and
so,
that
low
also
burnup
talking
protection
now
are
we
of
have
vastly
a
or
high
about
the
the
can
in
couple
of
different
than
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1
fuel that is, in a way, "protected" is probably the
2
right word, in an operating core.
3
Now, this fuel is supposed to be dry.
4
We
think
that
clad
5
ductile and intact for many, many years, but now
6
we're
7
concerned
about
8
container
resides
9
that are going on.
concerned
10
is
going
about
the
its
to
be
container.
environment
and
we
sufficiently
have
in
some
We're
which
other
Al pointed to one, nests.
that
things
Like could
11
be birds' nests, mice nests.
12
with
13
that's out in the middle of nowhere.
14
And that brings its own chemical problems on top of
15
whatever container those osprey have chosen to live
16
on.
is
osprey
loving
17
MR. LOMBARD:
18
MEMBER
to
One I'm very familiar
be
on
top
of
a
thing
It's warm.
Yes.
SKILLMAN:
So,
this
idea
of
19
retrievability brings with it the ability to get to
20
the
21
container in a way that enables the machinery and
22
the workers to get that fuel.
23
narrow to think of this only in the context of fuel
24
in a container that's nice and happy and protected
25
for a long time.
top
of
that
container,
or
access
to
that
So, I think it's
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1
There are a lot of other things that
2
can happen on that cask that make getting to the
3
topic of retrievability very complicated.
4
MR. LOMBARD:
Absolutely.
A couple of
5
things.
We wanted to put our inspection eggs -- we
6
wanted to put our eggs in the inspection basket,
7
because those are the things we can inspect and
8
control without experiencing a significant dose or
9
additional resource requirements for the licensees.
10
So, we're focusing on the aging management program,
11
inspections of what is accessible from the outside.
12
And
that
includes
canister
systems.
13
you get into the surface of the canister and we're,
14
again, encouraging industry to come up with better
15
methods to do just that without having to pull a
16
canister and open it up and go through all of those
17
operational considerations and challenges and does
18
to workers as well.
19
Now,
having
over
time
said
that,
whether
it's
if
operating
20
experience
domestic
or
21
international, if it shows that there is an issue
22
with fuel that would require a system to be open to
23
determine if it is an issue with a specific type of
24
fuel or specific system or potential vacuum drying
25
issue that you need to resolve, we will take a hard
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1
look at that and would take the appropriate action
2
at that point.
3
MR. CSONTOS:
fuel,
4
up
the
5
One
of
6
discussion of the risk is right now with our aging
7
management programs there is no aging of the fuel,
8
because it's an inerted environment on the inside.
the
9
the
That's good you brought
canister
things
There
I
is
inspections
didn't
no
bring
active
up
and
such.
during
degradation
the
modes
10
that we can -- that we've identified for the fuel
11
inside of an inerted canister.
12
You'll be in an unanalyzed condition if
13
you do have a through wall crack and what is the
14
state of the fuel, what is the state -- these are
15
things that we can evaluate, but it's in one of
16
those conditions -- it's in a state where we will
17
have to do some more work.
18
So, I think that's why, as I mentioned,
19
that's the other aspect to what we were talking
20
about
21
retrievability
22
versus a fuel basis.
23
24
with
the
risk
from,
you
and
know,
MEMBER SKILLMAN:
the canister.
25
then
a
looking
canister
at
basis
Well, it's not just
It's the overpack in the container.
MR. CSONTOS:
Absolutely.
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1
MEMBER SKILLMAN:
And so when we talk
2
about this, we need to be, at least in my mind,
3
thinking
4
confront those who would attempt to retrieve.
about
all
of
those
5
MR. CSONTOS:
6
MEMBER SKILLMAN:
shiny
that
will
Right.
So, it's not just the
7
nice
8
concrete cavern inside the -- inside the, if you
9
will, storage module, it is all the top work and
of
container
items
10
all
the
things
11
order to get into --
that's
that
12
MR. CSONTOS:
13
MEMBER
sealed
have
to
be
down
in
the
addressed
in
Right.
SKILLMAN:
--
that
protected
14
area.
And I would just offer there can be a lot of
15
furs,
16
other things that are really not anticipated.
17
those
18
challenge to people who do this work.
19
MR. CSONTOS:
fangs
and
are
--
fins
on
actually,
top
of
they
that
machine
present
a
or
And
real
You're absolutely right.
20
Our OpE shows right now that we have -- we have
21
more
22
structures
especially
23
than
canisters
24
themselves
25
pretty good.
indication
the
have
of
been
corrosion
on
the
of
the
support
horizontal
modules,
themselves.
pretty
--
The
they're
canister
looking
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1
MEMBER SKILLMAN:
Thank you.
2
MR. LOMBARD:
3
So we have a list of future documents
Any comments?
4
that we'd like you to think about.
5
see them, 1536/1567.
6
-- two for transportation, two for storage.
And
7
we're
for
8
transportation, one for storage.
9
forward with that project, it's about a two-year
10
consolidating
If you want to
So, we have four SRPs now for
them
into
one
each,
one
So, as we move
project.
11
September 2016 proposed final of this
12
first SRP for consolidation of the storage review
13
plans.
14
look at, we'd certainly be happy to come in and
15
talk to you about that.
If that's something you'd like to take a
16
The
discussion over the last year or so, or two years
19
now,
20
about it.
since
we
caused
actually
managing
MAPS
started
of
talking
aging
report,
thank
you,
processes
in
storage,
22
is,
23
January 2017 for proposed final.
25
lot
Proposed final is December of '16.
The
24
a
issue
18
think,
that's
regulatory
summary
21
something
fuel
17
I
is
high-burnup
Now,
this
other
set
of
there
it
that's
SRPs,
the
transportation SRP's proposed final in May of 2017.
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1
And
lastly
the
high-burnup
fuel
technical
basis
2
NUREG, which is really tied in with that -- I'm
3
sorry, where it is?
4
summary, second one from the top, and the last one
5
are tied together.
High-burnup regulatory issue
6
The last one, the NUREG, really takes
7
the information from the RIS itself, the regulatory
8
issue summary, and puts it into a NUREG format.
9
So, something we'd ask you to think about.
And if
10
you want more information about each one of those
11
before
12
provide that.
you
13
make
a
decision,
we
can
certainly
And the last one is our successes.
And
14
I know you've seen Kris Banovac a few times here in
15
front of the ACRS.
16
that
17
without extensive collaboration with the industry.
18
And I want to thank NEI and other folks that have
19
been
20
have gone on for the last two plus years on NUREG
21
1927.
it
couldn't
very
22
much
On 1927 Rev 1, it's something
--
wouldn't
involved
in
have
the
been
possible
discussions
It's a collaborative effort.
that
Folks in
23
the industry have heard me say that several times,
24
but, again, it could not have been done, it could
25
not have gotten to the version that it has, the
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1
benefit that it really has and the version that it
2
is now.
3
Now,
that
guidance
NUREG-1927
4
industry
along
5
sorry, NUREG, not NUREG.
6
number?
7
MR. SPEAKER:
8
MR.
9
with
has
an
that's
--
I'm
NEI 14-03, right?
Yes.
LOMBARD:
guidance out there.
its
also
Right
Correct.
So,
an
associated
NEI
We intend at some point maybe
10
not in this revision, but at some point we would
11
endorse
12
forward because, again, it reflects our thinking,
13
the collective "we" thinking that collaboration is
14
going on in renewals going forward.
15
hearing more about that later on this morning.
all
16
or
Rev
part
2,
of
ISG-2,
the
NEI
Rev
2
guidance
going
And you'll be
we
have
talked
17
about a lot.
When we looked at our world a few
18
years ago, there were several things that we felt
19
were lacking.
20
first one we looked at.
And the renewal framework was the
21
Retrievability was another one based on
22
what we knew about our current environment and we
23
wanted to put several initiatives in play and our
24
folks
25
alongside and seeing the value of these initiatives
had
just
been
fantastic
at
really
coming
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1
and turning them into actual documents.
So, the
2
NUREG-1927 and ISG-2 Rev 2 are two great examples
3
of that.
4
The testing we're doing at Oak Ridge on
5
high-burnup fuel samples, the Phase 2 testing going
6
on now, being great successes so far not only just
7
defining the actual how the testing is to be done,
8
but shepherding of the testing as it goes forward.
9
The
review
strategy
for
consolidated
10
storage, although I have to say with Oak Ridge, and
11
Michelle Bales was here, but she has stepped out,
12
our folks, our partners in research have been just
13
a key to us in going forward with all the research
14
that
15
testing.
we're
doing
and
especially
the
Oak
Ridge
16
Our review strategy, we've got a great
17
review team set up for consolidated storage, both
18
WCS
19
finalizing the review strategy to do the best job
20
we can to get that review done.
and
the
Holtec
applications
now.
We're
21
If we get a high-quality application,
22
we want to get it done in three years, both the
23
environmental and safety and security side.
24
25
And
little
bit
you'll
more
this
hear
from
morning
Donald
on
Chung
a
risk-informed
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1
framework
status.
2
depth and the safety goals.
3
good
draft
4
now.
And after we talk to you, we'll be scheduling
5
a meeting with industry pretty soon on that one as
6
well, a public meeting to talk about the safety
7
goals.
8
9
We've
safety
And
goal
defined
defense-in-
At least we have a
that's
licensing
the
up
for
process
discussion
changes,
we've
implemented several changes over the last two years
10
especially
we've
looked
at
acceptance
reviews
to
11
really hone in on what is the scope of acceptance
12
reviews and make sure they get done in a timely
13
manner, as well as other process changes.
14
And it's a testament to the folks that
15
work for us, the tech reviewers, the folks that
16
have kind of crafted these initiatives and brought
17
them
18
great
19
successful and make us what we are today.
to
fruition.
job
20
21
in
It's
all
--
these
they've
areas
to
done
such
help
us
a
be
So, if there's any questions or we can
move on to the next.
22
MEMBER
POWERS:
Mark,
this
was
an
23
ambitious title, but I have to say you've succeeded
24
admirably.
25
MR. LOMBARD:
Thank you.
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1
MEMBER POWERS:
2
the
best
presentations
3
been here a while.
I've
experienced
MR. LOMBARD:
5
MEMBER POWERS:
6
MR. LOMBARD:
7
MEMBER
I've
Thank you so much.
-- really superb.
Thank you.
POWER:
Really
very,
very,
useful.
9
MR. LOMBARD:
Thank you.
10
CHAIRMAN BALLINGER:
11
MR. LOMBARD:
12
CHAIRMAN BALLINGER:
13
MR. LOMBARD:
14
and
So, it's --
4
8
This is easily one of
Ditto.
Oh, thanks.
Thank you.
Carry on.
Okay.
Would you like to
switch chairs with me, Kris?
15
MS. BANOVAC:
No.
16
MEMBER POWERS:
Kris, this is a little
17
bit being stuck following a movie star or something
18
like that.
19
(Laughter.)
20
MS.
BANOVAC:
So,
we're
about
20
21
minutes behind actually, but Mark --
22
MR. LOMBARD:
Let's not get too over
MS. BANOVAC:
He did a superb job, but
23
the top.
24
25
I think I can breeze -NEAL R. GROSS
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1
(Laughter.)
2
MS. BANOVAC:
3
back on time.
4
5
So, hopefully we'll get
MEMBER POWERS:
Well, just at any rough
points, well, Mark already covered this.
6
(Laughter.)
7
MS. BANOVAC:
So, thank you, Mark.
My
8
name is Kris Banovac and I'm a project manager in
9
the Renewals and Materials Branch in Division of
10
Spent Fuel Management.
11
And going back to Mark's figure, in my
12
talk today I'll be talking about the work that the
13
staff is doing to create the sustainable framework
14
for
15
durations
16
So, I'll be talking about the work that we're doing
17
and that we're involved with.
renewals
18
as
and
we
are
possibly
So,
in
my
expecting
multiple
longer
renewal
presentation
storage
periods.
today
first
19
we'll start by just going over the requirements for
20
spent fuel storage renewals.
21
about our efforts to identify needed updates to the
22
storage renewal framework.
23
I'll
provide
an
I'm going to talk
overview
of
the
work
24
that the NRC is doing, and this is both ongoing and
25
future planned work.
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1
And then I'm also going to provide an
2
overview of some external work that is also being
3
done
4
future.
to
create
a
sustainable
framework
for
the
And this is work that NRC is involved in.
5
On the next slide, this is just a recap
6
of
our
requirements
7
licensees
8
installations and also certificates of compliance
9
for storage system designs.
for
10
for
independent
renewal
of
specific
spent
fuel
storage
NRC's regulations allow for renewal of
11
ISFSI's
and
12
years given that specific regulations that ensure
13
that the storage systems perform as designed and
14
the period of extended operation are met.
15
CoCs
The
for
a
renewal
period
not
to
applications
exceed
must
40
include
16
time-limited aging analyses and must consider the
17
effects
18
components
19
assesses
20
their intended functions in the period of extended
21
operation.
22
of
aging
that
their
The
are
on
structure
important
capability
renewal
to
to
applications
include aging management programs.
24
for
25
adversely
management
of
affect
the
safety
continue
23
the
systems
aging
and
to
it
perform
must
also
And those are
issues
structure
and
that
systems
could
and
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1
components important to safety.
2
And in order to NRC to approve storage
3
renewals,
licensees
4
aging effects on the dry storage systems will be
5
adequately and safety managed and addressed so that
6
those systems can continue to perform as they were
7
designed.
8
9
MEMBER
this:
need
to
demonstrate
SKILLMAN:
Kris,
that
let
any
me
ask
Is there any intentional connection between
10
subsequent license renewals for the ISFSIs and the
11
topic
12
licenses?
of
life
13
after
MS.
60,
SOR,
BANOVAC:
benefitted
greatly
for
Yes.
So,
we
actually
15
experience.
16
storage renewal team and we really reflected on the
17
reactor
18
reactors have gone through renewals.
renewal
a
experience
reactor
50
have
talk
the
Part
14
We'll
from
the
little
bit
since
renewal
about
most
of
our
the
19
And now, you know, we're just starting
20
our first renewal for storage and reactors are now
21
considering
22
there were a few sessions at the RIC just a few
23
weeks ago.
24
from
25
renewals, and we will continue to learn from them
the
subsequent
license
renewal.
I
know
So, we will be -- we've learned already
NRR
review
experience
for
the
reactor
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1
as
they
2
periods.
go
through
their
3
MEMBER SKILLMAN:
4
MS. BANOVAC:
72
Okay.
renewal
Thank you.
In February of 2011 we
5
updated
6
requirements.
7
2011, we issued the accompanying guidance for that
8
rulemaking.
9
review plan for storage renewals and that's NUREG-
10
Part
subsequent
to
include
these
specific
And also at that time in March of
And
that
guidance
is
the
standard
1927 Revision 0, which Mark mentioned in his talk.
11
So,
has
over
reviewed
the
past
years
the
staff
13
specific ISFSI licenses and also CoCs for storage
14
system designs.
15
reviews
16
Revision 0 needed to be expanded and clarified in
17
several areas.
18
15
for
both
And what we found through those
that
And
applications
NRC
12
was
renewal
few
the
since
we're
and
expecting
receive
20
several years, in the bow wave that Mark mentioned,
21
we
22
team and we had folks from the Division of Spent
23
Fuel Management, we had our research counterparts,
24
we
25
help us with that work and we looked at the storage
also
had
our
an
interagency
general
counsel
within
to
about
establish
applications
NUREG-1927
19
did
renewal
guidance
the
storage
next
renewal
counterparts
to
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1
renewal
framework
2
needed to make to NUREG-1927, but we also thought
3
about
4
infrastructure
5
this work going forward so we could have effective
6
and
7
getting so many of them all at the same time.
what
9
other
also
guidance
renewal
And
we've
figure
so,
had
out
was
review
during
extensive
what
changes
development
development
efficient
8
to
needed
since
the
or
to
we
past
other
support
will
couple
stakeholder
we
be
years
engagement.
10
And we received a lot of valuable input from the
11
stakeholders.
12
I
think
we
had
over
20
NRC
staff-
13
sponsored meetings.
14
specifically on changes we were planning to make to
15
our
16
stakeholder input.
guidance.
17
A couple meetings were focused
And
We,
of
so,
we
got
course,
some
came
to
really
the
good
ACRS
18
subcommittee last April when we got some good input
19
at that meeting.
20
been
21
industry to help us with our guidance development
22
and
23
creating the stable framework.
getting
help
24
25
us
And so, all along the way we've
this
to
input
identify
from
what
stakeholders
our
needs
are
and
for
We also learned from our national and
international
colleagues
through
our
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1
participational workshops and conferences and other
2
work, and that's our improved our knowledge and our
3
capabilities
4
mechanisms
5
period of extended operation.
6
and
and
assessments
how
MEMBER
they
to
should
SKILLMAN:
understand
aging
be
in
managed
Kris,
let
me
a
ask
7
this:
As I read the, I would say, extensive public
8
comments on this there are embedded within numerous
9
of those comments what I consider to be just raw
10
fear, concern about a crack, a leak, the perception
11
that these containers are sitting two miles from my
12
home or within 50 miles of eight and a half million
13
people.
14
And
I
lived
through
a
time
when
I
15
listened to the public fear, and I understood that
16
that fear was palpable and real.
17
people are truly afraid.
18
And
I
lived
through
I mean, those
a
time
where
we
19
went through an extraordinary effort to reach out
20
to those who were fearful to attempt to address the
21
fear.
22
United States and, in certain areas, a great deal
23
of public fear.
24
25
Here we have these facilities all over the
What's being done to address that?
I
mean, we talked about these technical issues with
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1
such precision and such specificity and we kind of
2
had the code talk, we understand what we're talking
3
about,
4
address the technical issues, but here is the soft
5
issue that in my view is just as real to some of
6
the technical issues that we talked about.
we've
got
eloquently
qualified
people
to
7
So, what's being done to address that?
8
MS. BANOVAC:
9
Well, I'll start out and
I'm sure Mark and Al may have things to say as
10
well.
So, one of the things that we are trying to
11
do not just here, but agency-wide, you know, the
12
word "plain language," we throw that out a lot, you
13
know.
14
The
and
work
we
engineers
do,
here
it's
on
the
a
lot
of
staff,
you
15
scientists
16
know.
17
terms that really are understandable to a member of
18
the public.
19
we've
20
comments, but in any -- I guess any documentation
21
we have whether it's even our standard review plan,
22
you know, we tried to make that in plain language
23
as well, but we really tried to explain these terms
24
and ideas that I think the staff and industry has a
25
great understanding for.
We use very technical terms, very scientific
And so, we're really trying and I hope
succeeded
in
our
responses
to
the
public
We tried to explain this
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1
so they make sense to everyone else.
2
I know with high-burnup fuel, you know,
3
and
Marge
will
be
addressing
that
a
little
bit
4
later, we've developed a one to two-pager, I think
5
it was, to really try to describe what is high-
6
burnup fuel, you know, what are some of the things
7
we're looking at in research.
8
And so, we're creating some tools like
9
that to put out there to try to share information
10
in
maybe
a
11
something I think now at our core we're always --
12
whatever
13
it's
14
backgrounders
15
public consumption, we're trying to explain things
16
and we're trying to explain NRC's robust framework
17
and what we're doing and why we're doing to make
18
sure that these things are safe.
we
more
write
responses
19
to
that
understandable
whether
public
we're
it's
way,
but
guidance,
comments,
putting
it's
whether
one-pagers,
out
there
for
And I think really it's a translation.
20
I think it's a translation issue.
21
really -- I would say I think that's really where
22
we're focusing on is on translating what we think
23
is
24
translating that to others so they can understand.
a
safe
25
and
robust
MR. LOMBARD:
framework
And so, we're
in
industry
and
It's interesting that you
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1
made that observation and my folks have heard me
2
talk about this several times over the last couple
3
of
4
accident we went -- we, the NRC, went off and built
5
an expedited transfer study, we did an expedited
6
transfer study whether it was prudent to require
7
utilities to transfer fuel out of spent fuel pools
8
to
9
assemblies and prevent, if it were necessary, in
10
years
--
increase
well,
the
since
distance
--
after
between
the
the
Fukushima
spent
order to reduce the likelihood.
11
And
I
sat
fuel
.
through
one
of
the
public
12
meetings.
And I think they only scheduled a two-
13
hour public meeting the first time they wanted to
14
engage with the public on it.
15
this would be two hours and we'll gather all the
16
comments and we'll be done with it.
And they thought
17
As I sat there during that meeting I
18
kept hearing one person after another call in and
19
express
their
20
sitting
there,
21
business for 35 years.
22
nuclear power?
23
fear
And
of
I'm
I
nuclear
thinking
I've
As
been
I
in
was
this
Why am I not afraid of
start
Well,
power.
because
thinking
I
spend
back
to
my
time
at
the
24
experience.
25
plants, I've written procedures, I've gotten them
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1
through the Plant Operating Review Committee, I've
2
come
3
applied to each one of those steps.
to
4
the
NRC,
And
I
I
know
hold
up
all
the
Terry
rigor
Pickens
that's
and
the
5
Prairie Island folks.
6
the Prairie Island Indian community that they have
7
a person who's spent -- many times he's come to
8
watch loading campaigns, he's seen other evolutions
9
at the plant.
fact
They've engaged so well with
He's gotten more comfortable with
10
the
that
with
the
11
plant applies to plant operations, but these folks
12
haven't had that experience.
13
All
they
level
know
of
is
rigor
that
that
this
the
is
14
radioactivity. This is really bad stuff.
15
- if I -- if they spilled it on my front doorstep,
16
my whole family would be dead within seconds.
17
it's true depending on the type of material you're
18
talking about.
19
So,
we've
really
stepped
out
If this -
in
And
this
20
area and have increased our engagement with folks
21
not just having public meetings, but engaging with
22
them directly, phone calls with them --
23
THE
OPERATOR:
Please
24
interruption.
25
three participants at this time.
pardon
the
Your conference contains less than
If you would like
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1
to continue, press *1 now or the conference will be
2
terminated.
3
4
CHAIRMAN BALLINGER:
I'm assuming he's
pressing *1.
5
(Laughter.)
6
MR. LOMBARD:
of
7
members
8
industry, but members of the general public who are
9
afraid of nuclear power.
10
the
And
public,
So, we have engaged with
done
don't,
great
job
just
you
over
members
know,
in
the
Canada
they've
12
spend millions of dollars engaging the public. And
13
in many cases they have folks who were intervenors
14
before, and now they're promoters of nuclear power.
That's not my goal.
the
of
11
15
a
I
not
years.
They
My goal is just to
16
educate folks and have them understand who we are,
17
what
18
they'll be at least a little bit more comfortable
19
with the job that we do here at the NRC to make
20
sure that it is safe and that the public is -- if
21
we continue doing our job the way we have been and
22
we plan to do so, that they're not going to be
23
impacted.
we
24
25
do,
why
we
do
MR. CSONTOS:
it
and
how
we
do
it
so
Let me just add that some
of the tangible things that we've done, we've done
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1
blog posts, we've done one-pagers so that people
2
will be able to read and see, you know, one page at
3
a high-level, plain English type of feedback to the
4
public.
5
We've
also
gone
that
certain
there
7
when
8
fuel and we're talking about how it goes to a spent
9
fuel -- from a spent fuel pool to the canisters and
10
talk about what we do in terms of our reviews and
11
all these things that we're doing.
they're
so
of
decommissioning
decommissioning,
are
types
6
they're
meetings
to
that
taking
the
12
We did the 20 public meetings, because
13
these were -- this is such a hot issue for the
14
public.
15
really afraid.
16
The public is, like you said, they are
And
I
know
Mark
and
I
have
been
--
17
emails, phone calls.
I've been here until nine
18
o'clock at night with some folks, you know, talking
19
to them because of their concerns.
20
And they, you know, what we try to do
21
is try to explain why we're doing what we're doing.
22
And there are a lot of educated folks out there
23
that really, you know, they get what we're doing
24
and they have a lot of questions on it.
25
And I think that there is an underlying
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94
1
piece that is, I think, a national issue, which is
2
the American public's distrust of government.
3
I think there is an underlying piece of that that
4
they're
5
saying.
And that's a hard, hard barrier to break
6
through.
I'll just say that.
not
7
sure
MR.
if
they
HSIA:
can
This
trust
is
Tony
8
Division of Spent Fuel Management.
9
add
10
that
we
want
to
thank
our
what
And
we're
Hsia
from
I just want to
NRC's
Office
of
Public Affairs.
11
We have a concerted effort working with
12
them to have a series of blog posts.
13
already have four that's posted.
14
are called Dry Cask 101, How Do We Manage Heat?
15
And there are other ones right now under the review
16
such
review,
and
17
probably another dozen or so has been planned.
So,
18
that
19
thank OPA for this effort.
as
inspections,
will
20
continue
And
such
that
also
as
A couple of them
ISFSI
effort.
like
Right now we
Mark
And
and
I
Kris
want
to
and
Al
21
mentioned that whenever we go to a public meeting
22
with our representation, we really gain the public
23
trust.
24
communicate much more effectively.
25
Once that trust is established, then we can
MR. LOMBARD:
Thank you.
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1
MS. BANOVAC:
Okay.
So, based on our
2
work we identified, as Mark mentioned, we need an
3
operations-focused approach for storage renewals.
4
I think Mark went over that.
The one
5
aspect that I do want to highlight is we do have a
6
learning aspect to our operations-focused approach.
7
And the thought is that aging management programs,
8
you
9
renewal application, but our thought is that those
10
are not static, that those are dynamic and that
11
they
12
operating
13
that dry storage system, that site or maybe even
14
other
15
nuclear industry and maybe even outside of nuclear
16
industry.
know,
those
should
are
change
experience
applicable
submitted
over
that's
operating
time
as
part
to
either
of
respond
applicable
experience
the
to
to
throughout
17
So, there is a learning aspect to our
18
approach and you'll be hearing more about that in
19
tomorrow's meeting also.
20
As we mentioned, the framework has to
21
be sustainable for the future for possible multiple
22
renewal periods just within certainty in the back-
23
end of the fuel cycle.
24
25
And also, we think that the framework
needs to have the flexibility to be changed.
So,
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1
as we get new operating experience, as we continue
2
to do our research and get our research results as
3
new information comes in, the framework needs to be
4
flexible to be able to be changed to respond to
5
that.
6
And so, given those overarching needs,
7
we
did
identify
8
guidance
9
infrastructure
10
some detail on.
specific
needs
development,
11
for
and
development,
both
also
which
I'll
NRC-led
external
get
into
This slide is just a pictorial display
12
of
the
various
13
planned work in the area of updating the storage
14
renewal framework.
15
past,
ongoing
and
some
of
the
Some of the work is NRC-led, some of
16
the
work
17
interrelated
18
working together to -- and collaborating to make
19
sure that we do have a sustainable framework going
20
forward.
21
inside and outside the NRC.
22
NRC
is
and
involved
there's
many
back?
24
6.
and
the
parties
work
that
is
are
So, there is a lot of work being done
MEMBER BROWN:
23
in,
Could I ask you to go
I just want to make sure I understand Slide
25
MS. BANOVAC:
Six.
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1
MEMBER BROWN:
I guess I -- maybe you
2
can -- maybe I confused myself.
3
by an operations-focused approach?
4
MS. BANOVAC:
What do you mean
So, the thought is that
5
instead of analyses, you know, doing analyses to
6
show, okay, everything is looking great, we want to
7
look.
So, want to monitor, we want to inspect.
8
We talked a little bit already, we're
9
going to hear a lot more tomorrow, but, you know,
10
the canister inspections.
11
go
12
degradation before a loss of intended function.
out,
13
look,
And
the
and
thought
using
the
inspect
is,
you
find
know,
techniques,
any
we're
looking,
15
right people looking for the right things.
16
we're looking, in time, to catch any degradation
17
that could impact a safety function well before it
18
would impact that safety function.
MR. CSONTOS:
right
to
14
19
we're
monitor
So, we actually want to
the
And
We were looking prior to
20
this, we were doing a lot of research to look at
21
what's going to happen in a hundred years.
22
inherent to that is the difficulty in artificially
23
aging things to simulate what would happen in a
24
hundred
25
that you don't know that you don't know.
years
and
there's
the
And
unknowns-unknowns
Okay.
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1
And
so,
rather
than
hypotheticalizing
2
everything going out to the next 300 years, which
3
could be an infinite amount of work, let's focus on
4
what we can do in an operations-focused way where
5
we do things like we inspect, assess, evaluate and
6
then
7
actions to then get us back into a state of where
8
the regulations are -- you're in compliance with
9
the regulations if anything does happen.
do
whatever
10
we
need
MEMBER BROWN:
to
do
Okay.
to
corrective
But what type of
11
operations are you looking at?
I mean, if casks
12
are dead, these pieces, they're dead weight sitting
13
in a facility or in the outdoors or wherever they
14
are, I mean, you have to define the operations that
15
you're going to deal with.
16
something.
17
they pick up a cask and move it, or how they open a
18
cask and look at it, or how they do what?
19
operations?
You've got to inspect
What are you inspecting on it?
20
MR. CSONTOS:
21
what we do in the plants, you know.
22
at how things degrade as a function of time.
23
infrastructure degradation, basically.
24
25
MEMBER
BROWN:
Degradation.
Well,
How
What
It's like
You're looking
when
you
It's
talk
about -- excuse me -- infrastructure meaning the
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1
facility that it's in, or the cask itself?
2
MR.
CSONTOS:
Overpack,
the
concrete
3
pad, the -- if it's important to safety and the
4
canister or cask, looking at it to make sure that
5
things
6
anticipated.
7
these
8
That's the operations part of it.
aren't
are
9
degrading
the
things
it's
11
really going on with --
reality-focused
12
than
you
we're
talking
about.
If you think about it,
approach.
MEMBER BROWN:
It's
what's
No, I'm not disagreeing.
I'm just trying to --
14
15
that
MR. LOMBARD:
a
rapidly
We planned for certain things and so
10
13
more
MR. LOMBARD:
Right.
What operations
are --
16
MEMBER BROWN:
-- connect some of the
17
dots as to how you go about doing it.
18
you've got a facility that's got 500 casks in it,
19
inspecting
20
difficult task.
21
500
casks
is
a
fairly
I mean, if
laborious
and
So, you've got to develop some type of
22
--
if
it's
just
sitting
there,
some
type
of
23
methodology to go do that.
24
give you -- that seems to me if you do the sample
25
approach, you're right back into you've got to have
Some sample that would
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1
some analysis basis for saying that my sample of
2
operations are going to be effective at identifying
3
degradation.
4
MS. BANOVAC:
And that's exactly what
5
the aging management programs do.
6
into this in a lot more detail tomorrow, but in the
7
guidance
8
management programs and the 10 elements of aging
9
management
in
NUREG-1927
program
we
and
talk
you
So, we'll get
about
step
the
aging
through
that
10
thought process to figure out, okay, what do I need
11
to look for, number one, how do I look for it, how
12
often do I look for it, what is my sample size?
13
And so, the aging management programs
14
sort of take you through that thought process to
15
figure out what you are going to do and inspection
16
space,
17
operation.
18
bit
19
that
20
management program.
essentially,
more
in
the
period
of
extended
And so, we will get into that a little
detail
would
21
be
essentially
MR.
potential
tomorrow,
LOMBARD:
that
is
embedded
in
Especially
the
aging
specific
to
mechanism
of
the
23
concern for that specific system and that specific
24
requirement.
MEMBER
degradation
something
22
25
material
but
BROWN:
Other
operations,
I
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1
would think, you mentioned in one of the pieces of
2
paper that we got for review was how do you open
3
the
4
that?
5
discussions or is that not part of this overall --
cask
and
what
are
the
processes
you
do
for
Is that going to be part of your subsequent
6
MS. BANOVAC:
7
a
little
8
presentation
9
this morning.
bit
more
that
will
Probably hear about that
in
be
the
right
retrievability
after
our
break
10
MEMBER BROWN:
Okay.
11
MR. LOMBARD:
And we hope we never see
12
one open.
13
MEMBER
you
talked
14
about your new paradigm, your 72, 71, 72.
So, I
15
presume
16
transporting it and putting it someplace else.
17
you're
BROWN:
taking
And
it
out
where
of
one
place,
Are there specific, I mean, I look at
18
a cask.
19
it on something, you've got to hold it down.
20
view those as operations.
21
22
I
Is that a part of this overall process
or thought process you're going through?
23
24
You've got to go pick it up, carry it, put
MR. LOMBARD:
Once you do that, you're
out of the storage realm and into transportation.
25
MEMBER BROWN:
Okay.
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1
2
MR.
Which
is
a
whole
different discussion.
3
4
LOMBARD:
MEMBER BROWN:
right.
That's true.
Okay.
All
Thanks.
5
MEMBER
REMPE:
You're
aware
that
the
6
research reactors are thinking about or trying to
7
go forward with this non-expiring license.
8
9
Have
you
ever
thought
of
doing
that
with the storage especially for the orphan plants
10
to have a non-expiring license?
11
them.
You're monitoring
You're not --
12
MS. BANOVAC:
I'd like to address that.
13
MR. LOMBARD:
No, no, go ahead.
14
MS.
BANOVAC:
Because
this
was
a
15
question I think Dr. Powers asked us, you know, the
16
last
17
perpetuity.
time
18
we
were
You
hear
know,
one
having
of
this
the
license
thoughts
in
for
19
having the license term is that, you know, there is
20
a technical -- there is a technical basis for a
21
license term.
22
In the 2011 rulemaking for Part 72, we
23
did extend the license term to 40 years.
It went
24
from 20 to 40 years.
25
basis for that was the demonstration at Idaho on
And, you know, part of the
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1
the low burnup fuel where we opened the cask and we
2
looked at the fuel.
3
And so, you know, you do have a term
4
that is based on -- has a technical basis, but I
5
think another unique thing with storage is we say
6
and we continue to say that the Part 72 ISFSI, it's
7
not the final step.
8
9
In this country, and I know right now
it's
sort
of
in
a
state
of
uncertainty,
but
10
eventually there will be geologic disposal.
11
ISFSIs will not be the final resting place for the
12
spent fuel.
13
And
if
you
offer
a
These
license
in
14
perpetuity or just a license that has no end date,
15
it kind of says a mixed message.
16
oh, these really, you know, this is going to be the
17
final resting place for this fuel?
18
And
I
know
our
Are you saying,
stakeholders,
we
were
19
just talking about the public fear and concern, I
20
would imagine they would not be very fond of an
21
open-ended license for storage.
22
And
I
23
because
they're
24
they're
still
25
paying for it.
think
still
maybe
holding
responsible
for
industry
as
well,
that
fuel,
they're
still
onto
it,
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1
So, I guess in our view having sort of
2
this open-ended license is not the best idea just
3
from a kind of perception standpoint, and also you
4
want a technical basis for your license term.
5
we're very comfortable with having right now our
6
40-year terms.
7
MEMBER REMPE:
8
MEMBER BROWN:
9
So,
Thank you.
Yeah, but you -- I want
to ask a follow-up on that.
But in your paperwork
10
you gave us, you comment, and you just commented,
11
you did that based on the results you got from your
12
low
13
that you actually did on that.
burnup
fuel
and
the
inspections
and
testing
14
The stuff you actually did, but yet you
15
were -- you extended it and then you made a comment
16
that, as I read it, you're kind of basing it on
17
hope, because you've got a future testing for high-
18
burnup
19
confirm -- so, you've already extended the license,
20
but
21
burnup fuel information; is that correct?
you
fuel
where
don't
you're
have
any
going
data
to
other
be
trying
than
the
to
low
22
MS. BANOVAC:
And that's exactly -- we
23
have a high-burnup fuel.
I guess it's technically
24
an AMP, but we call it a monitoring program.
25
we'll actually talk in detail about that tomorrow.
And
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1
Meraj may even touch on it a little bit
2
in his presentation, but essentially for -- to be
3
able to go past the 20 years for high-burnup fuel
4
because the demonstration that was done was only on
5
low-burnup fuel.
6
You know, what we're saying is so far
7
all the information we're seeing, all the research,
8
all the short-term data is showing us that high-
9
burnup
fuel
is
looking
okay,
but
there's
no
10
confirmatory data like there was for the low-burnup
11
fuel.
12
And
so,
that's
exactly
why
this
13
demonstration is being explored with DOE and EPRI.
14
And so, what we do with our framework and with our
15
renewals is if there is high-burnup fuel at that
16
site, there's a high-burnup fuel monitoring program
17
where essentially a licensee will be monitoring the
18
information that would come out of a demonstration
19
project
20
looking
21
think will happen.
for
for
high-burnup
that
fuel
information
to
and
essentially
confirm
what
we
22
Now, if information came out of a demo
23
that was, I guess, contrary, now it would be upon
24
the licensee to say, well, what does that mean for
25
my fuel now?
Will there be any reconfiguration of
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1
the
fuel?
Will
2
cladding?
3
high-burnup fuel monitoring program that we do have
4
as part of our renewals for licensees that store
5
high-burnup fuel.
6
on that tomorrow, if you'd like.
So,
there
that
is
any
exactly
MEMBER BROWN:
8
MS. BANOVAC:
9
Okay.
Okay.
why
we
to
the
have
our
Okay.
All right.
NRC-led
I'll hold off.
guidance
Thank you.
So, this slide just
10
lists
11
talk about in the next few slides.
12
damage
And we can get into more detail
7
the
be
development
that
I'll
So, first of all, we did identify the
13
high-priority
14
1927.
15
guidance,
16
guidance.
need
to
update
our
guidance
NUREG-
We did develop a draft revision 1 to the
17
and
we
We
did
made
updates
include
three
throughout
example
AMPs
the
as
18
part of Revision 1.
19
corrosion
and
20
stainless
steel
21
concrete structures, and then the high-burnup fuel
22
monitoring program that I just mentioned.
23
And those were for localized
stress
corrosion,
canisters.
One
cracking
for
of
reinforced
We did publish our draft guidance for
24
public comment last July.
And we have a separate
25
meeting tomorrow morning where we'll talk about the
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1
public comments that we received how we considered
2
those in the proposed final guidance.
3
And I think Dr. Ballinger mentioned if
4
we
need
to
5
scheduled for April 7th.
6
publish the final guidance in the summer.
7
go
to
full
committee,
we
have
that
And finally, we expect to
We also identified the need for a new
8
guidance document that was already mentioned.
9
this is the Managing Aging Processes and Storage,
10
or
MAPS
for
short.
11
provide
12
identification
of
13
effects,
what
14
management activities to manage those effects.
an
And
acceptable
and
what
essentially
generic
are
are
the
the
And
this
will
approach
to
credible
aging
appropriate
aging
15
MAPS will be comparable to NUREG-1801,
16
which is the generic aging lessons learned or goal
17
report
18
descriptions of the different storage systems, the
19
technical
20
credible aging effects, system-specific tables of
21
the
22
applicable
23
environment
24
management programs.
for
reactor
bases
for
subcomponents,
25
aging
licenses.
It
determining
their
will
what
provide
are
the
environments
and
effects
for
those
materials
combinations
and
also
example
and
aging
We think that the development of this
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1
document
will
2
applicants
3
and we think it's also going to increase efficiency
4
for NRC staff as we can focus our review on areas
5
where licensees or applicants propose things that
6
are alternative to the guidance in the generic MAPS
7
report.
in
8
9
increase
development
As
process,
efficiency
far
we're
as
of
their
where
for
applications,
we're
currently
both
at
with
working
with
the
our
10
contractor to develop draft guidance.
11
engage
12
hopefully to have a public meeting on -- before we
13
go out for public comment.
with
14
stakeholders
over
the
We plan to
coming
months
This was on one of Mark's slides.
is
something
15
this
16
interested in looking at, we would propose coming
17
to you with a propose final guidance.
18
publish the proposed guidance this summer, we would
19
consider public comments and just like NUREG-1927
20
we'd,
21
proposed final.
22
And
you
know,
that
you
think
address
those
currently,
we
you
might
If
So, after we
comments
plan
be
to
in
the
have
the
23
proposed final guidance ready in January of 2017.
24
So, if ACRS was interested in seeing that, that
25
would
be
the
time
we
would
be
ready
to
provide
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1
that.
2
3
Finally, we would hope to publish the
final guidance in Summer of 2017.
4
MR. CSONTOS:
Can I just say that we
5
prefer to go out for public comment.
6
industry would like to have this guidance as soon
7
as possible.
8
9
I think the
So, I think -CHAIRMAN
BALLINGER:
On
the
MAPS
report.
10
MR. CSONTOS:
On the MAPS report.
And
11
so, it would -- we would love to go out for public
12
comment as soon as possible rather than wait until,
13
you know, later.
14
15
I know we're talking about -- I think
you have various field trips in the summer?
16
MS. BANOVAC:
I think with the timing,
17
so we'll be ready with the draft this summer.
And
18
I
and
19
staff with scheduling with ACRS in the summer, we
20
would
21
publish our guidance if we needed to wait for to
22
meet with the ACRS this summer.
know,
be
23
you
know,
talking
waiting
with
essentially
Chris
three
Brown
months
to
And so, that's why we're proposing if
24
we
could
just
some
with
the
proposed
final
in
25
January of next year, then that way you would see
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1
all the public comments we received on the MAPS
2
report,
3
comments and the proposed final --
how
4
we're
proposing
MR. CSONTOS:
to
address
those
We can provide a version
5
for you all in a few weeks so that you can take a
6
look at it to see what it's looking like bake that
7
determination.
8
9
CHAIRMAN BALLINGER:
You mean in a few
weeks.
10
MR. CSONTOS:
11
CHAIRMAN
Right.
BALLINGER:
12
going to be my next question.
13
it amongst the subcommittee.
14
MR. CSONTOS:
Okay.
That
was
We have to discuss
We just received it last
15
Friday from our contractor.
16
what we want and then we're going to be putting it
17
out
18
consumption so that you can take a look at it to
19
see
20
version as it is.
onto
can
we
the
go
ADAMS
out
for
We're changing it to
website
public
for
the
comment
public
with
this
21
And we'll have many more bites of the
22
apple, but really it's the applicants who really
23
want
24
forward.
this
25
to
inform
their
CHAIRMAN BALLINGER:
applications
going
But how strong is
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1
their connection between 1927 and this?
2
MR. CSONTOS:
It's really close.
3
MR. LOMBARD:
Pretty strong.
4
MR.
CSONTOS:
1927
5
the SRP for -- it's like 1800.
6
1801 which is the GALL.
7
8
MEMBER
POWERS:
is
basically
And then you
like
I
would
not
have
make
decisions on this now, because --
9
MR. CSONTOS:
10
Right.
MEMBER POWERS:
-- of new ACRS staff
11
members that are coming on board where all this
12
stuff
13
nuclear
14
subcommittee to waste material storage.
probably
ought
materials
to
transfer
over
subcommittee
15
CHAIRMAN BALLINGER:
16
MR. LOMBARD:
to
meeting,
Oh, I see.
the
the
Okay.
So, if I may a little bit
17
of the why, why do we want to get it out for folks
18
to see and start using and give us feedback on,
19
because
20
preparing renewals now and we want them to have as
21
much information as possible as soon as possible so
22
they can put them together in accordance with what
23
we're already thinking.
24
25
that
renewal
And
bow
actually
wave,
there's
folks
been
collaboration on all these products.
who
a
lot
are
of
So, we expect
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1
that there's not going to be significant surprises
2
out there with the industry, but we want them to
3
have it to use as soon as possible.
4
5
MEMBER POWERS:
The closer you can get
it to a template, the better off you are.
6
MR. LOMBARD:
Exactly.
7
MR. CSONTOS:
Absolutely.
8
MEMBER POWERS:
9
there
is
one
lesson
If that's what we -- if
we've
learned
from
license
10
renewal, it is templates help a lot for you to look
11
at.
12
13
MR. CSONTOS:
doing what we're doing.
14
That's exactly why we're
Yes, that's right.
CHAIRMAN BALLINGER:
Yes, it's probably
15
a combination of this committee, plus the new waste
16
--
17
MEMBER POWERS:
Yeah, it seems to me I
18
would just move all of this stuff that's coming up
19
in the future over to waste.
20
materials
21
Materials Subcommittee to help.
22
CHAIRMAN BALLINGER:
23
they
can
always
call
in
the
I'm trying to sort
out the difference between 1927 and the MAPS.
