ML21074A306
| ML21074A306 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/2021 |
| From: | NRC/NMSS/DREFS/RRPB |
| To: | |
| James O'Driscoll | |
| References | |
| 10 CFR Part 50, 10 CFR Part 52, NRC-1405, NRC-2009-0196, RIN 3150-AI66 | |
| Download: ML21074A306 (32) | |
Text
CORRECTED Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Meeting on Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing Rulemaking Docket Number: N/A Location: teleconference Date: Tuesday, March 2, 2021 Work Order No.: NRC-1405 Pages 1-31 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 NUCLEAR REGULATORY COMMISSION 2 + + + + +
3 PUBLIC MEETING ON ALIGNMENT OF LICENSING PROCESSES 4 AND LESSONS LEARNED FROM NEW REACTOR LICENSING 5 RULEMAKING 6 + + + + +
7 TUESDAY 8 MARCH 2, 2021 9 + + + + +
10 11 The public meeting convened via Teleconference 12 at 1:00 p.m. EST, James ODriscoll, Rulemaking 13 Project Manager, presiding.
14 15 PRESENT 16 JAMES ODRISCOLL, Rulemaking Project Manager, 17 NMSS 18 ANNA BRADFORD, Director, Division of New and 19 Renewed Licenses, NRR 20 ALLEN FETTER, Senior Project Manager, NRR 21 22 ALSO PRESENT 23 Omid Tabatabai-Yazdi, U.S. NRC 24 CLINT ASHLEY, U.S. NRC 25 GARY BECKER, NuScale Power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 JANA BERGMAN, U.S. NRC 2 THOMAS BERGMAN, NuScale Power 3 ILKA BERRIOS, U.S. NRC 4 ROBERT VETTORI, U.S. NRC 5 CINDY BLADEY, U.S. NRC 6 ERIC BOWMAN, U.S. NRC 7 THERESA BUCHANAN, U.S. NRC 8 TISON CAMPBELL, U.S. NRC 9 HELEN CHANG, U.S. NRC 10 JACK CUSHING, U.S. NRC 11 HOWARD BENOWITZ, U.S. NRC 12 DAVID DESAULNIERS, U.S. NRC 13 CAROLINE EGLI, ICF 14 THOMAS FREDETTE, U.S. NRC 15 JONATHAN FISKE, U.S. NRC 16 WILLIAM FREEBAIRN, S&P Global Platts 17 DENNIS GALVIN, U.S. NRC 18 JOE COLACCINO, U.S. NRC 19 LIZ GORMSEN, ICF 20 ZACHARY HARPER, Westinghouse 21 RYAN HENDERSON, SNC 22 JOHN HONCHARIK, U.S. NRC 23 MARIELIZ JOHNSON, U.S. NRC 24 GLENN KELLY, NSM LLC 25 PETE LEE, U.S. NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 PAUL LOZA, Public 2 CAROLYN LAURON, U.S. NRC 3 CHRISTINE MELLEN, ICF 4 ROSS MOORE, OKLO 5 TAMMY MORIN, Holtec International 6 HUGH MOSSMAN, U.S. NRC 7 ADRIAN MUNIZ, U.S. NRC 8 ERIC OESTERLE, U.S. NRC 9 MARTIN ONEILL, NEI 10 DONALD PALMROSE, U.S. NRC 11 MALCOLM PATTERSON, U.S. NRC 12 AARON SANDERS, U.S. NRC 13 THOMAS SCARBROUGH, U.S. NRC 14 FRED SCHOFER, U.S. NRC 15 FARSHID SHAHROKHI, Framatome 16 JILL SHEPHERD, U.S. NRC 17 NIRY SIMONIAN, U.S. NRC 18 TODD SMITH, U.S. NRC 19 LANCE STERLING, Public 20 DONG PARK, U.S. NRC 21 MIKE TSCHILTZ, NEI 22 BRIAN THOMAS, U.S. NRC 23 DON WILLIAMS, Consultant 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P-R-O-C-E-E-D-I-N-G-S 2 (1:00 p.m.)
