ML17300A154
| ML17300A154 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 11/01/2017 |
| From: | Richter M Nuclear Energy Institute |
| To: | Office of Nuclear Material Safety and Safeguards |
| Lindsay H | |
| Shared Package | |
| ML17300A135 | List: |
| References | |
| Download: ML17300A154 (12) | |
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Mark Richter Division of Spent Fuel Management Regulatory Conference November 1, 2017 Efficient Transition to Reactor Decommissioning
This is an explanation of the main idea Overview
- Industry Challenges
- Background and Current Landscape
- Efficiency Opportunities in Transition Rulemaking
This is an explanation of the main idea Decommissioning Landscape
- NRC has a proven regulatory framework for decommissioning activities Regulations for Permanent Defueling, SAFSTOR, Radiological Decommissioning, & Spent Fuel Management are well established
- 11 plants have safely completed decommissioning
- 19 plants are in the process of decommissioning
- 7 plants planning near term shutdown
- There currently is no regulatory framework to govern the transition from operations to decommissioning
NATIONAL NUCLEAR ENERGY STRATEGY CREATE THE NUCLEAR IMPERATIVE 4
Appropriately value nuclear generation Create sustainability via improved regulatory framework and reduced burden
- Innovate, commercialize, and deploy new nuclear Compete globally PRESERVE SUSTAIN INNOVATE THRIVE
This is an explanation of the main idea NRC Rulemaking Objective
- As stated in the NRCs 2015 Advanced Notice of Proposed Rulemaking (ANPR The primary objective..is to implement appropriate regulatory changes that reduce.licensing actions during decommissioning
- NRC further affirms in the ANPR The need forrulemaking is not based on any identified safety concerns
This is an explanation of the main idea Our Industry Vision
- A more efficient regulatory framework that:
- Governs efficient transition from operating to decommissioning
- Eliminates unnecessary barriers and licensing actions
- Imposes no additional regulatory burden on licensees that have completed transition to decommissioning
This is an explanation of the main idea
.A More Efficient Regulatory Framework
- A more efficient regulatory framework that:
- Provides certainty, efficiency and transparency
- Leverages lessons learned from the transition to decommissioning process
- Affirms there are no safety issues to be addressed
This is an explanation of the main idea Efficiency Opportunities
- NEI agrees with the NRC that there is a sound regulatory basis for rule changes to improve efficiency in the areas of Emergency Preparedness, Physical Security Decommissioning Trust Funds Financial Protection/Indemnity Backfitting Rule
- NRCs recommendations are generally consistent with the rulemaking proposal that NEI submitted in its March 17, 2016 comments on the NRCs ANPR.
This is an explanation of the main idea Efficiency Impediments
- NEI notes that NRC is recommending rulemaking in two areas not previously addressed in the ANPR:
Contents of the Post-Shutdown Decommissioning Activities Report (PSDAR)
Do not agree with proposed new requirements for the PSDAR to contain a description of how spent fuel managed pursuant to a general independent spent fuel storage installation (ISFSI) will be removed from the reactor site License amendments for non-power reactors.
Agree that the regulations should be amended to clarify that the requirement for a license amendment prior to commencement of decommissioning activities applies only to non-power reactors
This is an explanation of the main idea Efficient Regulatory Transition
- Ongoing NRC rulemaking is generally headed in right direction
- NRCs Draft regulatory basis soundly supports changes to improve the efficiency of transition - but leaves open door for other changes
- Progress has been slow
This is an explanation of the main idea Efficiency and Safety Do Co-Exist
- NEI strongly urges NRC to Continue on a path of completing a rulemaking to improve the efficiency of the transition from operations to decommissioning as expeditiously as possible.
Utilize the proposal we submitted in response to the ANPR in developing the final rule language.
NRC staff remain committed to the timely review of exemptions and license amendments that are necessary until this rulemaking can be completed.
Industry Challenge Develop innovative approaches to reduce regulatory burden and improve efficiency in decommissioning transition rulemaking in partnership with the NRC