24
25
issues,
And where they have
MEMBER POWERS:
I don't think I would
worry about it.
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1
CHAIRMAN BALLINGER:
2
MR. LOMBARD:
3
list,
essentially,
by
4
management requirements.
Okay.
The MAPS will be a pick
system
by
5
MR. WISE:
6
CHAIRMAN BALLINGER:
7
system
of
aging
Is this on?
No, or you're too
tall.
8
9
Well --
MR.
Wise,
NRC
WISE:
staff,
Now,
the
it's
Renewal
on.
I'm
Materials
John
Branch.
10
Just to give you a perspective, I know everybody in
11
here
12
right?
is
probably
13
familiar
with
the
GALL
report,
I mean, it basically comes up with a
14
determination
15
effects
16
staff
17
impacts.
and
feels
18
of
which
the
aging
are
are
the
relevant
management
appropriate
to
aging
programs
that
manage
those
And so, that's not something -- that's
19
in 1927 right now, right?
Because the 1927 is our
20
methodology
for
staff,
21
criteria
which
22
whether an application is acceptable.
by
how
to
they
go
you
through
to
know,
the
determine
23
But just like the GALL report, the MAPS
24
report is going to be and here is a generically
25
acceptable
approach.
So,
here
are
the
aging
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1
effects we think are relevant and here are specific
2
aging management programs we think are appropriate
3
to address those aging effects.
4
And so, in a sense, it rolls up the
5
experience we've had in the recent renewals.
6
so
7
license renewals in the ISFSIs and people that are
8
familiar with the GALL report, you'll look at this
9
and you'll say, oh, this is very familiar.
anybody
that's
reviewed
any
of
the
And
recent
I mean,
10
it's not going to be very surprising.
It's really
11
a rolling up of all of the experiences we've had
12
both in the ISFSI renewals, as well as some lessons
13
learned from the reactor license renewals.
14
but again it's different than 1927 because it gives
15
that here is one acceptable approach.
And so,
16
1927 has a couple of aging management
17
programs, example ones, and the MAPS report will
18
just expand on that.
19
management programs, because the 1927 examples were
20
just that, a couple of examples.
21
a much more thorough look at the -- at all of the
22
system
23
systems.
24
25
structures
and
MR. CSONTOS:
It has five or six aging
components
So, it just takes
in
the
storage
And it's system-specific.
So, kind of like what you see in the GALL report
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1
where you have a BWR/PWR version there is a, you
2
know,
NUHOMS
3
blah,
blah,
4
different systems.
5
System,
blah.
And
there
And
then
so,
how
is
a
Holtec
there
you
are
port
System,
all
these
the
aging
6
management programs to those structure systems and
7
components according to safety that are related to
8
those,
9
they made out of, what's the environment, all that
you
know,
individual
components,
10
stuff.
11
best way to say it, for licensees to use.
12
what
are
So, it's a real template, I think is the
CHAIRMAN
BALLINGER:
Yeah,
I
mean
to
13
follow up on what Dana was mentioning, I'm just
14
trying to get a reading on what you would like from
15
us going forward and the timing that that may be,
16
because,
17
providing some feedback on 1927 now, or if it's
18
connected very, you know, with the MAPS report, is
19
there a reason to wait and take them as a bundle,
20
if you will, but then there's ISG-2 stuck in there
21
as well.
for
example,
are
you
interested
in
us
22
So, I'm trying to get a feeling for --
23
MR. CSONTOS:
We'd like to get 1927 out
24
the door and published, you know, fully done.
So,
25
hopefully get -- we're hoping to get -- we were
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1
going to talk about this tomorrow, but --
2
CHAIRMAN BALLINGER:
3
MR. CSONTOS:
Okay.
We were hoping to get a
4
letter from you on that to go ahead and get the
5
approval to publish that.
6
The MAPS report, we're hoping that we
7
can go out for public comment early this summer.
8
So, that has to look at the timetable for you all
9
to -- or the Nuclear Materials Subcommittee, how
10
that all meshes up, because we'd just like to get
11
out faster.
12
And then you'll see the public comments
13
for the MAPS report if you want to take a look at
14
it
15
publication.
again,
16
17
you
know,
when
we
CHAIRMAN BALLINGER:
MR. CSONTOS:
19
CHAIRMAN BALLINGER:
(Laughter.)
22
MS.
Okay.
final
We should
Yes.
-- because there
BANOVAC:
Okay.
We'll
keep
on
going.
24
25
for
are people getting antsy to go to the --
21
23
out
probably be moving on here --
18
20
go
So, the next slide is Slide 11.
We
also identified the need to develop guidance for
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1
NRC
inspections
2
activities.
of
licensees'
aging
management
3
We're currently developing a temporary
4
instruction and that's for inspection of licensees'
5
programs
6
aging
7
were approved as part of the renewal.
and
management
8
9
procedures
programs
After
instruction,
for
we
we'll
or
implementing
any
develop
then
conditions
their
that
the
temporary
an
inspection
develop
10
procedure.
And that will include more technical
11
detail
12
activities.
And so, that we'll be inspecting to
13
make
they're
14
inspections
15
that they're taking timely and effective corrective
16
actions as needed.
17
work on in the future.
regarding
sure
and
licensees'
doing
monitoring
aging
their
management
appropriate
assessments,
and
also
And so, that's something we'll
18
We also are considering development of
19
our regulatory guide to discuss how these various
20
pieces of the guidance framework fit together, the
21
1927 and MAPS.
22
serve as a potential vehicle for endorsement of NEI
23
14-03.
24
so, the reg guide would be the vehicle we would use
25
for that.
And also there, the reg guide can
I know Mark already mentioned this.
And
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1
Outside
of
3
going on to develop this surge renewal framework.
NRC
case
requested
consensus
6
canisters.
7
extensive
8
methodology
9
corrective actions for canisters.
inservice
work
to
that's
develop
inspection
a
of
And this would be a way to leverage the
experience
to
in
inspect,
ASME
on
for
ASME
5
10
code
important
guidance
development,
The
other
NRC-led
2
4
there's
the
Section
inservice
the
field,
assess
11
and
to
determine
created
inspections
develop
of
a
a
any
new
task
spent
fuel
11
group
12
storage and transportation containments.
13
their inaugural meeting in April of last year and
14
the NRC is involved in that continuing work.
15
we hope to have a consensus code case by 2020.
They had
And
16
We also continue our involvement with
17
the American Concrete Institute, or ACI, Committee
18
349, which develops standards for nuclear safety-
19
related systems and structures.
20
And a concrete expert panel was held in
21
2015 and the panel determined that the revised ACI
22
349.3R
23
structures
24
inspections for dry storage systems in the first
25
renewal period.
guide
on
could
evaluation
be
used
of
for
existing
aging
concrete
management
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1
The panel also identified some future
2
enhancements to the guide.
3
address
4
periods.
5
with the ACI to assure that any future changes to
6
the guide will be applicable to inspections of our
7
dry storage systems.
aging
mechanisms
in
subsequent
renewal
And so, we're going to continue to engage
8
9
And those would be to
NEI is leading the industry effort to
develop
guidance
for
storage
renewal
applicants.
10
So, this would complement the guidance and NUREG-
11
1927.
12
03.
And this is of course presented in NEI 14-
13
The NRC is currently reviewing Revision
14
1
to
NEI
14-03.
15
guidance or any portions of the guidance can be
16
endorsed, we may do that through a reg guide that I
17
mentioned on the previous slide.
18
NRC
And
also
if
we
determine
continues
to
that
assess
the
the
19
capabilities to inspect the dry storage systems and
20
particularly
21
inspections.
22
that
23
canister within the overpack.
can
24
25
the
capabilities
for
in
situ
So, being able to get instrumentation
navigate
And
the
the
close
industry
confines
is
of
the
currently
developing delivery devices or systems to be able
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1
to use already demonstrated inspection techniques
2
and methods, but just within the close confines of
3
the canister within its overpack.
4
Keith Waldrop will be speaking to that later this
5
afternoon.
6
Also,
we're
And I believe
currently
considering
7
participating in an IAEA effort to develop guidance
8
for aging management of dry storage systems.
9
So, in conclusion, we continue our work
10
to update the storage renewal framework so it is a
11
sustainable framework for the future.
12
framework has been informed by the staff's renewal
13
review
14
operating
15
for reactors, and also past and ongoing research
16
and work.
experience
over
the
and
also
experience
past
renewal
The updated
few
years,
experience
17
We feel that the framework is learning
18
and that aging management programs will continue to
19
be informed by future operating experience, results
20
of research and we'll be able to respond to that as
21
the ISFSIs and dry storage systems enter the period
22
of extended operation.
23
The guidance documents will be living.
24
So, we'll update those over time to include any new
25
information, knowledge or experience in the future
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1
regarding aging management.
2
And
in
this
way,
we
feel
that
the
3
framework will be able to be applied to the first
4
renewal and also subsequent renewal periods so that
5
we can have continued safe storage of spent fuel
6
for extended periods.
7
And my last two slides are just a list
8
of references and acronyms and I'll be happy to
9
take any other questions although I know we are
10
running over time.
11
MEMBER
SKILLMAN:
I
have
a
brief
12
question back to Slide 11.
13
inspection
14
developed inspections for AMPs and life extension
15
7100 series, 71002 and 3 really provide excellent
16
guidance for those inspectors.
17
Should
procedure.
Temporary instruction
The
we
agency
presume
that
has
what
well-
would
be
18
developed here would be, if you will, a version of
19
the
20
shortened
21
types of technical issues pertaining to casks and
22
the overpacks and the concrete?
very
same
and
23
It
24
template
25
understood,
type
much
of
focused
seems
that's
inspection
that
used
and
inspectors
know
on
procedure
specifically
that
--
useful,
how
to
you
much
these
have
very
use
it,
a
well
the
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1
industry understands what it is --
2
MR. CSONTOS:
3
MEMBER
Right.
SKILLMAN:
Absolutely.
--
would
you
be
4
basically plagiarizing that and saying here's the
5
new one?
6
MR. CSONTOS:
Actually, the word
I use
7
is "let's plagiarize it as much as possible."
We
8
have a team working on this, the TIIP.
9
the first one is a TI, because we have plants that
10
have been in -- that are through renewals right
11
now.
And it's --
12
We believe that they're -- we're giving
13
now a -- first of all, there's two parts to it.
14
One
15
It's
16
programs.
17
them, move on, but it's about, you know, really
18
what the licensee is doing and taking those aging
19
management
programs,
20
management
activities
21
out and does.
is
the
aging
great
that
management
we
do
the
activities
aging
itself.
management
It's great we review them and approve
making
that
them
someone
into
aging
actually
goes
22
And so, what we're doing is the first
23
part of this is to basically do what the, you know,
24
the reactor site does which is are they doing the
25
aging management activities in accordance with the
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1
approved
aging
2
simple part.
3
The
management
second
programs?
part
is,
is
That's
that
the
we're
4
giving change control authority to the licensees to
5
change their AMPs as a function of time with new
6
operational experience.
7
This is something that already on the
8
reactor side it does very well because they have
9
the INPO databases, they have all this other OpE
10
that they collect and distribute and provide and
11
reevaluate to.
12
Our side, we have a lower amount of --
13
a little bit less operating experience, by a lot.
14
And so, as we go forward looking into this and they
15
get more OpE, they can go and change their aging
16
management programs as a result of, oh, well, that
17
degradation
18
because
19
years.
20
mechanism
we're
not
seeing
isn't
it
applicable
for
40
here,
years
or
30
So, part of it is the oversight process
21
of the change control authority.
What was changed?
22
Did they use the 7248 process, which is the way to
23
change this, appropriately?
24
just to make sure that we're not getting people who
25
are just trying to get out of inspections.
Did they, you know,
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1
It's for the public, you know, concerns
2
on
giving
3
licensees.
the
change
control
4
MEMBER SKILLMAN:
5
MR. LOMBARD:
as
well.
7
management
8
right
9
already existing inspection programs.
into
the
want
to
or
these
that
aging
they
actual
them
12
individuals as well as ISFSIs.
13
to
be
easily
implementable
CHAIRMAN BALLINGER:
Okay.
meld
licensee's
We don't want them to be different.
want
by
We
the
No more questions?
Let's take a break until 10 of.
15
16
so
the
11
14
design
inspections
ISFSI
the
There's another piece to
this
program
to
Thank you.
6
10
We
authority
(Whereupon,
the
proceedings
went
off
the record at 10:36 a.m. and resumed at 10:50 a.m.)
17
CHAIRMAN
BALLINGER:
We're
back
in
18
session, I think.
19
some miscreants out there on the line that haven't
20
gotten
21
there
22
happening is a lot of people are getting feedback
23
that interferes with everything.
24
your phone on mute and things will work out a lot
25
better.
their
and
I've been told that there are
phones
your
on
phone
mute.
is
not
So
if
on
you're
mute,
out
what's
So please, put
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1
Our next presenter, Emma, has waited a
2
very long time for this.
3
of applause --
4
MS. WONG:
No.
There should be a round
5
applause.
6
address the full committee.
7
will be a very good presentation.
8
a lot from this.
9
I
No, I don't need a round of
have
waited
a
long
time
to
However, I think this
I hope you learn
So thank you.
I'm Emma Wong.
I'm going to present
10
today on spent fuel retrievability and the draft
11
ISG-2, Revision 2, that is now out there in the
12
public.
13
course,
14
will be making some decisions on whether or not
15
this ISG-2 needs to go to full committee, so I just
16
want to remind you of that fact.
And hopefully, you've all reviewed it.
Dr.
Ballinger
already
17
Next slide, please.
18
So
in
the
meeting
mentioned
topics
we
that
are
Of
you
at
19
retrievability, is outlined here in red.
20
going
21
Retrievability, I would like to highlight, is part
22
of
23
retrieving
24
transported somewhere.
the
from
storage
storage
the
to
transportation.
regulations.
So
it's
fuel
it
ready
to
get
So it's
storage,
to
be
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1
Next slide.
2
A brief outline of the things I'm going
3
to talk about today.
I am going to go into the
4
history of retrievability, where it came from and
5
how we got to where we are today.
6
the regulations.
7
guidance we have on retrievability and a little bit
8
of the history about that and where we are today,
9
the paradigm shift and how it changed our view on
And also go over
Then I'm going to go into the
10
retrievability.
11
go into the ISG-2, Revision 2 into a little bit of
12
that and how we updated that guidance.
13
So
And then, of course, I'm going to
going
into
the
history,
it
all
14
started in 1982 with the Nuclear Waste Policy Act
15
and it has been amended.
16
stated
17
retrievable storage, or MRSs.
18
should be designed, the MRSs should be designed to
19
provide for ready retrieval of such spent fuel and
20
waste for further processing and disposal.
21
is what they had envisioned for MRSs.
22
all
23
Policy Act.
and
they
24
was
had
a
But in this act, it's
lot
commented
on
about
the
monitored
It stated that they
in
the
So this
And that's
Nuclear
Waste
Now as the NRC, we had to do something
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1
with that, so we codified all this information in
2
the
3
regulations for Part 72 for MRSs.
4
deemed
5
for the fuel that MRSs had to go through should
6
also apply to
7
our regulations as 10 CFR 72.122(l).
8
into that a little bit more in the next slide.
1988
rulemaking
that
9
the
same
to
retrieval
ISFSIs.
Later,
add
in
this
into
our
However, we also
or
retrievability
And this was codified in
1990,
And I'll go
we
had
another
10
rulemaking to add 10 CFR 72.122(m) for Certificates
11
of
12
extent
13
system.
Compliance
to
possible
consider
in
the
14
Next slide.
15
So
a
retrievability
design
little
of
bit
their
more
to
the
storage
about
the
16
regulations.
I just mentioned to you regulations.
17
They are going to be here for your viewing.
18
storage,
19
retrievability.
20
Nuclear Waste Policy Act and what we thought, we
21
needed
22
systems must be designed to allow ready retrieval
23
of spent fuel, high level of radioactive waste, and
24
reactor
which
that
in
related
is
10
That's
here.
greater
CFR
72.122(l)
what
It
came
states
than
Class
which
out
that
C
of
For
is
the
"storage
waste
for
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1
further processing or disposal."
2
like
3
design must be there to allow that you have ready
4
retrieval.
to
highlight
5
this
I
regulation
would
is
that
the
This regulation only applies to general
6
and
specific
license
ISFSIs,
and
not
to
7
Certificates of Compliance.
8
and a lot later in the presentation I can kind of
9
go over that also.
There is a difference
The next regulation that I
10
had mentioned is 10 CFR 72.236(m) which applies to
11
Certificates
12
extent practicable in the design of storage casks,
13
consideration should be given to the compatibility
14
with
15
reactor
16
disposition by the Department of Energy."
17
is the part where retrievability is considered in
18
the design of a Certificate of Compliance for the
19
design of a dry -- or design.
of
removal
20
Compliance
of
site,
So
the
stored
with
that
retrievability really mean?
22
the regulations.
24
states
spent
transportation,
21
23
which
MEMBER BROWN:
being
fuel
from
and
said,
"to
the
the
ultimate
So this
what
does
I mean those are just
Okay, before you go on,
I've still got a little bit of confusion.
I read
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1
your stuff and I read your other history and I'm --
2
the
3
other regulation.
4
able to retrieve and in this case, maybe, maybe
5
not.
6
bother
with
7
cares?
I
8
indefensible
9
practical means of retrieval if you've got a CoC.
difference
between
this
regulation
If it's not practical, we're not going to
it.
We
mean
got
really
that
a
this
you
certificate,
seems
don't
to
have
I just -- that went down difficultly.
11
that way.
12
MS.
WONG:
So
a
so
be
to
who
pretty
have
a
Let's put it
Certificate
of
Compliance is given to vendors.
14
MEMBER BROWN:
15
MS. WONG:
16
the
And in one case you have to be
10
13
and
Who design?
Who design the dry storage
system.
17
MEMBER
not
18
just
19
they're stored.
20
the casks themselves?
21
casks,
BROWN:
but
the
look
this
in
senior
manager
23
Licensing
24
design the storage casks themselves.
The
at
NMSS,
storage
as
which
Or is it just
This is Bernie White.
22
Branch.
at
facility
Is that correct?
MR. WHITE:
project
also
I'll
Spent
casks,
I'm
Fuel
vendors
The pads they
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1
sit on and where they sit at the reactor facility
2
are done by the licensee.
3
licensee to ensure that it chooses a storage cask
4
design that can be retrievable since retrievability
5
is a requirement for licensees.
6
It's incumbent upon the
MEMBER BROWN:
If you make that clear,
7
that's one of the other comments in this thing that
8
the licensees are still required to comply with the
9
other ones.
It just seemed to be incompatible.
I
10
mean doesn't this backfit -- I mean if you look at
11
this on a -- if the general licensees are required
12
to
13
designer not comply?
14
that wrong.
15
just seemed to me --
comply,
16
how
in
the
world
Charlie.
18
product.
a
cask
storage
No, excuse me, maybe I have
Maybe I've got that backwards.
MEMBER POWERS:
17
can
But it
It's a little simple,
If you cannot comply and never sell this
19
MR.
WHITE:
to
cask
come
21
loading
as
22
The unloading process or the removal of it from
23
storage
24
overpack
and
is
unloading
putting
what
have
most
vendors
as
they
when
20
well
us,
Right,
it
we
into
look
the
procedures
storage
a
at
for
casks.
transportation
in
terms
of
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1
compatibility with removal from storage.
2
in a pool, in the event that they have to do to
3
repackage
4
transportation off site.
5
at
6
Certificate of Compliance.
that
it
piece
into
of
another
it
a
It is a little confusing.
I
8
MS. WONG:
the
vendors
All right.
was confused the first time I looked at it.
10
MEMBER BROWN:
I'm just a simple-minded
MS.
The
guy.
12
13
for
for
MEMBER BROWN:
11
overpack
So that's where we look
from
7
9
Unloading
WONG:
Certificate of Compliance.
vendors
get
the
It's hard for them --
14
MEMBER BROWN:
15
MS. WONG:
16
their Certificate of Compliance.
17
them
18
don't know what site it's going to be on, so they
19
can't actually comply with retrievability.
20
the general licensee, they have their site.
21
have their CoC.
22
goes together to comply with retrievability.
23
it's their responsibility as the general licensee.
24
They take something that the vendor has, they bring
to
comply
with
The cask vendors.
The cask vendors.
They get
It is hard for
retrievability
because
they
But for
They
They need to make sure everything
So
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1
it to their site, and they make sure that it can
2
comply with retrievability.
3
MEMBER BROWN:
can't
It seems to me that the
licensee
5
before the horse.
6
unless you know where it's going to go.
7
telling me they don't know that and unless somebody
8
asks them to design a cask to put in my facility,
9
they
have
a
--
No.
4
don't
ask
Does that help?
seems
to
me
the
cart
is
Somebody can't design a cask
product
that's
And you're
sitting
there.
10
They've got to do it from scratch after they've got
11
a
12
facility.
13
a lot of stuff and I would have never ever brought
14
anything in this manner.
request
15
to
design
a
cask
for
the
licensee's
It just seems to me when -- I've brought
MR. WHITE:
designs
Well, when a storage cask
16
vendor
17
characteristics, generic site characteristics.
18
reason that we have 72.212 which is the evaluations
19
that the general licensee has to do is to ensure
20
that
21
It's not common for us to get in a storage cask
22
design for a certain site characteristic and then
23
in two or three or four amendments because well, it
24
doesn't
the
cask
match
casks,
It's just insane.
matches
this
they
its
site,
design
site
it
to
site
The
characteristics.
the
design
basis
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1
earthquake isn't high enough for this site or for
2
this site or we need to add this fuel for this
3
site.
4
initial
5
characteristics once they have a contract in place.
We
have
design
amendments
which
which
account
6
MEMBER BROWN:
7
MS. WONG:
build
for
upon
the
site-specific
I'll turn off my mic.
All right, as we go through
8
the presentation we can talk more about this at
9
certain points if you're still confused.
10
11
MEMBER BROWN:
I just wanted to get it
on the table.
12
MS.
WONG:
Okay.
All
right,
fair
13
enough.
14
try to put in perspective what retrievability was.
15
As I said, when I was new to this retrievability, I
16
did not really understand what it was and where it
17
fit in into the big picture.
18
trying to relay that information.
19
So this a very over simplified diagram to
So this diagram is
At the top there, you do have storage.
20
It could be wet storage.
It could be dry storage.
21
You do have a little icon there for a pool and one
22
for a dry cask.
23
do retrievability by fuel assembly base.
24
pull fuel and put into whatever container you need
If you do have wet storage you can
You can
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1
it to go into to go for transportation.
2
be
3
prepping it for transportation.
retrieving
4
it
Of
or
course,
That would
retrievability
there's
a
lot
and
more
then
things
5
that go into that.
There's inspections.
6
why that's on there.
Repairs and replacements, you
7
probably
8
fuel,
9
container or a can which they can then be prepared
10
aren't
but
you
going
to
repair
could
put
it
or
That's
replace
into
a
the
secondary
for transportation.
11
MEMBER
BROWN:
When
you
say
pool,
I
12
think stuff I've been familiar with before is the
13
plants' spent fuel pools.
14
is not referred to -- that is not a spent fuel pool
15
in a nuclear power plant.
16
MS. WONG:
17
MEMBER
18
This is not -- that pool
That is correct.
BROWN:
Okay,
it's
a
separate
facility like a dry cask -- okay, that's fine.
19
MS.
WONG:
It's
20
pool that is for storage.
21
MEMBER BROWN:
22
MS. WONG:
more
of
a
dedicated
I've got it.
Okay.
For dry casks or dry
23
cask storage you could do retrievability.
24
to do it in two ways.
You have
You have to pull the cask or
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1
canister
from
2
need to do some sort of inspections, maybe some
3
repairs or replacements.
4
prepare it for transportation.
5
thing is you're retrieving it to prepare it for
6
transportation.
7
its
storage
site
and
you
probably
We hope not, but then you
That is the big
And once it's ready, then it goes into
8
the
transportation
9
transported,
a
lot
part.
of
And
that
I
think
it
can
you
be
already
10
know.
DOT regulates the whole transportation part.
11
We
12
packages.
13
disposal
14
consolidated storage or it could go to other like
15
another ISFSI site if needed.
16
needed to maybe do that if they don't have some of
17
the
18
replacements or other things that they need to do.
look
at
And
if
facility
19
licensing
I
then
there
on
do
the
it's
is
a
site
have
transported
site
to
a
packaging
lot
on
and
off
the
the
to
interim
Some people have
do
of
some
repairs
dotted
lines
or
on
20
there and that is going from that gray area in the
21
middle and so if you are repairing or you're doing
22
inspections and you're not ready to transport it
23
yet, it could go back to the storage site to sit
24
there until you are ready for transportation.
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1
MEMBER
Mark
about
REMPE:
believe
4
requirement that an operating plant or orphan site
5
has
6
transportation.
7
that.
capability
back
to
sites
I
3
responded
orphan
today,
asked
the
about
earlier
2
he
what
So
that
prepare
and
there's
the
fuel
I
no
for
But your diagram doesn't reflect
Maybe I misunderstood Mark's response.
8
MS. WONG:
So you mean an orphan site
9
with -- it's just the pad.
10
MEMBER REMPE:
A shut down plant and
11
they've left.
12
it
13
doesn't exist, but I would think that it's going to
14
exist in the future with the plants shutting down
15
that there will be plants with just a dry storage
16
facility
17
reactor or the spent fuel pool where they can bring
18
the casks back in and -- or the canister back in
19
and reopen it.
--
I'm
talking
and
20
If they have spent fuel, they've got
they
hypothetically.
no
longer
have
Maybe
the
this
operating
And so I was just kind of wondering --
21
you
were
talking
22
repairs, we hope that doesn't happen, but -- or if
23
they go to a larger storage system, how -- if they
24
don't
have
a
about
if
requirement
they
for
have
to
do
transportation
any
off
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1
site, how do they deal with that?
2
don't have a requirement to transport the material
3
off site eventually?
4
Is it true they
I mean we talked today about we don't
5
have
to
have
license
perpetuity
because
the
6
licensees don't want that because they do want to
7
have it moved off site.
8
of what's required and not required.
So I'm a little confused
9
MS. WONG:
ISFSIs are not meant to be a
10
permanent repository.
11
need to have retrievability which then infers that
12
they need to be able to transport it somewhere.
We know that.
13
MEMBER REMPE:
14
MS. WONG:
15
MR. WHITE:
So they do
It infers that.
It does.
The infrastructure needed
16
to transport a storage cask off site or a canister
17
off site exists.
18
storage cask vendors either have or will have a
19
transportation
20
off
21
transfer casks, the items that lift the canister
22
out of the stored overpack, put in a transfer cask,
23
move it over to a transportation packaging, put it
24
in place, prepare that and then ship it off site.
site.
The storage cask vendor, all the
packaging
They
also
available
have
the
for
lifting
transport
items
to
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1
What they don't have is a pool and the
2
event that for some unknown reason they'd have to
3
open up a canister to do some sort of inspection,
4
repair,
5
that's going to happen.
replacement.
6
In
We
terms
the
of
don't
when
evaluations
we
do
8
reports, there aren't any accidents or mechanisms
9
that could cause us to have to open up one.
management
11
you've
heard
about
12
later,
those
are
13
remain safe and intact.
14
15
plans
MEMBER
that
we're
earlier
designed
safety
safety
analysis,
aging
the
our
that
7
10
of
anticipate
and
to
REMPE:
The
working
will
hear
ensure
I
analysis
could
that
about
that
they
almost
even
thing
like
think you could put an over-canister --
16
MR. WHITE:
17
MEMBER
Absolutely.
REMPE:
--
such
a
18
that, too.
19
of these fuel storage systems that are so large
20
that you can't transport them?
21
just wondering --
22
23
What I'm wondering about are there any
MR.
transported.
24
WHITE:
No,
I don't know.
they
can
all
I'm
be
Most of them are by rail.
MEMBER REMPE:
So there's nothing --
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1
MR. WHITE:
They're specially designed
2
rail cars that can handle that and they may have to
3
use certain tracks or certain locations because of
4
potentially bridge weights or things like that, but
5
that's well beyond what we would evaluate.
6
7
MEMBER REMPE:
curious about that.
8
9
10
That helps.
I just was
Thank you.
MS. WONG:
Sure.
Any other questions
about this diagram and where retrievability fits in
the big picture?
11
If not, I will move on.
So now I'll go into a little bit of the
12
guidance of how to meet retrievability.
13
been several guidance documents on this.
14
the rule on retrievability was issued in 1998, the
15
guidance on retrievability was then issued in 1998,
16
which
17
Revision 0.
18
was put into the regulations and that dual purpose
19
canisters were a means to meet retrievability since
20
it could be taken off the storage area and put into
21
a
22
individual fuel assemblies in a spent fuel pool.
was
ISG-2
or
Interim
Staff
There have
So after
Guidance
2,
This guidance explains how the rule
transportation
cask
without
having
to
handle
23
Later though in 2001, this view changed
24
to requiring that each individual fuel assembly be
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1
retrievable by normal means as a means to meet the
2
retrievability regulation.
3
in guidance in 2010 in ISG-2, Revision 1.
4
guidance
5
ability to move a canister containing spent fuel to
6
either a transportation package or to a location
7
where
8
Additionally,
9
maintaining
it
states
the
that
spent
"ready
fuel
that
the
This was then clarified
ready
ability
retrieval
can
is
be
retrieval
to
In this
handle
the
removed.
also
means
individual
or
10
canned spent fuel assemblies by the use of normal
11
means."
12
in order to meet retrievability in this guidance
13
document.
So both of these conditions had to be met
14
This
clarification
of
the
individual
15
fuel assembly handling by normal means reflects a
16
time of anticipated near term repository.
17
was
18
mentioned this, that the fuel would only be stored
19
for
20
transported
21
thought they would probably need to maybe repackage
22
these and that was the thought at that time.
thought
one
23
24
at
to
this
two
away.
time
storage
So
and
periods
therefore
MEMBER BROWN:
Mark
Also, it
had
already
before
that's
why
being
they
When you say one or two
storage periods, are you referring to the 20 year
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1
and then another 20 years after that?
2
3
MS. WONG:
Correct.
So a total of 40
years.
4
MEMBER BROWN:
Thank you.
5
MR. LOMBARD:
But it could be up to 40
6
years.
7
MS. WONG:
8
MR.
9
renewals are up to 40 years.
10
But not at that time.
LOMBARD:
MS. WONG:
Not
that
Correct.
time.
New
So now we would
11
more likely think one storage period, but at that
12
time it was one to two which would be 40 years.
13
It's a good clarification.
14
Thank you.
Also during this time, due to the --
15
well,
it's
16
uncertainty in the national strategy for the back
17
end
18
happening
19
storage which is why we got to the 40 year time
20
period.
of
21
the
the
to
In
current
fuel
time
cycle,
consider
2009,
a
a
longer
also,
due
paradigm
periods
COMDAC
09001
to
shift
of
had
time
the
is
in
actually
22
asked the staff to develop to review the regulatory
23
--
24
MEMBER BROWN:
Can I?
I want to try to
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1
understand
something.
2
paradigm shift, and I didn't ask this question in a
3
previous presentation.
4
MS. WONG:
5
MEMBER
When
you
talk
about
a
Okay.
BROWN:
It
seems
to
me
the
6
paradigm shift was driven by the fact that we don't
7
have a long-term repository.
8
MS. WONG:
Correct.
9
MEMBER BROWN:
So it wasn't some great
10
mental leap where we decided to do this.
11
that
12
promised long-term repository.
the
government
has
13
MS. WONG:
14
MEMBER BROWN:
failed
to
It was
provide
the
Right.
I don't want to get into
15
the politics, but that's fundamentally where that
16
goes.
Is that correct?
17
18
MS. WONG:
reacting to the reality.
19
20
That is correct and we are
MEMBER
reality.
BROWN:
I'm happy with that.
21
MEMBER POWERS:
22
(Laughter.)
23
MEMBER BROWN:
24
That's
I am not happy with that.
fine.
That's
Thank you.
No, you aren't.
You are correct, Dana.
I tend not to work on
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1
things I can't control.
2
don't work on them. Thank you.
3
MS. WONG:
I think about them, but
Okay.
Thank you.
So in
4
response to all of that, we did have a COMDAC which
5
asked the staff to develop a plan to review the
6
regulatory programs for storage and transportation
7
and their adequacy for long-term storage that would
8
be
9
program improvements that were already ongoing.
in
addition
to
leveraging
on-going
licensing
10
In response to this COMDAC, the staff
11
issued COMSECY 10-007 in 2010 which included a plan
12
for
13
improvements.
near-term
licensing
and
inspection
program
14
Also, we have been looking at the long-
15
term performance of some of the internal components
16
which fuel is one of those components.
17
also the current focus of some research as being
18
done by the Agency and the industry.
19
additional
20
area,
21
assessing
22
inspections,
repairs,
23
mitigation
the
24
unnecessarily needing to open the cask or canister
research
there
may
these
of
has
be
been
conducted
unintended
internals
that
and
internals
And that's
And until
in
this
consequences
in
could
to
lead
replacements
that
could
lead
or
to
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1
and in doing this may increase the worker dose and
2
degrade the confinement boundary.
3
Also, in considering all of this, we,
4
the
staff,
5
between the storage and transportation frameworks.
6
It
7
retrievability needed to be reevaluated to address
8
the longer storage duration and the potential for
9
multiple
was
did
a
review
determined
storage
10
transportation
11
ultimate disposal.
12
of
the
the
two
2011
public
guidance
and
stored
in
compatibility
associated
spent
and
fuel
into
through
2012,
the
14
outreach where retrievability was discussed and we
15
got
16
subsequently in 2013, the staff issued a request
17
for public comment on retrievability where we asked
18
a series of questions that the industry and other
19
stakeholders did respond to in public comment.
20
we have that feedback on that retrievability.
feedback
21
from
meetings
on
13
some
held
that
the
locations
Therefore,
NRC
of
external
to
folks
do
and
some
then
So
After 2013, the work on retrievability
22
was
delayed
due
23
framework,
24
storage renewal framework better looked at and on
so
to
the
basically
storage
we
renewal
needed
to
license
get
the
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1
its way we would look at retrievability again.
2
in 2015, the work on renewals was far enough along
3
that the work on retrievability was then restarted.
4
This
5
between the year 2013 and '15.
is
why
6
there's
So
7
public
8
guidance
9
additional
in
meeting
on
a
gap
July
and
2015,
the
was
about
the
idea
retrievability
feedback
of
staff
of
was
two
But
years
held
a
revisiting
the
reintroduced
and
received
from
external
10
stakeholders.
11
from 2011, 2012, and the 2013 public comments, we
12
used all of this information to order to develop
13
the draft ISG-2, Revision 2.
14
issued for public comment on October 21, 2105 with
15
a
16
November 20, 2015.
30
day
With this feedback and the feedback
public
17
comment
Additionally,
And this draft was
period
the
which
staff
had
ended
a
on
public
18
meeting after it was issued for public comment to
19
discuss
20
public could make more informed comments to us.
any
21
clarifications
The
public
draft
health
the
focused
on
so
the
maintaining
the
23
spent fuel could be retrieved from storage safely
24
and
guidance
safety,
draft,
22
provides
and
ISG
on
to
the
ensuring
staff
on
that
the
licensing
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1
reviews.
2
So
just
a
quick
reminder
about
ISG-2
3
and the current revision one which is the current
4
guidance out there right now, you have to have the
5
ability to move a canister containing spent fuel to
6
either a transportation package or to a location
7
where spent fuel can be removed, and you would need
8
to have the ability to handle individual or canned
9
spent fuel assemblies by the use of normal means.
10
The use of normal means means you have
11
a crane and grapple and basically you can pull the
12
fuel without extraordinary circumstances.
13
In
the
draft
Revision
2,
be
more
14
focused on safety and design bases to allow maximum
15
flexibility
16
storage period.
to
maintain
safety
for
a
undefined
17
So now I'm going to go into the draft
18
guidance, but before I go into that I would like to
19
mention that we have received public comments.
20
have responded to the public comments.
21
comments and any clarifications that we had in the
22
draft
23
additionally,
24
understand whether or not you would like to have a
ISG
is
reflected
as
a
in
this
reminder,
we
We
The public
presentation
would
like
and
to
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1
full committee meeting on this in April.
2
So I'm going into it.
We have gone
3
back and we made changes to the definition of ready
4
retrieval which now states the ready retrieval is
5
the ability to safely remove with no operational
6
safety
7
further processing or disposal.
8
operational safety problems" is defined in the SRP.
9
I
problems
think
it's
the
1567.
spent
fuel
And
it
from
storage
for
Now the words "no
refers
back
to
10
compliance with the Part 20 requirements which is
11
dose requirements.
12
MEMBER SKILLMAN:
I made a comment on
13
this earlier and I would like to do it again.
14
seems to me with the addition of that phrase that
15
this is either so broad as to be paralyzing or so
16
vague it can be misinterpreted.
17
me that it would be wiser simply to say the ability
18
to remove, safely remove the spent fuel and leave
19
it at that.
20
By
introducing
the
It
It would seem to
notion
of
no
21
operational safety problems it just strikes me that
22
you invite an innumerable number of questions and
23
challenges.
24
the casks and the fuel assemblies have a pretty
I think the people that are handling
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1
good understanding of what is safe.
2
And when you introduce the idea of no
3
operational safety problems, now the issue is is
4
there an inspector there with a stop watch and if
5
it doesn't go as quickly as you hoped, if you're
6
suspended because your crane is broken or you have
7
some unexpected event occurring, because the time
8
is
9
slightly --
delaying?
10
Is
that
MS. WONG:
a
safety
problem
if
it's
It is not a safety problem
11
as long as workers are not getting more dose than
12
they're supposed to be getting.
13
MEMBER SKILLMAN:
Well, suppose they
14
are getting a few more millirem?
15
they
16
limits.
are,
but
they're
still
17
MS. WONG:
18
MEMBER SKILLMAN:
really
in
Supposing that
the
10
CFR
20
That's fine.
doesn't
add
Then introducing that
19
phrase
anything.
It
just
20
introduces in my view, an operational complication
21
because the people who are doing this really do
22
know how to do it, believe me.
23
are the ones who are going to protect themselves.
24
I mean you're not even going to go near that cask
They do. And they
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1
until you have your HP set up, until you have your
2
monitoring set up.
3
runs, rehearsals.
4
is ready to go.
5
Just
You probably have done some dry
You've confirmed
as
I
read
that
your equipment
phrase
and
I
6
actually read the comments from the people who are
7
out in the field, they pushed back on that phrase.
8
NEI did.
9
up
to
Yankee and Connecticut Yankee, the plants
the
north
back
that
we
all
really
those
don't
facilities
10
pushed
11
phrase.
12
guy and I've lived through campaigns like this and
13
I would find that phrase to be one that could only
14
be used to create a violation.
15
helps.
need
that
So I'm kind of a practitioner kind of a
16
17
saying
have
MS. WONG:
Okay.
I don't think that
Thank you for your
comment.
18
MR.
RAHIMI:
Meraj
Rahimi,
NRC.
So
19
what Emma is showing really that phrase comes the
20
genesis
21
Because that was the basis for protecting cladding
22
at all times.
23
24
of
that
MEMBER
wait.
phrase.
It
SKILLMAN:
is
Wait,
in
72122(h).
wait,
wait,
That's nice that you said that, but that's
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1
not what Emma said.
Emma said it has more to do
2
with radiological safety.
3
Those are two very different issues.
4
MR. RAHIMI:
You say for clad safety.
I understand that.
But
5
what I'm saying -- that genesis, it goes back to
6
radiation protection.
7
design,
we
review
the
8
loading
procedure.
We
9
assessment
that
When the applicant submits a
they
operating
review
have
procedure,
the
the
detailed
dose
done
under
their
10
radiation protection chapters.
11
hours of loading, unloading.
12
come up with the exposures requirement.
13
as they are within those limits, it goes in the
14
tech
15
those limits, they are fine.
spec
16
later
We
on,
review
as
Based on those that
long
those
They estimate the
as
they
operating
So as long
are
within
procedures.
17
It is based on the dose calculation.
If there is a
18
hang up, actually we had a case on the lightweight
19
transfer cask.
20
light transfer cask because the crane couldn't take
21
it.
22
at the time of the transfer.
23
that was an exemption request and we reviewed that
24
and we ended up approving that exemption request.
The licensee wanted to use a very
They wanted to take the shelling off and back
And they came in --
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1
But
what
we
approve,
2
procedure
3
assessments, what they believe the normal operating
4
procedure
5
assessment.
and
the
is
we
look
applicant,
going
to
at
the
they
do
result
in,
operating
the
the
dose
dose
6
So if they are within those dose limits
7
that some of those dose limits goes into the tech
8
spec, and also with the site-specific requirements,
9
they are fine.
So that phrase is not going to
10
really try to cite a violation for any smallest
11
change in the operating -- they have flexibility
12
because
13
procedure
14
embedded in there.
15
MEMBER
POWERS:
Can
safely
in
the
that
tech
we
review
and
and
in
the
approve,
Let
17
storage with operational safety problems?
good point.
20
at the value that that phrase adds?
spent
all
you
fuel
a
from
How about we take the action to look
MEMBER SKILLMAN:
only
it's
I think you bring up a
19
21
operating
ask
question.
MR. LOMBARD:
remove
me
16
18
I
spec
point
I'm
Thank you.
making,
Mark.
That is
22
the
What
I'm
23
suggesting is by introducing that, my view is that
24
creates a complication for the men and women that
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1
do this work.
And I can understand an individual
2
saying oh, you can't do that.
3
That's an operational safety problem.
4
MR. LOMBARD:
5
MEMBER
That's not safe.
Exactly.
SKILLMAN:
And
the
individual
6
who's operating the crane or the manipulator or the
7
device might say wait a minute, just because my
8
scale is not calibrated doesn't mean I'm unsafe.
9
do not have an operational safety problem.
I
We have
10
done this a hundred times and we know it's safe.
11
And I'm not worried about that device.
12
alone.
Leave me
Bingo, violation.
13
And I'm saying wait a minute.
Those
14
poor people don't need that complication.
15
remove that phrase, I submit that work can be done
16
safely anyways.
17
So
to
Dr.
Powers'
question,
If you
without
18
that phrase, can you do it safely?
19
can.
20
that's
21
You've got to put things back in the cask and keep
22
the shield.
And sometimes when you have a safety problem,
23
24
Yes, you really
when
it's
essential
MR. LOMBARD:
either
redundant
at
that
Right.
minimum
or
you
proceed.
I agree.
it
may
It's
introduce
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1
another interpretation which is not a good thing.
2
MEMBER SKILLMAN:
3
MR.
4
MEMBER SKILLMAN:
a
good
comment.
Thank you.
And you
thought this would be easy.
7
(Laughter.)
8
MEMBER BROWN:
9
MS. WONG:
10
11
It's
Thank you.
5
6
LOMBARD:
Thank you.
We actually read it.
I'm impressed.
MEMBER BROWN:
Okay --
That's what happens when
you give us something that's only five pages long.
12
MS. WONG:
I'll take a note of that.
13
(Laughter.)
14
MEMBER BROWN:
15
(Laughter.)
16
CHAIRMAN
Don't.
BALLINGER:
I've
just
been
17
notified by my handler that there are still people
18
out there on the line that have not muted their
19
phone.
20
stuff here, but apparently it's significant.
21
you're out there on the line and you're not wanting
22
to talk, please mute your phone.
We don't hear all of the cross talk and
23
24
MS.
we're
going
to
WONG:
ignore
Okay,
to
the
keep
So if
going
operational
and
safety
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1
problem
statement
2
next few slides so just ignore that for now.
3
4
that's
CHAIRMAN
going
to
BALLINGER:
appear
Can
in
you
the
quickly
edit this thing?
5
(Laughter.)
6
MS. WONG:
and
Chris?
everything.
No.
However,
It's already
7
printed
these
are
the
8
options that we have developed in order to comply
9
or you could comply with ready retrieval.
It is
10
the ability to do at least one of the following
11
options.
12
And there are three options here.
A is
13
the remove to the individual or canned spent fuel
14
assemblies from wet or dry storage.
15
a canister loaded with spent fuel assemblies from a
16
storage
cask
or
17
loaded
with
spent
18
storage location.
19
20
overpack.