3 MR. O'DRISCOLL: So, welcome, everybody.
4 My name is Jim O'Driscoll. I'm the lead rulemaking 5 project manager on this effort. My role is to help 6 the meeting go smoothly to achieve a common objective.
7 My approach will be to set ground rules, encourage 8 participation, and have an open dialogue and maintain 9 a respectful and professional environment. I will 10 keep the meeting focused on the topic at hand and 11 keep track of the agenda to ensure timeliness and 12 that all topics are covered.
13 This is a Category 3 public meeting, 14 which means that it is structured to provide 15 opportunities for public interaction. We have 16 provided an agenda, which includes time to discuss 17 your questions on the status of the rulemaking since 18 the last public meeting on April 29, 2020. Our 19 meeting is scheduled for one three-and-a-half-hour 20 session with no breaks. Next slide.
21 Okay. Before we get started, I'd like to 22 go over some logistics and housekeeping items. So, 23 for ground rules, one speaker at a time. Please state 24 your name before speaking, as the meeting is being 25 recorded and transcribed. Please hold your questions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 until after the NRC presentation. And please try to 2 be concise to ensure all stakeholders can share their 3 perspectives.
4 Again, the operator will place you in 5 queue to ask a question. She already went over what 6 you have to do for that. If you speak on the line, 7 please speak slowly and clearly. Remember to state 8 your organizational affiliation because we want to 9 get the transcriber to get it right. We have an 10 operator on the line to help us. And then, again, 11 you're in listen-only mode unless you notify the 12 operator that you wish to speak.
13 If you're at a computer and are not using 14 Microsoft Teams but still would like to see the slides 15 for today's meeting, you can access them from the 16 NRC's homepage, www.nrc.gov, under the Public 17 Meetings and Involvement heading. Click on the link 18 to the public meetings schedule, scroll down to 19 today's date and meeting time, find the information 20 for this meeting, and click on the "More" link. It 21 will bring up more details of the meeting. At the 22 bottom of the page, under "Related Documents," you'll 23 find a link to the presentation slides.
24 Please also note that a list of the 25 acronyms used in the slides is at the end of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 presentation. I'll try to say the full term at least 2 once to help folks follow along. Also note that a 3 list of the ADAMS accession numbers to the documents 4 referenced in the NRC staff's presentation can be 5 found at the end of the staff's slide presentation.
6 Also, of course, this is for any speaker, 7 please be careful to not discuss any safeguards, 8 security-related, classified or proprietary 9 information during this meeting. Although we intend 10 to have an open dialogue, please note that the NRC 11 will not make any regulatory commitments during this 12 meeting. Next slide.
13 So, today's meeting. We're on Slide 3 14 for people following along on the phone. The purpose 15 of today's meeting is to provide an update on the 16 staff's efforts since the last public meeting the NRC 17 held on this topic, which took place on April 29th of 18 last year. A summary of that meeting can be found at 19 ADAMS under Accession No. ML20141L609.
20 This meeting will provide an opportunity 21 to discuss the specific items in the rulemaking as 22 described in the regulatory basis, which was 23 published on the 29th of January of this year and 24 which is currently out for public comment. The detail 25 of the discussion will be at a high level because the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 rule's scope is so broad. We may not have the 2 specific subject matter expert available on the phone 3 to address your question if it gets too technical.
4 However, you always have the option to submit your 5 question formally.
6 We will also discuss the estimates of 7 costs and savings for the activity. And we will 8 conduct a question and answer session on any topics 9 of stakeholder interest.
10 Finally, we will provide you an update on 11 the next steps for the project. We hope that this 12 interaction will help you understand the contents of 13 the rulemaking regulatory basis that is out for 14 comment and the status of the rulemaking.
15 Like our previous public meetings, 16 although we will take the information, perspectives, 17 and questions we hear today into consideration when 18 developing the proposed rule, we do not intend to 19 formally respond to comments you provide at this 20 meeting. As I discussed, we will respond to written 21 comments about the subject that we receive during the 22 public comment period. I will briefly remind folks 23 of the ways that comments can be provided that is 24 detailed in the Federal Register notice for this 25 activity that was recently published. Next slide.
