ML17089A150
| ML17089A150 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/30/2017 |
| From: | Christian Jacobs Spent Fuel Licensing Branch |
| To: | Hsia A Division of Spent Fuel Management |
| Jacobs C | |
| Shared Package | |
| ML17089A146 | List: |
| References | |
| Download: ML17089A150 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 30, 2017 MEMORANDUM TO: Anthony Hsia, Deputy Director Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards FROM:
Christian Jacobs, Sr. Project Manager /RA/
Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF MARCH 2, 2017, MEETING WITH XCEL ENERGY TO DISCUSS XCEL ENERGYS PROPOSED EXEMPTION REQUEST FOR DRY STORAGE NUHOMS CANISTERS, NUMBERS 11-15, AT THE MONTICELLO NUCLEAR GENERATING PLANT On March 2, 2017, staff from the Division of Spent Fuel Management held a public meeting with representatives from Xcel Energy (XE), at the U.S. Nuclear Regulatory Commission (NRC)
Headquarters in Rockville, MD. The purpose of the meeting was to discuss XEs proposed exemption request to restore 10 CFR Part 72 compliance to NUHOMS dry shielded canisters, Numbers 11 to 15, at the Monticello Nuclear Generating Plant Independent Spent Fuel Storage Installation. There was no proprietary information discussed during the meeting. No regulatory decisions were made nor requested at this meeting.
The discussion during the meeting followed XEs PowerPoint presentation (Enclosure 2).
During the Q&A session, no members of the public asked questions or provided comments. A summary of the meeting follows.
NRC staff opened the meeting with a request that everyone remain open minded to the current proposed approach for XEs exemption request. NRC staff requested that XE be allowed time to go through their presentation in its entirety and hold questions until the end to enable a holistic understanding of XEs approach. NRC staff also requested that XE provide additional details wherever possible as they proceeded through the high-level slides.
At the conclusion of XEs presentation, NRC staff asked clarifying questions and provided feedback in a number of areas. NRC staff inquired if XEs risk assessment would be based on quantitative risk or qualitative risk. NRC staff remarked that a quantitative risk argument would CONTACT: Christian Jacobs, NMSS/DSFM 301-415-6825
be more compelling. XE responded that it may use a combination of the two. NRC staff also requested that if XE uses dose to a real individual (i.e. a worker) versus a theoretical person at the boundary as part of an overall risk argument, then XE should specify whether those doses are for an individual or spread across a group. NRC staff offered that XE could request another public meeting to discuss this topic further before submitting the proposed exemption request.
NRC staff indicated their commitment to, and encouragement of, further dialog.
Noting a slight evolution in the approach from the previous public meeting, NRC staff inquired why XE was no longer pursuing the bookend approach presented at the November 9, 2016, public meeting. The bookend approach is a phrase that XE and NRC staff have used to refer to a previously proposed XE alternative to request exemption for DSCs 11 - 15 by testing DSC 11 (the first DSC loaded) in a similar manner to the testing already conducted for DSC 16 (the last DSC loaded), and that the results from these two DSCs (i.e., the first and last, or bookends) could be used as representative of the remaining DSCs (12-15). XE responded that they had taken a fresh look at that possible alternative for a proposed exemption request and determined that the risk of their previously selected approach was greater than their current approach (which is to show that DSC 16 is representative of DSCs 11-15 with no further testing).
NRC staff and XE also discussed that any proposed exemption request should take a holistic approach of the risks versus the benefits (e.g., safer to keep DSCs where they are in the Horizontal Storage Module (HSM)? or moving from the HSM for further testing?). There was also some discussion between NRC staff and XE as to whether there is an open question concerning the movement of DSCs deemed inoperable. XE noted that this issue had been raised earlier, and that XE was not sure which regulatory approach should be pursued (e.g.,
exemption, license amendment, etc.); NRC staff explained that the licensee should make a determination of what actions are within their current licensing basis and propose a path forward for the NRC to review, if necessary. Discussion on this topic, however, was ultimately tabled, noting that movement of the remaining DSCs is not part of XEs current approach, and this could be a topic for a separate meeting if needed.
