ML18086B196
| 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
Mark Richter U.S. Nuclear Regulatory Commissions 2018 Regulatory Information Conference March 14, 2018
© NEI 2018. All rights reserved.
NEI Perspectives on Efficient Decommissioning
This is an explanation of the main idea
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 of licensing actions needed during decommissioning.
© NEI 2018. All rights reserved.
This is an explanation of the main idea 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 and certainty for NRC and licensees
- Some concerns with proposal
- Additional opportunities
© NEI 2018. All rights reserved.
This is an explanation of the main idea 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 (PSDAR) and related Guidance
- Physical Security
© NEI 2018. All rights reserved.
This is an explanation of th e main idea 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 federally issued environmental review documents
© NEI 2018. All rights reserved.
This is an explanation of the main idea 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 better inform the agencys regulatory decisions
- No deficiencies noted by NRC in current guidance for PSDARs hindering regulatory decision-making
© NEI 2018. All rights reserved.
This is an explanation of the main idea 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 PSDAR while not adding any safety benefit.
© NEI 2018. All rights reserved.
This is an explanation of the main idea 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
- Allowing licensee reassessments to be documented in changes to security plans under 10 CFR 50.54(p) lessens the regulatory burden on staff and licensees and streamlines process for adjusting security requirements
© NEI 2018. All rights reserved.
This is an explanation of the main idea 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 decommissioning
- Reduces need to do it prematurely by doing it more efficiently!
© NEI 2018. All rights reserved.
This is an explanation of the main idea 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
- Continue timely review of exemptions and license amendments until rulemaking is complete
© NEI 2018. All rights reserved.
Questions?
© NEI 2018. All rights reserved.