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8 1 So, now I'd like to introduce Anna 2 Bradford, the Director of the Division of New and 3 Renewed Licenses in NRR, for opening remarks. Anna?
4 MS. BRADFORD: Thank you, Jim. Can you 5 please confirm you can hear me? Jim?
6 MR. O'DRISCOLL: Oh, yes, I can hear you.
7 MS. BRADFORD: Great. Hi, everyone, and 8 welcome. As Jim mentioned, my name is Anna Bradford.
9 I'm the Division Director for the Division of New and 10 Renewed Licenses in NRR. My division has the 11 technical lead for what we informally call the Part 12 50/52 lessons learned rulemaking. We've been 13 planning for and working on this Part 50/52 effort 14 for several years now, and we've had multiple public 15 meetings on the topic already.
16 Today's meeting will focus on the status 17 of the rulemaking activities, and it's intended to 18 facilitate your understanding of the content of the 19 regulatory basis document which, as Jim mentioned, is 20 currently out for public comment. Once we've received 21 and evaluated the comments we receive on this 22 regulatory basis, then we plan to send the proposed 23 rule to the Commission in 2022, and the proposed rule 24 will then also go out for public comment.
25 I just want to say that I look forward to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 the discussion, I look forward to the questions today.
2 Input from all of you will help us make this a better 3 rule in the end. So, thanks. And Jim, I'll turn it 4 back over to you.
5 MR. O'DRISCOLL: Thanks a lot, Anna. Next 6 slide. We're going to roll into the staff 7 presentation right now. Next slide, please. We're on 8 Slide 6.
9 Again, good afternoon. I'm Jim 10 O'Driscoll, the lead rulemaking project manager on 11 the activity. I'm in the Office of Nuclear Material 12 Safety and Safeguards in the Division of Rulemaking, 13 Environmental, and Financial Support, otherwise known 14 as REFS. Also joining me today is Allen Fetter, who 15 is from the NRCs Office of Nuclear Reactor 16 Regulation. And we have several other NRC staff on 17 the call, as well. Next slide.
18 We're on Slide 7. The staff is engaging 19 in a rulemaking to better align portions of the 20 regulation to 10 CFR Parts 50 and 52 in four areas, 21 as described in the regulatory basis. The staff will 22 also address items derived from lessons learned from 23 previous new reactor licensing activities described 24 in the regulatory basis.
25 This activity implements the Commission's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 direction in SRM-SECY-15-0002. Our goal is to better 2 align Parts 50 and 52 licensing processes such that 3 equivalent designs submitted for the NRC review under 4 each process are assessed against consistent 5 technical standards that yield outcomes with 6 equivalent demonstrations of adequate safety, 7 security, and environmental protection.
8 In SECY-15-0002, issued January 8, 2015, 9 the staff made several recommendations to the 10 Commission regarding policy and regulatory updates to 11 ensure consistency in new reactor licensing reviews.
12 The staff also made recommendations to address staff-13 identified lessons learned obtained through the 14 licensing reviews completed up to July 2019. These 15 changes are intended to improve clarity and reduce 16 unnecessary burden on applicants and the staff. As 17 well as these, the staff has addressed or intends to 18 address editorial and administrative changes, as 19 well. Next slide.
20 We're on Slide 8. This is Slide 8. It 21 shows our typical rulemaking process. Rulemaking is 22 how the NRC develops its regulations. With the 23 publication of the regulatory basis for comment, we 24 have completed tasks in the second box, the regulatory 25 basis box. We are right now in the 75-day public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 comment period.
2 The written comments we receive during 3 this comment period will go on the docket for the 4 rule. In the proposed rule, we will include a summary 5 of the stakeholder interactions, comments, and key 6 messages we received from the public on the regulatory 7 basis. The next two major steps are the publication 8 of the proposed rule and the publication of the final 9 rule. We'll continue to provide opportunities for 10 public comment in this process.