And
fuel
C
B is to remove
remove
assemblies
MEMBER SKILLMAN:
a
from
cask
their
I've got to ask you a
question here.
21
MS. WONG:
22
MEMBER SKILLMAN:
review
comment
Sure.
to
There was my late at
23
night
myself.
How
24
guidance ensuring the outcome desired?
is
this
How does
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1
stipulating at least one of the following ensure
2
the
3
accomplish?
outcome
4
that
this
ISG
is
really
trying
to
It seems to me that the wiser way to
5
write
6
either
7
Because it could be that in certain sequences you
8
might have to do C before A or A before C or some
9
permutation
10
that
A
guidance
or
B
and
or
would
C
or
be
any
combination
the
ability
combination
that
isn't
to
do
thereof.
clearly
permitted by the way you write that first sentence.
11
MR. WHITE:
That's the intent of it, a
12
licensee can comply with either B or C or BC moving
13
it off the storage cask into a facility and they're
14
removing a single fuel assembly.
15
MEMBER SKILLMAN:
Then I would suggest
16
words should be something like ability to perform
17
any of the sequences below that ensure that the
18
outcome is successful.
19
MR.
WHITE:
And
we
can
revisit
the
20
language, but that was the intent of at least one.
21
Because
22
purpose casks.
23
from storage, prepared for transport, or put in a
24
transport packaging and then shipped off site.
we
have
dual-purpose
canisters
and
dual-
All they have to do is be removed
We
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1
would never have to do A.
2
depending on what your cask looks like.
3
4
But you can do B or C,
MEMBER
SKILLMAN:
MEMBER
BROWN:
Okay.
Thank
you,
good.
5
because
option
8
later, you say if an applicant is relying upon A,
9
then he must demonstrate retrieval under B and C as
10
well which seems to be inconsistent, so he can't
11
rely upon A unless he does B and C.
12
say I can only rely on A that you're saying well,
13
you can't really.
14
I see it as an inconsistency, that's all.
15
But
on
--
any
one
amplify
7
one.
either
just
that
is
said
would
6
A
you
I
several
of
which
paragraphs
So you could
You have to do something else.
MR. WHITE:
Well, B or C is to remove
16
the storage cask from its storage location to a
17
place where you could do A which would typically be
18
a spent fuel pool.
19
20
That was the intent of that.
MEMBER BROWN:
It didn't come across.
It was beyond my comprehension at that point.
21
MR. WHITE:
And then, of course, you
22
have places like GE Morris which is a wet pool.
23
They can only do A.
24
They have no cask.
There is no B or C for them.
They have no canister.
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1
MEMBER BROWN:
make
that
a
little
Okay.
You ought to try
2
to
3
thought
4
inconsistent.
5
practical
6
trapped somewhere along the line, that's all.
process.
clearer.
It
my
seemed
only
to
be
If you're reading this absent the
application,
7
just
That's
MS. WONG:
you
can
see
why
you
get
So hopefully, the slides are
8
clearer.
We can revisit the language later.
9
this is one of the combinations you could do.
So
You
10
pick option A with B or C and this currently is
11
what all sites are complying with, so there would
12
be -- if this were to go final, all the sites would
13
already be complying with a combination.
14
So
option
A
again,
is
fuel
assembly
15
removal and option B or C would be either cask or
16
canister removal, depending on what you had on your
17
site.
So you would pick B or C.
18
As you see in this little graphic here,
19
looks like they have -- it's a vertical storage
20
system
21
picture.
22
it on all these slides here.
23
24
and
horizontal
storage
system
in
And just ignore that last bullet.
Okay,
and
also
from
that
this
Ignore
last
slides
that's all for dry cask or canister storage.
There
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1
is not wet storage that I am aware of that has a
2
cask or canister so they could never do B or C.
3
that's why we have this option where you could just
4
do option A which is fuel assembly removal which
5
could
6
actually is a dry storage design that doesn't have
7
a cask or canister that could be removed and they
8
would have to use option A.
9
assembly
be
for
wet
or
removal,
a
fuel
dry
storage
design
So
or
This would be fuel
assembly
removal
-
-you
10
would have to be able to ensure that the fuel would
11
not
12
mean is if you want to read more about it, this is
13
in ISG-1, Revision 1.
14
there will not be any gross ruptures that would
15
lead to release of fuel particulates.
exhibit
16
gross
It
degradation.
does
What
that
would
This really does mean that
have
the
potential
for
gross
17
degradation, then you could put the fuel into a
18
secondary container such as a can and then put it
19
and that would be a way to be able to remove it
20
from storage.
21
bullet there.
And again, you can ignore the last
22
The last option that we saw was either
23
just taking option B or C by itself which would be
24
a canister or cask removal, depending on what you
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1
had on your site.
2
option, this information would need to be included
3
in
4
maintain this ready retrieval, that you would be
5
able to do this and remove your cask or canister
6
for removal.
your
And if you did choose this, this
technical
7
The
specifications
site
may
monitor,
have
and
in
a
order
program
mitigate
to
to
8
identify,
possible
9
degradation because now you're just relying on this
10
cask or canister removal.
11
need to comply with all of your 10 CFR Part 72
12
requirements
13
And ignore the last bullet.
14
So
regardless
And of course, you still
of
what
additionally,
in
option
the
you
ISG
pick.
there
is
15
guidance to the staff performing reviews.
16
initial
or
17
should
look
18
retrievability,
19
systems,
20
subcomponents
21
pertinent for retrievability and that we do have
22
tech specs in place to ensure that retrievability
23
capability can be maintained.
24
an
amendment
at
the
system
that
structures,
have
application
they
and
been
is
the
reviewer
designed
identify
components,
identified
For an
that
for
important
and
their
would
be
And for example, this is something that
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1
we currently do on sites and it is to maintain the
2
as-loaded conditions and this is in the tech specs.
3
And what this would mean is that you would need to
4
know the loaded fuel condition and configuration.
5
You
6
inerted environment.
7
maximum clad or fuel clad temperature.
8
thermal cycling.
9
forward, that should be able to ensure that the
10
fuel would be able to be remove individually by
11
normal means because that is the current guidance
12
that we have out there.
13
ensure
14
components, their performance would not be degraded
15
such that retrievability could be assured.
would
need
that
to
ensure
that
there
is
a
dry
You would need to limit the
And limit
If you can maintain that, going
the
And in doing this, we can
systems,
structures,
and
16
Additionally, for license renewals and
17
I know a lot of it is in NUREG 1927, Revision 1, a
18
reviewer
19
bases have been maintained, review the applicable
20
aging
21
analyses, review any operating experience that has
22
been shown are out there which would include any
23
inspections that have been done and analyses of the
24
structure
should
management
look
to
programs
systems
and
ensure
and
that
time
components
the
design
limited
and
aging
their
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1
subcomponents.
2
on renewals, they really should be going to look at
3
NUREG 1927, Revision 1.
4
And of course, for more information
So in the public comments, a lot of the
5
comments
allude
to
6
enough
7
Certificates of Compliances.
8
slides
9
clarity and additional words.
clarity
on
this
the
fact
under
to
try
to
that
there
was
retrievability
not
and
So I inserted a few
bring
some
additional
Actually, I think
10
there's a nice, big paragraph in there now, was
11
inserted into the draft ISG.
12
First, I would like to remind everyone
13
that for retrievability which is 10 CFR 72.122(l)
14
which is the main requirement, is not a requirement
15
for
16
Compliance are required to meet 72.236(m) to the
17
extent practicable.
18
for the Certificate of Compliance they do include
19
information that there are retrievability aspects
20
in their application, the review would considered
21
these
22
would be okay in that Certificate of Compliance.
Certificates
and
ensure
of
Compliance.
Certificates
of
However, if in the application
that
whatever
they're
proposing
23
They would also -- the reviewer would
24
also need to ensure that everything -- all the rest
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1
of the parts, ensure the requirements are also met.
2
As
we
had
licensee
previously
general
4
retrievability requirement of 72.122(l).
5
they would do is they would load in accordance with
6
the Certificate of Compliance and then demonstrate
7
that
8
fabrication, loading, and preparation for storage
9
requirement.
10
that
they
11
requirement.
12
cask
or
need
canister
to
meet
a
3
the
does
mentioned,
the
And what
would
meet
the
They would also need to demonstrate
would
For
a
also
meet
the
Certificate
general
retrievability
of
13
amendments,
14
adopt a later amendment.
15
amendment,
would
16
entirety.
So if, for instance, a Certificate of
17
Compliance
or
18
their Certificate of Compliance, they could submit
19
an amendment.
20
would be there and the general licensee could go
21
and adopt a later amendment.
22
to adopt it in its entirety.
23
make sure they can meet everything that was in that
24
amendment.
a
need
licensee
can
Compliance
voluntarily
And when doing so, the
to
retrieval
be
or
adopted
in
retrievability
its
in
The amendment, if it was approved,
But they would have
So they would have to
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1
Another
way
that
a
Certificate
of
2
Compliance could revise what's in their certificate
3
is
4
however,
5
revised in its entirety.
So that amendment, when
6
your
like
7
would
8
approved.
9
using CoC that's had a revision has to comply with
10
to
do
a
revision.
would
revision,
be
the
supersede
And
a
the
CoC
whatever,
current
revision
process,
amendment
Revision
revision
being
1,
after
that
that's
That would mean any licensee that is
that revision.
11
That
being
said,
that
CoC
that
has
12
submitted for the revision process, that is subject
13
to the backfit review because that would require
14
anyone who is under that amendment to comply with
15
that revision.
16
This is my last real slide.
So we have
17
received about 70 comments.
And we did draft some
18
responses to those comments and we have clarified
19
and updated ISG-2, Revision 2 to these comments.
20
think we've gotten a few more comments from the
21
subcommittee today that we will consider.
22
now there haven't been significant changes and I
23
think a lot of things you've also proposed would
24
not really be significant changes to the guidance.
I
Right
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1
So of course, since this is the time line, we're
2
here
3
review.
4
we'd be more than happy to do that.
5
hoping to issue the final guidance in the summer of
6
this year.
today
7
on
March
23rd
for
the
subcommittee
If we need to come back to full committee,
And
all
the
rest
of
And we are
the
slides
8
reference slides and abbreviation slides.
9
take more questions.
10
CHAIRMAN
11
Is
Now I'll
Pete
--
Pete
are you there?
12
13
BALLINGER:
are
MEMBER RICCARDELLA:
I'm here.
CHAIRMAN BALLINGER:
Okay.
I was
on mute.
14
You're the
15
only person that's complied with the request.
16
you have any questions?
17
MEMBER RICCARDELLA:
18
said
earlier,
19
presentations
20
understanding on the subject.
21
I
think
and
CHAIRMAN
I've
No, I think as was
these
are
gained
BALLINGER:
excellent
a
greater
Okay.
Thanks.
22
Now, should we go around before lunch?
23
should.
24
Do
We probably
Are there any members of the audience
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1
that would like to make a statement?
2
MR. EINZIGER:
3
CHAIRMAN BALLINGER:
4
Dr. Einziger.
Bob Einziger from the -I think you've got
to turn it on or get closer or something.
5
MR.
EINZIGER:
Is
this
better?
Bob
6
Einziger from the NWRTB.
7
comment
8
which I'm thankful for, but I didn't agree with the
9
response
and
I
and
got
I
a
think
I had submitted this as a
response
that's
back
from
because
the
the
NRC
comment
10
might have been misinterpreted.
11
retrieve it on the canister basis, then the clause
12
in the storage regulation that says that you can't
13
have gross rupture unless you take -- and if you
14
have gross rupture you have to take other steps
15
such as to have operational safety.
16
By
having
the
If they decide to
retrievability
on
the
17
canister basis, you've essentially maintained your
18
operational safety which means that there's nothing
19
to prevent them from having gross rupture of the
20
cladding and still meeting that clause.
21
the condition where the fuel has reconfigured or
22
had the gross rupture and still can meet all your
23
other
24
shielding,
safety
requirements
thermal,
what
is
such
to
as
prevent
Now if in
totality
the
user
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1
from saying I want to run this temperature on the
2
fuel up to 500 degree C.
3
to the cladding because I've already mete all your
4
regulations.
5
the utility pad and the DOE eventually comes to
6
take it to go take it to the repository wherever,
7
but under the standard contract that's still there,
8
it says it has to be retrievable on a fuel assembly
9
basis or if they decide to repackage it, that means
10
they've got to take things out and repackage the
11
fuel.
12
with down the road with being retrievable for the
13
purposes
14
repository?
Well, then this cask is sitting on
Isn't
of
15
To hell with what happens
that
essentially
final
disposal,
MEMBER REMPE:
being
I
incompatible
think
you
said,
These are just comments,
16
and so you actually -- I'm helping the chairman
17
here.
18
comment for consideration.
19
MR.
CHAIRMAN
EINZIGER:
BALLINGER:
20
eminence.
21
Is the outside line open?
22
If you're --
That's
Given
a
his
Is anybody out there?
23
MS. GILMORE:
Hello?
24
CHAIRMAN BALLINGER:
Yes, yes.
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1
2
MS.
GILMORE:
This
is
Donna
Gilmore.
Can you hear me okay?
3
CHAIRMAN BALLINGER:
4
MS. GILMORE:
Yes, we can.
Okay, great.
Mark had
5
made a comment about there was a leak in a canister
6
it would be a few molecules getting out.
7
not
8
supports
9
documentation
been
able
that
to
find
scenario,
any
but
supporting
I have
documentation
I've
that
we
seen
a
would
that
lot
of
actually
10
even have an explosion if say five percent error
11
gets in this set of canisters.
12
comments, but I really think there needs to be some
13
kind of documentation that addresses what actually
14
is
15
these
16
what's going to happen.
17
Onofre
18
living near these nuclear plants.
19
somebody making a statement without any technical
20
documents to back it up.
going
to
happen
approval
and
21
with
the
it's
documents,
canister
something
in
to
any
of
back
up
I live five miles from San
critical
CHAIRMAN
I know this is just
information
for
those
They have --
Thank you.
BALLINGER:
Thank
you.
22
thought I heard another person out there.
23
not.
I
Maybe
Is there anybody else on the line?
24
MR.
PLANTE:
Paul
Plante
from
3
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1
Yankees.
On Emma's definition slide, you talked
2
about GTCC canisters as well which as a canister
3
they
4
processed at the sites in different ways, some of
5
them cut up into small fuel assembly size, pieces,
6
and put them in canisters that way.
7
them cut them up into large segments and put them
8
in baskets.
9
would be on a canister basis.
would
10
be
retrievable,
but
the
GTCC
gets
And some of
So certainly retrievability at GTCC
CHAIRMAN
That's my comment.
BALLINGER:
Thank
you.
Is
11
there anybody else on the line that would like to
12
make
13
comments, then we are adjourned until 1 o'clock --
14
recessed,
15
o'clock
a
comment?
16
excuse
Okay,
me.
(Whereupon,
if
there
We're
the
are
no
recessed
further
until
above-entitled
1
matter
17
went off the record at 11:49 a.m. and resumed at
18
1:01 p.m.)
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1
A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N
2
(1:01 p.m.)
3
4
CHAIRMAN BALLINGER:
in session.
Okay, we're back
Meraj.
5
MR. RAHIMI:
Is it on?
6
MEMBER SKILLMAN:
Yes.
7
UPDATE ON STORAGE AND TRANSPORTATION OF
8
HIGH BURNUP SPENT FUEL
9
MR. RAHIMI:
10
name
is
11
Criticality,
12
in
13
NMSS, NRC.
the
Meraj
Rahimi.
So
high
I
Good afternoon.
My
am
of
the
Chief
Shielding and Risk Assessment Branch
Division
14
Okay.
of
this
Fuel
afternoon
going
don't
know
to
if
talk
16
remember back in summerish we came in with really
17
detailed presentation on the, both the testing that
18
we are doing.
19
presented
20
finished the Phase 1 test and we had not started
21
the Phase 2 test.
22
John Scapioni from Oak Ridge presented detail on
23
the consequence analysis.
25
I
I'm
within
about
all
fuel.
Management
15
24
burnup
Spent
you
Michelle Bales from Research, she
the
tests.
At
that
time
we
had
And also, at that time we had
So what really at this presentation I'm
going
to
give
really
sort
of
a
condensed,
very
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1
summarized
version.
2
presentation is to see how this piece fits into the
3
overall
4
goal.
storage
And
and
purpose
transportation.
5
MEMBER SKILLMAN:
6
THE OPERATOR:
of
the
That's
the
Meraj, let me --
Pardon the interruption.
7
Your
8
participants at this time.
9
continue press star one now, or the conference will
10
conference
the
contains
less
than
three
If you would like to
be terminated.
11
MEMBER
As
what
you
let
are
me
going
ask
this.
13
present, is what you are presenting the analysis
14
that in the RIS are identified as experimentally
15
justified?
16
about here for the next hour?
we're
anticipate
Meraj,
12
17
I
SKILLMAN:
to
Is that what we're really going to talk
MR. RAHIMI:
It's one of the pieces.
not
go
18
No,
going
to
into
details
19
analysis.
20
goes into the RIS, regulatory issue summary, and
21
how we're planning.
22
RIS.
the
23
writing now a new RIS that shows the implementation
24
of
25
licensing and certification of casks with regard to
I'm going to show all the pieces that
We haven't issued the final
We have issued the draft RIS.
that
on
RIS
and
how
does
it
And how we're
really
support
the
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1
high burnup fuels.
2
So
it's
we're
not
going
to
go
into
3
detail.
4
you would like
5
you know, about any of those parts we could answer
6
the question.
7
analysis.
8
references,
documents,
9
much
want
10
if
But I believe Michelle Bales is here if
-- if you have a detailed question,
But the RIS really doesn't have the
There
I
are
to
pointers
NUREGs.
go
into
in
It
there
would
detail
as
and
be
a
too
whole
reference.
11
MEMBER SKILLMAN:
Yeah, it was not my
12
intention to challenge you for detail.
13
trying to get clear in my mind, throughout the RIS
14
are these sentences that communicate, for instance,
15
"release
16
confinement analysis for non-leak type casks should
17
be experimentally justified."
fraction
values
used
as
I was just
part
of
the
18
And I'm thinking what you're going to
19
present is at least the basis for those experiments
20
and for that justification.
21
MR. RAHIMI:
Yeah.
Yeah, we, I mean we
22
could talk about it but I wasn't planning on going
23
into in detail sort of for containment what is or
24
what are the analyses or --
25
MEMBER
SKILLMAN:
So
the
answer
is
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1
really no.
You are not going --
2
3
MR. RAHIMI:
sorry.
The answer is no.
It's --
4
MEMBER
SKILLMAN:
5
that's fair enough.
6
should.
MR. RAHIMI:
8
MEMBER SKILLMAN:
10
No,
no.
No,
no,
I wasn't suggesting that you
7
9
I'm
Okay.
I was just trying to
get clear in my mind what you're going to try to
accomplish in the next hour.
11
MR. RAHIMI:
Yeah, it was -- this is a
12
piece of the really the big picture.
13
see, I'm going to focus on the two of those blocks.
14
Actually, the other one should be red.
15
performance, that's how this piece fits into the
16
overall.
17
of view that if I can answer your questions.
18
was my goal.
19
20
As you could
The fuel
And it's sort of from big picture point
MEMBER
SKILLMAN:
Thank
you.
That
That's
fine.
21
MR. RAHIMI:
Mark
started,
Okay.
Mark
So I think this
22
morning
is
our
division
23
director, I guess our star, our movie star.
24
I don't promise you I'm going to be like him.
25
tall and handsome; I'm not quite that.
Yeah,
He's
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1
(Laughter.)
2
MEMBER POWERS:
3
MR. RAHIMI:
4
try, you know to convey the message.
5
This is on the record.
But I'll, you know, I'll
So fuel performance.
This is, it is
6
important.
And it goes back a little bit to the
7
issue of retrievability also, the reason really we
8
tried
9
retrievability.
to,
you
know,
It
redefine
was
the
because
issue
of
of
fuel
10
performance.
11
looking at the renewal, the strict language that
12
was in the regulation and the guidance we have put
13
out
14
performance retrievability had to be by individual
15
fuel.
in
Because on the renewal, when we were
the
16
ISG-2,
Revision
1,
regarding
fuel
So when we looked at it we said, Okay,
17
I mean what does that mean in the renewals?
18
they have to, licensees, go and verify, open the
19
cask, you know?
20
So that, it all went back to that.
21
all was connected really.
22
performance
23
being really the main part.
24
So
25
guess
It
The renewal and fuel
retrievability.
I
Do
for
So
the
retrievability
rest
of
the
presentation I will try to give you the big picture
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1
about,
you
2
performance
3
transportation, cask certification and dry storage
4
licensing.
5
know,
in
how
we
the
are
tackling
context
of
the
spent
fuel
fuel
Just a little bit of background.
What
6
is it about the fuel?
I mean when these casks are
7
designed, what kind of safety role does the fuel
8
play?
9
know, to confine it and protect from the fuel, are
Other than the need to design the cask, you
10
we
assigning
any
safety
11
performance for the fuel?
12
Historically,
function
the
in
safety
terms
analysis
of
for
13
both the storage cask and transportation packages
14
have relied on the cladding integrity.
15
know,
16
containment, especially under normal condition, you
17
rely for the cladding to be there.
18
rest
19
safety
20
Because the analysis that is done by the applicant
21
it assumes that the fuel, spent fuel, it is in an
22
as-loaded
23
accident condition.
to
of
confine,
the
because
structural
relies
on
that
condition
in
assembly,
to
under
First, you
the
of
And also the
the
keep
area
the
normal,
criticality
geometry.
at
normal
That's the assumption.
24
So that's what historically has been,
25
the analysis has been done that the fuel geometry
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1
does not change over, you know, 20 years, 20-year
2
period of storage with the renewal and subsequent
3
transport, something has been, that fuel remained
4
intact.
So that's your storage cask.
5
The
AS
other
you
one
can
is
the
transportation
see,
the
transportation
6
package.
7
packages have these huge impact perimeters.
8
really the main impact of those impact perimeters
9
is not only to lower the G load to the containment,
And
10
cask containment, but also to the fuel.
11
fuel typically, you will see under transportation,
12
you know, sees about 45 to 50 G loads on the 30-
13
foot drop.
14
15
And the
That's typically the G load fuel sees.
And
on
the
storage
side
is
from
the
tip-over from drop, you know, is fewer G's.
16
So, okay, what are the, under Part 72,
17
what
are
the
requirements
18
especially, you know, with regard to spent fuel?
19
So under 72, Part 72, under the normal -- we've got
20
three type of condition:
21
accident
22
there are dynamic and thermal loads that the fuel
23
sees.
24
thermal
25
loading, draining and drawing.
condition.
And
under
Part
72,
normal, off-normal and
under
those
conditions
And especially in thermal loads, the high
loads
you
see
especially
during
cask
So it's the first
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1
time spent fuel has gone from an active cooling in
2
the pool into a dry passive environment.
3
So of course the fuel is being cooled
4
enough.
That's part of the design, that can be
5
cooled
6
maintained below a peak clad temperature given a
7
passive cooling system.
8
fuel is in that environment.
9
during the when the cask is drained, you know, from
and
the
cladding
can
maintain,
can
be
So it's the first time
And generally it's
10
the pool water.
Has sort of a transient condition
11
that the fuel temperature goes up.
12
way it is designed and that we review, approve that
13
making sure that the clad temperature, especially
14
with respect to high burnup fuel, does not exceed
15
400 degrees Celsius because that assures, you know,
16
cladding integrity.
But again, the
17
And other things that the fuel, that we
18
looked at off-normal condition, what are the off-
19
normal conditions?
20
equipment,
21
failure,
22
called under Part 72 off-normal conditions.
23
know, you look at the fuel, is the fuel challenged
24
if you have a vent blockage, when it's sitting out
25
on the storage pad, how much does the temperature
Human errors, out-of-tolerance
equipment
vent
blockage,
failure,
these
instrumentation
are
the
what
is
You
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1
go up and what's the ramification on the cladding
2
integrity?
3
And,
of
course
conditions,
we
under
look
at
Part
cask
72,
drop,
the
4
accident
tip-
5
over, tornado.
6
the loads in the fuel, what loads fuel sees under
7
those accident conditions.
All these sort of are translated on
8
Now, what are the transportation, what
9
are the requirements for transportation of Part 71?
10
Part 71 we have only two categories called normal
11
and accident.
12
normal.
13
normal transport vibration that the fuel sees.
14
foot
15
condition
16
extreme ambient condition also.
17
know, minus 40 degrees Celsius and also look at
18
the, you know, hot condition, 180 degrees Celsius.
And the dynamic and thermal loads from
drop
19
We don't have such a thing as off-
is
for
considered
the
And
transportation
so
Does
part
the
the
packages.
And
is
examined,
21
integrity
22
especially the structural integrity under 30-foot
23
drop?
24
transport which is sort of a very severe and is a
25
bounding kind of condition.
are
the
maintain
the
it's
behavior.
Those
also
normal
20
and
still
the
Look at the, you
fuel
it
of
1-
structural
accident
cladding
integrity,
conditions
for
And that's the one
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1
that
they
typically,
of
course
depending
on
the
2
transportation package design we're talking about
3
50 G's that the fuel will see.
4
And also we have a what is called for
5
specific, for spent fuel packages we have a 50-foot
6
immersion
7
terms of the pressure, you know, on the containment
8
boundary, not so much on the fuel because fuel is
9
inside of containment boundary.
under
10
transport
accident
condition
in
So those are, those are the conditions
11
that
I've
summarized
12
Part 71 and 72.
13
what fuel can see inside the task.
14
MEMBER
both,
under
both
regulation
That's relating the context of
SKILLMAN:
some
don't
communication,
these
15
requirements
16
it's in Part 71 or 49 C.F.R., for the radiation
17
levels adjacent to the cask?
18
include
Why
whether
Here's why I ask that question.
When
19
we went through this for TMI we had hysteria in a
20
lot of areas.
21
people realized that those of us who were doing the
22
work had the identical concern that they had, and
23
that is our wife and children were stuck on Route
24
95 on their way on vacation and they were next to a
25
tractor-trailer that had casks.
People were just terrified.
Until
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1
So
to
the
our
question
the
4
when it became clear that the exposure levels were
5
the same as taking an airplane flight across the
6
country
7
bringing it to that level of practicality, an awful
8
lot of the fear disappeared.
beach
for
we
are
engineers who are working on this activity?
the
when
the
3
at
kids
is
exposure
sitting
and
what
2
or
wife
was,
a
And
week,
by
9
And so I'm wondering why when we talk
10
about the accident, submersion, the drop from the
11
pin, the 10-meter drop, why we don't also in the
12
same
13
levels when these casks are under way?
14
that's the piece that people think about.
15
don't
16
analytical
17
they're not that practical to the men and women for
18
whom the fear is so great.
19
So
20
context
think
talk
about
about
issues,
some
that
why
radiation levels too?
21
the
proximate
of
are
don't
these
very
we
radiation
more
Because
They
arcane
important,
talk
about
but
the
That's my question.
MR. RAHIMI:
Okay.
Yeah, I think the
22
radiation levels are explicitly, you know, written
23
in the regulation that thou shalt not exceed those
24
radiation levels.
25
For example after drop, puncture, fire,
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1
which is done in sequence, that's how we look at
2
it, that package under accident conditions, we're
3
talking
4
condition is 10 millirem per hour at about 6.6 feet
5
from the cask.
6
task going down the road.
7
limited to.
8
more than 10 millirem per hour at 2 meters from the
9
cask.
about
10
accident
condition
--
the
normal
That's your normal condition of the
And that's what they are
They cannot emit any radiation doses
So those are explicit.
They actually
11
in Part 71 are cited.
12
when we present this stuff to put it in the context
13
that the -- but normally since it is written in
14
black and white in the regulation I don't go into
15
details,
16
what the regulation states.
you
17
18
know,
MEMBER
Thank you.
19
And, yeah, it's a good idea
because
I
SKILLMAN:
would
be
repeating
Okay,
that's
fair.
Okay, that's good.
MR.
RAHIMI:
Yes.
And
under
the
20
accident condition, again, these casks are designed
21
that
22
sequentially,
23
fires,
24
They have to maintain the containment.
under
25
they
those
you
accident
know,
confine,
is
they
conditions
the
contain
drop,
their
done
puncture,
content.
And in terms of the doses are a little
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1
bit higher.
It's about 1,000 millirem at 1 meter.
2
That is for the first responders.
3
requirement is set really.
That's what that
4
So now, so spent fuel cladding I just
5
want to show, you know, because of these thermal
6
structural
7
accident
8
because the assumption is made, the analysis that
9
is
loads
under
condition,
done,
these
sort
even
of
under
that
plays
a
off-normal
role.
accident
11
those
12
and even when it's subjected to 40 to 50 G loads.
So
events,
that
maintains
has
just
its
the
geometry,
assumption
15
research was done.
16
of the research, Mike Billone from Argonne was --
17
there's
18
some evidence regarding with respect to high burnup
19
fuel -- again, high burnup is defined as any spent
20
fuel that has been
21
45 gigawatt-days per MTU.
respect
to
body
some
--
there
might
be
burned or in the core more than
45
there
23
with
24
cladding.
25
conditions, drying conditions.
Given
years
Actually, one of the examples
international
Beyond
recent
after
historically.
22
in
been
even
14
an
Then
assembly,
condition,
historically
13
fuel
And
10
sequential
the
normal,
the
that
might
be
mechanical
it
goes
some
issue
properties
through
of
these
As I said that the
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1
drying condition when you load the cask it is the
2
first
3
cooling system in the pool, but
4
this comes out enough that you desire that you can
5
withstand a passive cooling system.
time
that
the
cask
is
outside
the
active
is, occasionally
6
But during that time if the temperature
7
goes up and there are some hydrides in the cladding
8
because these are the cladding from spent fuel that
9
has been in the core for three cycles.
10
And you
have corrosions on the cladding.
11
And
some
because
of
is
produced
the
chemistry,
13
corrosion has seeped into the cladding.
14
are corrosion layers.
15
there in the form of the circumferential because of
16
the pressure inside the spent fuel rod, but when it
17
goes through the drying the temperature goes up.
18
The hydrides go into the solution core, and when
19
the
20
rod, you know, also goes up.
21
And
is
that
corrosion,
12
temperature
hydrogen
the
from
And those
When these hydrides are in
high
reorient
the
pressure
the
inside
the
from
the
hydrides
22
circumferential, which you see on the left side --
23
that's the close look at the cladding, all those,
24
those
25
circumferential, and they kind of go similar to the
are
hydrides
that
are
generally
in
the
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1
picture
2
radial.
on
3
my
right
side
which
is
they
become
And Mike Billone and others had looked
4
at this phenomena.
5
it have on the cladding integrity?
6
this radial hydrides.
7
under de-fueled cladding that has gone through this
8
process
9
recompression test.
taking
10
the
And
he
Okay, what kind of impact does
And they called
And he'd done some tests
fuel
pellets
kind
of
out.
showed
It
these
was
a
hydride
11
reorientations was a possibility that the cladding
12
may not be ductile at some temperatures.
13
lose its ductility when this spent fuel is cooled
14
and
15
direction, and of course it's sitting in the dry
16
storage
17
getting
18
temperatures that could be around that, you know,
19
between
is
this
20
phenomena that you might lose this ductility.
And
21
under
22
maintain its integrity.
the
hydrides
20
years,
ready
125,
to
150,
transport
23
reprecipitate
beyond
move
at
20
condition
the
years.
this
that
in
it
That was sort of the test.
you're
the
there
might
radial
Now
fuel,
range
It might
not
clad
sort
of
Again, this
24
was based on a laboratory test, de-fueled cladding,
25
not
really
taking
into
account
the
system
as
a
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1
whole,
the
spent
2
pellets that provides the stiffness to the entire
3
cladding.
4
spent fuel rod, taking the fuel out and doing what
5
is called a recompression test.
6
at these low temperatures kind of, sort of it's a
7
little bit brittle.
You're
fuel,
just
the
fuel
taking
a
that
--
section
of
fuel
the
And showing that
It loses its ductility.
8
So this is called the DBTT phenomena.
9
And that's what really the whole issue of the high
10
burnup is.
11
I guess this next slide it sort of, I
12
got ahead of myself.
13
that
14
condition that the fuel integrity sort of needs to
15
be
16
integrity?
when
you
considered.
It explains what I just said,
move
this
Does
it
fuel
under
still
transport
maintain
its
17
So because of that sort of issue we --
18
actually those research that was funded by NRC and
19
Argonne, some of it, and some of it by DOE.
20
then later on was funded it at Oak Ridge taking out
21
the real fuel, not just the clad fuel, the refuel
22
clad, taking the entire sort of sample of the spent
23
fuel out with fuel in it.
24
tests and Phase 2 tests that the NRC is funding
25
currently at Oak Ridge.
And
Those are the Phase 1
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1
So about a year ago so we put out, this
2
was kind of an issue, we put out some kind of a
3
guidance to the applicants.
4
address if you are coming in, because they were
5
coming in with respect to the renewal.
6
high burnup fuel they had loaded in there.
And
7
they
for
8
renewal.
9
transportation
wanted
to
And
come
also
in,
some
Okay, how would you
get
of
application,
10
fuel.
11
would they tackle this issue?
the
them
moving
They had
approval
we've
high
got
the
burnup
And they needed some kind of a guidance, how
12
So we put out a guidance in the RIS.
13
And basically what that RIS was, the draft RIS, I
14
think we presented it this last summer to you.
15
really the main thing that is the technical basis
16
for this RIS was the ISG-24 which sort of addressed
17
the storage part, and ISG-11 which was both storage
18
and transportation.
19
we have published, one was based on the testing
20
because when we started a few years ago we said,
21
okay, what if this is really, is a real issue under
22
these conditions?
And
And the two main NUREGs that
23
So while we were doing testing we were
24
pretty confident these high burnup fuels, if it's
25
looked at as a system as a whole with fuel pellet
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1
in there, they're really robust.
2
got to confirm this.
3
But we said we've
We're doing testing.
At the same time we said, okay, let's
4
do a concept message.
5
don't materialize, what we thought our theory tells
6
us?
7
and the testing.
So we both, we studied both under consequence
8
9
What if, you know, things
So those two NUREGs were published, the
consequence and the test, the Phase 1 test.
And
10
then
Oak
11
Ridge is the Phase 2 test.
12
test?
13
that really hasn't gone through that dry storage
14
transition.
15
okay, what's the behavior on that?
16
those.
what
we
are
currently
we
are
doing
at
What was the Phase 1
It's basically taking a high burnup fuel
First establish, re-baselining that:
And we tested
I will go into detail.
17
Then
the
Phase
2
we
said,
okay,
now
18
let's really enter hydrides, let's apply the same
19
test.
20
observe the behavior of spent fuel rods.
21
assimilating normal condition, vibration and even
22
static bend test.
23
condition.
Let's observe the mechanical property, let's
24
25
Kind of
Try to simulate a transportation
So we've done, right now we are waiting
for the Phase 2 test results to be completed.
We
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1
started about a week ago the first test.
2
got a few more samples to test.
3
these
4
called
5
Transportation NUREG.
6
references, the information, a good story on the
7
licensing approach, and a new approach with respect
8
to the high burnup fuel.
documents
a
is
High
going
Burnup
to
And we've
And eventually all
feed
Spent
into
Fuel
what
Storage
is
and
It's going to have all the
9
And we're currently working on the High
10
Burnup Fuel NUREG as we are getting -- because we
11
have
12
basis documents.
13
the first test results.
14
ahead to some extent that that way we are ready to
15
issue the final RIS.
16
waiting
17
progress because one area in 1927 is the spent fuel
18
aging
19
burnup fuel.
published
for
most
the
management,
20
of
the
really
the
technical
I know everyone is waiting for
And we want to sort of get
Okay?
1927
which
SRP
Because we were also
to
really
be,
actually
touches
on
to
high
So and we also wanted to wait on the
21
retrievability.
So
all
these
three
main
pieces
22
that could be consistent and go forward at the same
23
time.
24
haven't issued the final RIS yet.
25
Phase 2 tests are completed, that's the plan.
That's the reason we've waited and not -- we
But when the
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1
And
to
1927
2
version
3
we've
4
draft -- I mean final.
5
for public comment.
made
6
be
is
on
issued.
good
The,
its
And
progress;
way,
the
final
retrievability
we're
ready
to
also
issue
We already issued a draft
quickly,
so
what
was
the
ISG-11
7
and ISG-24.
8
studying the, more the criteria in terms of the
9
cladding consideration in terms of temperature, in
of
ISG-11, again it was the cladding,
10
terms
11
internal
pressure.
12
criteria
that
13
burnup fuel.
14
the
hoop
we
And
stress,
in
terms
of
Those
are
some
sort
the
ISG-11
said
in
ISG-24
is
the
the
rod
of
the
about
use
of
high
demo.
15
Basically that is the vehicle that is used on the
16
storage side.
Okay, they're ready, and they've got
17
their
for
burnup
fuel
18
beyond 20 years or for worst technical basis.
The
19
demo really is the one that is the technical basis
20
on the storage side.
renewal
21
So
I'm
the
storing
going
to
high
briefly
so
go,
I'm
22
going to talk about this before.
The NUREG-7198
23
was a test that was done at Oak Ridge.
24
consequence analysis is the NUREG-7203.
25
that as you can see the pictures on the upper-right
And the
As I said,
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1
corner, those you see the actual spent fuel rod
2
samples
3
really wanted to test the real system.
4
want to take the cladding because this is the whole
5
system.
6
stiffness for the fuel rods.
with
the
pellets
in
them.
Because
we
We didn't
And the cladding provides really a lot of
7
And those are the Phase 1 test results.
8
And I will go into that in the next slide.
9
going to go into a little bit detail in these two
10
So I'm
NUREGs and provide a little bit more information.
11
On the consequence analysis, really the
12
figure on the lower right is sort of a talks about
13
all the scenarios that we looked at which I'm going
14
to go into a little bit details on that one.
15
So based on test results was it -- it
16
was that equipment that you see the picture on the
17
right,
18
reversible-bending
19
device that went into operation with the Office of
20
Research
with
21
division
and
22
device in order to test real spent fuel samples
23
with the fuel in it.
what
24
25
is
called
the
fatigue
tester.
our
the
senior
Oak
cyclic
This
advisor
Ridge
came
integrated
here
out
was
in
with
the
our
this
And the purpose was basically, first,
how
does
the
presence
of
fuel,
the
fuel
pellet
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1
inside the clad, which is more closer to reality,
2
impact the, you know, flexural rigidity of the fuel
3
rods under vibration?
4
goal that under the normal condition of transport
5
how does it behave.
That was really the first
6
And also the purpose was how does the
7
presence of fuel impact the failure strain of the
8
cladding?
9
brittle transition.
Again, it goes back to the ductile-toNormally anything, if you saw
10
a ductile percentage strain gauge.
11
that's
12
But if the fuel rod fails, you know, around that
13
area, 2 percent, that was the, you know, failure
14
criteria.
the
indication
15
that
the
So that's the,
fuel
is
ductile.
And how many cycles to failure for high
16
burnup
fuel
17
transport condition the fuel will see a range of a
18
million,
19
wanted to simulate the normal condition vibration.
20
And so we tested for failures.
21
them,
22
cycles does it take at different G loads for this
23
to fail.
you
know,
And,
least,
For
example,
million-and-a-half
24
25
rods?
will
went
of
radial
for
in
a
vibrations.
typical
And
we
You know, some of
days
to
see
course,
the
last,
hydrides
impact
the
how
not
many
the
bending
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1
stiffness or fatigue, given all this stuff based on
2
--
3
cladding,
4
transport conditions?
now,
5
if
you
how
does
So
are
really
1
hydrides
the
behavior
the
data.
that's
Phase
have
test
in
the
change
under
see,
again,
We
6
those
results.
Again,
we
7
presented this in
8
a detailed presentation on that.
9
them is the number of cycles, number of vibrations.
details back in the summer, made
And part about
10
On the left is the strain amplitude.
11
is related to the G loads because the G loads is
12
converted to the strain amplitude.
13
Michelle would have caught it and give you then the
14
fuel
15
exact formula.
structural
engineer,
they
That really
And I'm sure
can
give
you
the
16
And we saw nicely there is a pattern,
17
there is a trend that of course if you -- some of
18
those
19
strain rates correspond really to the middle part
20
you're
21
talking about maybe 50 to 60 G loads.
22
normal
23
not, you know, at that load.
24
order of a few G loads.
25
the entire range.
strain
rates
talking
condition
I
about,
of
might
at
say
the
transport,
that
those
beginning
the
are
you're
And normally
vibration
is
It's really in the
But we wanted to look at
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1
And on the low side, meaning the strain
2
amplitude around the .1 percent, you know really
3
correspond to 10 to 15 G loads.
4
fuels,
those
5
right,
actually
6
Those are samples that failed.
7
way to failure.
8
actually
9
especially at the 10, 15 G loads.
2
are
the
the
fuels,
HBR
is
And some of the
the
acronym
the
H.B.
on
the
Robinson.
We took it all the
That as you can see, went close to
million,
up
to
2
million
vibrations,
10
And some of them did not fail at all.
11
The H.B. Robinson, those hollow squares that even
12
after
13
didn't fail.
14
those data it is not from the NRC program, it is
15
from DOE program.
16
efforts and doing the same tests on different clad
17
types.
18
that
19
funded.
20
available to us.
10
million
of
And
cycles,
phase
weeks,
then some MOX fuels, some of
DOE is continuing actually our
So they're done on the MOX fuel and LMKs
Limericks
21
But
the
fuel.
So
those
of
course
the
test
are
the
DOE
results
are
So again, the burnup for these samples
22
range
23
Certainly it was a high burnup samples.
from
24
25
they
63.8
to
66.8
gigawatt-days
per
MTU.
And the Phase 1 test we, it was a total
of
completing
four
static
tests.
What
you
are
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1
seeing, these are the -- I just put the picture for
2
the dynamic test, the vibration.
3
basically taking the sample, you know, bending, you
4
know, all the way and looking at these failures.
5
Sometimes it didn't fail, it bent all the way.
6
it's still the behaviors show the same ductility at
7
Phase 1, under Phase 1.
8
9
10
The static test
So
We haven't done that yet for Phase 2,
rearranging the hydrides to feed the same test.
We
haven't done that part.
11
And we did a total of 16 samples.
a
vibration
test
on
16
samples.
We
12
did
Basically
13
tests that we started very recently, a week, two
14
weeks ago.
15
one sample, one or more if we have more samples.
16
If we have funding, you know, we would like to get
17
more samples.
18
we have is only we have a total of four samples.
19
And so we're going to use one for static and the
20
other three for remaining dynamic tests to cut that
21
to feed the same tests.
22
next month or so we could complete those tests.
And the plan is to do a bend test on
But at this point the funding that
So we're hoping in the
23
Now, what was the consequence of that?
24
Those were, that's kind of a quick overview of the
25
tests at Oak Ridge that we've been doing.
So as I
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1
said,
in
the
2
started that we started in parallel.
3
do consequence anyway.
4
would be, if the fuel fails can the casks still
5
meet all the safety requirements?
6
meantime,
So
what
a
few
years
ago
when
we
Okay, let's
Let's see, you know, what
we
defined
basically
three
7
categories of reconfiguration.
We defined at the
8
three
complete
9
failures.
categories
And
it
was
the
deformation
is
ranging
10
contraction to the rod expansions.
11
that
cladding
from
the
And as we see
appears on the right.
12
And
we
also
the
the
axial
alignment,
that
14
respect
the
15
rods kind of are not aligned with the poisons in
16
the cask we wanted to look at the consequence of
17
that.
18
And
rods,
at
13
to
fuel
looked
criticality,
we
looked
especially
safety,
at
in
if
all
the
four
with
fuel
major
19
areas in terms of consequence: criticality safety,
20
shielding, containment and thermal.
21
at those scenarios and the impact with respect to
22
those disciplines.
23
So we looked
Again, John Scapioni last summer gave a
24
detailed
presentation
of
the
results.
25
consequence these NUREGs have been issued.
As
a
And so
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1
I just put together one slide, very summary of the
2
results what you heard back in last summer.
3
With respect to criticality, what did
4
we
see
the
5
that from those major, the major configuration --
6
we actually wanted Oak Ridge to look at the entire
7
actual spectrum.
8
terms of the fuel failure in the -- it was very
9
really
unlikely.
