Dry Cask Storage License Renewal Implementation January 24, 2018 Curt Lindner ENERCON Services, Inc. 1
Background 10 CFR 72 Subpart K General License 72.210 Grants general license to power reactor licensees (GL) 72.212 Specifies conditions of general license 72.214 Lists dry cask storage systems (DCSS) approved for use under general license 2
Background (cont) 10 CFR 72 Subpart L Approval of Spent Fuel Storage Casks 72.238 Issuance of Certificate of Compliance (CoC) CoC issued for a term of up to 40 years 72.240 Conditions for CoC Renewal Renewal for term of up to 40 years Application must include time-limited aging analyses (TLAA) for systems, structures and components (SSCs) important to safety and an aging management program (AMP) for aging issues that could affect these SSCs. 3
Background (cont) ENERCON Experience 10 CFR 54 License Renewal Applications for 3 sites 10 CFR 54 License Renewal Implementation support at 8 sites Actively involved in NEI License Renewal Task Force and several Working Groups Currently authoring EPRI License Renewal Mechanical and Structural Tools documents Aging management requirements very similar between reactor and dry cask storage Currently working or in discussions for DCS license renewal implementation support at 6 sites 4
List of Approved Storage Casks Approaching Renewal Model CoC # Approval Date Expiration Date Renewal Date Standardized NUHOMS 1004 01/23/1995 01/23/2015 12/11/2017 VSC-24 1007 05/07/1993 05/07/2013 09/20/2017 HI-STAR 100 1008 10/04/1999 10/04/2019 TBD HI-STORM 100 1014 05/31/2000 05/31/2020 TBD NAC-UMS 1015 11/20/2000 11/20/2020 TBD TN-32 1021 04/19/2000 04/19/2020 TBD NAC-MPC 1025 04/10/2000 04/10/2020 TBD W-150 1026 02/15/2001 02/15/2021 TBD TN-68 1027 05/30/2000 05/30/2020 TBD Advanced NUHOMS 1029 02/05/2003 02/05/2023 TBD 5
DCSS CoC Renewal Guidance NRC Guidance Documents NUREG-1927 Standard Review Plan NUREG-2214 Managing Aging Processes in Storage (MAPS) Report Industry Guidance Documents NEI 14-03 Format, Content and Implementation Guidance for DCSS Ops Based Aging Management 6
MAPS Process for DCSS Vendors Scoping Evaluation Aging Management Review Establish materials and environment Evaluate aging mechanisms Identify aging management activities Perform TLAA Evaluations Develop AMPs 7
AMP Elements 10 CFR 72 AMP requirements defined in NUREG-1927. Elements are effectively equivalent to that imposed on Part 54 license renewals 1. Scope 6. Acceptance Criteria 2. Preventative Actions 7. Corrective Actions 3. Parameters Monitored or Inspected 8. Confirmation Process 4. Detection of Aging Effects 9. Administrative Controls 5. Monitoring and Trending 10. Operating Experience 8
DCSS Renewal Application Content NEI 14-03 provides format for CoC renewal applications recommended for consistency with NRC review guidance in NUREG-1927. Content of application follows MAPS process identify affected materials perform aging management reviews perform TLAA evaluations develops AMPs that address the 10 elements 9
Tollgate Assessments Defined in Sec. 3.6.5 of NEI 14-03 and addressed in Rev. 1 of NUREG-1927 Intended a structured approach for assessing operating experience (OE) in the aging management process Use of assessment process allows for learning AMPs considering results of ongoing inspections of DCSS and OE from research and industry initiatives ISFSI Aging Management INPO Database (ISFSI AMID) created for aggregation and dissemination of OE to DCSS vendors and GLs 10
Tollgate Assessments (cont) Key elements of the tollgate concept addressed in App A of NEI 14-03 GL perform tollgate assessments as required by the DCSS UFSAR/CoC Consider industry OE from INPO database and other sources Adjust aging management activities as necessary as a result of OE Share results of assessments with database and CoC holder 11
CoC Renewal Process Cask vendors submit license amendment request documenting information required by MAPS Identification of SSCs important to safety AMR of SSCs TLAA of SSCs AMP for cask system AMP inspection requirements implementing the 10 elements Tollgate assessments 12
DCSS Renewal Impacts After renewal of the DCSS CoC, the GL must be prepared to address AMP additions to the UFSAR Revised CoC expiration date and conditions Revised Tech Specs 13
GL Implementation Activities Update the 72.212 Report for changes to UFSAR, CoCs, and Tech Specs Develop high-level AMP implementing document Develop tollgate assessment procedure Prepare AMP inspection procedures for each required inspection 14
GL Implementation Activities (cont) Prepare 72.48 evaluations for revised documentation Generate engineering change packages for LRI documentation 15
Ongoing GL AMP Processes Perform required AMP inspections and tollgate assessments according to required schedules Repairs and corrective actions stemming from AMP inspections Modifications to AMPs resulting from inspection and tollgate findings made via 72.48 evaluations 16
Potential AMP Implementation Issues Chloride-induced stress corrosion cracking (CISCC) applicability screening GL may be able to perform air monitoring to exempt from CISCC AMP Access to pad and casks necessary to perform VCC or canister lift Equipment and qualified personnel needed to perform inspections Alkali-Silica Reactions (ASR) in concrete 17
Other ISFSI Aging Management Issues Cask vendors typically only address important to safety SSCs that are a part of the cask Components of the ISFSI may also require coverage by the AMP Concrete pad inspections (surface conditions and potential subsurface degradation) Groundwater chemistry monitoring 18
Other ISFSI Aging Management Issues (cont) Preparation for NRC inspection of AMP activities NRC plans to perform inspections using temporary instructions at selected sites in advance of development of their inspection procedure NRC inspections to review GL implementation of the 10 elements of each AMP 19
Implementation Timeline Schedule for implementation varies NUREG-1927 Section 3.6.3 indicates a 1 year schedule Renewed CoC requirements VSC-24 1 year Standardized NUHOMS 180 days 20
Implementation Timeline (cont) Near term actions Revise 72.212 Report for CoC renewal and AMP Develop AMP descriptive document for reference in 72.212 Prepare Tollgate procedure Prepare 72.48 Evaluation Implement ECN 21
Implementation Timeline (cont) Long term actions (> 20 years in storage) Develop AMP inspection procedures Perform inspections Perform Tollgate assessments 22
Questions? 23