11 Upon publication of the proposed rule in 12 the Federal Register, you will again have the 13 opportunity to review the proposed rule and provide 14 written comments to the NRC. We expect to hold a 15 public meeting during that public comment period.
16 Next slide.
17 We're on Slide 9, just some staff 18 milestones. So, although the staff received 19 direction to commence the rulemaking in 2015, the 20 Commission directed the staff to prioritize the 21 project in accordance with Project Aim. If you 22 recall, the purpose of Project Aim was to ensure the 23 staff continues its focus on those tasks seen as 24 essential for our mission as seen in the next few 25 years. To that end, this rulemaking project was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 deliberately budgeted to start in Fiscal Year 2019.
2 The staff commenced work in October 2018.
3 The staff's first task was to clearly define the scope 4 of the regulatory basis for the rulemaking. From the 5 staff's outreach efforts inside and outside the NRC, 6 the staff collected a large number of items to 7 consider for inclusion. On January 15th, 2019, the 8 staff held a Category 3 public meeting to request 9 feedback from the external stakeholders on what 10 should be included in the scope. NEI arranged for a 11 panel of industry representatives to attend.
12 Using the input from the staff and 13 stakeholders, the staff aligned on a scope on July 14 11th, 2019. In late August of that year, the staff 15 issued information paper SECY-19-0084, which provided 16 information to the Commission and the public on the 17 status and the scope of the regulatory basis. In 18 late September 2019, the staff briefed members of the 19 Advisory Committee on Reactor Safeguards' 20 Subcommittee on Regulatory Policies and Practices.
21 The staff received views and comments from the ACRS 22 as individual members, and there was no ACRS letter 23 issued on the topic. The slides and transcript for 24 the meeting are available at ADAMS in Accession No.
25 ML19294A009. Next slide.
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13 1 We're on Slide 10. We held a public 2 meeting on November 21st of that year. In that 3 meeting, NEI and other industry representatives asked 4 questions and provided comments on the scope of the 5 rule as it was described in SECY-19-0084. The slides 6 and transcript for that meeting are available at ADAMS 7 at ML19344C768.
8 In February of last year, the senior 9 technical project manager in NRR, Allen, received the 10 first draft of the regulatory basis inputs from the 11 technical writers. April of last year, the NRC held 12 another public meeting where we discussed several 13 specific issues that were of interest to the public.
14 As we previously stated, the slides and summary of 15 that meeting can be found in ADAMS under Accession 16 No. ML20141L609.
17 In January of this year, the NRC 18 published the regulatory basis for public comment.
19 Currently, we're in the public comment period where 20 the NRC is soliciting comments on the document for 21 consideration when developing the proposed rule. The 22 comments period will end on April 14th. All these 23 efforts are in direct support of the next steps. Next 24 slide?
25 Here's an overview of the next steps, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 we're on Slide 11. For the next steps in the project, 2 this week the staff plans to brief the ACRS full 3 committee members and allow them the opportunity to 4 ask questions on the regulatory basis. After the 5 public comment period ends in April, the staff will 6 carefully evaluate the comments received when 7 drafting the proposed rule.
8 We expect to complete the technical 9 development of the proposed rule in October of this 10 year. After this, the staff must perform several 11 tasks in order to finish the proposed rule. First, 12 we'll need to develop the regulatory analysis. We 13 will also need to hold management and ACRS briefings.
14 Finally, we will need to obtain management approval.
15 This is expected to be completed by May of next year.
16 Under the current schedule, the NRC will issue the 17 final rule by October 2024. We continue to look at 18 process efficiencies in order to improve the 19 schedule. Next slide.
20 Here is a little bit about the regulatory 21 basis. We're on Slide 12. The NRC requires a 22 regulatory basis for most of its rulemakings in order 23 to ensure sound and informed decision-making 24 throughout the rulemaking process. The regulatory 25 basis documents the justification for why rulemaking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 is the best way to resolve a regulatory issue. The 2 regulatory basis also describes the technical, legal, 3 and/or policy information that would support the 4 content of the rule. The regulatory basis out for 5 public comment includes a preliminary cost-benefit 6 analysis of the proposed changes. Next slide.