10
entire
range.
11
scenarios
12
criticality
13
percent increase in the fail factor.
14
we observed with respect to criticality safety.
15
analysis
But
the
safety
If
Again,
indicated
Again, some of the scenarios in
But
or
approach?
we
to
look
typically
from
credible
scenarios
you
you
wanted
would
look
at
the
see
the
at
the
plausible
less
in
the
than
5
This is what
reasonable
and
16
credible, you know, scenarios in terms of the all
17
three configuration fuel failures: complete breach,
18
bending and axial movement.
19
In the area of shielding, loss of the,
20
complete
21
reconfiguration, we saw that the surface dose might
22
go
23
doses, actually these cask vendors when they design
24
they are low.
25
push to the limit, for example 10 millirem.
up
by
loss
less
of
than
the
three
fuel
cladding,
times.
fuel
Normally
the
But some of them, you know, they
I mean
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1
they could come in with the, you know, 9 millirem
2
because these applications are really pushing the
3
margins.
4
shorter cool time?
5
Is there higher burnup, higher heat load,
So
So it's pushing.
it
is
not
unusual
to
see
the
6
situation that they are close to the regulator dose
7
limits.
8
So this is what we saw with respect if
9
we did a total fuel reconfiguration, what does it
10
mean?
And that assumption is we assume with the 25
11
percent redistribution.
12
could do other scenarios.
13
the scenarios, like 100 percent of the fuel failure
14
in one corner, you know.
15
non-credited and unreasonable scenarios.
16
is, these are the numbers that you will see for
17
credible scenarios.
18
Of course, you know, you
And we had Oak Ridge do
And those are the really
But this
In the area of containment and thermal,
19
again
allowable
leakage
20
decay-time
21
associated
22
offset by longer storage time.
23
the, if you see that the decay heat, for example,
24
that kind of situation you don't hear about the
25
cladding anymore, so what comes into play, okay,
dependent.
with
these
rate
and
So
decay
the
geometry
heat
are
consequences
changes
may
be
Which is true that
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1
are
you
still
maintaining
the
containment
seal
2
integrity if there is a concentration of the heat
3
source near the containment source.
4
But of course those can be played with
5
because you have a really flexibility with respect
6
to the cooling time.
7
leakage rate, that goes back to your question in
8
terms of we looked at the different fuel, failed
9
fuel fraction.
So with respect to allowable
Oak Ridge looked at it from .03 to
10
.10 to .15 percent.
11
numbers, as I said that the 3 percent fuel failure
12
under normal condition that we're assuming that's
13
the
14
fuel.
number
15
And, of course, some of these
was
historically
used
for
The
question
you
know,
is,
low
burnup
are
these
16
percentages, fractions, you know, is it high?
17
that's what we looked at the range from 3 percent,
18
you know, went all the way to 15 percent.
19
under the accident condition even for low burnup
20
currently what we approve, we make the applicant to
21
assume
22
containments,
23
criticality.
24
event, unlikely event, even all your fuel crumbles,
25
that
100
that
percent
not
fuel
with
failure
respect
with
to
So
And even
respect
to
shielding,
Because we want to make sure in the
overpack
will
confine
and
contain
the
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1
radioactive material.
2
So even currently now, you know, with
3
anything, you know, so 100 fuel failure, then use
4
the pressures that are released from the spent fuel
5
rod, use that as the internal pressure of the cask
6
containment
7
rate.
8
requirements under the accident condition with 100
9
percent fuel failure.
and
calculate,
you
know,
the
release
So they still have to meet the regulatory
10
Thermal:
saw
that
11
We
12
degrees Celsius, again because of the fuel failure
13
concentration
of
14
temperature,
the
15
temperature
16
Celsius within the canisters, the fuel being within
17
the canister.
18
they
basket temperature increases.
the
around
of
increase
fuel
effect
was
And,
would
course,
about
debris.
that
10
by
it
had
degrees,
that
And
the
on
the
you
depends
130
know,
on
the
19
cask design.
20
was used for this exercise it was a generic cask.
21
It was a 32 PWR and it was a metal system.
22
course is different, you know, the casks it was a
23
"Liporal."
24
from one design to another is different.
25
will
give
But typically the cask design that
The
you
heat
an
transfer
idea
about
system,
the
But of
you
range
know,
But that
of
the
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1
changes that we saw when we did the consequence
2
analysis.
3
MEMBER
SKILLMAN:
Meraj,
is
the
4
difference between the PWR fuel and the BWR fuel
5
the notion that for every single PWR assembly you
6
basically have four BWR assemblies?
7
MR. RAHIMI:
8
MEMBER SKILLMAN:
9
MR. RAHIMI:
In terms of the source?
Yes.
Yeah.
In terms of the --
10
as you well know, that the uranium content, yeah,
11
normally
12
PWR content.
13
you know, 170, 180 kilograms starting, the fresh
14
BWR,
15
kilogram uranium located in a single.
16
one to three that's what I would say.
is
generally
typically
one-third
of
the
You know, for example, you use about,
versus
you're
talking
about
450
to
500
It's kind of
17
That also when you deplete it, I would
18
say, you know, the same things in terms of source
19
strength.
20
because, you know, looking at the uranium content,
21
initial loading, normal PWR is two to three times
22
more initial uranium per assembly than compared to
23
BWR.
I
would
say,
you
know,
three
to
one
24
But, of course, you put more BWR in the
25
cask, the same diameter cask that they use, let's
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1
say
37
PWR,
same
diameter
2
assembly.
3
88, 89 in an assembly.
you
can
up
to
89
Those these vendors, you know, they fit
4
So
in
terms
of
the
source
then,
the
5
overall source then is equivalent at 89 BWR versus
6
37 PWR.
7
So
what
is,
this
is
the
big
picture
8
what is our next step, is our goal is to issue the
9
final RIS, you know, by the end of this calendar
10
year because our folks are working hard.
11
should
12
working on this, Michelle Bales, HUDAB, you know,
13
Ricardo, David Tang.
14
Burnup
15
hard, first, making progress on the NUREG.
acknowledge
Task
16
really
the
people
And I
that
are
There's a whole team, High
Force.
But
they're
really
working
Then we were at the point that we can
17
put
the
drafting
reg
to
be
issued
for
public
18
comment, at that time we want to issue the final
19
RIS.
20
issue those documents.
21
same dates that Mark put up.
And those are the dates that we have plans to
22
So
that
And I think those are the
was
a
quick
overview
so
in
23
terms of high burnup.
I'm sorry, maybe you wanted
24
more details, but we will be more than happy to
25
brief that, you know, go into, if you want, more
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1
detailed discussion on any part of this area on the
2
tasks we've done, on the consequence analysis.
3
will
4
information, details especially.
be
more
than
happy
5
MEMBER SKILLMAN:
6
MR. RAHIMI:
to
provide
And those are references
that I cite throughout my presentation.
8
the acronyms.
And
let's
see.
Oh,
I
Those are
had
a
10
back-up slides about RIS.
11
it's about a licensing approach flow chart.
12
the other one, transportation.
13
14
any questions, any more questions.
16
MR. RAHIMI:
17
CHAIRMAN BALLINGER:
18
MR. CHUNG:
19
CHAIRMAN BALLINGER:
Thank you.
Thank you.
Next.
Hello.
All the way at the
bottom.
21
MR. CHUNG:
All the way at the bottom.
Thank you, it's on.
23
24
So is
And I will be more than happy to answer
CHAIRMAN BALLINGER:
22
couple
That's what the RIS is,
15
20
more
Thank you.
7
9
We
CHAIRMAN
BALLINGER:
As
long
as
the
green light's lit.
25
MR. CHUNG:
Yes, the green light's lit.
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1
Thank you.
2
MR.
3
presentation
4
presentation.
RAHIMI:
here?
Let
5
MR. CHUNG:
6
CHAIRMAN
7
So
where
me
is
pull
All right.
BALLINGER:
Donald's
up
your
Wonderful.
Ah.
I've
been
waiting for this.
8
BUILDING A RISK FRAMEWORK FOR DRY STORAGE
9
MR. CHUNG:
Good afternoon, everyone.
10
My name is Donald Chung.
11
risk analyst.
12
Meraj in the Office of Nuclear Material Safety and
13
Safeguard.
14
I joined the NMSS about a year ago.
15
I
16
Assessment,
17
process, notice of enforcement discretion, effects
18
of regulation.
19
few years at TMI on the clean-up project.
spent
I currently work for, I work for
I'm a new player on the Storage Team.
ten
years
in
doing
NRR,
Prior to that
Division
significant
of
Risk
determination
And early in my career I spent a
20
Next slide.
21
Again,
22
I'm a reliability and
we're
doing
storage.
And
I'm
going to be talking about risk-informed storage.
23
CHAIRMAN
24
paper off the little thing there.
25
BALLINGER:
MR. CHUNG:
Oh yes.
Try
Yes.
to
keep
the
Thank you.
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1
2
CHAIRMAN
Otherwise
the
court recorder will go nuts.
3
4
BALLINGER:
MR. CHUNG:
Yes.
Thank you.
Thanks,
Chief.
5
A little background.
This is probably
6
very obvious to most of you.
7
longstanding policy on increasing use of PRA risk
8
approach.
9
The Commission has a
The risk-informed decisions extensively
10
used in reactor oversight and licensing.
11
reactors,
of
12
based
core
13
release.
14
have core damage frequency or large early release.
on
course,
PRA
damage
modeling
frequency
and
And in
insights
large
are
early
Of course, looking at spent fuel we don't
15
Next slide, please.
16
As mentioned earlier by Meraj, there's
17
been two PRAs done.
These were done roughly 10,
18
10, 14, 15 years ago.
19
one's by EPRI.
20
we go forward.
One's by NRC, the other
And I will mention more on these as
21
Go to the next slide.
22
Again, spent fuel is not the same as
23
reactors.
24
figure
25
Assessment for Five U.S. Nuclear Power Plants.
from
If
you
look
NUREG-1150,
on
the
Severe
right,
Accident
that's
Risk
a
and
And
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1
if you look on that figure, on the top you see
2
safety
3
plants:
4
Zion.
goal
and
then
you
see
the
bars
for
five
Surry, Peach Bottom, Sequoyah, Grand Gulf,
5
On
the
left
you
have
the
two
PRAs.
6
These
are comparison of the latent cancer risks
7
from reactors and from dry storage.
8
see, the two PRAs indicate that the latent cancer
9
risks are roughly four orders of magnitude than for
As you can
10
reactors.
And the red dot on top, of course, it's
11
a level of latent cancer risk that's accepted under
12
the
13
times E to the minus 6 cancer fatalities per year.
Commission's
safety
goal
policy,
which
is
2
14
Next slide please.
15
Boss talked about the paradigm change.
16
And basically what has changed since the last PRAs
17
were done 10, 15 years ago, the first of course is
18
increased
storage
duration
19
And
of
things
20
concern with aging effects, chloride-induced stress
21
corrosion
22
manufacturing defects.
23
canister misloads that we weren't aware of or at
24
least wasn't covered in the two earlier PRAs.
some
25
the
cracking.
We
for
we're
have
beyond
aware
new
20
years.
of
now
information
is
on
We have data on spent fuel
We have additional data on human error
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1
doing cask preparation.
2
also have historical data from the last 20 years.
3
And in the last 20 years there hasn't been a known
4
canister
5
ISFSI and had to be brought back for repair.
6
single one has failed.
7
dry cask storage systems out there.
8
some historical data that we didn't have before.
failure,
9
canister
that
was
placed
on
Not a
And there's been over 2,000
So we have
Next slide, please.
10
11
a
In addition to that we
Why do we want a risk-informed dry cask
storage?
Here's the objectives:
12
One
is
to
13
regulatory
efforts.
14
changes in risk.
15
anymore,
16
years,
17
change.
18
will be aging effect.
have
Be
better
focus
prepared
to
on
our
evaluate
We're not looking at 20 years
we're
looking
at
renewal
possibly
over
100
years.
looking
Things
at
60
will
There will be environmental effect, there
19
It would be nice to have a system in
20
place where we can evaluate changes in the risks
21
we're facing, even though the risk right now is
22
very low.
23
Again, we want to establish a decision
24
metric.
We're proposing to use confinement breach,
25
confinement breach of the canister.
If it is a
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1
dual-purpose cask, it will be the cask.
2
We will look at confinement breach as
3
comparable
to
4
damage
5
consequence
6
proposing.
what's
frequency.
7
used
We
in
will
measurement.
Again,
if
reactors
PRA
at
use
that
That's
what
results
core
as
a
we're
continue
to
8
indicate very low risk, as what we're seeing right
9
now
for
storage,
10
examine
11
requirements.
12
term
criterias
storage,
for
dry
staff
will
storage
re-
safety
We'll see as we go forward.
Okay.
In terms of phases of operation,
13
you have four phases of operation.
14
cask/canister
15
basically typically taking the fuel, you're putting
16
it into a canister in the pool.
17
you dry it, you weld it.
18
overpack.
19
Sits out there.
20
to transfer it.
21
loading
and
There's the
preparation.
This
is
You take it out,
You put it into a storage
The crawler takes it out to the ISFSI.
And then eventually you may have
Now, what has changed in the paradigm?
22
What
has
changed,
basically
the
last
two
steps,
23
step 3 and step 4.
24
it doesn't go anywhere, it doesn't move and no one
25
touches it for 20 years.
Before when you put it on ISFSI
Well, for license renewal
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1
things are going to be different because license
2
renewal requires periodic inspection.
3
And I want to point something out to
4
you.
If you look on the figure, it shows ISFSI and
5
the
6
sitting?
7
the ISFSI, the concrete pad, where do they start
8
putting it?
9
to the next end.
packages
on
there.
See
how
close
they're
When you put dry cask storage units on
They don't start from one end and go
That's not how they do it.
10
start from the middle.
11
may tilt over the years; right?
12
They
Because otherwise the ISFSI
So they start form the middle and they
13
go
outwards.
Now,
if
14
inspection, which one are you going to look at?
15
Are you going to look at the newest one out there
16
which is on the end?
17
one that's in the middle; right?
18
to do that?
19
in the middle.
No.
you're
going
to
do
an
You want to look at the
How are you going
That crawler can't pick one up that's
20
So if you do inspections there's a good
21
chance that you will have to move canister, you
22
have to move those packages.
23
to lift them up.
24
inspection.
25
You
You're going to have
So there is risk associated with
know,
in
reactors
we
have
risk-
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1
informed ISI, we have various things that's done in
2
terms
3
storage
4
there's opportunity for lifting.
5
associated with that.
6
ISFSI and not moving it has very, very low risk.
7
If you're lifting it, there's a chance that that
8
cask can drop.
9
are.
of
risk.
you
10
11
If
have
you're
risk
looking
opportunity
at
long-term
for
handling,
And there's risk
Setting it out there on the
And that's where your biggest risks
CHAIRMAN BALLINGER:
So are you saying
--
12
MR. CHUNG:
Go ahead.
13
CHAIRMAN BALLINGER:
-- that the risk-
14
informed approach would avoid you having to do the
15
inspection?
Because that's the lowest risk --
16
MR. CHUNG:
17
CHAIRMAN
18
Well, what would happen -BALLINGER:
--
that
you're
talking about.
19
MR.
CHUNG:
Well,
that's
a
good
20
question.
One example is what we do for reactors,
21
risk-informed ISI; right?
22
you could say, okay, now we're doing an inspection
23
that requires moving ten casks.
24
buying us?
25
reduction?
You could look at it and
Now what is that
Is that buying us significant safety
Maybe we don't want to do it every five
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1
years.
Maybe we want to do a sample and maybe we
2
want to do a sample every seven years.
3
You
could
do
an
evaluation
of
4
you're gaining in terms of risk reduction.
5
one of the considerations.
6
Do you have a question, sir?
7
MEMBER SKILLMAN:
8
MR. CHUNG:
9
MEMBER
10
That's
I do.
Go ahead.
SKILLMAN:
I
was
waiting
for
Ron.
11
MR. CHUNG:
12
MEMBER
13
what
Okay.
SKILLMAN:
Can
we
back
up
a
slide?
14
MR. CHUNG:
15
MEMBER SKILLMAN:
That
Sure.
16
Great.
17
discussion.
"Staff could re-examine criteria for
18
dry
safety
19
what?
storage
20
seems
like
Your fourth bullet.
spent
a
22
reorientation.
23
storage,
24
important?
25
lot
in
of
terms
place
For
for
example
For example, you know, we
time
Is
true
requirements."
MR. CHUNG:
21
a
talking
that
of
really,
storage
MEMBER SKILLMAN:
about
is
in
hydride
terms
that
of
really
Probably not.
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1
MR. CHUNG:
2
Well,
for
shipping
Yeah, probably not.
what
3
But
4
transportation
5
storage it might not be.
6
it
it
we
decided
might
might
be
be
on
eventually.
important.
important.
MEMBER SKILLMAN:
For
But
for
That seems to be a
7
very -- that's a good answer but it's a very narrow
8
answer.
9
MR. CHUNG:
10
Yes, sir, it is.
MEMBER SKILLMAN:
It seems like there
11
are, more like there are much broader implications
12
that this might present to industry that could be
13
huge savings because these containers are massive,
14
they are strong, they are passive.
15
MR. CHUNG:
16
MEMBER
themselves.
Right.
SKILLMAN:
to
impervious
to
18
vermin.
It seems that this could lead to some real
19
benefits
as
20
material will remain on the ISFSI pad for a long
21
time.
we
almost
happy
cool
as
are
are
17
long
They
They
hold
22
MR. CHUNG:
23
CHAIRMAN BALLINGER:
24
the
idea
that
this
I agree with you.
Let me expand on
that again.
25
MEMBER SKILLMAN:
Sure.
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1
2
CHAIRMAN
BALLINGER:
Right
now
1927
doesn't allow for this.
3
MR. CHUNG:
No, it doesn't.
4
CHAIRMAN BALLINGER:
Okay.
And I was
5
asking Al what prevents a licensee from doing this
6
in
7
prevents a licensee from coming to you and saying,
8
I have this ISFSI out here and I want to renew the
9
license but I want to use probabilistic -- I want
a
risk-informed
way
to
start
10
to take a risk-informed approach.
11
can't do that.
12
13
MR. CHUNG:
CHAIRMAN BALLINGER:
17
CHAIRMAN BALLINGER:
Right.
MR. CHUNG:
20
CHAIRMAN BALLINGER:
Right.
And I'm saying is
that your intention --
22
MR.
CHUNG:
It's
a
possibility
going
forward.
24
25
The third, fourth
dot.
19
23
Well, I'm looking
at that dot there.
MR. CHUNG:
21
Right now they
We're in an embryonic phase
16
18
What
of something.
14
15
with?
CHAIRMAN BALLINGER:
-- or is that a
possibility?
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1
2
MR.
a
CHAIRMAN BALLINGER:
possibility
going
Okay.
Possibility
as opposed to intention.
5
6
It's
forward.
3
4
CHUNG:
MR. CHUNG:
PRAs.
Right now we don't have the
We don't have, we don't have the data.
7
MR.
the,
RAHIMI:
yes,
we
are,
Yeah,
8
That
our
9
really go one way or another.
let
me
intention
add
is
this.
not
to
We are approaching
10
this with an open mind.
11
resources.
12
there's a really safety issue, you know, in terms
13
of coming over the criteria requirement.
14
is our approach.
And
this
We say we've got limited
focus
of
resources
where
So that
15
In some areas it might be, you know,
16
the numbers might show, oh, this is a high-risk
17
area and we have to increase it.
18
the scheme of things it might make a difference,
19
but really we need to lower our criteria.
20
CHAIRMAN BALLINGER:
In some areas, in
So starting from
21
10 to the minus 14.
22
don't -- that's not even on my calculator.
23
even set --
24
25
MR. CHUNG:
So that's a number which I
I can't
We haven't been on Earth
that long; right?
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1
MR. RAHIMI:
So 10 to the minus 14,
2
again, those actual studies that were done there
3
was
4
experience.
--
5
6
really
much
operating
Yeah, I will get into that.
CHAIRMAN
BALLINGER:
Well,
but
MR. RAHIMI:
No, no.
Twenty years, 20
years history we have.
CHAIRMAN BALLINGER:
12
MR. RAHIMI:
Okay.
The phenomena that wasn't
stress corrosion cracking at that time.
14
CHAIRMAN
BALLINGER:
Well,
stress
15
corrosion cracking existed since Roman times.
16
--
17
18
MR. RAHIMI:
I know.
But
But in terms of
with respect to the dry storage --
19
20
the
operating experience is zero failures.
11
13
that
That's right.
9
10
wasn't
MR. CHUNG:
7
8
there
MR.
CHUNG:
Maybe
it's
better
if
we
answer the question that they're asking.
21
MR. RAHIMI:
22
MR. CHUNG:
23
MR.
I think so.
I think so.
RAHIMI:
Yeah.
But
I
think
it's
the
24
important part that they know why we are doing this
25
study.
If we keep saying that this is 10 to the
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1
minus 14, 10 to the minus 13, yes, those studies
2
were
3
components.
4
they did those numbers.
5
experience that we have in terms of the loading
6
mis-loads.
done
without
two
main
And the more operating
So that is the reason.
CHAIRMAN
BALLINGER:
Okay.
But
my
question is why not do that?
9
MR. RAHIMI:
10
11
the
Aging was not a factor included when
7
8
incorporating
That's what we're doing.
CHAIRMAN BALLINGER:
Well, you said a
possibility.
12
MR.
CHUNG:
Well,
we're
in
the
13
embryonic phase.
14
we have the funding to get labs to do research for
15
us.
16
their ISFSIs.
17
there right now.
We
18
19
don't
We haven't got to a point where
have,
plants
don't
PRAs
for
There's very limited information out
MR. CSONTOS:
Let me -- can I distract
you over here?
20
NUREG-1927,
21
this.
22
something now.
Okay?
Rev.
1
does
not
preclude
What we've done is we have to do
23
CHAIRMAN BALLINGER:
24
MR. CSONTOS:
25
have
that have to be done now.
Right.
Okay.
Okay?
We have renewals
And we did do a
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1
qualitative risk informing through the staff to do
2
what we believe is reasonable.
3
We're not asking for inspection of all
4
2552 canisters that are out there.
5
looking at a very small, small subset to assess
6
whether or not there is significant degradation or
7
not, and to assess whether or not we need to go to
8
a
9
okay.
10
full
quantitative.
Because
is
expensive,
well in the funding arena.
CHAIRMAN BALLINGER:
12
MR. CSONTOS:
2020.
So what we have here is
we've got to do something.
14
15
it
We're
And NRC right now not, we're not doing so
11
13
Okay?
CHAIRMAN
BALLINGER:
Well,
you
have
your budget but they have their budget.
16
MR.
CSONTOS:
We've
got
to
do
17
something.
And I think that's what -- I don't,
18
1927, Rev. 1, you'll see it tomorrow, is a learning
19
process.
20
it's talking an operations-focused approach.
21
We're not going to be risk-based, we're going to be
22
risk-informed.
23
and
24
right now.
25
the operational experience and we'll move forward.
Okay.
that's
It's offering a risk -- basically
Okay.
We'll really be informed by, okay,
why
we're
Okay?
not
asking
for
everything
We're going to get and assess
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1
And how we move forward it may be a
2
full PRA.
It could be other things.
All right?
3
We're just setting the stage for what's going to
4
happen going down the road.
5
say, make points of preclusion.
6
correct.
7
options going forward because that's why we call it
8
an operations-focused approach.
9
CHAIRMAN BALLINGER:
So I don't want to
That wouldn't be
I would say that it's open to a lot of
10
MR. LOMBARD:
referenced
If I could go back also,
11
Don
12
require lifting a system.
13
inspection I could think of now that would require
14
lifting a system, that's during the inspection of
15
the underside of the system itself to see if there
16
is any degradation of the bottom.
17
So
the
Good.
fact
there
that
inspections
would
And there is only one
is
many,
many
other
18
inspections that need -- that would be, probably be
19
done under the aging management program, and they
20
would not require lifting a system.
21
that in perspective.
So just to put
22
When we started down this path over a
23
year ago, our intention was and still is to risk-
24
inform
25
oversight actually, you know, not just a regulatory
the
operations,
storage,
regulatory
and
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1
piece, not just a licensing piece, but inspection
2
and oversight as well.
3
to come up with a regulatory framework that would
4
provide some benefits.
So I think there still is
5
But as Meraj said, I mean as you go
6
through this you might find there is or many areas
7
that you can do less in, and there might be some
8
areas you might want to do more in based on the
9
qualitative risk-informed.
We had intended to do
10
PRAs or require PRAs on every single system.
11
don't
12
industry.
13
qualitative approach that we could apply building
14
this risk framework to then look at the systems and
15
move forward and within our storage framework.
want
16
17
to
put
that
We
are
trying
CHAIRMAN
burden
to
on
us
or
come
up
with
BALLINGER:
Any
We
the
a
other
questions?
18
MR. CSONTOS:
The
Let me just say one more
19
thing.
risk-informed
20
for
the
reactor
site
handles
21
cladding
systems
that
really
22
safety.
23
you, and you try to look at CDF, okay, I bet you
24
it's really, really low as well.
25
doing
Okay?
a
ISI
inspection
certain
don't
program
of
much
to
do
types
And if you take a look at that and
risk-informed
sampling
Okay?
approach
And so
is
the
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1
approach we're taking there.
2
with what the risk-informed ISI program and the Reg
3
Guide is all about.
4
Have
we
got
to
And that's in line
a
quantitative
5
informed ISI metric yet?
6
here is we're using that same principle.
7
why
8
doing is risk-informed here.
I'm
saying
it's
No.
Okay.
10
these things that we're doing.
11
What we're doing
risk-informed.
9
risk-
That's
What
we're
So just please be aware of all
CHAIRMAN
BALLINGER:
You
know,
it
12
really -- excuse me -- you look at these -- It's
13
on.
14
You
look
at
these
massive
things
and
15
you haven't had any failures.
16
I'm just listening to this stuff here since I'm not
17
a
18
sounds
19
vogue and the fad to do risk-informed analyses for
20
a
21
nothing,
22
without extreme risk.
23
look
24
which is more risk than doing nothing.
risk
guy.
And
like
you're
piece
of
25
just
doing
equipment
sits
inside
I'm
there.
of
them
I mean it almost --
wondering,
risk
that
You
because
goes
can't
it
almost
it's
nowhere,
take
it
the
does
apart
And they're -- you can't
without
taking
them
apart,
And so I just, I'm just sitting here
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1
looking at everybody's yelling about resources and
2
money, and it just almost seems like, I don't know,
3
it's like when you're playing poker and you keep
4
throwing money in.
It's bad money after good.
5
MR. CHUNG:
6
CHAIRMAN
bad.
That's
Good money after bad.
BALLINGER:
7
after
8
Show you how my brain's fried.
9
good.
Or
Thank
good
you
money
very
much.
But I mean and you talk about how you
10
have to move all these canisters around.
11
ways
12
oldest
13
canister that you've ever had.
14
that you don't have to move anything.
15
there and watch it, whatever it does, and if it
16
crumples then you've got one answer, and you don't
17
have a big -- so I, I'm just, it just kind of
18
boggles my mind that we're really now applying PRA
19
to something that is older than the universe.
to
load
and
20
a
pad
without
grungiest,
MR. CHUNG:
you
having
know,
move
the
container
or
You don't have, so
You just sit
I totally agree with you.
21
But let me finish the presentation.
22
-
23
to
There's
CHAIRMAN BALLINGER:
24
let you.
25
That goes without saying.
We'll finish -
Oh, we're going to
We know you'll finish the presentation.
I just -- go ahead.
I
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1
just wanted to make that observation.
2
the wrong direction, so.
3
4
MR. CHUNG:
We got going
Okay, doing the PRA, we'll
go back to a little bit on the safety function.
5
Basically you have spent fuel sitting
6
in,
typically
in
a
7
function that's required you have basically three
8
safety
9
release
functions.
of
10
canister.
11
release.
canister.
One
is
radioactive
And
to
the
safety
protect
material.
against
That's
the
The canister provides protection against
Okay?
12
And by protecting against release you
13
also protect against criticality.
14
water
15
criticality.
in
16
the
canister
Because without
you
will
not
have
Okay?
And
also
Again,
protection
exposure.
18
material spent fuel particulate isn't coming out of
19
the canister, you're pretty well protected.
20
know, you have the concrete overpack that provides
21
a lot of radiation shielding.
22
failure
23
greatest concern.
24
having
25
getting in and particles getting out, you basically
that
the
long
canister
as
the
radiation
17
of
as
against
radioactive
You
If you don't have
you're
--
that's
your
Having that canister in place,
canister
protecting
against
water
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1
fulfill most of your safety functions.
2
Next.
Going
3
defense-in-depth.
This is not a reactor.
4
fairly
You
5
prevention.
6
material,
prevent
7
exposure.
And that's being covered by C.F.R. 72,
8
CoC, standard review plan, and MAPS.
simple.
back
have
to
Level
1
basics,
is
It's
basic
It's to prevent release of radioactive
9
criticality,
limit
Level 2 is mitigation.
a
the
whole
lot
to
Again, there's
10
not
11
passive
12
being stored.
13
lot of -- you're not going to have a core melt,
14
you're not going to have your type accidents you
15
can
16
significant
17
storage system you have a very robust construction,
18
dry cask storage system, as you pointed out.
19
Level 2 is fairly simple.
system,
have
passive
here.
nature
of
This
the
reactors.
dispersion
There's
21
again,
22
emergency plan.
23
license
24
emergency
25
emergency.
you
a
material
mechanism.
lack
threat's
have
plan:
in
C.F.R.
of
Again,
Level 3 is emergency actions.
the
is
You not going to have a, you know, a
with
20
mitigate
radiation
72,
a
your
So
This is,
adhering
to
For ISFSI if it's a general site
basically
you
have
two
levels
alert
and
for
site
the
only
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1
And
for
ISFSI
that's
away
from
a
2
reactor all you have is alert.
There is no, there
3
is no evacuation in the emergency plan.
4
is because you don't have the type of dispersions
5
you have with reactors.
The reason
6
Since I came from the reactor world I
7
didn't know anything about dry cask storage system.
8
And I will share what I learned with you.
9
Basically
there
are
three
types.
10
There's the vertical above-ground system.
11
could be generalized into the HI-Storm 100 which is
12
on the right.
13
stainless
steel
14
overpack.
That's the one on the right.
15
And they
Again, that's a canister, welded
On
canister
the
left
sitting
is
a
in
a
concrete
dual-purpose
cask.
16
This is a carbon steel bolted system.
17
the hub steel cask is a double-gasket system, kind
18
of
19
monitored.
20
the
21
change in pressure they will
22
The
welded
system
Both
systems
are
23
like
two
the
vessel.
So
it's
actually
They could monitor the space between
gaskets.
If
there's
a
leak,
there's
a
is
no
know.
there
monitoring.
24
25
reactor
The lid on
convection.
cooled
by
natural
The one on the right you see there is
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1
an opening on top.
2
bottom.
There's also an opening on the
Natural circulation cools the canister.
3
Okay.
The
PRAs
that
were
done,
NRC
4
evaluated the HI-Storm 100, which is the concrete
5
overpack one on the right.
6
on the left which is the TN, TN system.
EPRI valuated the one
7
Next slide please.
8
One
system
that's
much
more
popular
9
today, I guess partially because it's less costly,
10
is the NUHOMS system which is a horizontal system.
11
Again you have that canister.
12
The world of stainless steel canisters
13
also
refers
14
canister.
15
a concrete boat or concrete storage module.
16
this is, it's cooled by natural circulation.
17
have an opening on the bottom.
18
there's
19
natural circulation.
20
very robust.
21
vertical.
22
to
in
many
places
a
multi-purpose
The canister is stored horizontally into
an
air
opening
on
top
please.
24
secured UMAX.
25
that's
You
Air goes in and
that's
cooled
by
The system is, again, it's
The canister is horizontal instead of
And then there's a third system.
23
Again
This is a HI-Storm UMAX.
Next
HI-Storm MAX and
This is a canister sitting in a silo
underground.
It
has
some
advantages,
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1
obviously.
2
terrorists, but it has some practical issues such
3
as it's probably more difficult to inspect.
4
want to look at whether there's a corrosion of the
5
liner, what have you, I'm not sure how you're going
6
to do it.
7
8
There's
less
of
a
target
area
for
If you
Again, there hasn't been much study on
these.
9
Go ahead again, please.
10
Proposed
Okay.
risk-informed
regulatory
11
framework.
Again we're, I'm looking at this from
12
my reactor background.
13
whether it's BWR, PWR, whatever type of reactor,
14
I'm looking at a framework that would apply to all
15
dry cask storage systems.
You know, it doesn't matter
16
Okay, next.
17
Okay,
and
proposing
confinement
19
risk.
20
storage,
21
your confinement.
22
credit to cladding.
The overpack has openings for
23
natural
so
24
confinement.
It's
the
frequency
basically
canister
as
when
metric
for
you're
looking
at
that
canister
is
systems,
Okay, the clad, we're not giving
circulation
they
don't
It's the canister.
The
the
adopting
18
25
breach
I'm
dual-purpose,
of
provide
any
Okay.
course,
is
hard
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1
steel, it's one layer, 6-inch thick.
2
one layer.
3
that we use as the metric.
4
It's that's
So the confinement is what I propose
And
also
Okay.
we
propose
to
set
a
5
confinement breach frequency limit for storage in
6
ISFSI.
7
what they evaluate is one canister sitting out on
8
the ISFSI.
9
for exactly one canister.
The two PRAs that are available right now,
Okay.
The 10 to the minus 14, that's
10
Now, if you go to the ISFSIs that are
11
out there today, there are 60 ISFSIs, a lot of them
12
have 40, 50, 60 dry cask storage units out there.
13
And if we look at interim storage in Texas or New
14
Mexico,
15
several thousand storage systems.
16
you're
looking
at
possibly
a
field
of
So but then if you look offsite for one
17
of
these storage areas you want to know what your
18
risk is, regardless how many canisters that are out
19
there.
20
the road you want to know what your risk is, not
21
what your risk is based on the number of canisters
22
being stored.
23
24
Right?
If you're living five miles down
So I think it's good to set a limit for
the entire ISFSI.
25
And
Makes sense.
then
we
would
like
to
propose
a
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1
risk-informed regulatory guidance, basically a risk
2
metric,
3
compare risk.
4
these things in the following slide.
a
5
risk
metric
that
will
allow
you
to
And I will talk about all three of
CHAIRMAN
BALLINGER:
So
confinement
6
breach is the metric, what Al would say would be we
7
want zero perforation of the canister.
8
9
MR.
mean,
yes,
we
CSONTOS:
would
with
the
like
It
really
to,
Right, Al?
depends.
I
you
know,
stay
in
regulations,
which
10
compliance
is
the
11
confinement function that's being maintained.
Of
12
course, you know, we'll have to see.
13
always treat ISFSI as like a disease, you know.
14
Let's see if we have it first before we go, go off.
You know, I
15
If we see we have a disease, then let's
16
go off and figure out what we're going to do about
17
it.
18
some doctors say "don't do more harm."
19
we find out that the risk to the workers to do all
20
this remediation work is more harmful than leaving
21
the crack in there, okay, and that's the time to do
22
some sort of risk analysis on this, then that's the
23
time when we'll have to think about this.
Whether or not, you know, there is you have
24
25
But
as
of
right
now,
the
Okay.
ideal,
If
the
situation is what the regulations state which is
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1
that
the
confinement
2
maintained.
3
the aging management programs at a small level.
4
function
to
be
And that's what we're trying to do in
MR. LOMBARD:
risk
needs
analysis
5
A
6
alluding
7
you'd know what the consequences are at the end,
8
just to be clear.
to,
9
means
So let me just clarify.
in
probability
MR. CHUNG:
11
MEMBER
12
little bit.
13
follow.
POWERS:
15
MEMBER POWERS:
Al
was
consequences.
So
Right.
Can
we
come
back
a
Okay.
That said, okay, if I'm
out in New Mexico --
17
MR.
CHUNG:
I'm
sorry,
you
have
to
in
New
speak up a little bit.
19
MEMBER
POWERS:
You
were
out
Mexico and you had thousands of canisters.
21
22
as
You had a discussion I didn't quite
MR. CHUNG:
20
case,
Any other questions?
14
18
and
CHAIRMAN BALLINGER:
10
16
this
MR. CHUNG:
a closed system.
23
Canisters.
Right, you have
Right.
MEMBER
POWERS:
And
then
you
said
24
something to the effect you wanted to limit the
25
number of canisters?
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1
MR. CHUNG:
No.
We have a Commission
Right?
And that's according
2
safety goal policy.
3
to that policy it defines what's negligible risk.
4
According
5
fatality for the general population near a nuclear
6
facility
7
percent.
to
should
8
9
no
more
the
than
latent
cancer
one-tenth
of
1
I'm familiar with your
-MR.
CHUNG:
You're
familiar
with
the
policy.
12
13
be
policy,
MEMBER POWERS:
10
11
that
MEMBER
POWERS:
--
productivity
procedures.
14
MR. CHUNG:
No, that policy does not
15
state on your site whether you have one reactor,
16
two
17
Basically what I'm saying is that the same thing
18
should apply here.
19
or 1,000 canisters, your risk all sites should be
20
the same.
reactors,
21
three
reactors
or
four
reactors.
Whether you have one canister
If you live near a ISFSI, you should be
22
exposed
to
negligible
23
according
basic
policy
24
regardless how many canisters are there.
Right?
25
Does that make sense?
to
the
risk,
negligible
Commission's
risk
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1
2
MEMBER POWERS:
things I can pick on here about this.
3
4
MR. CHUNG:
I'm sorry, Dana, I can't
hear you.
5
6
MEMBER
POWERS:
There
are
lots
of
things I can pick on here is policy is not law.
7
MR. CHUNG:
8
MEMBER POWERS:
9
MR. CHUNG:
10
11
Well, there are lots of
Policy is what?
Policy is not law.
Yes, you're right.
MEMBER POWERS:
And so I can quibble
with you there.
12
The next question that I have is have
13
you identified mechanisms by which you would get
14
concurrent failure of canisters?
15
MR. CHUNG:
16
MEMBER POWERS:
And those are?
17
MR.
Some
CHUNG:
earthquake, toppling over, toppling canisters over.
20
Those are not going to involve just one canister if
21
you
22
imagine a plane hitting an ISFSI with 100 casks and
23
only strikes one.
24
you
25
involve multiple canisters.
have
an
of
they
a
include
thousand.
plane
are
19
field
PRAs
that
evaluated
a
the
actions
18
have
in
Yes.
It's
crash,
hard
That's kind of hard to see.
accident
like
that
you're
going
to
If
to
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1
If
you
have
an
event
that
caused
2
toppling, what caused one canister to topple will
3
likely cause other canisters to topple as well.
4
MEMBER POWERS:
5
MR. CHUNG:
6
MR. LOMBARD:
But it has to fail.
That's correct.
If I could be clear, some
7
of these scenarios were looked at after 9/11.
8
don't know if you all were privy to any of those
9
presentations.
10
11
MEMBER POWERS:
Well, I want to stay
away from the --
12
MR. LOMBARD:
13
MEMBER
14
Security?
POWERS:
--
security
issues
Because
that's
right now.
15
MR. LOMBARD:
16
MEMBER
POWERS:
Yes.
excluded
from
17
explicitly
18
safety policy statement.
19
MR. LOMBARD:
20
MEMBER POWERS:
21
from that.
22
crash or an earthquake.
the
safety
policy
pool,
Right.
So we want to stay away
We're talking about an accidental plane
23
MR. LOMBARD:
24
MEMBER POWERS:
25
I
Right.
Okay.
So what is the
probability that an earthquake topples a bunch of
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1
canisters and the canisters fail?
2
3
MR.
CHUNG:
probability
of
an
earthquake toppling any canister is very low.
4
MR.
LOMBARD:
5
actually
6
over.
7
they're not to fail.
designed
against
And
a
the
systems
non-mechanistic
are
top-
If they were to fall over they're, by design
8
9
The
MR.
scenario.
CHUNG:
But
let
me
give
you
a
There was a previous slide where I show
10
a field of dry cask storage systems.
You notice
11
how close they fit?
12
have to do an inspection and you have to lift one
13
of these things up and you accidentally drop it and
14
it tips over, there's a good chance that it will
15
bump into the next dry cask storage system; right?
If you have a lift, if you
16
MEMBER POWERS:
17
MR. CHUNG:
Yes.
I'm not saying that you're
18
going to have a domino effect, but potentially you
19
can have multiple canisters impacted.
20
21
MEMBER POWERS:
that
But it's not evidence
it causes the canister to fail.
22
MR. CHUNG:
23
can talk about the question, sir.
24
I'm
25
presentation.
going
to
address
Well, let me go on and we
some
Because I think
of
that
in
the
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1
MEMBER POWERS:
2
what you're saying.
3
to do.
4
Well, at least I know
And that's all I really wanted
MR. CSONTOS:
You know, we're not, the
5
inspections that we're looking at, okay, that EPRI
6
is doing a really phenomenal job at creating these
7
robots and stuff like that to go in, very small
8
robots and such just to look, they would require no
9
movement of canisters or casks.
And so they would
10
just -- what would happen is little robots, which
11
we tried out at Palo Verde I think -- you know,
12
you're going to be talking about it, right, Keith?
13
MR. WALDROP:
14
MR. CSONTOS:
be
autonomous
Yes.
So those are, you know,
15
they'll
16
they'll have cables in it, but there, that would
17
mean you don't have to move them around.
18
every
19
evaluate risk of movement, risk of any of these
20
other operations to what's the information you're
21
going to gain out of it and what you're doing to
22
the workers.
operation
23
So
--
involves
we
have
to
not
be
risk.
be
autonomous
So
you
cognizant
but
Because
have
of
to
that.
24
And that's what we've done in our, in our team in
25
that
qualitative
risk-informed
kind
of
approach
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1
that we're doing here.
2
3
So FYI.
just want to make clear.
4
5
I don't want to frame them, I
MR.
CHUNG:
Yes,
thank
you.
That's
very good, Al.
6
And technology's evolving.
ways
to
7
be
8
right now I can only tell you based on what we have
9
right now.
10
do
inspection
MR. RAHIMI:
without
There may
Yes.
lifting.
But
I think I need to
11
qualify what Donald is saying that at all times in
12
the
have
to
13
withstand a design-basis accident at all times.
We
14
approve them for 20 years, at any time during 20
15
years.
16
say up to 40 years.
system
17
18
that
we
approve
and
they
If we renew them another 40 years, let's
So
tip-over,
drop,
at
all
times
they
have to meet.
19
So even given any possible degradation,
20
I mean that's what we're going to evaluate, will
21
they continue to meet a design-basis accident and
22
safety requirements.
23
lift and drop because those are given that at all
24
times these systems during their life sitting on
25
the pads up to 60 years at this point, they should
So if it is, I mean not the
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1
meet
their
2
design-basis accident.
3
at least for what we have approved, we have looked
4
at it, and that's where the whole renewal, whole
5
aging management comes into play that they continue
6
to
7
accident.
assure
confinement
that
8
9
the
back
a
And they do.
casks
MR. CHUNG:
us
requirement
meet
the
At this point
the
design-basis
Let me just kind of bring
little
bit.
The
is
talk
about
purpose
this
presentation
11
framework
12
going beyond building this framework.
13
we're in the embryonic stage.
14
actually how is this going to be applied?
15
much.
16
NRR how risk-informed is used.
17
the spent fuel storage and I'm saying, okay, how
18
that knowledge could be applied here.
19
developing a process for risk informing.
building.
risk-informed
You
know,
we're
You know,
We're not looking at
Not so
But right now I'm bringing my knowledge from
20
21
we're
the
of
10
that
to
given
And I'm looking at
And we're
In terms of going forward, I think that
there's a lot of work to be done.
22
MEMBER
23
this is a conceptual approach.
24
concrete.
25
POWERS:
MR. CHUNG:
What
I'm
hearing
is
This is not cast in
No, it's not.
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1
2
MEMBER
POWERS:
This
is
embryonic
thinking.
3
MR. CHUNG:
Yep.
4
MEMBER POWERS:
And this is, at least
5
at this point in time the general direction that
6
you're heading.
7
it's subject to challenge, but at least this is a
8
place to start.
