ML18086B196
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| ML18086B196 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 03/29/2018 |
| From: | Richter M Nuclear Energy Institute |
| To: | Office of Nuclear Material Safety and Safeguards |
| B WATSON DUWP NMSS | |
| Shared Package | |
| ML18086B191 | List: |
| References | |
| Download: ML18086B196 (11) | |
Text
NEI Perspectives on Efficient Decommissioning Mark Richter U.S. Nuclear Regulatory Commissions 2018 Regulatory Information Conference March 14, 2018
© NEI 2018. All rights reserved.
=
Background===
- On November 20, 2017, NRC issued the Regulatory Basis Document (RBD) for rulemaking proposing changes to decommissioning regulations.
- Stated objective in NRCs Advanced Notice of Proposed Rulemaking (ANPR) is to implement appropriate regulatory changes that reduce the number This is an of licensing actions needed during decommissioning.
explanation of the main idea
© NEI 2018. All rights reserved.
Industry Position
- RBD provides sound foundation for regulatory improvements needed to meet NRCs stated objective, but leaves the door open to changes that could add unnecessary regulatory burden
- Recommendations support replacement of licensing actions for shut down plants with new regulations enhancing efficiency This isand an certainty for NRC and licensees
- Some explanation of concerns with proposal the main
- idea Additional opportunities
© NEI 2018. All rights reserved.
Industry Concerns
- Some RBD recommendations could impose burdensome new guidance or requirements not necessary to assure safety or reduce regulatory burden:
- Post Shutdown Decommissioning Activities Report This is(PSDAR) an and related Guidance explanation of
- Physical Security the main idea
© NEI 2018. All rights reserved.
PSDAR - Environmental Impacts
- Modified language in 10 CFR 50.82(a)(4) to state that licensees must:
- Evaluate the environmental impacts of planned decommissioning activities in the PSDAR
- Evaluate if the impacts are bounded by previous This isfederally an issued environmental review documents explanation of th e main idea
© NEI 2018. All rights reserved.
PSDAR - Community Advisory Board
- Address the creation of community advisory boards including details on frequency, makeup, and topics
- No increase in public safety or efficiency
- Community interaction is a site-specific consideration
- Changes to PSDAR content should be driven by need to This is an explanation better of inform the agencys regulatory decisions the main
- idea No deficiencies noted by NRC in current guidance for PSDARs hindering regulatory decision-making
© NEI 2018. All rights reserved.
PSDAR - Spent Fuel Management
- Additional discussion in the PSDAR or Spent Fuel Management Plan to address
- Management of spent fuel before dismantling systems for handling and shipping fuel.
- Adds new burden to prepare and submit the This isPSDARan while not adding any safety benefit.
explanation of the main idea
© NEI 2018. All rights reserved.
Physical Security
- NRC disposition of NEI comments on minimum number of armed responders diverges from the stated objective of rulemaking.
- Final RBD proposes no changes to the inefficient process where licensees submit reassessment of the minimum number of armed responders although NRC recognizes the significant reduction in risk and targets This is an
- Allowing licensee reassessments to be documented in changes explanation of to security plans under 10 CFR 50.54(p) lessens the regulatory the main idea burden on staff and licensees and streamlines process for adjusting security requirements
© NEI 2018. All rights reserved.
Value Proposition
- Decommissioning Rulemaking that addresses inefficiencies without adding burden:
- Saves 90+/- U.S. operating plants nearly $1.5 billion
- Reduces transition process time, now 12-18 months
- Preserves decommissioning trust fund for radiological Thisdecommissioning is an
- Reduces explanation of need to do it prematurely by doing it more the main idea efficiently!
© NEI 2018. All rights reserved.
Conclusion
- NEI strongly urges NRC to:
- Complete rulemaking to improve the efficiency of the transition from operations to decommissioning as expeditiously as possible.
- Utilize NEI response to the ANPR in developing the final rule language This is an
- Continue explanation of timely review of exemptions and license the main amendments idea until rulemaking is complete
© NEI 2018. All rights reserved.
Questions?
© NEI 2018. All rights reserved.