7 We're on Slide 13. Here I'll try to 8 provide a snapshot of the scope in the regulatory 9 basis. There are 50 items in the scope in the 10 regulatory basis. This is down from the 54 items 11 that we had in the scope earlier in the development 12 at the time of our last public meeting. The 13 regulatory basis has a detailed discussion on how the 14 staff evaluated each item that was communicated in 15 SECY-19-0084.
16 Among these items, the staff evaluated 17 and discussed 115 alternatives. These alternatives 18 are primarily a no action, a rulemaking, and a 19 guidance-only alternative for each item. However, 20 for several items there are additional alternatives 21 analyzed depending on the issue. Most of these are 22 multiple different rulemaking options.
23 Of the 50 scope items, 43 of them 24 recommend rulemaking. So, you can see that we 25 recommended that many items screen in to the proposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 rule. Of these 43 items, 23 of them will also require 2 guidance updates or new guidance to be developed and 3 issued for comment in the proposed rule.
4 In the regulatory basis, the staff 5 identified 17 different guidance documents that could 6 be affected. This rule also spans a large number of 7 CFR parts besides Parts 50 and 52 in order to make 8 conforming changes. These parts include Parts 2, 21, 9 26, 51, 55, 70, and 73. Next slide.
10 We're on Slide 14. The scope consists of 11 four items meant to align Parts 50 and 52. These are 12 discussed in detail in Appendices A through D of the 13 regulatory basis. Next slide.
14 The scope also includes 46 lessons 15 learned items. These are broken up into the general 16 areas of operator licensing, physical security, 17 fitness for duty, emergency planning, Part 52 18 licensing process, environmental topics, 19 applicability of other processes to the Part 52 20 process, and miscellaneous topics. I will now briefly 21 summarize the staff's recommendation on each of these 22 items. Next slide.
23 We're on Slide 16. Starting with the 24 issue of severe accidents in Part 50, which is covered 25 by Appendix A of the regulatory basis, the staff has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 identified that the Part 50 process does not 2 adequately address the NRC's severe accident policy 3 statement. We are recommending rulemaking to revise 4 Part 50 to include Part 52-like requirements to 5 address severe accidents. We identified Section 6 50.34 as the affected section, along with the standard 7 review plan, Chapter 19, which deals with these 8 requirements. Next slide.
9 We're now on Slide 17 for those folks on 10 the phone. We have several issues that relate to PRA 11 requirements -- that's probabilistic risk assessment, 12 that's what PRA is -- requirements that we are 13 addressing. These are related to requiring the use 14 of PRA in design, making the risk-informed process 15 for safety-related structures, systems, and 16 components more accessible, and changing the timing 17 of PRA upgrades.
18 The staff recommended rulemaking with 19 guidance changes to address these items. The 20 regulatory changes include Sections 50.34 and 50.71 21 and 50.69. We will also revise several Regulatory 22 Guides related to the PRA. Reg Guide 1.174, which is 23 Revision 3. And that's titled, An Approach for Using 24 Probabilistic Risk Assessment in Risk-Informed 25 Decisions on Plant-Specific Changes to the Licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 Basis.
2 It also looks like we're going to change 3 Regulatory Guide 1.200, Revision 2, which is titled, 4 An Approach for Determining the Technical Adequacy of 5 Probabilistic Risk Assessment Results for Risk-6 Informed Activities. We're also looking at 7 changes to Regulatory Guide 1.201, which is 8 Guidelines for Categorizing Structures, Systems, and 9 Components in Nuclear Power Plants According to Their 10 Safety Significance.
11 We're going to look at Regulatory Guide 12 1.205, Revision 1, which is titled Risk-Informed, 13 Performance-Based Fire Protection for Existing Light-14 Water Nuclear Power Plants, dated 2009.
15 And we're also looking at Regulatory 16 Guide 1.206, Revision 1, which is titled Applications 17 for Nuclear Power Plants. Next slide.