9
And this is subject to change,
MR. CHUNG:
Yes, sir.
10
MEMBER POWERS:
11
MR. CHUNG:
12
MEMBER POWERS:
13
MR. CHUNG:
14
MEMBER
15
Riccardella.
Is that correct?
You're absolutely right.
Thank you.
Any other questions?
RICCARDELLA:
is
Pete
Am I online?
16
MR. CHUNG:
17
MEMBER RICCARDELLA:
breach
You are.
18
confinement
19
operating year?
20
a CDF, core damage frequency.
A question on this
frequency.
Is
that
per
I'm trying to draw the analogy to
21
MR. CHUNG:
22
MEMBER RICCARDELLA:
23
MR. CHUNG:
24
MEMBER
25
This
Yes, it's per year.
Per year.
Right.
RICCARDELLA:
Could
that,
we
usually talk in terms of per reactor-year; right?
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1
MR. CHUNG:
Right.
2
MEMBER
3
multiple reactors at a site, --
RICCARDELLA:
4
MR. CHUNG:
5
MEMBER
6
back
to
7
discussed.
this
8
9
RICCARDELLA:
--
multiple-cask
you
if
you
have
Yes.
MR. CHUNG:
reactor-year,
And
issue
Right.
don't
take
I'm
getting
that
you
When you say per
a
site
with
three
10
reactors and divide it by three, you treat it as if
11
there's only one reactor.
12
site.
13
So
with
And basically it's per
confinement
breach
frequency
14
what I am proposing is that we have it the same
15
way, we have it per site.
16
17
MEMBER
RICCARDELLA:
Okay.
So
it's
directly comparable then.
18
MR. CHUNG:
Yes.
19
MEMBER RICCARDELLA:
20
MR. CHUNG:
Okay.
Think of the person living
21
five miles off from the ISFSI.
22
be living with greater risk when you have more dry
23
cask storage systems on the site?
24
living
25
storage systems you have.
with
the
same
risk
Are they going to
They should be
regardless
how
many
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1
MEMBER RICCARDELLA:
I understand.
2
MR. CHUNG:
Okay.
3
Right.
Ready to go
forward?
4
MEMBER REMPE:
Yes.
5
MR.
Okay.
6
three concepts.
7
first one.
8
proposing
9
reconformed.
CHUNG:
I
presented
the
And I'm going to go through the
This is confinement breach, why I'm
confinement
10
breach.
The
metrics
The reasons are the following:
precursor
the
12
when you talk about risk from storage, the risk is
13
really to workers, these people on site.
14
when
15
concerned
16
contamination.
17
justification for selecting confinement breach.
talk
release
about
about
of
one is
11
you
to
were
risk,
risk
you're
of
Okay.
Next slide, please.
19
This
just
environment
or
kind
that's
of
presentation on how the PRAs were done.
21
they have initiating events.
22
this
23
event.
24
confinement,
25
breach.
an
event
tree.
Also,
also
20
is
two,
really
That's,
18
is
radionuclides;
a
my
brief
Basically
They have, you know,
You
have
an
initiating
In this case it's a drop, you have the
the
split
fraction
for
confinement
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1
You also have split fraction for fuel
2
cladding.
And the two PRAs, any time you have a
3
mechanical impact it assumes that the fuel cladding
4
would fail.
5
cladding it would fail.
Okay, if you have a drop, the fuel
6
So if you look in confinement breach,
7
basically the frequency of initiating event times
8
the
9
probability of fuel cladding failure, in most cases
10
probability
of
canister
failure
times
the
the probability of fuel failure is one.
11
One exception to this is here is when
12
you have a fire, it's recognized that because you
13
have such a robust system, even if you, even if you
14
damage
15
That's our only exception.
the
16
canister
not
go.
This is how it's done in the PRA.
I'm
17
not defending it.
18
what is there.
19
the
may
I'm not -- I'm just presenting
MEMBER POWERS:
confinement
cladding
20
using
21
fail to recognize that the potential source term is
22
vastly small compared to the reactor?
23
breach
Is it the form you're
MR. CHUNG:
frequency,
doesn't
that
Dana, you brought up a very
24
good point.
This is very different from a reactor,
25
as
out
I
point
in
the
very,
very
early
slide.
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1
Okay.
In the reactors if you have an accident, it
2
doesn't matter if it's a new reactor or a 45-year-
3
old reactor, your source term is going to be pretty
4
much the same.
5
Here the spent fuel decays with time.
6
Right?
7
you want to look at the consequence where the spent
8
fuel is less radioactive over time, so this gets
9
very
10
So if you want to look at a consequence, if
complicated
if
you
want
to
look
at
consequence.
11
So, again, going to that next slide --
12
MEMBER POWERS:
13
source term?
14
MR. CHUNG:
15
MEMBER POWERS:
16
What is the potential
I'm sorry.
What?
What is the potential
source term?
17
MR. CHUNG:
What's the potential source
18
term?
I have a very -- I have a slide at the very
19
end of the presentation.
20
that question now or can I answer later?
21
22
MEMBER POWERS:
I'm perfectly willing
to wait.
23
24
Do you want me to answer
MR. CHUNG:
end of the presentation.
25
Okay.
Let's do that at the
Appreciate that.
MEMBER SKILLMAN:
I would like to ask
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1
this question before you proceed.
2
MR. CHUNG:
3
MEMBER
4
Sure.
SKILLMAN:
In
this
conceptual
PRA --
5
MR. CHUNG:
6
PRA.
7
is
8
consequence.
This is not a conceptual
This is how the PRA EPRI, NRC PRA 1864, this
basically
9
what
they
do
in
MEMBER SKILLMAN:
terms
Okay.
of
modeling
Well, what I'm
10
stuck on is the definition of what's confinement.
11
As I see it, there are at least three confinements.
12
You've got the canister, the fuel clad, but you
13
also have the overpack confinement.
14
MR.
15
confinement
16
top.
17
CHUNG:
because
The
it's
MR. RAHIMI:
overpack
open
on
the
is
not
bottom
a
and
Yeah, in some systems, in
18
most of the systems the vented system overpack is
19
not
20
cool vented.
your
21
containment,
because
it's
vented,
very
But the metal system, yes.
MEMBER
SKILLMAN:
The
metal,
so
I'm
22
thinking particularly of the metal system where it
23
acts as a shield, and then you have the canister
24
and then you have the fuel clad.
25
this, this model is acceptable --
So it seems like
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1
2
MR. RAHIMI:
Yeah, this is the NR --
right, this is the NRC model.
3
MEMBER SKILLMAN:
4
except the steel overpack --
5
MR. RAHIMI:
6
MEMBER SKILLMAN:
7
MR. RAHIMI:
8
MEMBER SKILLMAN:
9
-- for all, for all
Yes.
-- design.
Yes.
Okay, I'm clear now.
Just making sure.
10
MR. CHUNG:
11
Move
Good question.
forward.
Okay.
Again,
the
12
typical initiating event, this is in the standard
13
review
14
events and they also have thermal events.
15
is typically what's evaluated for, for accidents of
16
drops, tip-over, seismic, water currents during a
17
flood, strike from a heavy object, shock waves from
18
nearby
19
know, vent blockage, lightning, fire from aircraft
20
fuel.
plan
where
explosion;
21
And
they
evaluate
thermal
so
the
event
way
the
of
the
mechanical
And this
course,
PRA
is
you
done,
22
basically they have all these -- this is just some
23
of the event
24
have all these event trees and they combine them
25
for
each
trees that are there.
facility
basically
They basically
adding
the
cuts
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1
together and that gives you the confinement breach
2
frequency.
You know, all these events they have
3
initiating
frequencies,
4
frequency and so forth.
you
5
Going forward.
6
Now,
7
previous
8
aging
9
cracking.
as
we
presentations,
effect,
have
mentioned
there
is
chloride-induced
a
the
breach
earlier
concern
stress
in
with
corrosion
One way that could be addressed is to
10
have event trees that basically instead of having a
11
split fraction of yes and no, you have ones that
12
basically have the different wall sites, different
13
through-wall crack sites.
14
Eventually
you're
going
to
be
doing
15
inspections.
16
canister and the canister is 60 years old and you
17
say, oh, there is a small crack here.
18
you
19
somewhere and repackage?
20
have to do that.
21
risk-informed and look at it and say, okay, now
22
given that there's a 10 percent through-wall, what
23
is the probability of that canister failing?
24
percent through-wall, what is the cut there, what's
25
the probability of it failing?
have
to
You know, you're going to look at a
take
the
canister
back
But then do
to
the
pool
Well, hopefully you don't
Hopefully you will be able to use
A 20
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1
And you can evaluate it here so that
2
you don't have to repackage the canister for every
3
single little flaw that you find.
4
Go ahead.
5
CHAIRMAN BALLINGER:
6
Well, what if you
can't tell?
7
MR. CHUNG:
Well, that's a, that's a
8
different problem.
9
may have to do whatever you have to do.
10
I guess you have to, then you
I mean you're familiar with aircrafts,
11
you're familiar with reactors.
12
done, years ago I worked in crash mechanics.
13
for airplanes they have cracks, what they do is
14
they put a yellow line there and they basically
15
look at the rate of crack growth.
16
what's the critical size of that crack and they
17
decide whether they can still fly the plane or not.
18
Right?
CHAIRMAN
BALLINGER:
MEMBER RICCARDELLA:
is Pete.
What
I'm
asking
Excuse me.
This
But we do that same thing in reactors.
23
MR. CHUNG:
24
MEMBER RICCARDELLA:
25
And they look at
you is what if --
21
22
And
Same kind of concept to be applied here.
19
20
The way things were
Yes.
You don't need PRA
to do that.
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1
MR. CHUNG:
2
MEMBER
3
RICCARDELLA:
service inspection.
MR. CHUNG:
5
MEMBER
do
an
in-
Right.
RICCARDELLA:
--
we
do
a
deterministic evaluation.
7
8
We
If we find a crack --
4
6
Yes.
MR. CHUNG:
Right.
And what happens,
that could be applied here.
9
CHAIRMAN BALLINGER:
Doing this for 50
10
years, you may very likely see some canister with
11
flaws.
12
THE
OPERATOR:
conference
pardon
interruption.
14
three participants at this time.
15
to continue press Star One now, or the conference
16
will be terminated.
CHAIRMAN BALLINGER:
contains
less
the
13
17
The
Please
than
If you would like
My point is, what
18
if you can't ever decide that it's 10, 20, 30 or 40
19
percent through-wall?
20
what
21
inspection technique that's reasonable --
if
the
only
What if you can see only --
thing
22
MR. CHUNG:
23
CHAIRMAN
you
can
see
with
any
Right.
BALLINGER:
--
is
something
24
that gives you an idea that there may be something
25
going on?
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1
MR. CHUNG:
2
CHAIRMAN BALLINGER:
3
MR. CHUNG:
4
CHAIRMAN
5
Right.
This is hypothetical.
BALLINGER:
Well,
mine's
hypothetical as well.
6
MR. CHUNG:
7
CHAIRMAN BALLINGER:
8
Now what?
Yes.
But I think it's
more less hypothetical than this is.
9
MR. CHUNG:
10
Yeah, okay.
MR. CSONTOS:
I don't want to take away
11
Chief's thunder but there are techniques that they
12
show that the Palo Verde demo that can look at 50
13
percent through-wall.
14
simple
15
thing that can see how deep cracks are with phased-
16
array eddy current systems they have which is -- it
17
was on the back of that robot.
50
percent
So you may even have just a
through-wall
go/no
go
type
of
18
All I'm saying is that this is nice.
19
What Pete said is actually is what we're trying to
20
do in the code right now.
21
we have a deterministic process, and we're trying
22
to mimic what Pete just talked about in terms of
23
what the reactors are doing to what we're doing
24
this side of the house for, you know, looking at
25
cracks, how much of an area do you need to look at,
Pete was mentioning that
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1
where do you need to look at?
2
find out, if you can get this determination of what
3
size crack it is then, you know, we can figure it
4
out.
5
6
And then if you can
But first is first.
have a disease.
7
Let's see if we
Then we move on to the next thing.
CHAIRMAN BALLINGER:
But the 50 percent
8
through-wall was already there.
9
there and you were trying to size it; right?
10
You knew it was
At
Palo Verde.
11
MR.
12
that
was
13
individual
14
didn't
15
that
made
16
surprised.
it
50
could
17
So
by
was
expect
we
CSONTOS:
Well,
somebody
of
a
able
to
let
me
ask
see
that.
from
sample
The
other
an
ourselves,
We
were
operational
perspective,
if
19
characterize
them?
20
cracks you put it in the corrective action program
21
and then you do your assessment as a licensee.
23
If
MEMBER BROWN:
you
cracks
We
18
22
find
a
surprise.
through-wall
be
you
was
else.
something
percent
it
can
can
characterize
you
the
Why do I care if there's
a crack?
24
MR. CHUNG:
I'm sorry?
25
MEMBER BROWN:
Why do I care if there's
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1
a crack?
2
percent, 20 percent, even if it goes all the way
3
through if it's not circumferential and the whole
4
thing is going to tip over?
5
6
Just let's get down to through-wall 10
MR. CHUNG:
Okay, why -- Okay, go to
the next slide, please, Meraj.
7
Why
do
you
care
with
these?
What
8
happens is that when you look at the PRA, when you
9
look
10
at
things
that
could
happen,
you
have
basically all these things.
11
MEMBER BROWN:
Let me, I don't want to
12
look at a PR -- why do I care if there's a crack, I
13
mean all the way through?
14
manifestation of a through-wall crack that probably
15
does not go straight through but meanders around
16
and all this other kind of stuff?
17
MR.
CHUNG:
What is the physical
The
robustness
of
that
18
container is compromised.
19
over or a drop, there's a greater likelihood that
20
you
21
greater likelihood that --
will
22
23
confinement
MEMBER BROWN:
breach.
There's
a
Maybe you ought to pack
them closer together so they don't fall over.
24
25
have
So if you have a tip-
MR.
CHUNG:
Well,
if
they're
sitting
there, they're sitting and you're not moving it,
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1
you know, you don't have to worry.
2
is
3
storage, you will be lifting, you will be doing
4
inspection, and there's a chance that you may have
5
a drop or some kind of accident that causes that
6
crack to lead to a confinement breach.
7
MEMBER BROWN:
8
if
you,
if
you
look
at
But the thing
storage,
long-term
Can the crack start on
the inside and work from the inside out?
9
MR. CHUNG:
We don't believe so.
The
10
type of crack that we're looking at is chloride-
11
induced stress corrosion cracking, and there's no
12
salt inside.
13
MR. CSONTOS:
14
the
canister,
15
environment,
16
fuel
17
have asked for --
19
just
doesn't
18
so
have
The inside is inerted, of
if
like
any
MR. CHUNG:
I
you
have
said
earlier
aging
an
inerted
about
mechanisms,
that
the
we
Well, we don't know of any
mechanism that causes a crack from the inside.
20
MEMBER BROWN:
So you're going to go
21
eddy current test thousand -- I'm going to take
22
your thousand test field.
23
MR. CHUNG:
24
MEMBER BROWN:
25
No.
No, you do a sampling.
I have a term for that
that I won't use on the public airways.
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1
MR. CHUNG:
Okay.
2
MEMBER BROWN:
3
MR. WALDROP:
I hear you.
I'll talk a little bit
4
about that in my presentation of a way to get a
5
good
6
inspect.
--
to
determine
which
ones
you
want
to
7
And also on your question about why do
8
we care, I guess there's a few ways to answer that.
9
One,
I
mean
you're
leading
towards
10
consequence analysis.
11
you do have a through-wall crack?
12
question.
13
the
full
What's the dose really if
That's a good
We did an analysis at EPRI looking at
14
what is the flaw tolerance?
15
most likely crack that you'll get in the direction
16
that it goes, these systems are very flaw-tolerant.
17
And I don't remember the exact details.
18
done by one of my co-workers.
19
20
Like
close to, you know, 80 percent -MR. CSONTOS:
It's in the meters.
It's
in the meters --
23
MR. WALDROP:
24
MR.
25
It was
But basically you remember, Al?
21
22
In these systems, the
side.
CSONTOS:
Yeah.
--
for
critical
flaw
So it's very flaw-tolerant.
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1
2
MR. WALDROP:
A huge flaw that you need
before you have an issue.
3
Trying to, I guess what he's looking at
4
as
far
as
the
probability
5
starting
6
occur?
7
that point as an input parameter.
condition
and
part,
what
what's
event
do
your
you
have
So I guess he's concerned about it from
8
MR. CHUNG:
Well, what you said, Keith,
9
is very important because if you're talking about
10
risk-informed and you know what's the probability
11
of, looking at the canister, okay, if you know, if
12
you know that, okay, up to a certain crack size you
13
don't have a problem for the type of lift height
14
that
15
justify
16
repackaging it.
17
But
you're
going
not
to
be
taking
and
you
dealing
that
don't
canister
want
back
to
these
That's why it's important to know what your crack
20
size
21
probabilistic approach to this here so you can say,
22
okay,
23
there's
a
24
process
we're
25
because if we have a drop with this type of flaw
we
have,
we
did
flaw
in
this
going
why
you
testing
to
want
and
canister
limit
can
and
19
that's
you
open
can
canisters
And
if
you
18
is.
repackage
with,
help
to
we
the
have
know
here.
lift
it.
For
a
that
our
height
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1
size,
as
long
2
we're not going to have a breach.
3
4
as
MEMBER
we
don't
BROWN:
see
a
You
certain
can
height
always
slip
another sleeve around it.
5
MR. CHUNG:
Not that simple.
6
talking about very heavy lifting here.
7
MEMBER BROWN:
You're
I didn't say move it.
I
8
said bring another sleeve in and put it over the
9
top.
10
11
MR. CSONTOS:
overlays too.
12
13
MR. CHUNG:
We could be very creative
on --
14
15
Pete's company does weld
MEMBER RICCARDELLA:
is Pete.
Excuse me.
This
Can you hear me?
16
CHAIRMAN BALLINGER:
17
MEMBER RICCARDELLA:
You know, I heard
talk
and
lot
18
a
19
cracks
20
these through-wall cracks -- if one of these cracks
21
that's 40 percent through-wall, grows to through-
22
wall, even if very small, isn't that a confinement
23
breach?
24
25
of
and
about
critical
ruptures
Yes.
flaw
MR. CHUNG:
length,
dropping
but
Yes, that is.
if
one
and
of
But what
happens, when you have a confinement breach without
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1
-- what happens, if you have a through-wall crack,
2
the
3
particulate.
4
you
5
small.
crack
think
in
itself
doesn't
lead
to
release
of
You know, some of these cracks, if
stress-corrosion
cracks
they
were
very
And as long as it's sitting in place --
6
MEMBER RICCARDELLA:
7
MR. CHUNG:
Right.
-- and you're not moving it
8
there's no, there's no driving force for material
9
get out unless you drop a canister or you tip it
10
over,
you
11
concern.
12
any release from that canister.
13
know,
you
really
don't
have
a
major
You probably won't even be able to detect
But the thing is that if you're sitting
14
out
there
15
canister, then you have a concern.
16
you know, you need to deal with, okay, what is the
17
critical qualify for the list that I have to do?
18
19
and
you're
going
MR. CSONTOS:
to
have
to
move
the
You need to,
But as Pete said, I think
-- Kris, do you want to talk about that?
20
MS. BANOVAC:
And I think along those
21
lines so the, I guess the licensing basis or design
22
basis for most, if not all I guess, of our ACC and
23
dry storage system is that to meet the confinement
24
safety
25
barrier.
functions
that
it
is
an
impassively-tight
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1
Now, we do have the dose limits in Part
2
72, the 72.104 dose limits.
3
know, a licensee or a CoC holder, you know, wanted
4
to show that, okay, I can have this happen to my
5
canister
6
quals to wade through.
7
meet the dose limit.
8
if
9
review.
they
or
my
wanted
10
system.
It is possible if, you
I
could
have
this
many
And, oh by the way, I still
They could go down that path
to.
That's
something
we
would
But I think it's fair to say -- and
11
please,
anybody
12
correct me if I'm wrong -- I think it's fair to say
13
that
14
currently how they meet the confinement function is
15
that it is a impassively-tight barrier for storage.
most,
if
in
not
the
audience
all,
of
our
if
I'm
wrong,
systems
are
--
16
So I think if -- yeah, but it doesn't
17
preclude if someone wants to go down the other path
18
to show, hey, I could have, you know,
19
cracks, this many through-wall cracks.
20
the way, I still meet, you know, the dose limits;
21
that's something we would review and consider, but
22
currently no one is doing that.
23
24
MR.
CUMMINGS:
Cummings from NEI.
25
Kris,
this many
And, oh, by
this
is
Kris
That's not entirely true.
MS. BANOVAC:
Okay.
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1
MR. CUMMINGS:
The earlier generations
2
of the welded casks were not tested to leak type
3
because they were tested a little bit differently.
4
The closure weld was tested with a helium sniffer
5
test.
6
down to that sensitivity with the natural helium in
7
the background.
And so you run into some issues with getting
8
The point being is that the licensing
9
basis of the cask is that there is a design basis
10
leak rate based on what they tested it to.
11
tended to be around 5 times 10 to the minus 6.
12
There were some of the even older casks in that
13
that were 1 times 10 to the minus 4.
14
So
they,
as
part
of
their
It
licensing
15
they calculate what their dose consequences are at
16
the site boundary, and they have to show with the
17
number of casks that were loaded to that CMN limit,
18
that lower leakage rate, that they still meet the
19
25
20
indication when we are talking about consequences
21
that you can have 10, 20, 30, 40 casks out there
22
with
23
the regulatory requirements for normal conditions,
24
25 millirem per year.
millirem.
a
25
And
so
that
lower-than-leak-type
gives
basis
and
us
a
still
25 millirem per year is nothing.
good
meet
That
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1
is a tiny, minuscule amount of radiation.
2
still meet that.
3
MEMBER RICCARDELLA:
We can
I understand.
The
4
numbers you were quoting, those are leak rates in
5
what units?
6
7
MR.
CUMMINGS:
Atmosphere
per
second.
8
MEMBER RICCARDELLA:
9
CHAIRMAN
10
could be in theory from a crack.
11
12
CCs
Okay.
BALLINGER:
MR. CUMMINGS:
But
Right.
Thank you.
that
leak
I mean in the
cases of those casks they're --
13
CHAIRMAN
BALLINGER:
In
theory.
I
14
don't know what the leak rate would be but it could
15
be in theory from a crack.
16
MR. CUMMINGS:
Right.
In those, in the
17
cases of those casks they're at leak tight as any
18
other.
19
sensitivity at the time, and that was 10, 10 to 15
20
years ago.
21
22
They just couldn't be tested down to that
CHAIRMAN BALLINGER:
would put a floor on what would be allowed --
23
MR. CUMMINGS:
24
CHAIRMAN BALLINGER:
25
So that in effect
Sure.
-- if you had a
leak.
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1
MR. CUMMINGS:
Sure.
It's a good data
2
point that we have, understanding that you can have
3
certain flaws that would lead to a certain leakage
4
and
5
conditions.
But
6
confinement
integrity
7
normal or off-normal condition.
8
regard to an accident condition.
you
could
still
meet
a
at
least
confinement,
I
don't
the
a
think
normal
loss
would
of
be
a
It would be in
9
And so those older tests did look at
10
loss of confinement boundary integrity and showed
11
with large amounts of damage to the fuel that they
12
could
13
which are much higher.
meet
14
15
condition
BALLINGER:
requirements
But
that
leak
could come from a chloride stress corrosion crack.
MR.
CUMMINGS:
It
could.
It
could.
Yes.
18
19
accident
CHAIRMAN
16
17
the
CHAIRMAN BALLINGER:
I mean nobody says
where the leak would come from, it's just there.
20
MR. CUMMINGS:
21
CHAIRMAN BALLINGER:
22
MR. CUMMINGS:
23
MEMBER
24
that
crack
could
25
constitute, --
Right.
Right.
Correct.
RICCARDELLA:
get
Correct.
big
Yeah,
enough
that
presumably
it
would
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1
CHAIRMAN BALLINGER:
2
MEMBER
and
Yeah
RICCARDELLA:
rupturing
3
dropping
4
containment -- a confinement breach.
5
MR. CUMMINGS:
6
MR. CHUNG:
even
would
Right.
without
constitute
a
Correct.
Again this is a, we're in
7
embryonic
8
concept going forward.
9
spend a lot of time dwelling on this unless you
10
stage.
it
--
This
is
just
some
proposed
So I don't think we need to
really want to.
11
Any other questions?
12
(No response.)
13
MR. CHUNG:
14
Again,
All right, next slide.
you
know,
based
on
the
15
Commission Safety Goal, you know, you'd have what's
16
defined
17
Nuclear
18
Quantitative
19
negligible risk to 2 times E to the minus latent
20
cancer per year as the, as negligible risk.
as
negligible
Material
21
risk.
Safety
Health
And
then
Safeguard
Guideline.
And
also
has
that
the
this
defines
And so for confinement breach, based on
22
the
Quantitative
23
this
24
calculation
25
something
is
based
Health
on
Guideline
NUREG-1864,
--
this
based
on
--
that
number
would
come
like
5.5E
to
minus
3
the
again,
their
out
per
to
year,
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1
confinement breach per ISFSI.
2
Okay.
Again,
I
think
going
forward,
3
more study may, consequence study may be needed.
4
They
5
burnup fuel.
6
what would happen if you had MOX fuel and what have
7
you.
8
that's currently out there.
only
looked
But,
9
at
one
type
of
fuel,
not
high
You know, you may want to consider
you
know,
that's,
that's
the
number
Next slide, please.
10
And
decision
11
metrics
would
support
12
changes
in
13
acceptable change in risk.
risk
and
metrics,
evaluation
provide
Next slide, please.
15
Now,
this
of
basis
14
again
again
comes
decision
quantitative
for
right
assessing
from
the
16
NRR.
And I think a lot of you are familiar with
17
Reg. Guide 1.174.
18
the
19
requirements,
20
numerical risk.
21
be relaxed if the initial risk is, it's already low
22
and the incremental increases from the change, from
23
a change are also small.
counts
24
25
And we're basically looking at
in
1.174.
you
know,
And
what
basically
is
the
acceptable
And the specific requirement may
Example is at inspection, okay.
If you
look at the risk where the risk is 10 to the minus
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1
12,
and
if
you
2
years,
3
increase in risk?
4
say, well, that's fine.
you
do
don't
it
do
every
inspection
10
years,
every
what
five
is
the
If it's also very low you might
Okay.
5
Go to the next figure, please.
6
And
this
is
a
figure
7
1.174.
8
For reactors you have this figure.
9
I, Region II, Region III.
from
Reg
Guide
I think a lot of you are familiar with it.
You have Region
You know, 10 to the
10
minus 5 versus bigger 10 to the minus 6.
Then 10
11
to the minus 4 is greater than 10 to the minus 5.
12
So if you're in Region I you're in a higher risk
13
and you're not allowed to have an increase in risk.
14
If you're in Region III you're allowed
15
to have up to 10 to the minus 6 increase in risk.
16
If you're below 10 to the minus 6, you can have up
17
to 10 to the minus 5 increase in risk.
18
In other words, if your ISFSI planning
19
has a confinement breach frequency of 10 to the
20
minus
21
inspections, you may be allowed to increase your
22
risk by 10 to the minus 5.
6
and
you
want
to
eliminate
some
of
the
23
It's a, you know, it's a concept from
24
reactors, if you're familiar with how, how we do it
25
with reactors.
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1
MR. CSONTOS:
One thing about that, the
2
risk-informed ISI SRP for NRR talks about how you
3
can
4
augmented inspection requirements for, at the time
5
it was
6
not subject to the risk-informed ISI.
So we're
7
trying
combining
8
these two right now.
do
risk-informed
ISI.
But
if
there
are
IGSCC, PWSC, things like that, those are
to
do
something
that's
kind
of
9
So just FYI, just you know, we had to
10
make sure that we're for normal kinds of fatigue
11
and other things, those were fine to go ahead and
12
risk inform.
13
found that the cracking disease, that they were,
14
that had different augmented requirements at NRC.
But for things that were, that we
15
MR. CHUNG:
16
MR. CSONTOS:
17
the risk-informed ISI.
18
MR. CHUNG:
Right.
Those were not subject to
Right.
Thank you, Al.
19
brought up a very good point.
20
risk-informed, not risk-based.
21
here
22
number of other requirements.
23
meet regulations.
24
depth.
25
to be monitored.
with
Reg
Guide
1.174,
You
The word here is
Right?
If you're
risk-informed
Right?
has
a
It has to
It has to maintain defense-in-
It has to maintain safety margin.
It has
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1
You
know,
there's
other
requirements,
2
risk-informed just provide one additional piece to
3
your decision making.
4
So just because you're low risk and you're asking
5
for a slight increase in risk, it may or may not be
6
granted.
7
in caucus of Nuclear Reactor Regulations.
8
MEMBER SKILLMAN:
9
It's not risk-based.
Okay.
That's the way risk-informed is defined
Don, back up a slide,
please.
10
MR. CHUNG:
11
MEMBER
Yes, sir.
SKILLMAN:
Do
the
owners
have
12
tools that are sufficient to enable them to justify
13
their CVF and their delta CVF?
14
MR.
CHUNG:
Currently
the
owners
15
doesn't have anything.
16
have PRAs.
17
a risk analysis and they come to us and we have our
18
staff core model.
19
their values and we say, okay, yeah, we agree with
20
their evaluation.
21
22
For reactors every -- you know, they do
We run our model.
We confirm
For ISFSIs we don't have PRAs for the
licensees.
23
24
Currently the owners do not
MEMBER
SKILLMAN:
Okay.
So
this
proposal presumes that somewhere along the line --
25
MR. CHUNG:
Right.
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1
2
MEMBER SKILLMAN:
-- these tools will
become available?
3
MR. CHUNG:
Yes, sir.
4
MEMBER SKILLMAN:
5
MR. RAHIMI:
Thank you.
I'm good.
Let me qualify that.
I
6
mean at this point our approach is coming there
7
with
8
looking at our requirements, you know, we see where
9
we are, you know, in the risk area given that 10,
10
15 years ago we did a couple of PRAs that didn't
11
have
12
experience.
13
point
14
create a requirement, you know, for the licensee to
15
go and --
method
aging
the
and
applying
management,
to
our
didn't
criteria
have
and
operating
So that's the approach really, at this
goal,
you
know,
is
not
to,
you
know,
16
MEMBER SKILLMAN:
17
MR. RAHIMI:
18
Now, we are coming up with a method, an
19
approach and we're applying it and looking at from
20
the generic basis where are we after 15, 20 years?
21
Last time we did a PRA study with this, you know,
22
aging
manual
with
23
we've
got.
How
24
changed from 10 to the minus 13, 10 to the minus
25
14?
-- do these things.
some
has
The PRAs, right.
operating
that,
how
experience
has
the
that
numbers
That's what the goal is at this point.
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1
MR. CHUNG:
To kind of follow up with
2
what Meraj just said, we talk about, talk PRAs.
3
The PRAs you know, if I'm assuming that every ISFSI
4
has to have a PRA, you know you can have kind of a
5
collaborative effort for sites that are similar.
6
They can -- because there are only so
7
many different types of dry cask storage systems,
8
they can work together and develop a generic PRA
9
for
similar
sites,
similar
environments,
similar
10
storage systems.
11
have that 60 PRAs out there.
12
or half dozen PRAs that capture all the different
13
environments and storage systems.
14
15
So you may, you don't necessarily
You may have a dozen
Again, we're in the early stage.
And
there are lots to be developed as we go forward.
16
Okay,
information
needed
for
risk-
17
informed decisions.
18
going forward, we need to have more information on
19
aging effect during storage.
20
about
21
know, there really -- as far as impact on canisters
22
there hasn't been any failures.
23
we don't have a whole lot of information available.
chloride-induced
24
25
Some of the stuff that we need
There's a lot of talk
stress
corrosion
but,
you
We have, you know,
And we need to have more information on
canister failure probability for accidents.
This
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1
is
probabilistic
mechanics.
If
you
have
--
2
stainless steel is very ductile.
3
crack in there you're not going to have brittle
4
failure.
5
the probability of having a through-wall breach if
6
you have a 50 percent or 60 percent, 70 percent
7
through-wall
8
information on that.
So you have a
You know, dropping it, you know, what is
9
crack?
We
need
to
have
some
We need to do some more Level 3 PRA
10
evaluation
of
consequences.
Right
now
we're
no
11
longer looking at one type of fuel, the high burnup
12
fuel.
There's MOX fuel.
13
There needs to be some consideration of
14
common cause failure.
15
that point.
16
Dr. Power kind of touched on
And also, the PRAs that were done, they
17
were point estimates.
18
some
19
that there are manufacturing flaws in some of these
20
canisters, there are weld flaws and so forth.
uncertainty
21
evaluation.
Options
going
22
develop
23
risk-informed framework.
24
25
the
And we need to probably do
required
PRA
You
know,
forward.
One
information
to
we
is
know
to
support
The other one, again, because the low
risk
we
might
consider
adopting
a
deterministic
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1
framework since there isn't very high risk.
2
That's
all
I
have.
And,
Dana,
I
3
indicated that there's a slide -- please go to the
4
end.
Keep going.
5
Here
Keep going.
it
is.
Keep going.
You
asked
me
about
a
6
consequence.
7
assembly and it's sitting probably in the back of
8
the room I guess from where I'm sitting, about 35
9
feet away, what is the dose rates, about 30 rem per
10
hour.
11
old.
Okay, if you have a 35-year-old fuel
Okay.
12
That's kind of spent fuel 35 years
MEMBER POWERS:
You know what I'm more
13
interested in is suppose that I drop the canister
14
hard.
I crack it.
15
MR. CHUNG:
16
MEMBER
Okay.
POWERS:
The
17
scrambled, completely scrambled, --
18
MR. CHUNG:
19
MEMBER POWERS:
20
into debris.
21
likely to get?
22
23
insides
are
Okay.
-- I mean it's rendered
What kind of the source term am I
Now,
in
the
case
of
melting
down
a
reactor core I know what it is.
24
MR. CHUNG:
25
MEMBER
Right.
POWERS:
Here
it's
not
so
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1
obvious.
2
MR.
CHUNG:
No,
sir,
it's
not.
It
3
depends on the age of the fuel.
4
impact, again as I mentioned earlier on an earlier
5
slide,
6
environmental contamination.
7
have to store energy.
You don't have the driving
8
force
site.
9
basically looking at having a net or wherever you
10
dropped it, whether it's on the ISFSI, whether it's
11
on the road.
the
to
impact
get
12
it
is
really
off
13
the inside.
14
truck,
15
ferocious fire under it.
busts
the
gas
and
You know, you don't
You
know,
you're
Let's drop it, scramble
tank
and
we've
got
a
Okay?
MR. CHUNG:
17
MEMBER POWERS:
Okay.
18
we've got a driving force.
19
out.
21
worker
In the course of dropping it it hits a
16
20
the
And -MEMBER POWERS:
it
And most of your
MR. CHUNG:
So it heats up.
So now
We're pushing things
If the truck is moving it
it's sitting in overpack.
22
MR. RAHIMI:
23
has to be determined.
24
storage --
25
I think the context of it
If we're talking about dry
MEMBER POWERS:
Probabilistic gas tank.
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1
I'm going to put a fire under this some way.
2
MR. CHUNG:
3
MEMBER POWERS:
4
driving force.
5
force pushing stuff out.
Yep.
Okay.
MR. CHUNG:
7
MEMBER POWERS:
Right.
How much is it going to
push out?
9
MR. CHUNG:
10
11
Because I want to get a
So now I've got a driving
6
8
Okay.
Good question.
MEMBER POWERS:
I just did a back of
the envelope calculation.
12
MR. CHUNG:
Okay.
13
MEMBER POWERS:
Obviously I'm trying to
14
be as conservative as possible here, but basically
15
because I can use all round numbers.
16
MR. CHUNG:
17
MEMBER
18
curies per day.
19
MR.
Okay.
POWERS:
Come
out
with
That's not a whole hell of a lot?
CHUNG:
Well,
again,
the
impact
20
would be basically to the workers; right?
21
that
22
There's going to be environmental contamination.
are
23
near
100
where
that
MEMBER POWERS:
accident
People
occurred.
What I'm saying is that
24
it's not evident to me that I can draw a complete
25
analogy
between
CDF
for
reactors
and
containment
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1
breach frequency just because the CDF was accepted
2
because
3
whether you have a BWR or a PWR --
4
MR. CHUNG:
5
MEMBER POWERS:
everybody
knew
it
doesn't
really
matter
Right.
-- once you melt down
6
the core you're going to have a hell of a source
7
term.
8
MR. CHUNG:
9
MEMBER POWERS:
10
Right.
Here the source term is
so much smaller, --
11
MR. CHUNG:
I totally agree.
12
MEMBER POWERS:
-- so microscopically
13
small that I don't think you can draw the analogy
14
completely.
15
calibration factor in there someplace.
16
yeah, even if I bust the hell out of these things,
17
I do the most grievous thing I can think of, and I
18
bust 100 of them, I'm still dealing with an event
19
that, as you properly characterized, is completely
20
local.
21
I
MR.
22
contamination.
23
contamination.
24
25
think
CHUNG:
You
have
you've
You
got
have
lots
of
to
put
a
It says,
environmental
environmental
The ground's --
MEMBER POWERS:
Well, not very much.
I
mean it is pretty small.
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1
2
MR.
CHUNG:
It
MEMBER
POWERS:
4
released, what, 2 million --
5
MR.
CHUNG:
I
Well
be
very
mean
Fukushima
good,
I'm
glad
we
you
brought up Fukushima.
7
MEMBER POWERS:
8
MR. CHUNG:
9
to
complicated because --
3
6
gets
up
Fukushima
because
-- curies?
Well, I'm glad you brought
very
few
people
died
from
10
radiation, offsite population died from radiation.
11
It's zero?
12
13
I'm not sure whether it's zero or not.
MEMBER POWERS:
I was going to say, I
thought it was zero.
14
MR. CHUNG:
15
cases.
16
biggest
17
contamination.
18
canister failure --
Well, there is some cancer
So I don't, I don't really know.
concern
19
is
the
environmental
You know, if they -- if you have a
MEMBER
is
there
But the
like
POWERS:
one
of
You're
these
trying
sites.
to
say
And
I'm
20
Fukushima
21
telling you I can do 100 of them and I release 1
22
curie.
23
Cesium is what you're worried about.
Fukushima was 2 million curies of cesium.
24
MR. CHUNG:
25
MEMBER
Yes.
POWERS:
All
the
rest
of
the
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1
stuff is crap.
2
Okay.
And so what I'm saying is right there
3
I've been as conservative as I possibly can be.
4
mean just because I can do the numbers as factors
5
of 10 and don't have to do very hard arithmetic
6
here.
7
MR. CHUNG:
8
MEMBER POWERS:
9
curies.
I
Right.
And I come up with 100
And so I say let's do 100 canisters, you
10
know.
Something really bad happening, there's 100
11
canisters,
12
curie versus 2 million.
13
would be very careful about using CDF criteria and
14
standards in evaluating.
15
that
16
magnitude difference in consequence here.
each
because
17
one
it's,
of
I
MR. CHUNG:
them
released.
mean
it's
six
orders
of
Well, we're not using this
19
that we can be better risk-informed.
We're using this as a yardstick so
MEMBER POWERS:
Right?
What I'm telling you is
you're using a micrometer as a yardstick here.
22
MR. CHUNG:
23
MEMBER POWERS:
24
1
I'd be very careful about
to regulate.
21
get
It seems to me that I
18
20
I
Well, -You've got much more,
you've got huge margins here --
25
MR. CHUNG:
Yes.
Yes, we do.
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1
2
MEMBER POWERS:
public consequences.
-- before you get into
You know, you --
3
MR. CHUNG:
4
MEMBER
Right.
POWERS:
--
are
probably
not
5
going to be real popular with the Oil, Chemical and
6
Atomic Workers but as far as public dose you're
7
talking about a very small number.
8
MR. CHUNG:
9
Well, we recognize that in
the very beginning; right?
We were talking about
10
this.
If you have a mechanism to measure the risk
11
it
12
regulations.
13
is better than having no measurements; right?
14
you're doing deterministic --
offers
you
opportunity
to
revisit
our
This is just a -- having a micrometer
15
MEMBER
POWERS:
16
willing to make that argument.
17
MR. CHUNG:
18
MR. LOMBARD:
19
message
loud
and
20
we'll take that back.
I'm
not
sure
If
I'm
Okay.
clear
Dr. Powers, we get your
and
21
MR. CHUNG:
22
MEMBER POWERS:
understand
it.
And
We're open to better ideas.
Well, all I'm showing
23
you is that I think, I think you need to go a step
24
further.
25
something --
You
mentioned
maybe
we
have
to
do
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1
MR. CHUNG:
2
MEMBER
Right.
POWERS:
--
in
the
nature
of
3
Level 3 kind of analysis.
4
yeah, I think you really do because the threat here
5
under the worst -- I mean, what did I have to do, I
6
had to put a fire under it, I had to bust them, I
7
had to bust a bunch of them.
And you won't believe
8
how
the
9
particles.
bad
I
was
on
And I'm telling you,
assuming
size
of
aerosol
You get no vaporization really because
10
your temperature is not going to get hot enough to
11
vaporize things.
12
To get any kind of release you pretty
13
well have to do at least a crude kind of Level 3
14
analysis.
15
MR. CHUNG:
Well, that's one of the --
16
that's the last slide, that's one of the things
17
that's proposed, we need to do more Level 3 PRAs to
18
have a better appreciation for the consequence.
19
MEMBER POWERS:
You know, I don't know
20
that you need to do anything comparable to what was
21
done for reactors.
22
order
23
radioactivity you're going to release here and do
24
your
25
initiating
of
But you need to at least get
magnitude
scaling
not
event
feel
only
but
also
for
by
the
the
the
amount
frequency
magnitude
of
of
of
the
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1
source term.
2
Now if I can come back, you made the
3
point
throughout
4
experience at NRR.
your
5
MR. CHUNG:
6
MEMBER
of
POWERS:
various
In
mentioned one below grade underground canister.
Yes.
of
course
8
MR. CHUNG:
types
the
discussing
10
canisters
of
you
Yes, I can go back to
that.
11
MEMBER POWERS:
you
are
of
course
In your experience at
12
NRR
13
problems at a lot of sites of flooding --
well
14
MR. CHUNG:
15
MEMBER POWERS:
16
your
Uh-huh.
7
9
the
presentation
aware
that
we
have
Yes.
-- cable chases, things
like that.
17
MR. CHUNG:
18
MEMBER
Yes.
POWERS:
Does
19
pause on these underground things?
20
MR. CHUNG:
underground
with
things.
22
out of sight, out of mind.
23
easily.
MR. LOMBARD:
25
MEMBER
cause
you
I have a lot of problem
21
24
that
Underground
things
are
You can't inspect as
I would add --
POWERS:
There's
not
much
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1
problem in New Mexico let me assure you.
2
3
MR. CHUNG:
You don't have flash floods
in New Mexico?
4
MEMBER POWERS:
Yeah, we've got a lot
5
of flash floods but, boy, we've got a lot of drying
6
mechanisms too.
7
MR.
CHUNG:
Okay.
I
just
remember
8
running a -- I went to Albuquerque and I noticed
9
there was a canal, right, there's a mountain range,
10
there's a canal -- I'm not sure it was a canal.
11
It's a dry trough.
12
MEMBER POWERS:
They're called arroyos
13
and they criss-cross the cities.
14
flood like crazy.
15
MR. CHUNG:
16
MEMBER POWERS:
17
MR. CHUNG:
18
And, yeah, they
Right, right.
About twice a year.
Twice a year, okay.
Twice
a year could be a problem.
19
MEMBER
20
They're bone dry the next day.
21
MR.
POWERS:
CHUNG:
It
Except
won't
when
stay
long.
you're
in
a
22
silo and the water gets in there, the silo is not
23
going to be dry the next day; right?
24
25
CHAIRMAN
little
bit
far
BALLINGER:
afield
here.
We're
A
getting
little
bit
a
far
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1
afield
and
2
reasonable schedule.
3
4
we
have
to
MR. CHUNG:
have.
try
Yep.
to
keep
on
some
Anyhow, that's all I
Any other questions?
5
(No response.)
