ML21201A028
| ML21201A028 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 07/23/2021 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| YJChen NMSS/DFM/STL 301.415.1018 | |
| References | |
| Download: ML21201A028 (34) | |
Text
1 Public Meeting with Holtec International on HI-STORM 100 Amendment No. 16 Conference Line: 301-576-2978 Conference ID: 342 181 124#
Fuel Cladding Gross Rupture 2
Meeting Agenda
- 1. Introduction and Meeting Logistics
- 2. NRC Presentation and Discussion
- 3. Opportunity for Public Comments
- 4. Summary and Closing Remarks
Introduction and Opening Remarks 3
HI-STORM 100 Amendment No. 16 and Graded Approach 4
HI-STORM 100 Amendment No. 16 5
- Submitted application on March 9, 2021 (ML21068A360)
- The application includes both technical changes and changes to reorganize the CoC and appendices
- Reorganization included using graded approach evaluation forms
- NRC staff completed acceptance review and issued request for supplemental information (RSI) for technical changes (ML21179A179)
- Discuss staffs feedback on CoC and appendices reorganization in this public meeting
Purpose of Graded Approach 6
Streamline the content and format of storage certificates of compliance (CoCs) and their appendices by focusing mainly on:
- safety-related/significant items
- risk-significant content
- reorganize CoC format
- remove duplicative items, as appropriate
- relocate non-safety related items to other licensing basis documents, as appropriate
Endorsement of Graded Approach 7
- NRC endorsed the graded approach in January 2020 (ML19353D337) as developed and described in RIRP-I-16-01 (ML17138A119)
- This streamlined content allows vendors of spent fuel storage systems to be able to make some non-safety-related changes through the existing regulatory process rather than having to request a new or amended certificate, which would require rulemaking.
- Each existing individual CoC requirement receives a written evaluation against the CoC format and content guidance and selection criteria using risk insights and expert knowledge.
- The Evaluation Form records the decision-making process and justification for retaining a CoC requirement in the CoC or relocating it.
- In performing the risk insight, think about subsequent changes to a relocated CoC requirement. Specifically, ask the question "what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction"?
8 Expectation on Graded Approach Evaluation
Expectation on Graded Approach Evaluation (Cont) 9 The evaluation form should clearly provide the information in a manner that allows the staff to make the needed determination that, after applying graded approach, the CoC and appendices continue providing the needed information or requirements to the necessary level of detail to ensure the design and operations of the cask system will continue to meet the regulatory requirements for safe storage of spent nuclear fuel as set forth in 10 CFR Part 72.
10 New CoC Location Goal of the Evaluation Criterion No.
Sub Criterion No.
Evaluation Criteria Sections I and II CoC Body,Section I, Technology Include in the CoC a concise description of the technology, components, and functionality of the dry cask storage system.
1 Identify and evaluate:
if future modifications would be considered a significant deviation to the type of technology, components, or fundamental way the cask system operates.
if the modification to this section could not be performed through an amendment under 10 CFR 72.244, Application for amendment of a certificate of compliance.
CoC Body,Section II, Design Features Include in the CoC design features that would have a significant effect on safety.
2 Identify and evaluate:
design features that would have a significant effect on safety if altered or modified (e.g., materials of construction, geometric arrangement).
if the modification to this section could not be performed through an amendment under 10 CFR 72.244, Application for amendment of a certificate of compliance.
Appendix A CoC Appendix A, Inspections, Tests, and Evaluations Include in the CoC the inspections, tests, and evaluations (ITE), and acceptance criteria, that ensure that a dry storage cask system has been manufactured and will operate in conformance with the certified design.
3 Identify the applicable ITEs, and acceptance criteria.
Evaluate if ITEs, and acceptance criteria are necessary and sufficient to provide reasonable assurance that a cask manufacturing and operation will conform with the certified design.
Ensure that the safety functions of confinement, sub-criticality and shielding are maintained.
NOTE: Assuming ITEs are performed and the acceptance criteria is met.
Pilot Safety Evaluation Report (ML20226A080)
Table 2.1. New CoC format and content and corresponding evaluation criteria
11 New CoC Location Goal of the Evaluation Criterion No.
Sub Criterion No.
Evaluation Criteria Appendix B CoC Appendix B, Technical Specifications, Section 1, Definitions, Use, and Application Include in the CoC the key definitions and administrative rules for implementing the TSs.
4 Identify the key definitions and administrative rules that should reside in CoC Appendix B, Technical Specifications, Section 1, that allows for understanding AND implementing the logic of the Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs) in the TSs.
CoC Appendix B, Technical Specifications, Section 2, Approved Contents Include in the CoC the minimum set of parameters needed to define the approved contents in the certified design that, if altered or modified, would have a significant effect on safety.
5 A1 Evaluate if the information provided in CoC Appendix B, Technical Specifications, Section 2, Approved Contents, meets one or more of the following criteria:
Criterion A1: The characteristic or parameter is identified in 10 CFR 72.236(a).
Criterion A2: A characteristic or parameter for which verification is a necessary condition to provide reasonable assurance that the cask safety functions of confinement, sub-criticality, and shielding will be performed.
Criterion A3: A characteristic or parameter that has a significant impact on public health and safety, based on risk insights and expert knowledge.