18 We're now on Slide 18. The staff is 19 recommending rulemaking with guidance changes to 20 align Parts 50 and 52 with respect to the submission 21 of the Three Mile Island-related information. The 22 regulations in 50.34 will be affected, along with the 23 standard review plan. In addition, we have a specific 24 request for comment question in the FRN that relates 25 to what impacts of the TMI requirements on non-light-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 water reactor applicants should be considered in the 2 scope of this proposed rule. Next slide.
3 We're on Slide 19. The staff recommends 4 Section 50.34 to be changed to clarify the specific 5 fire protection information that needs to be 6 submitted with a Part 50 application. We don't 7 anticipate any guidance changes for this item. Next 8 slide.
9 We're now on Slide 20. The staff 10 recommends rulemaking and guidance to address an 11 inadequacy in the regulations with respect to 12 operator training for operators of plants undergoing 13 construction, which we call cold plants, the criteria 14 for simulation facilities, and requirements for plant 15 walkthrough and continuing training. Several 16 sections of Part 55 would be amended, and a new 17 guidance document would have to be created. Next 18 slide.
19 We are now on Slide 21. In the area of 20 physical security, the staff has recommended 21 rulemaking to reduce what we believe is an unnecessary 22 regulatory burden related to the physical protection 23 of unirradiated fuel. We propose to amend several 24 sections of Parts 70 and 73, and to update guidance.
25 Next slide.
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20 1 We're on Slide 22. The staff is 2 recommending rulemaking and guidance to address some 3 lessons learned related to construction site access 4 for contract employees, fitness for duty related 5 lessons learned from reactor plant construction, 6 medical review officer procedures, and other 7 technical corrections. We are proposing changes to 8 several sections of Part 26 and Regulatory Guide 9 changes. Next slide.
10 We are now at Slide 23. The staff is 11 proposing a variety of rulemaking and guidance 12 changes to address several issues related to 13 emergency planning. These are the initial emergency 14 classification and action level scheme, the emergency 15 plan change process, the emergency preparedness 16 exercises, significant impediments to the development 17 of emergency plans, and requirements for off-site 18 contacts, arrangements, and certifications.
19 The staff is recommending guidance for 20 Item 1, rulemaking for Items 2 and 5, and rulemaking 21 and guidance for Items 3 and 4. The regulations 22 affected include several sections of Parts 50 and 52, 23 and several sections of Appendix E to Part 50. In 24 addition, we have a specific request for comment 25 question in the FRN that relates to what is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 appropriate distance within which to perform the 2 siting analysis. Next slide.
3 We're on Slide 24. We are addressing 4 several different areas that relate to the Part 52 5 licensing process. These areas are design 6 certification renewal in Section H.1 of the reg basis, 7 the Part 52 change process discussed in Section H.2 8 of the reg basis, design scope and standardization 9 discussed in H.3 of the regulatory basis, standard 10 design approval discussed in Section H.4, and the 11 contents of applications discussed in Section H.5 of 12 the regulatory basis. Next slide.
13 We're on Slide 25. For those items we 14 are making the following recommendations. We 15 recommend rulemaking to remove the 15-year duration 16 of design certifications. We're recommending 17 rulemaking and guidance to clarify aspects of the 18 change process. We're recommending rulemaking and 19 guidance to clarify the term "essentially complete 20 design," and to streamline some requirements related 21 to design information. We're recommending rulemaking 22 to clarify requirements when filing an application 23 that references one or more standard design 24 approvals. Finally, rulemaking and guidance to 25 clarify the contents of applications.
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22 1 Additionally, we have three specific 2 request for comment questions in the FRN that relate 3 to whether to eliminate or change the duration 4 requirements for manufacturing licenses, a question 5 about whether to eliminate or change duration 6 requirements for standard design approvals, and a 7 question of whether to remove the expired design 8 certification rules from Part 52 appendices.