6
MR. CHUNG:
Well, thank you very much.
7
I enjoyed this opportunity presenting to you.
8
feel free to contact me if you have questions for
9
us.
10
11
MEMBER
presentation.
12
13
POWERS:
That
was
And
a
nice
I enjoyed it.
MR. CHUNG:
Well thank you, sir.
Thank
you very much.
14
CHAIRMAN BALLINGER:
We're maybe 10, 10
15
or 15 minutes behind, so it's not a big deal I
16
don't think.
17
MR. WALDROP:
So the pressure's off.
18
CHAIRMAN BALLINGER: No, no, no, no.
19
MR. WALDROP:
So I'm here to present on
20
the industry perspective of research in the areas
21
of storage and transportation.
22
have going on in EPRI.
23
kind of an overview of some of the R&D and focus
24
areas and then get into a little bit of the detail
25
of some of the work that we're doing.
The work that we
So I'm going to provide
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1
So if you think about the total spent
2
fuel management picture, you've got first the area
3
of storage, both wet and dry, then transportation
4
and eventually disposal.
5
So starting with wet storage, although
6
this isn't the focus here I just want to remind
7
everybody storage begins with wet.
8
some
9
looking at spent fuel pool criticality, leading to
active
burnup
research
credit,
going
and
on
then
And we do have
in
these
neutron
areas
10
full
absorber
11
material performance where we're focusing mostly on
12
BORAL these days.
13
In the dry storage areas we've talked
14
about, we're relying on these systems to last much
15
longer than originally intended.
16
be sure that they're going to be able to maintain
17
their safety functions for those periods of time.
18
So we've got to
We've got a lot of good experience so
19
far with them.
20
got to look forward.
So one of the first things
21
that
2009
22
develop an extended storage collaboration program.
23
And it has grown a great deal over the years.
24
fosters good global collaborative research.
25
helps us look at what areas that we need to work
we
did
They're performing well but we've
back
in
was
to
establish
or
It
And it
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1
on.
2
In that program we are able to look at
3
the entire big picture collectively and then kind
4
of cypher up or split apart the pieces of the pie
5
that different people need to work on.
6
been a big success.
7
Next
we've
8
management.
And
9
susceptibility
of
10
got
there
the
area
we're
stainless
So that's
of
focused
steel
aging
on
the
canisters,
the
CISCC that we've talked about.
11
We've got high burnup fuel performance.
12
And
we
talked
13
that
14
little bit more detail.
we
about
have
going
the
on
data
collection
there.
I'll
get
project
into
a
15
And then we went on to transportation
16
where we're looking at the properties of advanced
17
claddings
18
hypothetical
19
transport.
20
for
long-term
accident
storage,
and
both
normal
in
conditions
the
of
Also, although not a lot of work going
21
on
these
22
transportation.
23
And
24
disposal,
25
this
time.
days,
we've
but
then,
got
We're
full
lastly,
little
just
burnup
in
to
kind
no
of
credit
the
area
involvement
keeping
tabs
in
of
at
on
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1
what's going on, both DOE and internationally.
2
So as I mentioned, since these systems
3
are
being
relied
4
intended or licensed, so we need to be sure that we
5
know, understand and can manage the aging effects
6
of these systems.
7
we took the initial steps of a literature review
8
and a failure modes and effects analysis.
9
And
on
for
longer
than
originally
So starting, to get us started
the
results
of
the
failure
modes
10
and effects analysis showed us that this CISCC is
11
the
12
mechanism
13
penetration.
14
dry storage components, it has been observed on the
15
reactor side on stainless steel components when we
16
have the classic of these three elements present,
17
both elevated stress, susceptible material, and a
18
corrosive environment.
most
19
likely
that
potential
could
active
degradation
to
through-wall
lead
While we haven't seen CISCC on any
For
CISCC
that
corrosive
environment
20
gets a little more complicated.
21
chlorides
22
canister through the air.
23
sufficient humidity such that those chlorides will
24
deliquesce,
25
you a corrosive environment.
transported
create
a
to
You've got to have
the
surface
of
the
Then you have to have
concentrated
brine
and
give
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1
So to address things, EPRI has a multi-
2
year project looking at two things, both developing
3
ageing management guidelines for specific to CISCC,
4
and
5
capability.
develop
6
and
So
demonstrate
developing
the
the
inspection
aging
management
7
guidelines we take the results from a literature
8
survey and failures modes and effects analysis, as
9
well as I referenced earlier, a flaw growth and
10
tolerance assessment that we performed.
11
that
12
using.
we
got
13
a
crack
And
that
led
that
to
susceptibility
probably of interest.
16
of this in some of the discussions today.
17
can help us define what are the site conditions in
18
the canister parameters for each canister that are
19
important
20
information
21
canisters are more susceptible than others and what
22
sites are more susceptible than others to help us
23
prioritize what our inspections might be.
25
and
allow
something
that
were
15
CISCC.
think
a
we
assessment
to
I
us
model
14
24
criteria,
growth
And out of
is
We poked around the corners
Then
we
ourselves
CHAIRMAN BALLINGER:
And it
can
take
that
to
rank
what
I have a question.
Now, I can see where you could fairly easily decide
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1
which sites are the most at risk.
2
wondering how to decide which canister within that
3
site
4
Because
5
population of the overall canisters.
6
MR. WALDROP:
7
CHAIRMAN BALLINGER:
would
be
I
about
the
one
presume
that's
the
you're
most
sampling
at
risk.
a
small
Uh-huh.
know
9
welding fractures and things like that was let's
10
just say a little bit less rigorous for inspections
11
and
12
affected stresses and, in particular, weld repairs
13
and
14
unknown
15
canisters to inspect?
things
in
16
like
older
So given what we
8
things
especially
But now I'm
like
that,
that
canisters,
MR.
so
canisters
since
which
how
may
do
WALDROP:
You
where
this
not
you
weld
--
up
heat
may
decide
bring
the
be
which
a
good
17
point.
18
what's the decay heat?
19
get it into that deliquescent range where the site
20
is
21
chlorides there.
22
what temperature range you're in, whether or not
23
you're getting deliquescence.
24
Other
25
So really the primary factor is driven on
going
to
It's that what's going to
determine
whether
or
not
there's
The canister's going to determine
factors
that
you
do
want
to
consider, if you have that information as put in
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1
the report, are things like was there local repair
2
done on that?
3
help
4
canisters that are equally ranked.
you
That might be some information to
further
5
differentiate
CHAIRMAN BALLINGER:
guess
say
Yeah, I could see
easily
7
population
8
temperature
9
That's, so that narrows it down a little bit.
of
where
I'd
6
10
I
between
canisters
range
you
could
where
you
get
you
get
deliquescence.
where
construct
the
a
right
I
don't know how far it narrows it down.
11
But
then
within
that
population
you
12
won't, sometimes you won't know whether there was a
13
weld repair made.
14
inspect
15
population?
all
16
of
So does that mean you have to
those
MR. WALDROP:
--
the
canisters
No.
susceptibility
within
that
And forgive me for
17
the
criteria
assessment
18
report has got a lot of those details in them.
19
won't remember the exact details off the top of my
20
head.
21
know, what's the highest rank.
22
to inspect within numbers and also understand the
23
fidelity of what went into that.
It's not perfect,
24
you
way.
25
something.
I
But basically you work to what are your, you
know,
it's
kind
of
this
And then you want
But
it's
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1
So
certainly
one
of
the
factors
is
2
canisters within a rank, if you find something, now
3
you
4
canisters within the same rank of two because we
5
don't know it that well.
6
MR. CSONTOS:
want
think
to
7
I
for
8
perspectives.
9
going
to
start
--
be
expanding
you
that
inspection
to
Just to say a few things.
need
to
look
at
the
global
The environment is one that's not
different
really
between
different
10
canisters at a site that it is or is not, does or
11
not have chlorides.
12
thermal decay heat, what's the temperature of the
13
surface of the canister.
14
And
The what you just said is a
another
part
to
it
is
deposition
15
rate of chlorides that would be there as a function
16
of the age of a system.
17
when a licensee comes forward, and we're going to
18
get
19
meeting, what, a couple days ago looking at how the
20
licensee
21
these canisters, okay, for inspection.
an
application
is
22
now
So, you know, when you,
here,
saying
we
this
just
is
had
why
we
a
PREOP
selected
And so one of them, you know, I think a
23
couple
of
them
you
have
to
think
about
the
24
temperature but you also have to think about the,
25
about the chlorides that could be present.
So that
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1
would include the deposition rate which would then
2
be relevant to age.
3
how long has it been on the pad?
4
So
How old is this canister and
those
that
have
the
lowest
5
temperature on the pad I think would be the ones
6
that you would want to go after.
7
CHAIRMAN BALLINGER:
8
MR. WALDROP:
9
So then the next step in our process is
probabilistic
Okay.
Okay.
So let's back up.
10
a
11
And
12
cumulative probability of canister leakage due to
13
CISCC over time.
14
case that we set a value equal to one.
15
what
16
parameters,
17
inspection
18
inspecting it and see what effect does that have on
19
our
20
leakage rather.
what
that
you're
confinement
does
is
it
to
do
is
particularly
regimes
to
takes
and
assessment.
looks
at
a
Looks at it compared to a base
able
ability
integrity
of
detect
go
in
very
different
at
different
looking
how
--
you
on
might
the
And then
go
about
probability
of
21
So say for example, if I inspect every
22
20 years versus every ten years or five years, am I
23
seeing
24
probability?
25
a
big
reduction
in
that
canister
leakage
And there it also does some sensitivity
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1
analysis looking at the base case on what are some
2
of the assumptions going in there.
3
sanity check to see that the model's working right
4
and what are the important parameters.
5
And all this finally will lead into the
6
integration
7
management guidelines for CISCC.
of
8
9
Kind of just a
all
these
pieces
into
aging
I'll also point out I think in one of
the
earlier
presentations
talking
about
the
ASME
10
efforts that these aging management guidelines and
11
our steps along the way I think are going to be key
12
references into the work that's going on right now
13
on the development of an ASME code case for in-
14
service inspection criteria.
15
So this just summarizes the different
16
steps that we've taken along the way and lists what
17
the EPRI report numbers are.
18
last two that are expected to be out later this
19
year, the aging management guidelines.
20
And then the very last one is really
21
our
22
consequence side.
23
that by the end of the year.
first
24
25
And I'd point out the
look
So
at
doing
a
scoping
study
on
the
So we're going to take a stab at
with
the
guidelines
talking
about
inspections, we certainly understand that those are
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1
going
to
be
2
developing
3
four
4
capability:
main
5
needed.
that
areas
in
get
biggest
7
together to do that;
8
bang
we're
EPRI
developing
Collaborations.
the
also
capability.
6
9
So
for
is
the
looking
at
focused
on
inspection
We want to be able to
the
buck,
and
working
Working on finding and developing mockups.
The
non-destructive
evaluation
technology,
10
what are we going to use to be able to inspect
11
that?
12
The EPRI efforts right now are focused
13
on looking at eddy current array, guided wave and
14
acoustic emission.
15
And then, lastly, let's not forget the
16
delivery
system.
17
necessarily to have to move these systems, but to
18
be able to use these two examples here of a robot
19
kind of car thing that will be able to go inside
20
these
21
location it needs to.
systems
22
So
AS
and
has
get
backing
been
your
up
to
alluded
to,
technology
mock-ups,
to
not
the
there's
a
23
couple efforts there.
One, a mock-up with flaws
24
embedded in it to be able to test your technology.
25
And another mock-up of a full-blown canister and
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1
overpack system to be able to test your delivery
2
techniques.
3
demonstrate
4
frame.
With the goal that we'll be able to
these
5
So
techniques
moving
on
to
in
the
cladding
2017
time
behavior
in
6
high burnup fuel.
7
we've talked about and then performance of advanced
8
cladding materials.
9
So
The high burnup R&D project that
we've
talked
about
this
some,
but
10
from a different perspective, a little background
11
on low burnup versus high burnup.
12
about this a little bit, but the technical basis
13
for
14
through
15
taking
16
cask, opening it up 14 years later and examining to
17
find
18
degradation,
19
still significant creep life left.
low
burnup
a
20
low
that
and
For
that.
has
demonstration
actual
out
fuel
We
the
have
fuel,
was
testing
provided
program
burnup
there
been
We've talked
that
was
loading
it
little
some
mainly
of
high
burnup
a
technical
the
side
done
in
evidence
a
if
properties,
we
basis
haven't
21
done
but
it's
22
based primarily on lab testing at this point.
And
23
as we've talked about, it showed that the hydrides
24
can reorient, leading to a loss of ductility, which
25
is really more of a problem for transportation than
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1
it
is
for
storage.
You've
got
2
applied to this to worry about it.
to
have
a
load
3
But what that did do was it allowed --
4
we used bounding conditions and allowed guidance to
5
be developed such that we could go forward with
6
licensing high burnup fuel.
7
that aspect.
8
limiting peak clad temperature of 400 degrees C.
9
So
10
that
So it was a success in
So ISG-11, Rev 3, basically gave us a
was
good
for
storage
and
for
up
to
20
years.
11
Now we're to the point of needing to
12
extend
those.
13
actually ISG-11, Rev 3, says it doesn't apply.
14
the transport licenses on high burnup fuel that we
15
have are very limited and restricted.
16
And
for
transportation
licenses,
So
So what we have is a lack of data on
17
high
burnup
fuel
under
the
actual
dry
storage
18
conditions.
19
earlier low burnup demonstrations using high burnup
20
fuel.
21
behavior
22
typical dry storage conditions.
23
North
24
types.
25
develop a really good demonstration project.
And we want to go and repeat those
It will give us the ability to look at the
of
Anna
So
multiple
site
we're
is
types
to
going
use
in
of
cladding
under
So the plan at the
four
with
different
this
clad
trying
to
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1
It will, another key aspect is it will
2
provide
data
3
models so that we can best understand that and be
4
able to model things.
5
for
In
benchmarking
addition,
it
fuel
performance
supports
a
need
for,
6
that we have for data in existing renewed licenses.
7
Calvert
8
tollgates
to
9
project.
And as Mark talked about, there's a bow
Cliffs
and
look
coming
at
10
wave
11
renewals coming due.
12
by
Prairie
data
2020
of
Island
coming
several
both
out
have
of
more
this
license
As well as it's going to support the
13
need
for
data
14
future,
15
storage and internationally.
16
a big issue with Spain and transport of high burnup
17
fuel.
both
18
So
to
support
with
U.S.
giving
just
transportation
plans
for
in
the
consolidated
Certainly Spain it's
kind
of
a
high
level
19
picture of what are the major steps in the project
20
that we have going on, well, first we developed and
21
we are now implementing a final test plan.
22
design
23
application
24
currently under review.
25
is
completed.
has
been
The
submitted
Final
storage
license
to
and
NRC
is
Next is we've identified, extracted and
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1
shipped some of these sister rods that are going to
2
be able to give us these baseline characteristics
3
to Oak Ridge National Lab to be able to begin that
4
non-destructive and destructive exam.
5
make sure we're on the same page, so these sister
6
rods
7
characteristics
8
that are going to be in the cask.
were
carefully
as
identified,
some
rods
So just to
have
uniquely
the
same
identified
9
So we went and looked at the operating
10
histories and everything that we could to identify
11
these rods compared to rods that are actually going
12
to be in the cask.
13
The next steps are to modify the cask
14
lid.
We're going to have penetrations in the lid
15
to be able to insert the instrumentation after the
16
fuel
is
17
Then
pending
18
storage
19
runs and load the cask and immediately begin to
20
collect
21
temperatures
22
certainly in the initial period while it's in the
23
fuel building.
24
25
loaded.
NRC
review
license.
the
coming
and
gets
we'll
looking
going
and
that
and
Dominion
data
Then
project
Fabricate
approval,
will
out
take
instrumentation.
perform
of
gas
forward,
we've
get
the
the
dry
this,
samples
so
started
now
being
in,
the
collecting
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1
data.
So where do we go from here?
2
idea
3
That's not a magic number, it may change.
4
ship
5
basically a large hot cell.
6
because we don't want to put this back in a pool
7
and
8
possibly affect the properties that we're actually
9
trying to measure.
is
to
the
open
store
cask
the
to
it,
a
we
cask
for
fuel
could
Nominally the
about
10
years.
And then
examination
facility,
And we need to do that
re-quench
the
fuel
and
10
So the fuel examination facility, which
11
is yet to be identified or be, well, I'd say, yeah,
12
just
13
there we can open the cask and examine the fuel and
14
perform those same destructive and non-destructive
15
exams
16
sisters to the ones that are being tested earlier,
17
and
18
two rods.
19
this high burnup fuel?
identified
on
those
identify
at
this
rods
what's
point.
that
the
Then
we've
once
it's
identified
difference
between
as
these
So what is the effect of dry storage on
20
And
if
we
want
this
for
extended
21
storage, certainly the option is to re-close it and
22
let
23
again later.
it
24
25
store
longer
with
the
option
to
open
it
There's no reason to stop this.
So
demonstration
that's
project.
on
So
the
moving
high
on
burnup
to
the
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1
performance of advanced cladding materials.
2
The issue here being that data on these
3
advanced clads, Zirlo, Optimized Zirlo, M5, AXIOM,
4
those
5
for high burnup, we need data on that to understand
6
the performance to be sure that we're meeting the
7
regulatory requirements applicable to dry storage
8
and transport.
9
guidance
10
materials
in
that
were
developed
specifically
And the reason for that is that the
ISG-11,
a
lot
of
that
is
based
on
testing done on Zircaloy-4 fuel.
11
As
well
as
for
transportation,
while
12
we've got ISG-11 for storage, we don't have similar
13
generically-accepted guidance on transportation.
14
CHAIRMAN BALLINGER:
I have a question.
15
I think I know what AXIOM is but I'm not exactly
16
sure.
Is that -- what is AXIOM?
17
18
MR.
WALDROP:
It's
CHAIRMAN BALLINGER:
20
MR. WALDROP:
21
CHAIRMAN BALLINGER:
22
MR.
From who?
I don't know.
CUMMINGS:
It's a Westinghouse advanced.
24
25
advanced
cladding type that --
19
23
another
Does anybody know?
It's
a
Westinghouse.
It's niobium.
CHAIRMAN BALLINGER:
That's the latest
one?
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1
MR. CUMMINGS:
2
CHAIRMAN BALLINGER:
3
MR. CUMMINGS:
4
full use yet.
5
6
Yes.
Okay.
It's not, it's not in
It's still in LTA.
MEMBER POWERS:
What kind of an alloy
MR. CUMMINGS:
It's a zirc 1 percent
is it?
7
8
Yes.
niobium with some changes in the minor aspects.
9
MEMBER POWERS:
10
MR. WALDROP:
Thank you.
So lastly, the steps we
11
have going in this project are we're participating
12
in collecting some of this post-irradiation data.
13
It's very expensive to collect this data.
14
talking nuclear and we're talking spent fuel, so
15
it's very expensive in hot cells.
16
We're
So what we do is we participate where
17
we
can
18
hydride
19
hydride cracking.
20
feeding it into our fuel performance models to be
21
able to try to come up with good models to predict
22
the performance.
23
to
collect
things
reorientation,
And
a
like
DBTT,
thermal
and
even
creep,
delayed
Then we take that data and we're
lot
of
the
things
that
we're
24
learning here is also helping provide guidance in
25
the
high
burnup
demonstration
program,
with
the
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1
goal of being able to resolve the regulatory issues
2
of extending dry storage licenses beyond 20 years,
3
and eventually transportability of the high burnup
4
fuel.
5
MR. LOMBARD:
So if I may add a fun
6
fact about the demonstration project.
For me it's
7
fun because thermal couples will be active from T
8
equals zero.
9
we, will be able to track the temperature inside
10
the system from the time it's loaded to the vacuum
11
drawing process and it goes on the pad.
So we'll be able to, we, collective
12
So that's going to tell us a lot and I
13
know the industry a lot as well as we go forward
14
with that.
15
MR. WALDROP:
Yeah, and I didn't get
16
into, yeah, too much detail on some of it.
But if
17
you're interested in more of the high burnup demo,
18
I can talk about the science part but not anything
19
to do with licensing.
It's under review right now.
20
CHAIRMAN BALLINGER:
21
MEMBER
POWERS:
Questions?
You
certainly
showed
22
pictures of hydrides, both in the laminar and in
23
the radial direction and the reorientation of this
24
stuff.
25
have difficulties with hydride blisters?
Do we still with these high burnup fuels
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1
MR.
WALDROP:
Not
my
area
of
--
I
2
believe that's more of a BWR thing.
3
believe it is but I can certainly, I 'll be glad to
4
take that back to my --
5
MEMBER POWERS:
And I don't
Well, if you find some
6
information on it, it would sure be interesting to
7
me because they've always been a conundrum in what
8
to think about them.
9
CHAIRMAN BALLINGER:
10
Other questions?
We've gone over quite a bit.
11
take a, can we take a 15-minute break.
12
MEMBER POWERS:
Can we
Another quick thing to
13
point out.
14
pictures up there but you're not confronting the
15
issue of fuel adherence to that clad when you get
16
to high burnup complete picture.
17
an issue.
18
You show some what I think to be clad
MR. WALDROP:
And that, that's
That was one of the big
19
things that came out of the surf testing that they
20
found was, particularly in high burnup fuel, the
21
bonding effect that you get between the fuel and
22
the clad is really helping you.
23
MEMBER POWERS:
24
CHAIRMAN
25
That's right.
BALLINGER:
So
we'll
take
a
15-minute break, back just before quarter of.
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1
(Whereupon,
the
above-entitled
matter
2
went off the record at 3:29 p.m. and resumed at
3
3:46 p.m.)
4
MR.
CUMMINGS:
So
I'm
Kristopher
5
Cummings.
I'm a Senior Project Manager at NEI.
6
seems like I sometimes try to get out of the used
7
fuel area, but I keep getting dragged back to it,
8
so but, it's good, we can --
9
MEMBER POWERS:
It
You made the mistake of
10
claiming some knowledge in this area, which nobody
11
understands.
12
13
MR. CUMMINGS:
that for me.
14
15
Somebody maybe claimed
CHAIRMAN
BALLINGER:
Somebody
dropped
the dime on you.
16
(Laughter)
17
MR. CUMMINGS:
Exactly.
Exactly.
But,
18
we've had a lot of discussions with the NRC over
19
the last two-and-a-half years, at least, when I've
20
been with NEI and we've made some --
21
(Off microphone comment)
22
MR. CUMMINGS:
I think we've made some
23
real good progress working collaboratively with the
24
NRC, to ensure that we bring our perspectives from
25
the Industry and operational perspective, and then,
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1
of
course,
2
perspective, as the regulator.
3
tried
to
understand
the
NRC's
So what I wanted to try to do is, was
4
give
a
little
5
Industry
6
because we think there are some opportunities to
7
make larger achievements, with regard to, you know,
8
how dry storage casks are regulated and some of the
9
technical issues associated with it.
on
10
the
bit
of
the
overall
Next slot.
perspective
dry
storage
just a very broad overview.
12
casks loaded, as of January this year.
13
about 200 of them per year.
14
point where we know how to do it.
15
safely.
Just
of
the
as
point
fuel
the
framework,
So before I get into that,
11
16
of
of
17
percent
that's
18
currently, in dry cask storage.
19
and competitive industry.
We have about 2,250
We load
We've gotten to the
We do it very
reference,
out
there
about
now
36
is,
It's a very robust
20
I think that's one of the things that
21
really lends a lot of the innovation in the dry
22
cask storage arena, the vendors are always figuring
23
out new ways to, either, put more fuel assemblies
24
into
25
introduce materials --
the
casks,
or
increase
the
cask
load,
or
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1
2
MEMBER
POWERS:
Are
we
getting
casks
too big to go into repositories?
3
MR. CUMMINGS:
That's a good question.
4
We've, EPRI, EPRI has done studies to show that the
5
large casks can go into the repository, obviously,
6
the repository is envisioned at Yucca Mountain had
7
a
8
individual packages, but as we go on with longer
9
and
10
very
low
longer
heat
times
load,
not
12
having
Kilowatts,
a
for
repository,
the
those
canisters --
11
(Off microphone comments)
12
MR. CUMMINGS:
-- go down in heat.
So,
13
you know, if there were a silver lining, maybe,
14
with a delay of a repository, maybe, you can --
15
MEMBER POWERS:
The internal optimist,
16
always looking for the good side here.
17
(Simultaneous speaking.)
18
MR. CUMMINGS:
19
side, exactly.
20
Exactly.
I'm looking for the up
So --
MEMBER POWERS:
21
that's a problem, because --
22
MR.
23
But
you
can
design
a
repository with a higher heat load capacity.
24
25
CUMMINGS:
Well, I mean, that's a,
MEMBER POWERS:
Well no, what I'm more,
I mean, what you don't want is to repackage.
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1
MR. CUMMINGS:
2
MEMBER POWERS:
3
Right.
MR. CUMMINGS:
5
MEMBER POWERS:
Right.
Okay, but you, what you
really don't want to do is repackage, because if --
7
MR. CUMMINGS:
8
MEMBER POWERS:
9
-- and you don't have
to worry about shipping them.
4
6
Correct, and --
Correct.
-- we have to repackage
that's, that's just an operational nightmare.
10
MR. CUMMINGS:
11
repackage
12
those 2,200 that are loaded would now become 5,000,
13
or
14
studies of four PWRs and nine BWRs and other, other
15
combinations.
16
adds to the scope of the issue of designing and
17
building a repository, so --
10,000
into
and
smaller
Well, and if you need to
DOE
packages,
has
looked
then,
at,
you
then
know,
all
the
But, yes, it certainly, it certainly
18
MEMBER POWERS:
19
MR. CUMMINGS:
Okay.
Next slide.
High burnup
20
fuel.
I wanted to give you just some, kind of,
21
rough
22
characterize
23
depends, to some extent, on how you include the
24
uncertainties
25
from reactor records.
numbers
and
high
and
these
burnup
how
you
are
rough,
fuel,
how
about
determine
your
people
45,000,
burnup
But, there's about 600 casks
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1
have, at least, one fuel assembly of high burnup
2
fuel in them.
3
out there.
4
That's about a quarter of the casks
But it's about 9,500 assembly, so it's
5
not
super
prevalent,
6
understand, as you can see from this graph that,
7
the amount of high burnup fuel that's going into
8
dry
9
because, they've taken a lot of the low burnup fuel
10
and put it into storage already, or they're simply
11
managing their fuel effectively and mixing some of
12
the high burnup fuel with the low burnup fuel, so
13
that they can manage their heat load inventory and
14
be able to continue to load dry cask storage.
15
slide.
storage
16
is
at
increasing
this
point,
with
but
time,
we
simply
Next
So in terms of improving the regulatory
17
framework,
we've
18
perspective
19
experience with dry cask storage.
20
the
21
experience, we have 30 years, I think, the oldest
22
ISFSI is 1985.
comes
Industry
had,
you
that
we
perspective,
know,
don't
we
sometimes
have
a
the
lot
of
I think, from
have
a
lot
of
23
You know, we've got a lot of casks out
24
there, we're learning more about them, obviously,
25
as
we
do
inspections
we're
going
to
learn
even
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1
more.
But we have a lot of experience from the
2
reactor side that's completely applicable.
3
Concrete
plants
are
used
also
used
in
in
5
storage.
There's not many unique materials in the
6
dry
storage
7
what's used in the dry cask storage.
But
arena
we
that
are
believe
dry
the
power
8
they're
steel
4
cask
and
and
different
that
we
can
cask
than
gain
9
efficiencies, especially, in the consideration of
10
the relatively low risk of dry cask storage and
11
making sure that it's appropriately recognized.
12
So
specifically,
rulemaking
the
had
define
the
14
certificate
15
along with a safety criteria similar to what's in
16
5036., specifically, tying the criteria to safety
17
goals,
18
recognition of defense-in-depth aspects.
essentially,
and
in
tech
then,
to
2012,
proposed
compliance
NRC,
in
13
of
to
NEI,
spec
also,
an
contents,
explicit
19
And one of the final things was also
20
looking, when we get into a little bit more of the
21
detail, is where are there areas that we think the
22
review of dry cask storage applications can be more
23
focused,
24
considerations.
25
especially,
So
the
when
two
you
that
I
look
put
at
in
risk
here,
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1
specifically,
are
shielding
and
radiation
2
protection evaluation.
3
of detail that goes into the chapter for shielding
4
calculations and then you calculate what your total
5
occupational dose is going to be, as you load that
6
cask and put it out on the ISFSI.
7
There's,
There's a tremendous amount
those
perspective
are
very
9
there's not a lot of value there, because you end
going
out
11
casks anyway.
12
and
Now
making
you
a
still
our
a
bounding
up
from
been
8
10
and
done
perspective
measurement
on
need
sort
some
those
of
13
shielding analysis, but whether you need some of
14
the detailed review of that analysis, as been done
15
in
16
environment.
the
past,
17
18
is
questionable
in
a
Can
I
risk-informed
Next slide.
MEMBER
BROWN:
ask
you
a
question?
19
MR. CUMMINGS:
Sure.
20
MEMBER BROWN:
If you go back to slide,
21
the one with the graph.
22
operating our plants, since when?
23
MR. CUMMINGS:
24
MEMBER BROWN:
25
Thank you.
So we've been
Sixty something.
When did the first one
start at the, when was the first Naval Nuclear one,
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1
what year, do you remember that?
2
MR. CUMMINGS:
3
(Simultaneous speaking.)
4
MEMBER BROWN:
5
(Off microphone discussion)
6
MR.
7
CUMMINGS:
I don't know.
-- shipping port.
I
was
born,
maybe,
a
year or two after, no --
8
MEMBER
BROWN:
'57,
'58,
or,
'58
or
9
'59, I thought, somewhere in that ballpark. Okay.
10
And then we built more and more and more, so for 50
11
plus years, 56 years, is that right?
12
--
13
(Off microphone comments)
14
MEMBER BROWN:
Sixty plus 60
We've uploaded and put
15
fuel into casks, we've got 600 casks today, you
16
say?
17
18
MR. CUMMINGS:
the high burnup, we've got 2,258 --
19
MEMBER BROWN:
20
MR.
21
Well, no, this is just
CUMMINGS:
High burnup?
--
of
2,268,
as
of
January --
22
MEMBER BROWN:
Okay that's, I like that
24
MR. CUMMINGS:
Yes.
25
MEMBER
23
number, too.
BROWN:
That's
good,
I
like
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1
that.
2
MR. CUMMINGS:
3
MEMBER
BROWN:
Yes.
Let
me
use
4
2,268 in 56 years.
5
and how many, at 76 sites, or roughly --
that
one,
We're projecting 3,200 casks,
6
MR. CUMMINGS:
Just about everywhere.
7
MEMBER BROWN:
Yes, but how many, let's
8
see, how many per site?
Because that's, that's
9
ten, 50 per site, or something --
10
MR. CUMMINGS:
Yes.
11
MEMBER BROWN:
-- like that?
12
MR. CUMMINGS:
13
more,
others
14
started loading.
15
have
less,
MEMBER BROWN:
Right.
Some, some have
depending
on
All right.
when
they
So I'm just
16
trying to calibrate this to the discussion from the
17
last
18
could then cascade and have ginormous problems --
19
(Off microphone comment)
20
MEMBER POWERS:
presentation
about
hundreds
interim storage facility there.
22
MEMBER
23
casks
that
You're talking about an
21
BROWN:
of
I'm,
well,
I'm
just
talking about all these little --
24
MR. CUMMINGS:
Right.
25
MEMBER BROWN:
-- ISFSIs, okay?
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1
MR. CUMMINGS:
So --
2
MEMBER BROWN:
They're interim storage.
3
MEMBER
4
MEMBER
BROWN:
MR. CUMMINGS:
8
MEMBER
10
MEMBER BROWN:
we've
got
76
Sixty-eight sites.
DOE's
proposal
is
to
Right.
Well that's a bad idea.
But I'm just --
14
MEMBER POWERS:
I know, it's a stupid
MEMBER BROWN:
I'm just wondering on,
idea, but --
16
if we don't do it --
18
19
interim
all these nuclear --
12
17
the
have, have specialized sites where they would bring
MR. CUMMINGS:
15
Well,
POWERS:
11
13
no,
sites, right now, I mean, if you just kept --
7
9
But,
would accumulate all these.
5
6
POWERS:
MEMBER
POWERS:
We're
talking
about
DOE, Charles.
20
MEMBER BROWN:
done
anything.
Yes, I understand, but
21
nobody's
22
repository,
23
specialized site that's in place, and if, I can
24
just foresee that we're going to continue business,
25
as usual, for another 50 years.
there
is,
I
you
mean,
know,
there's
no
no
other
So we get up to
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1
6,400 casks, I'm going out to 2020, at 70 or 80
2
sites, which may be 20, 25, 30, maybe, 50, maybe,
3
100 casks.
4
huge populations, which generate great risks.
5
just wanted to make a point.
6
It's not like we have these sites with
MR. CUMMINGS:
7
question
8
self-identifying --
9
there
I was looking for the
and,
MEMBER
I
you
BROWN:
know,
There
is
there's
no
no
question.
10
I'm working for the point. That point being is that
11
we're
12
usual, you will have still 75, maybe more, sites,
13
with 50 or 60 casks, maybe more, a few more, but
14
not huge sites with forests full of casks sitting
15
around --
looking
16
17
at,
if
everything
MEMBER POWERS:
continues,
as
So you're, that's the
DOE's intention.
18
MEMBER BROWN:
Well, I know, but the
19
intent, you know, the world is fraught with good
20
intentions, which rarely ever come to fruition, so
21
particularly, you know you don't --
22
MEMBER POWERS:
23
to
project,
you
got
to
24
knowledge you have and --
25
MEMBER BROWN:
I mean, if you're going
project
on
the
best
No, I --
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1
MEMBER POWERS:
2
MEMBER BROWN:
3
that
nothing's
going
4
additional ISFSIs.
-- that's --- the best knowledge is
to
happen,
other
than
5
MR. CUMMINGS:
Yes.
6
MEMBER BROWN:
Little --
7
MR. CUMMINGS:
Right.
8
MEMBER BROWN:
Little --
9
MR. CUMMINGS:
Right.
10
MEMBER BROWN:
-- little storage sites.
11
MR. CUMMINGS:
And we've loaded, we've
12
loaded fuel into direct cask storage at just about
13
every site, I mean, between now and --
14
MEMBER BROWN:
No, I'm good --
15
MR. CUMMINGS:
-- and 2020 --
16
MEMBER BROWN:
17
I'm just trying to put
the risk in perspective --
18
MR. CUMMINGS:
19
MEMBER
of
Right, right.
BROWN:
doing
--
risk
based
informed
on
analyses
the
20
projections
21
non-existent locations with non-existent numbers of
22
casks that are, create problems --
23
MR. CUMMINGS:
Well let's --
24
MEMBER BROWN:
-- that's all.
25
MR. CUMMINGS:
of
Let's hold that thought
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1
--
2
MEMBER BROWN:
In my own --
3
MR. CUMMINGS:
-- because --
4
MEMBER BROWN:
5
In my own mind that's
all.
6
MR.
CUMMINGS:
Because
I
think,
I
7
think, from our perspective, we can develop that
8
framework to mitigate and manage that risk in an
9
appropriate manner with appropriate programs.
10
MEMBER BROWN:
I --
11
MR. CUMMINGS:
So that, that's --
12
MEMBER BROWN:
I'm not questioning you
MR. CUMMINGS:
-- what I'm going to get
MEMBER BROWN:
We've been doing it now
13
--
14
15
into --
16
17
for --
18
MR. CUMMINGS:
Exactly, 30 years.
19
MEMBER BROWN:
-- many, many years --
20
MR. CUMMINGS:
Yes.
21
MEMBER BROWN:
-- and so -- decades.
22
MR. CUMMINGS:
Right.
23
MEMBER BROWN:
All right, thank you.
24
I
appreciate just --
25
MR. CUMMINGS:
No problem.
Next slide.
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1
MEMBER SKILLMAN:
Kris, I wanted to ask
2
you about your slide -- looking for a number here -
3
-- number 4.
4
5
MEMBER POWERS:
You're going backwards,
Kris.
6
(Laughter.)
7
MR. CUMMINGS: It'll never get done.
8
MEMBER
9
SKILLMAN:
I
was
listening
to
what you were saying and I was trying to understand
10
the meaning of what you were saying.
11
the third bullet, the last item under the third
12
bullet,
13
review of shielding, are you suggesting that there
14
should be a de minimis, or no effort, to review
15
shielding?
guidance
16
MR.
for
risk
CUMMINGS:
For the last,
appropriate
Well,
I
level
think
for
there
17
should be, there's a minimis, because, I mean, this
18
is one of those things where you do these computer
19
calculations to determine what is your dose from
20
your cask, so that you can show that the cask would
21
meet
22
requirements,
23
boundary.
the
10
CFR
dose
72.104
and
106
requirements,
at
shielding
the
site
24
However, with something like shielding,
25
you end up going out and making a measurement of
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1
that
cask.
2
canister and the transfer cask gets pulled out of
3
the spent fuel pool, you got RP people right there
4
making measurements.
5
I
mean,
When
you
over-pack,
when
the
cask,
transferred
them
are
the
into
the
certificate
of
6
storage
7
compliance requirements and tech spec requirements
8
to make a measurement, to ensure that the dose is
9
less than a certain amount.
10
there
when
So this is an area where, putting a lot
11
of
effort
12
shielding
13
certificate of compliance, which is done with very
14
bounding considerations, and so you may calculate
15
on the surface of your casks a 100 millirems per
16
hour,
17
measure it, it's like two millirems per hour, so is
18
there a lot of, is there a lot of benefit?
when
19
into
the
analysis
you
review
that
actually
of
the
goes
go
accuracy
into,
out
and
like,
of
a
measurement,
And that's where we think, we wanted to
20
give
a
specific
21
could
22
applications and, and we see here that this may be
23
an
24
bringing in a risk informed perspective.
risk
inform
opportunity
25
example
to
MEMBER
the
where
review
increase
SKILLMAN:
we
felt
of
the
the
like
individual
efficiency,
Yes,
but
you
it
by
seems
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1
like the, the other side of the argument is one
2
that you should be, that we should be sensitive to,
3
and
4
supposed to be two MR an hour, and it turns out to
5
be 100 MR an hour.
6
good shielding calcs.
that
is,
supposing
MR. CUMMINGS:
8
MEMBER
it
was
Sure.
SKILLMAN:
9
you are not suggesting --
10
MR. CUMMINGS:
11
MEMBER
So
I'm
hoping
that
--
that
such
No.
SKILLMAN:
activities should not be undertaken?
13
14
calculated,
There is good reason to have
7
12
being
MR. CUMMINGS:
No.
I'm not suggesting
that those would not be undertaken.
15
MEMBER SKILLMAN:
All right.
16
MR.
But
CUMMINGS:
that,
you
would
17
still do a shielding analysis, but when, when we
18
look at, maybe, some of the aspects where we get
19
REIs on, well, what's the impact of the dose right
20
around a bolt, because there's, maybe, some neutron
21
streaming through that?
22
on what the dose is at the site boundary, and so
23
that's, really, where we're trying to provide some
24
recommendation on --
25
MEMBER
Well, that has no impact
SKILLMAN:
Okay,
I
can
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1
understand --
2
MR. CUMMINGS:
3
MEMBER SKILLMAN:
4
you
are
5
problem --
specific
in
-- that feature, if
communicating
6
MR. CUMMINGS:
7
MEMBER
8
Right.
that
is
the
Understood.
SKILLMAN:
--
you
would
like
solved.
9
MR. CUMMINGS:
10
Right.
MEMBER SKILLMAN:
But, I think, at an
11
overall level, it's mighty important to understand
12
how thoroughly shielded those casks are, just --
13
MR. CUMMINGS:
14
MEMBER SKILLMAN:
15
MR. CUMMINGS:
16
MEMBER SKILLMAN:
17
Absolutely.
-- case in point.
Right.
We've all loaded one
at TMI, its contact there was 250,000 R, per hour.
18
MR. CUMMINGS:
Yes.
19
MEMBER SKILLMAN:
And when we settled
20
it in its transfer cask, we had calculated 10 MR an
21
hour on the outside of the cask.
22
who looked at that calc, said there's no way.
23
MR. CUMMINGS:
24
MEMBER SKILLMAN:
25
And most of us,
Yes.
I mean, it's going to
be hundreds and -NEAL R. GROSS
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1
MR. CUMMINGS:
2
MEMBER SKILLMAN:
3
Yes, right, right.
-- it was 8 MR an
hour.
4
MR. CUMMINGS:
Yes, yes.
5
MEMBER SKILLMAN:
And so there is value
6
in that, that was the Rockwell Codes and we were
7
fortunate --
8
MR. CUMMINGS:
I agree.
9
MEMBER SKILLMAN:
-- to have had the
10
precision and the ability to calculate, as we did,
11
but there's value in --
12
MR. CUMMINGS:
13
MEMBER
14
calculations
15
direction.
16
Yes, I'm --
SKILLMAN:
really
guide
MR. CUMMINGS:
-you
in
in
having
the
right
-- not questioning the
17
value of doing the calculation, I'm questioning, to
18
some
19
especially,
20
we've seen on impacts of some of the minor features
21
of the --
extent,
doing
in
the
a
super
context
22
MEMBER SKILLMAN:
23
MR. CUMMINGS:
24
MEMBER
25
detailed
of
some
of
review,
the
REIs
No, I understand.
-- casks on the --
SKILLMAN:
Okay.
Thank
you,
Kris.
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1
2
MR.
CUMMINGS:
--
on
the
shielding
right now --
3
MEMBER SKILLMAN:
4
MR.
CUMMINGS:
Okay, thanks.
--
currently.
So
in
5
terms of the proposed rulemaking, the vision here
6
was
7
themselves, and, specifically, the certificate of
8
compliance.
to
standardize
9
the
dry
storage
licenses,
Looking through some of the certificate
10
of
compliances
that
11
detailed,
12
licenses.
13
compliance is something like 280 pages long and has
14
tremendous
15
specifications
16
redundant
17
certificate.
they're
are
more
out
there,
lengthy
they're
than
the
more
reactor
One, I think the largest certificate of
amounts
to
of
that,
other
details
in
some
requirements
on
loading
respects,
that
are
are
in
the
18
So level of detail and then, also, that
19
was consistent with the Commission policy statement
20
on
21
things
22
appropriate
23
licensing, placing more information under licensee
24
control, i.e., the 7248 process.
improved
25
in
tech
that
specs.
proposed
risk
And
we
had
rulemaking,
prioritization
in
some
other
such
as
the
dry
storage
Currently, the Part 72 does not extend
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1
the
Back-fit
2
sometimes,
3
licensees having application of the Back-fit Rule,
4
but
5
effects the general licensees anyway, if you make
6
changes
7
application to the Back-fit Rule.
8
some other minor changes to the rule, to improve
9
its efficiency.
not
10
Rule
a
the
to
CoC
holders,
disconnect
between
CoC
the
So
to
holders,
cask
where
design
so
there
the
general
invariably
and
is,
there's
that
no
And then we had
Next slide.
the
keys
to
ensuring
safety,
with
11
more information under licensee control, first, of
12
course, is having a robust and mutually agreeable
13
7248 change process that, both, the Industry and
14
the NRC has a high confidence in, and we've had
15
some discussions, recently, with --
16
OPERATOR:
Please,
17
interruption.
18
three participants, at this time.
19
like to continue --
20
21
the
Your conference contains less than
MR. CUMMINGS:
If you would
I was hoping a fourth
would call in, at some point, today.
22
OPERATOR:
23
MEMBER POWERS:
24
pardon
-- press star one now.
Nobody wants to listen
to you, Kris.
25
(Laughter.)
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1
2
MR. CUMMINGS:
Well -- I'm going to let
that one go.
3
(Laughter.)
4
MR.
CUMMINGS:
with
with,
having
robust
especially,
6
Aging Management Programs in place.
7
this is, I think, a good, a place where we've had
8
good
9
understand both, both perspectives on both sides.