A large portion of the meeting centered around NRCs staff seeking clarification from XE on how DSC 16 is representative or bounding of the remaining DSCs 11-15. XE responded that DSC 16 was not bounding, but that it was representative of the campaign. XE offered some reasons why they considered DSC 16 to be representative of the remaining DCSs including:
materials of construction design considerations (e.g., stress corrosion factors) weld process and experience visual inspection and examinations performed on DSC 16.
NRC noted that further details on each of the items listed above would be needed in the proposed exemption request to describe the basis that DSC 16 is representative. For example, qualifications of personnel to perform visual inspections need to be appropriate for the process inspected. Also, it needs to be clear how the licensee would account for uncertainties when describing DSC 16 as representative.
In conclusion, NRC offered to have additional public meetings to discuss XEs approach for their exemption request. XE responded that they appreciated the opportunity to discuss their proposed exemption request with NRC staff, and that XE heard the feedback that NRC staff had shared at the meeting. XE also indicated that they take ownership of the fact that they do have
five remaining non-compliant DSCs (11-15), and that they want a safe solution. NRC staff expressed a willingness to support further engagement with XE and that NRC did not wish to present any obstacles to XEs ability to meet the schedule requirements in the confirmatory order. XE indicated they would need to reconvene to discuss internally first regarding how they plan to proceed. No specific determinations on the next steps were decided by XE or NRC staffat this meeting. However, XEs presentation slides indicate their proposed exemption request will be submitted in June 2017.
The attendance list (Enclosure 1) and XEs PowerPoint presentation (Enclosure 2) are attached to this memorandum.
Docket No.: 72-58
Enclosures:
- 1. Attendance List
- 2. Presentation
SUBJECT:
SUMMARY
OF MARCH 2, 2017, MEETING WITH XCEL ENERGY TO DISCUSS XCEL ENERGYS PROPOSED EXEMPTION REQUEST FOR DRY STORAGE NUHOMS CANISTERS, NUMBERS 11-15, AT THE MONTICELLO NUCLEAR GENERATING PLANT, DATE: MARCH 30, 2017 DISTRIBUTION:
NRC attendees G:/SFST/Jacobs/Monticello Exemption DSCs 11-15/ Pre-App Meeting_March-02-2017/
Meeting Summary/ Meeting Summary 03-02-2017.docx ADAMS Package No. ML17089A146 Memo: ML17089A150 Slides: ML17058A484 OFC:
DSFM DSFM DSFM NAME:
CJacobs WWheatley (via email)
JMcKirgan DATE:
03/29/17 03/30/17 03/30/17 OFFICIAL RECORD COPY
March 2, 2017 ATTENDANCE LIST Name Affiliation Christian Jacobs NRC/DSFM Norma Garcia-Santos NRC/DSFM Meraj Rahimi NRC/DSFM John McKirgan NRC/DSFM Anthony Hsia NRC/DSFM Darrell Dunn NRC/DSFM David Tang NRC/DSFM Joe Borowsky NRC/DSFM Michael Layton NRC/DSFM Scott Moore NRC/DSFM Cathy Kanatas NRC/OGC Glenn Adams XE Scott Marty XE Patrick Burke XE Michael Baumann XE Martin Murphy XE Kent Scott XE Mark McKeown XE Pete Glass XE Pat Burke XE Raheel Haroon TN Americas LLC Jay Silberg Pillsbury (Participating by phone)
Marlone Davis NRC/DSFM Jason Piotter NRC/DSFM Jorge Solis NRC/DSFM Lisa London NRC/OGC Matthew Learn NRC/RIII Rhex Edwards NRC/RIII Jo Simpson NRC/OCFO Gene Eckholt XE Carlyn Greene UxC Publications
ENCLOSURE 2: Xcel Energy Presentation Slides Exemption Request for Restoring Dry Shielded Canister (DSC) 11 - 15 Compliance to 10 CFR Part 72 March 2, 2017