A2 A3
12 New CoC Location Goal of the Evaluation Criterion No.
Sub Criterion No.
Evaluation Criteria Appendix B (Continue)
CoC Appendix B, Technical Specifications, Section 3, Limiting Conditions for Operations and Surveillance Requirements Include in the CoC the following information:
the lowest functional capability or performance levels of equipment required for safe operation of the ISFSl and cask, and functional and operating limits to protect the integrity of the stored fuel,
- workers, environment, and the public health and safety.
6 L1 Identify and evaluate functional and operating limits on fuel handling and storage conditions necessary to protect the integrity of the stored fuel, employees against occupational exposures, and prevent the uncontrolled release of radioactive materials.
Identify the subsequent subsections that will include LCOs for operation of the independent spent fuel storage installation (ISFSI) facility or cask with appropriate SRs.
To ensure the safe operation of the ISFSl and cask system, evaluate each LCO and corresponding SR that meet one or more of the following criteria:
Criterion L1: Installed instrumentation that is used to detect and indicate a significant abnormal degradation of the casks confinement boundary.
Criterion L2: An initial condition of a design basis accident that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion L3: A structure, system, or component that has a significant impact on public health and safety, based on risk insights and expert knowledge.
L2 L3
13 New CoC Location Goal of the Evaluation Criterion No.
Sub Criterion No.
Evaluation Criteria Appendix B (Continue)
CoC Appendix B, Technical Specifications, Section 4, Administrative Controls Include in the CoC the organization and management of procedures, recordkeeping, review and audit, and reporting requirements necessary to assure the safe operations related to the storage of spent fuel and reactor-related greater-than-class-C waste in an ISFSI.
7 This section should include high-level descriptions of the programs and the essential elements of the programs required to assure safe cask or ISFSI operation.
Identify the programs descriptions that include only the essential elements of the programs required to assure safe cask or ISFSI operation, with additional supporting information relocated to the FSAR, as necessary.
Implementation details would be included in general licensee procedures.
Risk insight Not Applicable Identify items that should not be removed from the CoC.
Evaluate the following questions:
8
- 8. Will removing this requirement from the CoC result in a significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
9
- 9. Will removing this requirement from the CoC result in the possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
10
- 10. Will removing this requirement from the CoC result in a significant reduction in the margin of safety for ISFSI or cask operation?
Holtecs Application on CoC Reorganization 14 Holtec provided:
- Evaluation forms like graded approach pilot
- Reformatted version of CoC and appendices NRCs observation of the application:
- Reorganized CoC format
- Removed duplicative items
- Not full graded approach evaluation as described earlier
NRCs Review & Evaluation 15
- The NRC welcome any initiative to improve the CoC and its appendices
- Completing the graded approach evaluation is voluntary
- Staff seeks clarification of Holtecs intent
- Reorganize CoC and appendices
- Complete graded approach, similar to the pilot
Need Information on Reorganization 16 Need a complete set of CoC and appendices prior to reorganization (for easier comparison of before and after)
Why does the new format have six appendices instead of two appendices as described in RIRP-I-16-01?
Evaluations of why an item is appropriate in a particular section in the new format:
Why move Appendix A Section 5.8 to Appendix B Section 4?
Why keep the first paragraph of the CoC at the same location? (no evaluation form)
Why move a blank item and remain blank?
Move Appendix A LCO 3.2.1 to Appendix B LCO 3.2.1 (no evaluation form)
17
- Items discussed on the previous slide
- Evaluations of and bases for what is important enough, i.e., safety-related/significant items and risk-significant content, to retain in the CoC/appendices
- Evaluations and bases for the level of detail of the information that should be retained in the new CoC/appendices versus what could be relocated to the FSAR Need Information for Graded Approach
18
- Evaluations/considerations of what information may need to be included in the new CoC/appendices based on the graded approach criteria (e.g.,
definition of operability)
- Evaluation bases to support yes/no responses in risk insight evaluation
- Inconsistencies (e.g., CoC-6 & CoC-7)
- Justification for content changes and incomplete changes (e.g., CoC-11)
Need Information for Graded Approach (Cont)
Moving Forward 19 Depend on Holtecs intent
- Reorganize CoC and appendices Provide clarification
- Graded approach Close coordination and communications Multiple public meetings to provide feedback Schedule
Public Comments 20 Please complete the online public meeting feedback form
Summary and Closing Remarks 21
BACKUP SLIDES Examples from Evaluation Forms
Appendix A Section 5.8
Appendix A Section 5.8 (page 2)
First paragraph of CoC
Appendix A LCO 3.2.1 Appendix B LCO 3.2.1
Pilot (TN)
Evaluation Form on Leakage Test
Pilot (TN) Evaluation Form on Leakage Test (Page 2)
Pilot (TN)
Evaluation Form on Definitions
HI-STORM FW Amendment 7 Evaluation Form for CoC-4
HI-STORM FW Amendment 7 Evaluation Form for CoC-4 (Page 2)
- Make sure the references are updated
- Retain = No change to language and stay at the same place in CoC or appendix
Evaluation Form for CoC-6
Evaluation Form for CoC-7
Evaluation Form for CoC-11