10
with
renewal
second
5
discussions
license
A
the
NRC
And, again,
and
been
able
to
And then, the final one is a reliance
11
on
the
NRC
Inspection
12
Industry, we see the NRC as one NRC, we don't see
13
the
14
headquarters
15
different.
regional
inspectors
Programs.
here,
in
as
Within
separate
Rockville,
the
and
as
the
something
16
We see that all as, collectively, part
17
of the regulatory oversight of our plants, of our
18
dry
19
licensees, of our cask vendors, we see that as one
20
organization and we need to leverage the different
21
parts
22
different branches, or offices, so that we have a
23
holistic view of how we're managing the safety of
24
spent fuel storage.
cask
of
25
storage,
that
So
our
systems,
organization,
even
of
our
if
general
they're
in
Next slide.
specific
improvements
to
that
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1
regulatory framework that we've been working with
2
the NRC on, and an Industry, submitted in 2012, a
3
72.48
4
the guidance on 72.48 processes contained in any
5
I90-607, which was on the 50.59 process for making
6
changes to the plant.
guidance
and,
really,
that
was,
currently,
7
There's an appendix in there, Appendix
8
Bravo, which was, kind of, not the best fit in the
9
world.
It had the Part 50 perspective applied to
10
Part 72, so we decided that we'd write a guidance
11
document that would be really more reflective of
12
the Parts 72.48 process.
13
Now there's a lot of simulators there,
14
but
there
15
recently had with the NRC, I think, we reached a
16
good consensus, or are reaching consensus on some
17
of the fundamental issues of concerns.
18
making
19
consensus on the 72.48 process that I talked about
20
earlier.
21
are
some
good
process
Sorry
a
nuances.
little
about
that.
more
on
that
So we're
reaching
Second,
and
that
we'll
23
NEI-1403, those are the guidance the Industry put
24
together
25
operations based to aging management process, and
a
his
we
talk
implementing
about
meeting
22
on
bit
there
A
dry
tomorrow,
cask
is
storage
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1
also, on the format and content for licensees to
2
submit their license renewal application.
3
And so there's four, what I'm calling
4
fundamental cornerstones that are included in that,
5
the
6
submitting
7
and
8
that's that we're providing the information to the
9
NRC that they're expecting.
10
first
is
ensuring
good,
there's
a
that
quality
we
know
that
applications
consistent
format
and
to
we're
the
content,
NRC
so
That goes hand-in-hand
with NUREG- 1927.
11
Second,
is
through
an
operations-based
12
management,
13
programs that was discussed a little bit earlier,
14
by the NRC, in that we need to have the flexibility
15
of the Aging Management Programs that we develop,
16
as part of the license renewal application, have
17
the
18
things we learn through operating experience.
ability
19
to
learning
be
age
modified
and
aging
flexible,
management
based
on
So that goes to the third cornerstone,
20
which
is
sharing
21
across
22
amongst the different utilities.
the
23
of
Industry,
that
operating
amongst
the
cask
experience
vendors,
So we've worked with the four cask, the
24
four
major
25
International,
cask
Areva
vendors,
TN
and
Holtec
Energy
and
AC
Solutions.
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1
Through info, they're developing a database where
2
they
can
3
that
we
4
inspections, into this database that is now fully
5
searchable by the utilities, by the vendors, and
6
we'll have some ability to share that information
7
with
8
regular basis.
the
start
putting
get,
NRC,
the
through
either
on
operating
age
their
experience
and
management
request,
or
on
a
9
And the fourth cornerstone is, kind of,
10
a regular toll gate safety assessments where we go
11
back on a periodic basis and look at what we've
12
learned,
determine
13
Programs
that
14
license
renewal
15
appropriate
16
something
17
something that we now have new evidence on that
18
says, well, maybe, we don't have to look at that
19
particular issue on as frequent of a basis, as we
20
first thought, in the Aging Management Programs and
21
stuff.
22
Next slide.
23
whether
were
developed,
Aging
as
application,
Aging
else
the
Management
we
need
to
Management
part
of
the
are
still
Programs,
is
there
is
there
look
for,
the
I'll go into more detail on that tomorrow.
So I want to touch on high burnup fuel
24
cladding integrity.
And the last time we talked
25
about this, with the risk, again, I put this up
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1
here.
And, I think, we talked a little bit about
2
the
3
retrievability
4
maybe that wording came from.
5
When
we
I
focus
operational
safety
ISG,
6
Regulation,
7
highlighted here.
8
fuel
9
ruptures.
against
problems
and,
I
look
think,
at
on
that
this
this
the
was
in
is
part
things
the
where
of
that
the
I've
One, you know, protecting the
mechanisms
that
lead
to
gross
I think that's very important.
10
And, second, such that the degradation
11
would
pose
12
think, those two are key things to keep in mind and
13
exactly
14
slide.
how
15
operational
the
So
safety
Regulations
if
I
problems.
are
take
And,
written.
a
I
Next
risk-informed
16
perspective on fuel cladding, it sits in the dry
17
storage environment, it's been inerted, it's got a
18
helium environment in there, there's no significant
19
stresses
20
under normal, off normal, or accident conditions.
on
the
fuel,
in
storage,
whether
it's
21
The casks are designed to prevent the
22
canister from losing its confinement integrity, and
23
also, protect the fuel, during the various accident
24
and normal/off normal conditions that are required
25
to be analyzed by the NRC, to ensure safety.
Going
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1
back to the PRAs that were conducted, previously.
2
We've talked about those, they show very, very low
3
risks.
4
EPRI
gave
a
presentation
at
our
Used
5
Fuel Management Conference, last year, which said,
6
you know, kind of, looked at this holistically, the
7
high burnup fuel issue, and came up, and I put a
8
couple of the conclusions in there that high burnup
9
fuel is likely not brittle.
10
We're seeing now that the temperatures
11
are not getting up into the 400 degrees C-range, or
12
even in the 320 degree C-range, where you get a
13
significant amount of high dried re-orientation.
14
And so I go down to the second EPRI
15
results, best estimate, little or no re-orientation
16
should be expected, during dry storage.
17
only is the fuel maintained within the cask, but
18
we're seeing that these mechanisms that were found
19
in some of the ring compression testing, may not
20
actually be occurring to the extent that they would
21
at 400 degrees C.
22
And
then,
which
is
finally,
also
the
And so not
fuel
the
fuel
internals,
24
geometric
25
criticality, that it's unlikely, even for accident
which
is
to
cask
23
rearrangement,
particular
and
important
for
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1
conditions that you're going to get any significant
2
fuel reconfiguration.
3
And
even
if
you
do
get
fuel
4
reconfiguration, you have that confinement boundary
5
in place, and so there are no consequences and if a
6
confinement
7
don't,
8
out,
9
getting in that you would need to sustain a nuclear
10
boundary
one,
but
you
then
remains
don't
you,
also,
criticality reaction.
11
The
place,
then
radionuclides
don't
have
you
leaking
the
water
Next slide.
other
point
I
wanted
make
13
certainly, the NRC, the surf testing, you know, I
14
think, was a very good piece of research, in terms
15
of
16
pellet,
17
interaction
18
holistically,
19
compression testing, which was just looking at the
20
material properties of the cladding, itself.
actually
the
fuel
looked
at
with
the
rod
between
rather
research
is
there's
it
significant
to
12
that
still
have
in
the
the
with
entire
pellet,
cladding
than
ongoing,
and
some
and
the
of
fuel
the
pellet,
the
ring
21
There's some ongoing studies by Sandia,
22
they've already done on the road, vibration tests
23
of an instrument assembly.
24
They're now going to be doing one with a full size
That was on a road.
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1
cask on a railcar, so there's some of those that
2
are going to be going on.
3
Obviously,
there's
the
DOE
EPRI
4
Demonstration Program that's going to provide some
5
additional
6
burnup fuel with storage times.
7
before,
8
Testing of high burnup fuel.
verification
the
9
Oak
of
Ridge
no
ISFSI
of
high
And, I mentioned
Sponsored
Fatigue
Next slide.
I can't help but note
10
that
11
knowing about its roads, which are terrible, I mean
12
that is probably not a useful thing.
13
is
behavior
Energy
MEMBER POWERS:
there
the
in
MR. CUMMINGS:
New
Mexico.
Right.
And
so
Well, there's no
14
ISFSI there now, and there has been a proposed one
15
there, in Texas, and those are very similar, so --
16
17
MEMBER POWERS:
Mexico with Texas.
18
(Laughter)
19
MEMBER
20
But do not confuse New
POWERS:
You'll
piss
off
the
Texans.
21
MR.
CUMMINGS:
Yes,
I
have
a
22
sister-in-law who is Texan, and I would never dare
23
make
24
slide.
that
mistake
to
confuse
those
two.
Next
So I think another point is the link to
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1
retrievability,
you
know,
it's
funny,
because
I
2
want to call this back, there and back again, going
3
back.
4
Revision O, it was, maybe, two paragraphs, and it
5
really said retrievability can be defined, as the
6
ability to go get the cask, put it in a transport
7
cask, and take it off.
8
later, we've been -- it's 15, or five pages, excuse
9
me.
If you go back and actually look at ISG-2
10
Well,
but
And now, you know, 15 years
still,
we're
going
back
to
11
where we were when we first designed these casks,
12
which was, as long as we can show that we can go
13
get
14
transportation, be able to ship it and get it to a
15
facility
16
something
17
definition of retrievability.
that
18
canister,
where,
more
get
maybe,
with
And
that
you
it,
we're,
cask,
would
then
be
that
certainly,
prepare
able
to
meets
very,
for
do
the
are
19
complimentary of the NRC to take on that effort, to
20
go back and look at this again, after having made
21
the
22
retrievability.
decision
to
go
to
individual
fuel-based
23
And just, the last thing is that, you
24
know, even if something happens to the fuel, even
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1
if it's minor, we have the ability to handle fuel
2
with gross ruptures, small ruptures, I mean, I go
3
back to, you know, when I first started working for
4
Holtec, they loaded the Trojan Fuel into dry cask
5
storage and included in with some of that fuel were
6
fuel debris cans with pallets and fuel assemblies
7
that had broken off rods.
8
And
it
is
perfectly
viable
for
the
9
Industry to be able to go in and take fuel that's
10
not in a pristine condition, put it into dry cask
11
storage, leave it there, and be able to, either,
12
analyze it for potential realistic configurations,
13
or
14
configuration going forward.
to
ensure
15
that
that
fuel
remains
in
a
safe
Next slide.
So I want to talk a little bit about
16
PRA Metrics.
We met with the NRC, I think, it was
17
in February of last year, where they were talking
18
about updating the previous PRA study that was done
19
before.
20
copy of one of my slides from there.
And so this is just is, pretty much, a
21
And at that point, we said, look, we
22
still
think
latent
cancer,
or
prompt
fatality
23
metric, it is one good way to go, because it does
24
allow you to do a direct comparison of the risks,
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1
which
include
2
reactor-related risks, and we had some discussions
3
about that.
4
consequences,
MEMBER
as
POWERS:
part
Why
go
to
the
to,
to
5
fatalities and not just go ahead and stick with
6
dose?
7
MR. CUMMINGS:
8
and
9
dose, dose might be another way to do it.
10
we
have
come
back
That's a good question,
and
said,
you
know
what,
But, I
think, the most --
11
MEMBER POWERS:
there's
one
I think dose is just so
12
much,
step
13
controversial that you avoid, by going with dose.
14
MR. CUMMINGS:
15
MEMBER POWERS:
in
Sure.
there
that's
Sure.
And, especially, here.
16
I mean, the fatality metric is, is just extremely
17
small --
18
MR. CUMMINGS:
19
MEMBER POWERS:
20
Yes.
Right.
-- here, whereas dose,
at least, gives you a number that's comprehensible.
21
MR. CUMMINGS:
Right, right. Yes.
And
22
we're certainly open to that.
What I think is very
23
important and I had a chance to look at Donald's
24
slides before today, and, you know, I think, what's
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1
missed
2
part.
by
3
4
confinement
breach,
MEMBER POWERS:
MR. CUMMINGS:
6
MEMBER POWERS:
7
MR. CUMMINGS:
MEMBER POWERS:
10
MR.
CUMMINGS:
Yes, I, I mean, it, I
Because, other ways --- I just don't see --- other ways, you know,
-- that you use the -You
get
this
illusion
that confinement breach then --
12
MEMBER POWERS:
13
MR.
14
consequence
--
9
11
the
--
5
8
is
CUMMINGS:
Yes.
--
is
this
massively
consequential, can't have it --
15
MEMBER POWERS:
16
MR. CUMMINGS:
Consequence.
-- horrible result, when
17
you really look, and in my previous life, I've done
18
those
19
sophisticated
20
simplicity,
21
get back to, hey look, the consequences are really,
22
really small.
consequence
codes,
in
analysis,
MAX
accordance
II,
I've
with
using
done
ISG-5,
very
it
you
very
always
23
Because, realistically, what's going to
24
happen if you have a loss of confinement, with a
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1
through wall crack, the noble gases out, and that's
2
even if you have cladding deformations.
3
If
you
don't
have
any
cladding
4
deformations, you've got all intact fuel, most of
5
the fuel is intact.
6
intact, most of the fuel rods are intact.
7
And even the stuff that's not
It may have one leaking fuel rod in one
8
of
the
rods
9
really only going to get the noble gases to come
10
out.
11
anything.
of
a
single
fuel
assembly,
Those aren't very reactive with, with much of
12
That's, there are no gases --
13
MEMBER POWERS:
14
MR.
15
you're
No more --
CUMMINGS:
Right.
Exactly.
Exactly.
16
MEMBER POWERS:
17
MR. CUMMINGS:
18
MEMBER POWERS:
19
their dose consequence --
20
MR. CUMMINGS:
21
MEMBER POWERS:
22
MR. CUMMINGS:
this
that
But -So -But more importantly,
Right.
-- numbers are low.
Right.
EPRI
will
Right.
be
So Keith
23
mentioned
doing
some
24
consequence analysis and I've been trying to assist
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1
them with getting some of the previous work that,
2
either, I, or other people, have done, so that they
3
know, kind of, some of the approaches that can be
4
taken.
5
CHAIRMAN BALLINGER:
6
why
the
7
first?
consequence
8
9
analysis
MR. CUMMINGS:
Well, one wonders,
shouldn't
have
been
Well, I would actually
say that the consequence analysis is out there.
I
10
mean, it's been done before.
11
perspective,
12
nobody's ever come back to it again, because, well
13
why do I need to calculate 1 x 10 - 14?
14
the
It's just, from my
consequence
MEMBER
POWERS:
is
But
so
what
low
are
that
the
15
problems that you, you truthfully had in this, to
16
be completely fair?
17
many, many of your scenarios are going to result in
18
just a noble gas release.
19
MR. CUMMINGS:
20
MEMBER POWERS:
21
Because, I agree with you,
Right.
But you cannot discount
the more extreme scenarios --
22
MR. CUMMINGS:
23
MEMBER POWERS:
24
Right.
Right.
-- where you will get a
particular release.
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1
MR. CUMMINGS:
2
MEMBER
3
Sure.
POWERS:
MR. CUMMINGS:
5
MEMBER POWERS:
8
MEMBER POWERS:
poor
-- on estimating what
the
consequence
Right.
analysis.
Okay that complicates
Is
it
insurmountable,
absolutely not.
11
MR. CUMMINGS:
12
MEMBER POWERS:
13
in
those particles look like.
MR. CUMMINGS:
10
are
Yes.
7
9
we
stead --
4
6
And
Right.
Right.
It just hasn't gotten
the attention.
14
MR. CUMMINGS:
15
MEMBER POWERS:
at
the
Right.
But, I think, without
16
looking
consequences,
17
don't think you need to go to, to actual fatalities
18
and --
19
MR. CUMMINGS:
20
MEMBER POWERS:
at
least,
dose,
I
Right.
-- and I think there
21
are complications in doing that in this context.
22
But, to look at the actual releases, the only way
23
to put it in perspective, the fact that you're not
24
talking
about
a
three
million,
a
three
billion
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1
curie source --
2
MR. CUMMINGS:
3
MEMBER POWERS:
4
Right.
Correct.
-- on the front end of
this accident scenario.
5
MR. CUMMINGS:
6
MEMBER POWERS:
Correct.
And so when you make
7
those reactor analogies, you're inherently implying
8
that three billion curie source --
9
MR. CUMMINGS:
10
11
MEMBER POWERS:
MR. CUMMINGS:
13
MEMBER POWERS:
14
MR. CUMMINGS:
15
MEMBER POWERS:
-- and that's just not
Correct.
-- nothing here.
Right.
Right.
I don't care how you do
it, --
17
MR. CUMMINGS:
18
MEMBER POWERS:
19
Correct.
--
12
16
Right.
Right.
-- you cannot get to
those kinds of potential releases.
20
MR.
CUMMINGS:
Yes,
the
path
for
21
release of the particular finds, the volatiles, the
22
gases, the aerosols, are a very small percentage of
23
what is actually even in the cask contained in the
24
cladding.
You really have to have some of these
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1
severe,
I
would
call
them,
2
scenarios, with massive damage to the fuel, to even
3
get enough of a source term in the cask cavity --
4
MEMBER POWERS:
5
MR. CUMMINGS:
6
somewhat
unrealistic
I mean, we're --- that would even be
available for release.
7
MEMBER POWERS:
-- we're worried about,
8
or
rare events, and rare events with, I mean, the
9
hypothesis of an airplane crash effecting multiple
10
cancers
was
raised
here,
11
canisters, I can't call that zero.
12
to, at least, give a pass and consideration, but --
13
MR. CUMMINGS:
14
MEMBER POWERS:
or
effecting
multiple
And so you need
Right.
But, I think, you have
15
to go to consequences to get any kind of comparison
16
--
17
MR. CUMMINGS:
I agree.
18
CHAIRMAN BALLINGER:
But, for the most
19
probable scenario, even if it is probable, once you
20
depressurize
21
equal across it, the event is over.
the
canister,
22
MR. CUMMINGS:
23
CHAIRMAN
24
once
Right.
BALLINGER:
the
pressure's
So -Of
course,
the
whole --
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1
MR. CUMMINGS:
You might have a little
3
MEMBER POWERS:
Oh I --
4
MR. CUMMINGS:
-- breathing of the cask
MEMBER POWERS:
-- I don't think that's
2
5
bit of --
and --
6
7
true.
8
CHAIRMAN BALLINGER:
9
MEMBER
10
Because
the
rod's
pressured.
11
12
POWERS:
No?
CHAIRMAN BALLINGER:
Oh, so you have to
get the rods, as well?
13
MEMBER POWERS:
Yes, you have to crack
14
the canister, then you fill the rod --
15
CHAIRMAN BALLINGER:
16
MEMBER
POWERS:
17
burst release.
18
over just because you've --
19
Okay.
And
then
you
get
a
And so I don't think the action's
MR. CSONTOS:
And, also, I think one of
20
the things to think about is that, when we do see
21
these types of this mechanism, on the reactor side,
22
it's usually not just one crack, it's usually many
23
cracks, okay.
24
another one and then another one, but if that's,
It may go through a wall, and then,
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1
that's
what
2
terms
of
3
locations.
4
we've
piping
Now,
but,
seen
on
systems
there
there's
the
reactor
and
other
will
be
breathing
a
side,
types
in
of
limited
extent,
other
things,
5
still,
and
6
these are all things that I was telling you about
7
before that, if we start going down this path of
8
consequence analysis, there's lots of stuff we need
9
to start thinking about, and lots of stuff cost a
10
lot of money to start evaluating.
11
point in time, we may not be in that place to be
12
able to handle that in our resource department.
13
MR.
LOMBARD:
I
And, at this
think
that's
why
14
defining the balance of the analysis and the input
15
assumptions, though, are very critical --
16
MR. CUMMINGS:
17
MR.
LOMBARD:
18
the consequence analysis.
19
MR. CUMMINGS:
20
MR.
LOMBARD:
They are critical.
--
moving
forward
with
Correct.
Make
them
realistic,
21
maybe, do some type of sensitivity analysis, some
22
sensitivity study, as part of it, but to keep them
23
as realistic, as possible, based on the data that
24
we have.
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1
MR. CUMMINGS:
Well, and I think that's
2
important to, not only look at, maybe, some of the
3
bounding
4
realistic scenarios, so that you have a feel for
5
what
6
also, to add another complexity to it, you know,
7
you've also got the fact that, what we talked about
8
earlier that, the social term is decreasing with
9
time,
10
that
scenarios,
is,
and
so
and,
but
and,
you've
got
also
you
to
know,
something
look
I
at
the
think
with,
it's
like,
CISCC, which takes decades to occur.
11
And so as time goes on that source term
12
is
decreasing
and
13
could happen to the fuel, if you do have loss of
14
confinement,
15
because the temperature's decreasing.
you
the
potential
know,
reduced
impacts
with
of
time,
what
also,
16
And so I mean, you're getting into a
17
lot, you know, you could make this really, really
18
complex.
19
either do it in a bounding manner, but, I think,
20
again, we've had good discussions with the NRC to,
21
don't just go out and try to do the most bounding
22
thing that you can, to try to, you know, bless it
23
away, maybe, do that and then look at some of these
24
sensitivities of what might be more realistic, so
Typically,
we
try
to
simplify
it
and
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1
that you have a good feel for, kind of, the more
2
probable and the what if.
Next slide.
3
So in summary, having an efficient dry
4
storage licensing process is essential for managing
5
the dry cask storage systems that are out there.
6
Like I said, there's 2,200 systems plus.
7
simply grow.
8
or 2022, we're going to have about half of the fuel
9
in dry cask storage.
It will
I think our projections are by 2021,
10
We have achieved some success with the
11
NRC in applying a risk-informed framework in some
12
focused areas, specifically, retrievability is one
13
of
14
72.48
15
progress, especially, recently on that.
those,
having
process,
16
and
I
a
common
think,
And
then,
how
we
understanding
we've
certainly,
develop
some
the
good
NUREG-1927
1403,
18
Programs
and
how
19
flexible
and
considerate
20
going to learn stuff, especially, in the next five
21
or ten years, as we go forward.
allow
of
those
the
Aging
and
17
we
the
had
of
Management
programs
fact
that
to
be
we're
22
But we would certainly like to see the
23
NRC pick up 72-7 and implement that, the principles
24
that are in there, so that we can reduce the level
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1
of
detail
that's
in
flexibility
to
2
more
3
changes, especially, to the contents.
4
the
certificates,
the
CoC
and
holders,
allow
to
make
You know, just case in point, if you
5
want
to
add
a
new
fuel
assembly
that's,
pretty
6
much, identical to the ones that have already been
7
licensed for the casks, you have to go back to the
8
NRC for a licensed member request for that.
9
Reactor side, they're able to make fuel
10
design changes, under 50.59, especially, if you're
11
going from one to another.
12
the
13
different on both sides, but the level of detail in
14
our certificates for dry cask storage is, I would
15
say, in order of magnitude, higher than what's on
16
the reactor side and we would like to bring that,
17
at a minimum, in line with the reactor level of
18
detail.
licensing
19
process
MEMBER
There's some nuances in
that
are
SKILLMAN:
a
Kris,
little
I'm
not
bit
sure
20
that's completely accurate.
21
you have to submit your COLR, your Core Operating
22
Limits
23
analysis for that new fuel.
24
upon your COLR --
Report,
in
which
When you change fuel,
you
embed
all
of
your
So you actually do,
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1
MR. CUMMINGS:
You do, but --
2
MEMBER SKILLMAN:
-- licensing of what
3
will be, if you will your reload, plus your LTAs,
4
or whatever you're going to load.
5
MR.
from
CUMMINGS:
8
However, if you switch from, say, an RFA-1 to an
9
RFA-2, some of that and, especially, large parts of
10
a scope of that, could be done under 50.59, with
11
maybe just the things that needed to be changed in
12
the tech spec.
But
the
license
methods,
you
member
know,
then
a
typically,
a
another,
make
7
to
to
you
change
have
vendor
if
6
13
one
Sure,
you,
request.
would
not
14
have been changed, you would've used the methods
15
that were already in the COLR.
16
that there are a little bit of nuance differences
17
in the licensing regime there.
18
MEMBER
So yes, I recognize
SKILLMAN:
Have you all seen it?
Have
we
seen
PRM
19
72-7?
20
raise the issue is just for my own understanding of
21
what you are asking for.
22
MR. CUMMINGS:
23
MEMBER SKILLMAN:
24
members
have
seen
PRM
So the only reason I
Okay.
And I don't think the
72-7.
That
might
be
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1
something that would be --
2
MR. CUMMINGS:
Specifically.
3
MEMBER SKILLMAN:
4
MR.
Okay, thank you.
CUMMINGS:
I
mean,
just
very
5
quickly, to summarize, it's essentially, in 50.36
6
there are criteria for what you include in the tech
7
specs,
8
criteria
9
something
we're
simply
and
have,
very
saying,
either,
similar
let's
those
that's
cask storage.
11
that, in that proposed rulemaking.
those
criteria,
applicable
10
12
take
to
or
dry
That's the biggest thing that's in
MR. LOMBARD:
If you look at 72-7, I'd
13
ask you to keep in mind our current environment in
14
the rulemaking space and how that rulemaking would
15
score.
16
and how it would score in the future --
17
MEMBER POWERS:
Fortunately --
18
MR.
--
19
LOMBARD:
MEMBER POWERS:
with
the
-- we are blessed with
a proscription of, against managing the agency.
22
(Laughter)
23
MR. LOMBARD:
24
pertaining
rulemaking.
20
21
How it would have scored, even a year ago,
I understand that and our
plan is to achieve some of the goals, as many as
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1
possible, if any, through SRP development and the
2
risk-informing
3
together,
4
that, in future, after you get your eyes on 72-7.
and
5
we
can
question
7
anyway.
that's
8
totally
MR. CUMMINGS:
we're
another
putting
discussion
on
Kris, let me ask you a
unfair,
but
I'll
ask
it
That's fine, I wouldn't
expect anything less from you.
10
(Laughter)
11
MEMBER POWERS:
12
that
have
MEMBER POWERS:
6
9
framework
I just wondered if NEI
had any particular view on deep boreholes?
13
MR. CUMMINGS:
14
(Laughter)
15
(Simultaneous speaking.)
16
MR.
CUMMINGS:
Oh jeez.
I'm
trying,
I'm
just,
17
I'm pausing, because I'm trying to think of what is
18
-- Rod, do you want to -- I'm trying to make sure I
19
don't
20
before.
21
sure he gets it right.
say
something
different
(Laughter.)
23
MR. McCULLEN:
used
what
we
said
I'm going to defer to my boss, to make
22
24
than
fuel
position,
we
Yes, we haven't, in our
haven't
staked
out
a
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1
particular position on deep boreholes, but we do
2
know, and I think DOE has come to realization, as
3
well, that it's very unlikely that it will be any
4
kind
5
fuel.
6
I think that's one of the reasons DOE is splitting,
7
you
8
repository, because -- and they're, DOE is not, the
9
answers that DOE is not, currently, not looking at
10
deep boreholes for commercial used fuel and I think
11
we're in agreement with, if you're going to, if
12
you're going to look at boreholes that's probably a
13
good distinction to make.
of
a
foreseeable
future
solution
for
used
It would be more likely for smaller sources.
know,
14
they're
considering
MEMBER POWERS:
splitting
the
Yes, I think the -- I
15
really, honestly, don't know where they stand, but
16
at one point they were contemplating the test on
17
it, but not, not for commercial fuel, for DOE-type
18
waste.
19
MR. CUMMINGS:
20
MR.
21
By
Yes.
the
way,
for
the
record, I was Rod McCullen, at NEI.
22
23
McCULLEN:
Yes.
MR. CUMMINGS:
something.
24
Thank you.
I knew I brought him for
And now --
(Simultaneous speaking.)
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1
MR. CUMMINGS:
2
MR. McCULLEN:
My arm's twisted -Just trying to make you
3
look good, Kris, that's all I'm doing, I'm playing
4
the straight guy here.
5
(Laughter.)
6
MR.
CUMMINGS:
MR.
LOMBARD:
7
last,
but
not
pages
of
least.
8
9
Okay,
closing comments.
were
I
No.
three
I really don't.
know,
there
11
about
today,
12
Subcommittee's
13
these topics to you and give you an idea of the
14
overall environment that we deal in, as well as,
15
these
16
technical topics that we brought before you today.
again,
time
specific
I
things
we
to
don't
really
be
technical
that
think
it's
talked
appreciate
able
topics
we've
I, you
10
17
many
have
to
and
a
bring
some
big
the
these,
not
benefit
so
to
18
rehash those topics, and we had great discussion
19
and, I think, through those discussions that we did
20
state what our, kind of, where we're coming from,
21
in each one of those technical topics.
22
So I'd rather just leave it open for,
23
for feedback from you all, if there's any other
24
questions
that
you
didn't
ask
earlier,
on
the
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1
technical topics, and also, leave time for public
2
comments, which is on your agenda.
3
CHAIRMAN
BALLINGER:
Thank
you.
Thank,
4
everybody. I think we now, are there people in the
5
audience that would like to make a comment, while
6
we're getting the line open? Pete, are you still
7
there?
8
(No response.)
9
CHAIRMAN
BALLINGER:
Apparently
not.
10
They, apparently, got four feet of snow.
11
sent us a picture. Put a real crimp on his style,
12
he was teaching skiing out in Denver.
13
MEMBER RICCARDELLA:
14
(Laughter.)
15
MEMBER RICCARDELLA:
16
CHAIRMAN
BALLINGER:
MEMBER RICCARDELLA:
20
CHAIRMAN BALLINGER:
Do
you
have
any
Nope, nope, I -Because we've got
to go around the table, then.
22
23
I'm still here, I
comments, Pete?
19
21
I'm sorry.
didn't take off, as much as I was tempted to.
17
18
And he
MEMBER RICCARDELLA:
-- thought it was
very, very informative.
24
CHAIRMAN
BALLINGER:
It
sounds
like
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1
something's open. Are there any folks out on the
2
public line that would like to make a comment?
3
MS.
GILMORE:
Yes,
this
is
Donna
4
Gilmore.
5
experience
6
have, but since we haven't been able to inspect any
7
of them for cracks, we have no idea how many cracks
8
they have, or how deep the cracks are, so --
9
There was mention about having a lot of
with
these
And
then,
the
we
something
12
60
13
assessment of, you know, of that issue and does it
14
affect our aluminum?
there
in
wasn't
determined that the aluminum may last longer than
think,
the,
that
11
I
that
probably
addressed
and,
fact
so
10
years
is
canisters,
Japan,
needs
to
they
be
an
15
And there's also a March Sandia Report,
16
March 2015, that, due to the, it was stating that
17
due to the higher temperatures of our canisters,
18
those
19
years, or less.
cracks
20
I
could
don't
go
through
know
if
the
you're
wall
in
five
familiar
with
21
that, I'm, I could share documents for what I'm
22
talking
23
comments, but I think I might take an hour or so
24
I'll just, I'll stop at this point.
about
here.
I
have
a
lot
of
other
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1
CHAIRMAN
BALLINGER:
2
much.
3
like to make a comment?
4
MR. LEWIS:
5
Thank
you,
very
Is there anybody else out there that would
My name is Marvin Lewis,
member of the public.
6
CHAIRMAN BALLINGER:
7
MR. LEWIS:
Yes, Marvin.
All right, look, back when
8
WIPP, Waste Isolation Pilot Project, was starting,
9
we're going to get the same problem, as they do in
10
the Ukraine.
11
And,
nothing's
going
to
burn
down
12
there, we're going to have all this waste packed in
13
bentonite and a, an inorganic.
14
ago, sure enough, things started burning at WIPP
15
and,
16
bentonite, it was packed in a wood waste.
sure
17
enough,
And
the
I'm
waste
Well, a few months
was
wondering,
not
just
packed
how
in
many
18
assumptions and how many promises will be kept with
19
these
20
enriched spent fuel casks and how many assumptions
21
will be right?
22
are the fires still burning at WIPP?
high-level
23
24
spent
fuel,
I
mean,
highly
And I'm wondering, also, is this,
CHAIRMAN
BALLINGER:
Thank you.
Thank
you.
Anybody else that would like to make a comment out
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1
there?
2
(No response.)
3
CHAIRMAN BALLINGER:
4
can close the line.
5
member comments. Dick?
6
We can go around the table for
MEMBER
7
comments
earlier
8
presenters today.
9
of
presentations
Hearing none, we
SKILLMAN:
and
I
No,
appreciate
I
made
my
of
the
all
This has been a good solid set
that
have
really,
in
my
view,
10
identified a number of action items that we, in the
11
ACRS need to take, but it's also made us aware of a
12
lot of action in the Agency that we had not been
13
aware of, and also NEI.
14
presentations and, thank you.
So thank you, for today's
15
CHAIRMAN BALLINGER:
16
MEMBER POWERS:
these
one
were,
18
presentations that we've had in a long time and I
19
thank
20
enjoy this.
Chairman
of
Well, to be sure, these
17
the
was
Dr. Powers?
for
the
best
bringing
CHAIRMAN BALLINGER:
22
MEMBER
POWERS:
failings in other respects.
24
us
together,
of
to
This was terrific.
21
23
sequences
CHAIRMAN
Pathological liar.
Despite
his
obvious
Technically --
BALLINGER:
Now
he's
not
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1
lying.
2
MEMBER
POWERS:
Technically,
I
think
3
there are just a couple of points that I'd like to
4
make.
One is, I reiterate that, yes, we need to
5
think,
not
6
failure, frequencies alone, but we do need to do,
7
go to some sort of level three kinds of analysis.
in
terms
of
crack,
or
containment
8
I don't think it merits the kinds of
9
detail we do for the reactors, because I think we
10
know that the source term is just not, as big, but
11
we
12
radioactivity we're, we can potentially expose to
13
the public here, just to put things into a proper
14
context.
need
to
have
some
feeling
for
how
much
15
The other one is, I'd like to remind
16
the Committee, in thinking on this subject that, we
17
are prescribed, by Charter, for managing the Agency
18
with
19
technical
20
because
21
responsibility.
whatever
22
23
charge
advice,
the
we're
whether
resources
giving
they
are
the
can
not,
CHAIRMAN BALLINGER:
Commission
take
is
it
out,
not
our
Thank you.
Right.
I'm looking at Charlie.
24
MEMBER BROWN:
You're looking at me in
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1
trepidation.
2
I'll
3
times, but I do appreciate the presentations.
make
No, I made my only real comments,
earlier
is,
is
I
voiced
a
couple
of
4
I agree with Dan and Dick that, it was
5
well-organized and well put together and, I think,
6
there was a lot of good ongoing back and forth and
7
discussion that was very open and very positive, so
8
I
9
clarified
10
thank
you.
a
I've
number
learned
of
a
good
questions
that
bit
and
it
I
had
in
like
to
preparing for it, so thank you.
11
CHAIRMAN
BALLINGER:
And
I'd
12
thank you, all the presenters, everybody.
It was
13
really an outstanding, long day, but outstanding.
14
Regarding what Dick's comment was on action items,
15
I've got, at least, three that we need to think
16
about, we have, we was going to pick up tomorrow
17
morning and talk about 1927, but the issues that we
18
have to think about are 1927 and a meeting with the
19
full Committee, related to that.
20
ISG-2, there's been a suggestion that,
21
that the staff could go and make the word changes
22
that we've suggested, but that, once that is made,
23
that does not rise to level of coming to the full
24
Committee,
or
anything
like,
so
that's
another
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1
thing to discuss, maybe, at the end of the day,
2
tomorrow.
3
And, third, we have been challenged by
4
the
staff
5
session,
6
Subcommittee
7
risk-informing and the whole, that whole issue, and
8
so Kris is taking that up.
a
to
participate
closed
and
in
a
brainstorming
other
brainstorming
session
members,
of
the
related
to
9
And we're trying to, we actually had a
10
time slot in May, which we had gave up, but now
11
we're trying to get it back.
12
thing that's on our, on our plate.
So there's another
13
And, I think, we had some discussions,
14
amongst ourselves, earlier, and I think Dick talked
15
with John Stetkar, as well, so I think we're all,
16
in generally, very much in favor of something like
17
that.
18
So those were the three things that --
19
was there any other action item that you thought we
20
had to deal with?
21
(No response.)
22
CHAIRMAN BALLINGER:
Okay.
Then, thank
23
you, very, very much for participating in this and
24
coming
before
us
and,
again,
it
was
really
an
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1
outstanding day.
2
MR. CUMMINGS:
3
CHAIRMAN
4
BALLINGER:
(Laughter.)
6
CHAIRMAN
we
look
BALLINGER:
We
are
now
adjourned.
8
9
And
forward to another outstanding half day.
5
7
Thank you.
(Whereupon, the meeting in the aboveentitled matter was concluded at 4:42 p.m.)
10
11
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Overview of the
Spent Fuel World
Mark Lombard, Director
Division of Spent Fuel Management
Meeting with Advisory Committee on Reactor Safeguards
Subcommittee on Metallurgy & Reactor Fuels
Framework for Storage and Transportation of Spent Fuel
March 23, 2016
Agenda
•
•
•
•
•
•
•
•
Roles and Responsibilities
Part 71
Part 72
The New Paradigm
Interim Consolidate Storage
The Perfect Storm
ACRS Topics
Successes
2
Roles and Responsibilities
• Licensing, Certification, and Inspection
– Part 71
• Spent fuel transportation packages
• Radioactive material transportation packages
– Part 72
• Spent fuel storage facilities
• Spent fuel dry cask storage systems
– Vendor, QA, and ISFSI inspections
• Coordination with:
– State and federal agencies (most notable DOT and
DOE, but also EPA)
– Foreign and international regulatory agencies
– Native American tribes
• Public outreach
3
Division Branches
•
•
•
•
•
Confinement, structural, thermal (CSTB)
Criticality, shielding, dose, risk (CSRAB)
Materials, renewals (RMB)
Project managers (SFLB)
QA, inspection, oversight, rulemaking
(IOB)
4
Transportation of
Radioactive Material, Part 71
• Approximately 100 active Certificates of Compliance
(CoCs)
• 50-70 transportation cases each year
• Support transport of nuclear materials used for:
–
–
–
–
Spent fuel
Medical and industrial applications
Power and research reactors
Fuel cycle facilities
• Work closely with DOT in both domestic and
international transportation
• Also coordinate with DOE, States,
and IAEA
5
Dry Cask Storage, Certificates
of Compliance, Part 72
• Approximately 12 active storage
CoCs
• 20-30 storage cases each year
• Coordination with DOE project
planning and research
organizations
• Significant engagement with
stakeholders
6
Status of Independent Spent
Fuel Storage Installations
(ISFSIs)
7
The New Paradigm
• Uncertainty regarding backend
of the fuel cycle
• New paradigm
– Longer storage periods
– 72-71-72
• Interim Consolidated Storage
• DOE TSAR
8
Interim Consolidated
Storage
• Received letters of intent from Waste Control
Specialists and Holtec/Eddy Lea Alliance
to submit applications in 2016
• Potential DOE TSAR
• Part 72 is adequate for storage and
packaging
• Continue to monitor and coordinate, as
appropriate, with DOE and industry
9
FY16 – FY20
The Perfect Storm
WCS and Holtec
Normal
workload
CoC and ISFSI
Renewals
DOE TSAR
10
ACRS Meeting Topics
Fuel
Performance
Risk
Informed
Fuel
Performance
Renewal
STORAGE
Dry Storage
System
Performance
RETRIEVABILITY
TRANSPORTATION
Initial Storage
Term
Extended
Storage
System
Performance
11
Renewals
• Aging Management
– Time-limited aging analyses
– Aging management programs
• In-service Inspections
– Operations-based
– Appropriate monitoring and inspection techniques
and timeframes
– Assessment of monitoring data and inspection
findings
– Reporting, aggregating, and trending of operating
experience
– Learning aspect
12
Fuel Performance
• Demonstration Project
– Long-term demonstration program to provide
the confirmation of continued safe storage of
HBU fuel
– The NRC is closely monitoring
– Currently reviewing the North Anna License
Amendment for the HBU Demo cask
• ORNL Testing
– Research activities of high burnup spent fuel
rods specifically focused on the effect of
hydride reorientation on structural response of
spent fuel rods (cladding and fuel pellets) to
conditions experienced under 10 CFR Part 71
Microscopic Views of
Fuel Clad Hydrides
13
Risk-Informed Regulatory
Framework
• To better enable the staff to focus its spent fuel
storage regulatory efforts, improve guidance,
streamline casework activities, help assess 10 CFR
72.48 changes, and evaluate requests for
exemptions to the storage regulations while
maintaining appropriate margins of safety and
security.
• Currently developing risk framework to quantify the
impact of changes associated with components
important to safety on the overall risk of spent fuel
storage systems.
14
Retrievability
• In 2001, NMSS defined retrievability on a
fuel assembly basis
• Impractical in the New Paradigm
• Refined and broadened definition in ISG-2
• Allow options to approach
15
Future documents for possible
coordination with ACRS
• NUREG-1536/1567 – Consolidation of Storage Standard
Review Plans (SRPs)
– September 2016 (proposed final)
• High-Burnup Fuel Regulatory Issue Summary
– December 2016 (proposed final)
• Managing Aging Processes in Storage (MAPS) NUREG
Report
– January 2017 (proposed final)
• NUREG-1609/1617 – Consolidation of Transportation
SRPs
– May 2017 (proposed final)
• High-Burnup Fuel Technical Basis NUREG
– July 2017 (proposed final)
16
Successes
•
•
•
•
•
NUREG-1927, Revision 1
ISG-2, Revision 2
ORNL testing
ICSF review strategy
Risk informed framework status
– Defense in depth
– Safety goals
• Licensing process changes
17
Spent Fuel Storage
Renewal Framework
Kristina Banovac
NMSS/DSFM/RMB
Meeting with Advisory Committee on Reactor Safeguards
Subcommittee on Metallurgy & Reactor Fuels
Framework for Storage and Transportation of Spent Fuel
March 23, 2016
Fuel
Performance
Risk
Informed
Fuel
Performance
Renewal
STORAGE
Dry Storage
System
Performance
RETRIEVABILITY
TRANSPORTATION
Initial Storage
Term
Extended
Storage
System
Performance
2
Outline
• Background
– Requirements for spent fuel storage renewals
– NRC effort to identify needs for the storage renewal
framework
• NRC guidance development
• External infrastructure development
3
Background –
Storage Renewal Requirements
• Renewal of Independent Spent Fuel Storage Installation
specific licenses and Certificates of Compliance for dry
storage system designs, for a period not to exceed 40
years
• Maintain intended functions in the period of extended
operation
– Time-limited aging analyses
– Aging management programs (AMPs)
4
Background –
Effort to Identify Needs
• NRC staff experience with storage renewal reviews
indicated a need for expanded guidance
• NRC team assessed current regulatory framework to
determine what changes were needed
• Extensive stakeholder engagement and valuable input
received from stakeholders
5
Background –
Needs
• Operations-focused approach to storage renewals
– Learning, proactive and responsive
• Sustainable regulatory framework for storage renewals
• NRC guidance development and external infrastructure
development
6
Infrastructure for Updated
Storage Renewal Framework
TI / IP
Inspections
SRP 1927R1
Staff consideration of
Stakeholder inputs
NUREG-###
Managing Aging
Processes in Storage
(MAPS) Report
Temporary
Instructions &
AMA
Inspection
Procedures
Technical Consensus Storage/
Issue
Reactor
Codes
Resolution
OpE
MAPS
NUREG
SRP
NUREG1927R0
NEI
14-03
RG
Regulatory
Guide
DOE/ANL
Report
7
NRC Guidance Development
• NUREG-1927, Rev. 1 (Standard Review Plan for storage
renewals)
• Managing Aging Processes in Storage (MAPS) Report
• Guidance for NRC inspections of licensees’ aging
management activities
• Regulatory Guide
8
NUREG-1927, Rev. 1
• Revisions and updates made throughout Rev. 1
• Includes example AMPs
• Draft guidance published for public comment in July 2015
• Staff has considered public comments and has
developed proposed final guidance for coordination with
ACRS
• Path forward:
– engage with ACRS in March/April 2016
– Publish final guidance in summer 2016
9
MAPS Report
• Provide an acceptable generic approach to aging
management for dry storage systems
• Comparable to NUREG-1801 for reactor renewals
• Increase efficiency of preparation and review of storage
renewal applications
• Path forward:
– Engage with stakeholders and ACRS
– Publish draft guidance for public comment (summer 2016)
– Publish final guidance (summer 2017)
10
NRC Inspection Guidance
• Guidance for NRC inspections of licensees’ aging
management activities
– Verify that licensees are effectively implementing AMPs by:
• maintaining effective procedures for AMP
implementation
• conducting proper inspections and monitoring
• completing timely and effective corrective actions
– Temporary Instruction, Inspection Procedure
– Under development
11
Regulatory Guide
• Regulatory Guide that discusses storage renewal
guidance framework
– Vehicle for potential endorsement of industry guidance in
NEI 14-03
– Future development, pending NEI 14-03 review and MAPS
development
12
External Infrastructure
Development
• Consensus American Society of Mechanical Engineers
Boiler and Pressure Vessel Code Section XI Code Case
for inservice inspection of dry storage canisters
• Consensus American Concrete Institute Guide for
inservice inspection of concrete overpacks
13
External Infrastructure
Development (cont.)
• NEI 14-03, Rev. 1, Format, Content and Implementation
Guidance for Dry Cask Storage Operations-Based Aging
Management
• In-situ nondestructive examination capabilities
• International Atomic Energy Agency guidance on
development of AMPs for dry storage systems
14
Sustainable Renewal Framework
• Informed by review experience, operating experience,
and research
• “Learning” – aging management programs consider and
respond to operating experience
• “Living” – guidance will be updated over time, as needed
• Applicable to first and subsequent renewal periods
15
References
• Draft NUREG-1927, Rev. 1, Standard Review Plan for Renewal of
Specific Licenses and Certificates of Compliance for Dry Storage of
Spent Nuclear Fuel
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1927/r1/
•
Proposed Final NUREG-1927, Rev. 1 and responses to public
comments (for ACRS coordination)
ADAMS Accession No. ML16053A199
• NUREG-1801, Generic Aging Lessons Learned (GALL) Report
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1801/
• NEI 14-03, Rev. 1, Format, Content and Implementation Guidance
for Dry Cask Storage Operations-Based Aging Management
ADAMS Accession No. ML15272A329
16
Acronyms
• ACRS – Advisory Committee on Reactor Safeguards
• AMP – aging management program
• DSFM – Division of Spent Fuel Management
• MAPS – Managing Aging Processes in Storage
• NEI – Nuclear Energy Institute
• NMSS – Office of Nuclear Material Safety and
Safeguards
• RMB – Renewals and Materials Branch
17
Spent Fuel Retrievability
Emma Wong
Division of Spent Fuel Management
Meeting with Advisory Committee on Reactor Safeguards
Subcommittee on Metallurgy & Reactor Fuels
Framework for Storage and Transportation of Spent Fuel
March 23, 2016
Fuel
Performance
Risk
Informed
Fuel
Performance
Renewal
STORAGE
Dry Storage
System
Performance
RETRIEVABILITY
TRANSPORTATION
Initial Storage
Term
Extended
Storage
System
Performance
2
Outline
•
•
•
•
•
•
•
•
History
Regulations
Retrievability
Guidance
Paradigm Shift
Proposed Guidance
ISG-2
Updating Guidance
3
Regulatory History
1982 Nuclear Waste Policy
Act Section 141(b)(1)(C)
1988 Final Rulemaking
10 CFR 72.122(l)
1990 Final Rulemaking
10 CFR 72.236(m)
• NWPA Section 141(b)(1)(C) as amended
“to provide for the ready retrieval of such spent fuel and waste
for further processing and disposal”
• Codified in 1988 rulemaking to add 10 CFR 72.122(l)
• 1990 rulemaking added 10 CFR 72.236(m) for CoCs
to consider design consideration of retrievability
4
Applicable Regulations
• 10 CFR 72.122(l) - Retrievability
“Storage systems must be designed to allow ready
retrieval of spent fuel, high level radioactive waste,
and reactor-related GTCC waste for further
processing or disposal”
• Applies to general and specific licensed ISFSIs
5
Applicable Regulations(con’t)
• 10 CFR 72.236(m)
“To the extent practicable in the design of storage
casks, consideration should be given to compatibility
with removal of the stored spent fuel from the reactor
site, transportation, and ultimate disposition by the
Department of Energy.”
• Applies to storage CoCs
6
Retrievability
7
Guidance
1998 ISG-2 Rev. 0
Fuel Retrievability
2001 SECY-01-0076
Retrievability of Spent Fuel from
Dry Storage Casks
2010 ISG-2 Rev. 1
Fuel Retrievability
• “…the ability to move a canister containing spent fuel
to either a transportation package or to a location
where the spent fuel can be removed. Ready retrieval
also means maintaining the ability to handle individual
or canned spent fuel assemblies by the use of normal
means.” (ISG-2, Rev. 1)
• Reflected a time of a near term
repository
8
Paradigm Shift
2010 COMSECY-10-0007
Project Plan
2011 & 2012 Public Meetings
Licensing and Inspection
Enhancements
2013 Request for Public
Comments on Retrievability
• Long term performance of aging internal components
– Ongoing agency and industry research
• Unintended consequences of current guidance
– Difficulties in assessing internals may lead to opening the
cask/canister
– May increase worker dose & degrade/eliminate the
confinement boundary
9
Proposed Guidance
2015 July Public Meeting
Retrievability of Spent Fuel
2015 FRN & Draft ISG-2 Rev. 2
Fuel Retrievability
2015 October Public Meeting
Draft ISG-2 Rev. 2
• Interactions with the public
• Draft ISG-2, Rev. 2
– Continue to protect public health and safety
– Ensure spent fuel can be retrieved from storage safely for
further processing or disposal
– Provide guidance to the NRC staff on licensing reviews
10
ISG-2
• Current revision 1
– Ability to move a canister containing spent fuel to
either a transportation package or to a location
where the spent fuel can be removed and
– Ability to handle individual or canned spent fuel
assemblies by the use of normal means
• Draft revision 2
– Focuses on safety and design bases to allow
maximum flexibility to maintain safety for an
undefined storage duration
11
Ready Retrieval
The ability to safely remove, with no operational
safety problems, the spent fuel from storage for
further processing or disposal.
12
Ready Retrieval (con’t)
Ability to do at least one of the following options:
A. remove individual or canned spent fuel
assemblies from wet or dry storage,
B. remove a canister loaded with spent fuel
assemblies from a storage cask/overpack,
C. remove a cask loaded with spent fuel
assemblies from the storage location.
13
Ready Retrieval: Option A and
Option B/C
•
•
•
•
Currently at all sites
Fuel assembly removal
Canister/cask removal
No operational safety
problems
14
Ready Retrieval: Option A
• Wet and dry storage design
• Fuel assembly removal
– Assure that the fuel will not
exhibit gross degradation
– Or the fuel is placed inside a
secondary container
• No operational safety
problems
15
Ready Retrieval: Option B/C
• Canister/cask removal
– Include technical specifications
(TS) to maintain ready retrieval
– May have program to identify,
monitor, and mitigate possible
degradation
– Complies with 10 CFR Part 72 requirements
• No operational safety problems
16
Licensing Applications
• Initial and amendments
– System designed for retrievability
– Identified important SSCs & subcomponents
– TS ensure retrievability capability is maintained
• For example: Maintain as-loaded condition
according to the TS
– Known loaded fuel condition and configuration
– Dry and inert environment
– Maximum fuel clad temperature limits
– Thermal cycling is limited
17
Licensing Applications (con’t)
• Renewals
– Ensure design bases is maintained
– Review AMPs and TLAAs
– Review operating experience
• Inspections and analyses of SSCs and subcomponents
– For more information refer to NUREG-1927, Rev. 1
18
Certificate of Compliance
• Initial application
– Not required to meet 10 CFR 72.122(l), retrievability
– Meet 10 CFR 72.236(m) to the extent practicable
– If included, evaluate the retrievability aspects and
that other 10 CFR Part 72 requirements are met
• General licensees
– Required to meet 10 CFR 72.122(l), retrievability
– Load in accordance with a CoC
– Demonstrate that the canister/casks meet the
fabrication, loading, and preparation for
storage requirements
19
Certificate of Compliance (con’t)
• Amendments
– General licensees can voluntarily adopt a later CoC
amendment
– Must be adopted in its entirety
• Revisions
– Supersedes the CoC amendment being revised
– General licensees using the CoC amendment being
revised must comply with the revision
– Subject to backfit review
20
Updating Guidance
2016 February Updated Draft
ISG-2 & Responded to
Comments
2016 March/April ACRS
Meetings
2016 Summer Issuance of Final
ISG-2, Rev. 2
• 70 comments received and NRC responses drafted
• Clarified and updated draft ISG-2, Rev. 2
• ACRS meetings
– March 23, subcommittee overview
– April 7, full committee (if needed)
• Issue final guidance
21
Questions/Comments
Contacts:
Emma Wong: (301) 415-7091
[email protected]
Haile Lindsay: (301) 415-0616
[email protected]
22
References
•
•
•
•
•
•
•
•
•
42 U.S. Code §10101 et seq. Nuclear Waste Policy Act (NWPA) of 1982, as
amended.
53 FR 31651 1988 Final Rulemaking “Licensing Requirements for the Independent
Spent Fuel Storage of Spent Nuclear Fuel and High-Level Radioactive Waste.”
78 FR 3853; July 17, 2013. “Retrievability, Cladding Integrity and Safe Handling of
Spent Fuel at an Independent Spent Fuel Storage Installation and During
Transportation.”
COMSECY-10-0007 “Project Plan for the Regulatory Program Review to Support
Extended Storage and Transportation of Spent Nuclear Fuel,” ML101390216.
Draft ISG-2, Revision 2, “Fuel Retrievability in Spent Fuel Storage Applications,”
ML15239A695.
Final draft ISG-2, Revision 2, “Fuel Retrievability in Spent Fuel Storage Applications,”
ML16019A128.
FRN requesting public comment (78 FR 3853) & comments, ML15110A370.
ISG-2, Revision 1, “Fuel Retrievability,” ML100550861.
ISG-2, Revision 0, “Fuel Retrievability”
23
References
•
•
•
•
•
•
•
NUREG-1536, Revision 1, “Standard Review Plan for Spent Fuel Dry Cask Storage
Systems at a General Facility,” ML091060180.
NUREG-1567, Revision 0, “Standard Review Plan for Spent Fuel Dry Storage
Facilities,” ML003686776.
NUREG-1927, Revision 0, “Standard Review Plan for Renewal of Specific Licenses
and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel,”
ML111020115.
NUREG/CR-7198, “Mechanical Fatigue Testing of High-Burnup Fuel for
Transportation Applications,” ML15139A389.
Response to Stakeholder Comments on the Final Draft of ISG-2, Rev. 2,
ML16019A134.
SECY-01-0076, “Retrievability of Spent Fuel from Dry Storage Casks.”
Summary of Public Meeting on July 27, 2011: “Enhancements to Licensing
and Inspection Programs,” ML113000303.
24
References
•
•
•
Summary of Public Meeting on August 16, 2012: “Meeting to Obtain Stakeholder
Feedback on Enhancements to the Licensing and Inspection Programs for Spent
Fuel Storage and Transportation,” ML12261A069.
Summary of Public Meeting on July 29, 2015: “Public Meeting on
Retrievability of Spent Fuel at an Independent Spent Fuel Installation,”
ML15216A272.
Summary of Public Meeting on October 29, 2015: “Public Meeting on the Draft
Interim Staff Guidance (ISG) 2, Revision 2: Fuel Retrievability Under 10 CFR Part
72,” ML15317A259.
25
Abbreviations
•
•
•
•
•
•
•
•
•
•
•
•
ACRS – Advisory Committee on Reactor Safeguards
AMP – Aging Management Program
CFR – Code of Federal Regulations
CoC – Certificate of Compliance
FRN – Federal Register Notice
GTCC – Greater than Class C
ISFSI – Independent Spent Fuel Storage Installation
ISG – Interim Staff Guidance
NWPA – Nuclear Waste Policy Act
SSC – Structures, Systems, and Components
TLAA – Time Limited Aging Analysis
TS – Technical Specification
26
STORAGE AND TRANSPORTATION OF
HIGH BURNUP SPENT FUEL
Meraj Rahimi
Chief of Criticality, Shielding, & Risk Assessment Branch
Meeting with Advisory Committee on Reactor Safeguards
Subcommittee on Metallurgy & Reactor Fuels
Framework for Storage and Transportation of Spent Fuel
March 23, 2016
Fuel
Performance
Risk
Informed
Fuel
Performance
Renewal
STORAGE
Dry Storage
System
Performance
RETRIEVABILITY
TRANSPORTATION
Initial Storage
Term
Extended
Storage
System
Performance
2
Background
• Historically, safety
analyses for design
of storage casks
and transportation
packages have
generally relied on
spent fuel cladding
confining fuel in asloaded geometry
inside casks and
packages under
normal and accident
conditions
3
Requirements for
Storage (10 CFR 72)
• Normal/Off Normal/Accident Conditions
– Dynamic and thermal loads from normal fuel
loading into casks, draining, drying, transfer to
pad, and extreme ambient conditions
– Human errors, out-of-tolerance equipment,
equipment failure, instrumentation failure,
vent blockage
– Cask drop and tipover, flood, tornado,
earthquake
4
Requirements for
Transportation (10 CFR 71)
• Normal/Accident Conditions
– Dynamic and thermal loads from normal
transport vibration, one-foot cask drop, and
extreme ambient conditions (e.g., -40 oC)
– 30-foot free drop, puncture, fire, and 50-foot
immersion under transport accident conditions
5
Spent Fuel Cladding
Mechanical Prop.
• Research (e.g., M.C.
Billone, etl.) has indicated
possibility of changes in
high burnup (i.e.,>45
GWd/MTU) spent fuel
cladding mechanical
properties when subjected
to cask loading conditions
and subsequent long
period of storage.
6
Hydride Reorientation
• During cask draining and drying, fuel
temperature and fuel rod internal pressure
increases causing hydrides in cladding to
go into solution form and reorient from
circumferential to radial directions during
storage
7
Ductile To Brittle
Transition Temperature (DBTT)
• Hydride reorientation
results in a less
ductile and more
brittle of the cladding
when the cladding
temperature falls
below a certain value
after a long period in
storage
8
Design-Basis Loads
• Due to aging of high
burnup fuel in storage
and potential of
design-bases loads
during transportation
(e.g., vibration,
impact), high burnup
fuel cladding integrity
needs to be
considered
9
Draft Regulatory Issue
Summary (RIS)
• Issued in March 2015
• Provides a road map on some
approaches acceptable to the NRC
for applications containing HBF
based on the research and the
guidance to date.
10
Guidance on Storage and
Transportation of High Burnup Fuel
Draft
RIS
ISG-24
NUREG/CR7198
Phase 1 –
Cladding with
non-reoriented
hydrides
NUREG/CR7203
ISG-11
High Burnup
Spent Fuel
Storage and
Transportation
NUREG
Phase 2 Cladding with
reoriented
hydrides
11
Interim Staff Guidance
(ISG)
• ISG-11, Rev. 3
– “Cladding Considerations for the
Transportation and Storage of Spent Fuel”
• ISG-24, Rev. 0
• “Use of a Demonstration Program as a
Surveillance Tool for Confirmation of Integrity for
Continued Storage of High Burnup Fuel Beyond
20 Years”
12
NRC-Sponsored
Research
• “Mechanical Fatigue Testing
of High-Burnup Fuel for
Transportation Applications,”
NUREG/CR-7198
• A Quantitative Impact
Assessment of Hypothetical
Spent Fuel Reconfiguration
in Spent Fuel Storage Casks
and Transportation
Packages,” NUREG/CR7203
113
Cyclic Integrated ReversibleBending Fatigue (CIRF) Tester
• How does the presence of fuel
impact the flexural rigidity
(bending stiffness) of the fuel
rod?
• How does the presence of fuel
impact the failure strain of the
cladding?
• How many cycles to failure for
high burnup fuel rods at a
range of elastic strain levels.
• Will radial hydrides impact the
bending stiffness or fatigue life
of high burnup fuel rods?
14
CIRF Tester (cont.)
•
•
PWR Spent Nuclear Fuel (SNF) with
Zircaloy-4 Cladding
Burnup ranged from 63.8 to 66.8 GWd/MTU
•
Phase 1 test (non-reoriented HBF samples)
program
– Static bend tests have been completed
on 4 samples
– Vibration fatigue tests have been
completed on 16 samples, at a wide
range of bending moment amplitudes
Phase 2 test (reoriented HBF samples)
program
– Static bend tests will be performed on 1
or more sample
– Vibration fatigue tests will be performed
on 3 or more samples, at a range of
bending moment amplitudes
Strain Amplitude (%)
0.40
•
HBR
Failure
0.50
y = 3.5693x-0.252
R² = 0.8722
HBR No
failure
NA Failure
0.30
0.20
NA No
failure
0.10
MOX
Failure
0.00
1.00E+03
LMK
Failure
1.00E+05
1.00E+07
Number of Cycles or Cycles to Failure
15
Spent Fuel
Reconfiguration Study
• Three categories of
reconfigurations
– Cladding Failure
– Rod/assembly
deformation
– Axial alignment
• Consequences
–
–
–
–
Criticality
Shielding
Containment
Thermal
16
Spent Fuel
Reconfiguration Study
•
The reconfiguration scenarios involving cladding failure and fuel axial relocation exhibited the
largest impact in the technical disciplines evaluated
–
Criticality: <5% Δkeff increase for plausible scenarios
–
Shielding: <3x difference between intact and 25% redistributed fuel
–
Containment and Thermal: allowable leakage rate and decay heat are decay-time dependent
so consequences associated with geometry changes may be offset by the longer storage
times
• Equivalent allowable leakage rates for PWR failed fuel fractions of 0.03, 0.10, and 0.15
and BWR failed fuel fractions of 0.03, 0.4, and 0.7 at 5-, 40-, and 100-year decay times
–
•
Thermal: basket temperature increase ~130 C from nominal and cask surface temperature
~10C Redistribution of the thermal energy source term within the canister can alter the heat
transport paths from the fuel to the canister wall.
The consequences associated with cladding failure for the criticality and shielding technical disciplines are very
sensitive to the modeling assumptions, and will be strongly dependent on canister- and assembly-specific
characteristics.
17
Next Steps
• Issue final RIS – December 2016
• Issue draft NUREG on HBF – September
2016
• Issue final NUREG on HBF – July 2017
18
References
•
•
•
•
•
•
MC Billone, TA Burtseva, and MA Martin-Rengel, and RE Einziger,”Ductileto-brittle transition temperature for high-burnup cladding alloys exposed to
simulated drying-storage conditions,” J. Nucl. Mater. 433 (2013) 431-448
RIS 2015-XX, Considerations in Licensing High Burnup Spent Fuel in Dry
Storage and Transportation
SG 11, Cladding Considerations for the Transportation snd Storage of
Spent Fuel, Revision 3.
ISG-24, The Use of a Demonstration Program as a Surveillance Tool for
Confirmation of Integrity for Continued Storage of High Burnup Fuel Beyond
20 Years, Revision 0.
NUREG/CR-7198, Mechanical Fatigue Testing of High-Burnup Fuel for
Transportation Applications
NUREG/CR-7203, A Quantitative Impact Assessment of Hypothetical Spent
Fuel Reconfiguration in Spent Fuel Storage Casks and Transportation
Packages
19
Acronyms
•
•
•
•
•
•
•
•
DBTT – Ductile to Brittle Transition Temperature
RIS – Regulatory Issue Summary
ISG – Interim Staff Guidance
CIRF – Cyclic Integrated ReversibleBending Fatigue
HBF – High Burnup Fuel
HBR – H.B. Robinson
NA – North Anna
MOX – Mixed Oxide
• LMK - Limerick
20
»Backup Slides
HBF Storage
Uncanned
fuel
Canned
fuel
Dry Storage beyond
20 years
Dry Storage up
to
20 years
Normal, Off-normal
Conditions*
Normal,
Off-normal, and
Accident
Conditions
No deviation
from current
licensing
approach
*This approach is
valid provided
results from the
demonstration
cask as described
confirm the original
fuel condition
licensing
assumptions.
Normal,
Off-normal, and
Accident
Conditions
Accident Conditions
or
TEST DATA
A demonstration
cask program in
accordance with
Interim Staff
Guidance (ISG)24, "The Use of a
Demonstration
Program as
Confirmation of
Integrity for
Continued Storage
of High Burnup
Fuel Beyond 20
Years”
Available
materials
data?
ANALYSIS
Confirm that the
initial assumptions
on fuel conditions
remain valid
+
Perform, as part of
defense-in-depth,
safety analysis
assuming 1% fuel
failure for normal
conditions, 10% for
off-normal
conditions, or other
justifiable values
Yes
No
TEST DATA
ANALYSIS
Perform structural
analyses using
appropriate
materials property
data
Perform safety
analysis with
reconfigured fuel
assuming 100%
fuel failure or
another
justifiable value
Demonstrate
structural
performance of
the can used for
damaged fuel.
Perform safety
analysis with
fuel
reconfiguration
confined to the
boundary of the
fuel can
*If minimum fuel temperature is above the
ductile-to-brittle transition temperature
(DBTT), then fuel can be treated as
directly shipped from pool
HBF Transportation
Uncanned
fuel
Canned
fuel
Fuel that has been in dry
storage*
Direct shipment
from the pool
Normal
Conditions of
Transport and
Hypothetical
Accident
Conditions
Use guidance in
ISG-11, “Cladding
Considerations for
the Transportation
and Storage of
Spent Fuel,” to
determine the
maximum
cladding
temperature and
verify the
minimum
temperature that
maintains ductility
of the cladding
Normal Conditions of
Transport
Hypothetical Accident
Conditions
Available
materials
data?
Available
materials
data?
Yes
TEST DATA
Perform
structural
analyses using
appropriate
materials data
No
ANALYSIS
Perform safety
analysis
assuming 3%
fuel failure, or
another
justifiable value
Confirm fuel
meets
content
specified in
the
Certificate of
Compliance
prior to and
after
transport
Yes
TEST DATA
Perform
structural
analyses using
appropriate
materials data
Normal
Conditions of
Transport and
Hypothetical
Accident
Conditions
No
ANALYSIS
Perform safety
analysis with
reconfigured
fuel assuming
100% fuel
failure, or
another
justifiable value
Demonstrate
structural
performance
of the can
used for
damaged fuel.
Perform safety
analysis with
fuel
reconfiguration
confined to the
boundary of
the fuel can.
Risk-Informed Application for
Dry Cask Storage Systems
Donald Chung, PhD
Meeting with Advisory Committee on Reactor Safeguards
Subcommittee on Metallurgy & Reactor Fuels
Framework for Storage and Transportation of Spent Fuel
March 23, 2016
Fuel
Performance
Risk
Inform
Fuel
Performance
Renewal
STORAGE
Dry Storage
System
Performance
RETRIEVABILITY
TRANSPORTATION
Initial Storage
Term
Extended
Storage
System
Performance
Risk-Informed Decision-Making
at The US NRC
• Commission has a long standing policy on
increasing the use of Probabilistic Risk
Assessment (PRA) approaches.
• Risk-informed decisions are extensively
used in licensing and oversight activities for
operating reactors.
• PRA modeling/insights with Core Damage
Frequency (CDF) and Large Early Release
Frequency (LERF) are used as metrics for
reactors.
Slide # 3
Background Dry Spent Fuel Storage PRAs
Previous PRAs of Dry Cask Storage
Systems (DCSS):
• NUREG-1864, “A Pilot Probabilistic Risk
Assessment of a Dry Cask Storage System at
a Nuclear Power Plant” (2007).
• EPRI Report, “Probabilistic Risk Assessment
of Bolted Storage Casks: Quantification and
Analysis Report,” (2003).
Slide # 4
Latent Cancer Risk Comparison
Dry Cask Storage System PRAs
NUREG-1150, “Severe Accident Risk,
An Assessment for Five U.S. Nuclear
Power Plants”
Slide # 5
What has Changed Since The
Last PRA Studies
• Increase storage duration to beyond just 20 years.
• Aging issues - Chloride-induced Stress Corrosion
Cracking (CISCC)
• New information on manufacturing defects
• Data on spent fuel canister misloads
• Additional data on human error during cask
preparation
• Historical data (20 years) indicating no detectable
release from existing ISFSI
Slide # 6
Objective of Risk-Informing
Dry Cask Storage Systems
• Better focus regulatory efforts.
• Be prepare to evaluate changes in risk.
• Establish decision metric (confinement
breach frequency) for assessing risk
significance.
• If PRA results continue to indicate very low
risk, staff could re-examine criteria for dry
storage safety requirements.
Slide # 7
Phases of Operation
1. Cask/canister loading and
preparation
2. On-site Transport
3. Storage in Independent Spent Fuel
Storage Installation (ISFSI)
4. Cask/canister transfer
Slide # 8
Safety Functions Required
in for DCSS
Protection
against release of
radioactive materials
Protection
against radiation
exposure
Safety
Functions
Protection against
nuclear criticality
Slide # 9
Defense-in-Depth
Three levels of safety
Level 1, Prevention
(10 CFR 72, CoC, SRP, AMP, MAPS)
Level 2, Mitigation
• Prevent release of radioactive material
• Prevent criticality
• Limit radiation exposure
• Accident assessment
• Perform remedial actions
• Perform Repair
Level 3, Emergency Actions
(10 CFR 72.32, Emergency Plan)
• Accident detection/assessment
• Notification
• Protective response
Slide # 10
Dry Storage System
Vertical Dry Cask Storage Systems
• HOLTEC HI-Storm 100 Cask System with MPC
• Dual Purpose Cask TN-XX
• MAGNASTAR
Slide # 11
Dry Storage System
Horizontal Dry Cask Storage System
NUHOMS Dry Cask Storage
• Horizontal storage module
• Dry shielded canister
Slide # 12
Dry Storage System
Underground Dry Cask Storage Systems
• HI-STORM UMAX
• HI-STORM 100U
Slide # 13
Proposed Risk-Informed
Regulatory Framework
• Generic framework for all DCSS
• Adopt Confinement Breach
frequency (CBF) as the metric for
risk
• Set a CBF limit for storage in
ISFSI. (Numerical Guidance)
• Propose risk-informed regulatory
guidance. (Decision Metrics)
Slide # 14
CBF as Metric for RiskInforming DCSS
Reasons for selecting Confinement Breach
Frequency (CBF) as the metric for risk:
– Precursor to release of radionuclides;
– Indicator of risk to Workers
– Indicator or risk for environmental
contamination
Slide # 15
Dry Storage System
PRAs
Slide # 16
Dry Storage System PRAs continued
Initiating Events:
• Mechanical Events
–
–
–
–
–
Accidental drops or tip-overs
Seismic event
Water currents during a flood
Strikes from heavy objects
Shockwaves from explosions
• Thermal events
– Vent blockage
– Lightning
– Fire from aircraft fuel
Slide # 17
Dry Storage System PRA
- Continued
Drop
Lightling
Tornado
Burial under debris
Earthquake
Other
CBF =
CBF(flood) + CBF(tornado) +CBF(earthquake)+CBF(lightning)+CBF (burial)+CBF(other)
NUREG-1536, “Standard Review Plan for Spent Fuel Dry Storage Systems
at a General License Facility”.
Slide # 18
Dry Storage System PRA
- continued
What is the increase in MPC CBF for an mechanical
event if there is a partial through-wall (TW) crack?
Slide # 19
Dry Storage System PRA continued
Drop
Lightning
Slide # 20
Numerical Guidelines for
DCSS
• Based on Commission Safety Goal Policy definition of
“negligible risk”
• Based on NMSS Quantitative Health Guideline (QHG)
defining “negligible risk” as less than 2.0E-06/yr.* additional
cancer fatality.
• CBF for QHG, needs to be evaluated by a level 3 PRA
consequence assessment. (e.g., Less than 5.5 E-03/yr.**)
*Risk-Informed Decisionmaking for Nuclear Material and
Waste Application, Revision 1, February 2008.
**Based on consequence calculation from NUREG-1864.
Slide # 21
Proposed Decision Metric for
Risk
Decision Metric should:
• supports evaluation of quantitative changes
in DCSS risk.
• provide basis for assessing acceptable
changes in risk.
Slide # 22
Proposed Decision Metric for
Risk-Informing Dry Cask Storage
-continued
• Proposed guidance for decision metric is
taken from the example in RG 1.174*.
• Specific requirements may be relaxed if the
initial risk is already low and the incremental
increases from a change are also small.
*RG-1.174, “An Approach for Using Probabilistic Risk
Assessment in Risk-Informed Decisions on Plant-Specific
Changes to the Licensing Basis.”
Slide # 23
Proposed Decision Metric for
Risk-informing Dry Cask Storage
- continued
*Adopted from RG 1.174, An Approach for Using PRA in
Risk-Informed Decisions on Plant-Specific Changes to
Licensing Basis.
Slide # 24
Information Needed for
Risk-Informing Decisions
– aging affects during
storage,
– canister failure probabilities
for accidents
– Level 3 PRA evaluation of
consequences
– common cause failure,
– uncertainties
Slide # 25
Options for Going
Forward
• Option 1: Develop the required PRA
information to support risk-informed
framework.
• Option 2: Consider adopting a
deterministic risk framework for DSS,
since risk is significantly lower than for
reactors.
Slide # 26
Questions?
Slide # 27
References
•
•
•
•
•
•
•
•
EPRI 1009691, “Probabilistic Risk Assessment (PRA) of Bolted Storage Casks,
Updated Quantification and Analysis Report,” 2004.
NUREG-1150, ”Severe Accident Risks: An Assessment for Five U.S. Nuclear
Power Plants,” 1990.
NUREG-1536, “Standard Review Plan for Spent Fuel Dry Storage Systems at a
General License Facility,” Revision 1, 2010.
NUREG-1864, “Pilot PRA of Dry Cask Storage System At a Nuclear Power
Plant,” 2007.
NUREG-1927, “Standard Review Plan for Renewal of Spent Fuel Dry Cask
Storage System Licenses and Certificates of Compliance,” 2011.
NUREG-2150, “A Proposed Risk Management Regulatory Framework,” 2012.
RG-1.174, “An Approach for Using Probabilistic Risk Assessment in RiskInformed Decisions on Plant-Specific Changes to the Licensing Basis.”
“Risk-Informed Decisionmaking for Nuclear Material and Waste Applications,”
Revision 1, 2008, Office of Nuclear Regulatory Research, Office of Nuclear
Material Safety and Safeguards.
Slide # 28
Abbreviations
AMP
CBF
CDF
CFR
CISCC
CoC
DCSS
EPRI
ISFSI
LERF
MPC
NMSS
QHG
PRA
MPC
SRP
TW
aging management activity
confinement breach frequency
core damage frequency
Code of Federal Regulations
chloride-induced stress corrosion cracking
certificate of compliance
dry cask storage system
Electric Power Research Institute
independent spent fuel storage installation
large early release frequency
multi-purpose canister
Nuclear Material Safety and Safeguard
Quantitative Health Guideline
probabilistic risk assessment
multi-purpose canister
Standard Review Plan
through-wall
Slide # 29
Risk from Spent Fuel
One 35 year-old unshielded fuel assembly at
35 feet distance:
dose rate = 30 rem per hour
Slide # 30
Industry Perspectives:
Ongoing Storage and
Transportation
Research
Keith Waldrop
Principal Technical Leader
Advisory Committee on Reactor
Safeguards
Meeting of the Subcommittee on
Metallurgy & Reactor Fuels
Framework for Storage and
Transportation of Spent Fuel
Rockville, MD
March 23, 2016
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Main Research and Development Areas (1/2)
 Storage
– Wet Storage:
 Spent Fuel Pool Criticality - Full Burnup Credit
 Neutron absorber materials performance (BORAL)
– Dry Storage
 Extended storage (>60 years)
– Extended Storage Collaboration Program (ESCP)
 Fosters global collaborative research
– Aging management
 Susceptibility of stainless steel canister to chloride-induced
stress corrosion cracking (CISCC)
– High-burnup (>45 GWd/MTU) Fuel Performance
 Collect data on high burnup fuel in dry storage (with US
DOE)
2
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Main Research and Development Areas (2/2)
 Transportation
– Properties of advanced claddings after long-term storage
Hypothetical accident conditions
Normal conditions
– Full Burnup Credit
 Disposal
– Little to no involvement at this time
– Monitoring ongoing DOE and international activities
3
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Aging Management of Dry Storage
Systems
Chloride-Induced Stress Corrosion Cracking of Stainless Steel Canisters
4
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Aging Management of Dry Storage Systems
 Initial steps to perform a literature review and a Failure Modes and
Effects Analysis (FMEA)
 FMEA identified Chloride-Induced Stress Corrosion Cracking
(CISCC) as the most likely of potentially active degradation mechanisms
to lead to through wall penetration
 CISCC of stainless steel reactor components has occurred when all three
elements are present:
– Elevated stress
Tensile
Stress
– Susceptible Material
– Corrosive Environment
 Surface contamination by atmospheric chlorides
 Sufficient humidity
 EPRI has a multi-year project to
– Develop aging management guidelines specific to CISCC
– Develop and Demonstrate Inspection Capability
5
© 2016 Electric Power Research Institute, Inc. All rights reserved.
SCC
Susceptible
Material
Corrosive
Environment
Stainless Steel Canister Degradation Aging Management
Results of literature survey, FMEA, and flaw grow & tolerance assessment are
utilized in:
 Susceptibility Assessment Criteria
– Define site conditions and canister parameters associated with earlier potential for CISCC
initiation and growth
– Allow ranking of canisters to set priorities for inspection and other aging management efforts
– Limited guidance on use of ranking criteria to identify canisters that are considered
“bounding”; will be expanded in aging management guidance
 Probabilistic Confinement Integrity Assessment
– Predicts cumulative probability of canister leakage due to CISCC over time; results reported
on a relative scale where the “base case” value is set to 1
– Compares results for various alternate inspection regimes to the “base case”
– Includes sensitivity studies to understand the impacts of assumptions in the “base case”
 Aging Management Guidelines for CISCC
– Integration of all these pieces into guidance
– Key reference and input for ASME in-service inspection criteria being developed
6
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Stainless Steel Canister Degradation Aging Management
 Literature Review of Environmental Conditions and Chloride-Induced Degradation
Relevant to Stainless Steel Canisters in Dry Cask Storage Systems
– Published May 2014, EPRI# 3002002528
 Failure Modes and Effects Analysis (FMEA) of Welded Stainless Steel Canisters
for Dry Cask Storage Systems
– Published December 2013, EPRI# 3002000815
 Flaw Growth and Flaw Tolerance Assessment
– Published October 2014, EPRI# 3002002785
 Susceptibility Assessment Criteria for CISCC of Welded Stainless Steel Canisters
– Published September 2015, EPRI# 3002005371
 Aging Management Guidance to Address Potential CISCC
– Will include Probabilistic Confinement Integrity Assessment
– Planned Publication November 2016, EPRI #3002008193
 Dry Cask Storage Welded Stainless Steel Canister Breach Consequence
Analysis Scoping Study
– Planned Publication December 2016, EPRI #3002008192
7
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Stainless Steel Canister Inspection Capability
 EPRI is focusing on 4 main areas
–
–
–
–
Collaborations
Mockups
Nondestructive Evaluation (NDE) Technologies
Delivery Systems
 Goal is to demonstrate NDE techniques with a
functional delivery system in 2017
8
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Cladding Behavior in High Burnup Fuel
High Burnup R&D Project (Extended Storage Demonstration, with DOE)
Performance of Advanced Cladding Materials during Extended Storage
9
© 2016 Electric Power Research Institute, Inc. All rights reserved.
High Burnup R&D Project
Background
 Technical basis for Low Burnup fuel:
– Based on demonstration with low burnup fuel
 No evidence of degradation after 14 years
 Still significant creep life left in cladding
 Technical basis for High Burnup (HBU) fuel:
– Based on lab testing
 Testing showed hydrides in clad can reorient during dry
storage loading operations; can lead to loss of ductility
 Bounding conditions of testing allowed guidance for
licensing HBU fuel (ISG-11 Rev.3 – Limit peak clad
temperature to 400°C)
 Storage licenses limited to 20 years
 Transport licenses very limited and restricted
10
© 2016 Electric Power Research Institute, Inc. All rights reserved.
High Burnup R&D Project
Motivation
 Lack of data on HBU fuel under actual dry storage conditions
 Repeat earlier low burnup demo using high burnup fuel
– Provide data on behavior of multiple types of HBU cladding under
typical dry storage conditions
– Provide data for benchmarking models to predict performance of HBU
fuel over extended time periods
– Supports need for data in renewed licenses for high burnup
 Calvert Cliffs and Prairie Island
 10 more by 2020 (58 sites)
– Supports future need for transport of high burnup fuel
 US plans for consolidated storage in 2020s
 International needs for transport of HBU fuel (e.g. Spain)
~20% of casks loaded in US contain HBU fuel
11
© 2016 Electric Power Research Institute, Inc. All rights reserved.
High Burnup R&D Project
Overview
 Develop and implement the Final Test Plan
 Complete final design
 Submit storage license application to NRC
 Identify, extract and ship sister rods to conduct non-destructive
and destructive examinations (pre-characterization)
 Modify the cask lid
 Fabricate instrumentation
 Obtain storage license from NRC (tentative, pending NRC
review and approval)
 Perform dry runs
 Load Cask
 Begin data collection (temperature & gas samples)
12
© 2016 Electric Power Research Institute, Inc. All rights reserved.
High Burnup R&D Project
Overview
 Store cask about 10 years
 Ship cask to a Fuel Examination Facility (to be provided
by DOE)
 Open cask and visually examine the fuel
 Extract high burnup rods for non-destructive and
destructive examinations of the rods at the national
lab(s)
– Compare end-of-storage and “t=0” cladding
properties
 Option: re-close cask and continue storage; re-open
again later
13
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Performance of Advanced Cladding Materials (1/2)
 Issue
– Data on “advanced” claddings (ZirloTM, Optimized ZirloTM, M5,
AXIOM, etc.) are needed to verify that the performance of these
claddings will meet the regulatory requirements applicable to dry
storage and transportation conditions
 Guidance published in ISG-11 for storage of high-burnup fuel
largely based on experimental data obtained on Zircaloy-4 cladding
 Generically accepted guidance for high-burnup fuel transportation
applications have not been established
Circumferential Hydrides
14
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Radial Hydrides
Performance of Advanced Cladding Materials (2/2)
 Actions
– Participation in projects collecting post-irradiation data on fuel
irradiated to high burnup
 Thermal creep, Hydride Re-Orientation (HRO), Ductile-to-Brittle
Transition Temperature (DBTT), Delayed Hydride Cracking (DHC)
– Incorporation of data into cladding and fuel performance models
– Provide active guidance to the DOE-EPRI High Burnup R&D project
 Goals
– Resolution of regulatory issues associated with
 Dry storage license extensions (>20 years)
 Transportability of high-burnup fuel
15
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Together…Shaping the Future of Electricity
16
© 2016 Electric Power Research Institute, Inc. All rights reserved.
Industry Perspective on the
Dry Storage Regulatory Framework
Kristopher Cummings
Nuclear Energy Institute
ACRS Subcommittee on Metallurgy and Reactor Fuels
March 23rd, 2016 • Rockville, MD
Used Nuclear Fuel in Storage in the U.S.
• Used fuel inventory
January 2016
- Approximately 76,400 MTU
- Increases 2 - 2.4k MTU annually
• ISFSI* storage
-
97,843 assemblies
27,726 MTU (36%)
2,268 casks/modules loaded
70 Operating ISFSIs
• 1 pool ISFSI, 1 modular vault
• Projections for 2020
-
Estimating 86,000 MTU total
Estimating 35,000 MTU at ISFSI
3,200 casks/modules loaded
At 76 ISFSIs
• Almost all plant sites + Morris & INEL
- Fuel from 119 reactors
*ISFSI = Independent Spent Fuel Storage Installation
2
High Burnup Nuclear Fuel in Storage in the U.S.
January 2016
High Burnup Fuel in Dry Storage
• ISFSI storage
~9500 assemblies
~600 casks/modules loaded
At 30 Operating ISFSIs
Up to ~58.0 GWD/MTU
• Projections for 2020
- ~17000 assemblies
- > 1,000 casks/modules loaded
600
500
# of Canisters
-
700
400
Per Year
300
Cumulative
200
100
0
2004
2006
2008
2010
2012
2014
2016
Year
3
Improving the Regulatory Framework
• Experience with and increasing use of dry storage
demand a more efficient framework
- Also consistent with NRC Project AIM
• Efficiencies can only be gained if the relatively low risk of
dry storage is appropriately recognized
• Specific guidance and rule changes can be targeted:
- Incorporation of the principles contained in PRM 72-7
- Explicit recognition of aspects of defense-in-depth
considerations
- Guidance for a risk appropriate level of review for shielding,
radiation protection and other evaluations.
4
PRM 72-7 Vision
• Standardize Dry Storage Licenses
- CoC/Tech Spec Format and Content
- Level of Detail
- Consistency with Commission Policy Statement on Improved TS
• Achieve Appropriate Risk Prioritization in Dry
Storage Licensing
• Place more information under licensee control
• Extend Back-fit Rule to CoC holders
• Make specific changes to the rule to improve its
efficiency
Keys to Assuring Safety with More Information
Under Licensee Control
• 10 CFR 72.48 Change Process
- NRC and Industry must have confidence in a
common understanding of process
• Aging Management Programs
• NRC Inspection Programs
Improvements to the Regulatory Framework
• Industry submitted 72.48 guidance (NEI 12-04)
- Recent NRC meeting helped reach consensus on four
fundamental issues of concern.
• NEI 14-03, “Format, Content and Implementation Guidance
for Dry Cask Storage Operations-Based Aging Management”:
- Consistent format and content of license renewal
applications (LRAs)
- Operations-based aging management through learning
aging management programs
- Sharing of operating experience related to aging
management - AMID
- Periodic “tollgate” safety assessments
7
Regulatory Requirements - Cladding
• Storage - 10CFR72.122(h):
- “The spent fuel cladding must be protected during
storage against degradation that leads to gross
ruptures or the fuel must be otherwise confined
such that degradation of the fuel during storage
will not pose operational safety problems with
respect to it’s removal from storage”
Risk-Informed Perspective: Fuel Cladding
• Risk-informed perspectives and risk analysis
continually show low risks
- EPRI and NRC Dry Storage PRAs conducted in 2007
-
Annual cancer risk between 1.8E-12 and 3.2E-14 *
* Compares to 2E-6 LCF/yr. public & 1E-5 LCF/yr .
worker thresholds of negligible risk from NRC’s
framework for “Risk-Informed Decision-making
for Nuclear Material and Waste Applications”,
Revision 1, February 2008
9
Ongoing Cladding Research
• Sandia studies on loads during normal
conditions of transport, fuel assembly shaker
table experiments.
• DOE/EPRI demonstration program to provide
additional verification for high burnup fuel.
• ORNL fatigue testing of high-burnup fuel
(including fueled cladding segments).
Link to Retrievability
• Retrievability
- Dry storage cask technologies have been designed to
prevent/limit degradation or damage to fuel during storage:
•
•
•
•
•
•
Inert environment (i.e., helium)
Limited/no residual water via established drying process
Basket/canister design prevent significant fuel movement
Limitation of the peak clad temp below 400°C (realistically much lower)
Natural events fail to cause significant stresses on the fuel
Confinement boundary prevents water ingress
- Technologies exist today to handle fuel with gross ruptures or
structural defects without impact on worker or public safety.
- A revised performance-based and risk-informed definition for
“canister-based” retrievability is a good application of a riskinformed framework.
11
PRA Metrics
• Previous studies (EPRI 1009691) and NUREG1864 have found the risk to be extremely low.
- Latent cancer and prompt fatality metric provides for
ready comparison to reactor related risks.
- Use of another metric may confuse the issue and not
provide for an easy comparison to other nuclear
related risks.
- Any proposed metric must address the consequences
to be risk-informed.
• Industry supports continued use of latent cancer
and prompt fatality metric.
12
Summary
• Efficient dry storage licensing processes are essential for
effective management of the growing and aging dry
storage cask population.
• Success in achieving a risk-informed framework has
already shown progress in several focused areas:
- Defining retrievability as canister based
- Common understanding of the 72.48 process (NEI 12-04)
- More efficient and flexible license renewal process (NEI 1403 and NUREG-1927, Revision 1)
• Comprehensive reform (e.g., PRM 72-7) is needed to
assure an effective and consistent regulatory approach.
13