9 Just some regulations that these affect, 10 I'll just go through them real quick. For H.1, we're 11 going to touch Sections 52.55, 52.57, 52.59, and 12 52.61, and the Part 52 DC appendices. For item H.2, 13 we're going to change Sections 52.63 and 52.98, 14 Sections IV.A.2.a and VIII.B.5 of the Part 52 DC 15 appendices. For item H.3, we're going to change 16 Sections 52.1, 52.47, 52.63, 52.79, 52.93, 52.137, 17 52.157, and 52.171, and Sections II, IV.A.1, and 18 IV.A.2.a through IV.A.2.f of the Part 52 appendices.
19 We're also going to change Sections IV.A.2.d and IX 20 in Part 52 DC appendices, A through D only. For item 21 H.4, we're going to change or modify Sections 52.73, 22 52.133, and 52.153. For H.5, we're going to modify 23 or change Sections 50.34, 50.100, 52.17, 52.47, 24 52.79, 52.137, and 52.157. And for guidance for item 25 H.2, we're going to change or modify Reg Guides 1.187 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 and 1.206. For Item H.3, we're going to change and 2 modify Reg Guide 1.206 and NUREG-0800. For item H.5, 3 we're going to change or modify Reg Guide 1.206. Next 4 slide.
5 So, we're on Slide 26. For environmental 6 topics, we've identified two issues. The first, the 7 staff considered changes that would ease the process 8 for submittal of an environmental report in a Part 50 9 construction permit application. The second topic 10 relates to fixing the regulations to enable an 11 applicant to incorporate a prior environmental 12 assessment in the Part 50 construction permit 13 process.
14 The staff recommended no action on the 15 first item because there was no clear cost savings to 16 the action. For the second item, the staff 17 recommended rulemaking to allow a construction permit 18 applicant to reference a prior environmental report.
19 Next slide.
20 We're on Slide 27. Here we are addressing 21 three issues. The first is really a correction to 22 clarify the rules around an ITAAC hearing. The second 23 is a change that would reduce burden on certain 24 combined license applicants and holders of submittals 25 for FSAR updates. And the third clarifies an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 inconsistency relating to backfitting and issue 2 finality. The staff recommends rulemaking for the 3 first and second items and rulemaking with guidance 4 to address the third item. Next slide.
5 We're on Slide 28. In this area we 6 address 10 separate topics. We are recommending 7 rulemaking with no guidance changes needed for eight 8 of the items. For the items related to the change 9 process for plant-specific technical specifications 10 bases, and the use of ASME Boiler & Pressure Vessel 11 Code Section XI in the Part 52 process, the staff is 12 recommending no changes. Next slide.
13 This is a little bit about estimates of 14 costs and savings. We're on Slide 29. As part of 15 the development of the regulatory basis, the staff 16 considered the potential costs and savings for both 17 the industry and the NRC. These estimates are 18 preliminary and subject to change as we further 19 develop the regulatory solutions. In the proposed 20 rule, we intend to make available a separate draft 21 cost estimate document that will have more detail.
22 We evaluated the proposed changes against 23 the regulatory baseline; that is, what we're 24 currently doing. We analyzed savings for the next 10 25 years where it was applicable. Next slide.
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25 1 We're on Slide 30. We calculated the net 2 averted costs to the NRC and industry using two 3 different discount rates to represent an uncertainty 4 in the alternative rate of return that the savings 5 could generate. Using the higher seven percent rate 6 of return, the savings for the rulemaking to industry 7 could be over $12 million. The savings to the NRC 8 could be close to $6 million. The estimates go up as 9 the discount rate goes down, when using a lower 10 discount rate of three percent net present value.
11 The biggest items of averted costs are 12 the items related to security requirements for the 13 storage of unirradiated fuels, the elimination of the 14 need for DC renewals, the clarification of the scope 15 of Tier 1 information, and the elimination of 16 information requirements related to conformance to 17 the standard review plan. And also enabling a 18 construction permit applicant to reference a reviewed 19 environmental assessment.
20 There were several areas where the 21 changes increased costs. The major ones are the 22 evaluation of severe accidents earlier in the Part 50 23 process, the items related to PRA changes, the TMI 24 requirements for Part 50 applicants, and operator 25 licensing requirements for cold plants. Next slide.
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26 1 We're on Slide 31. As I said, the total 2 net savings could be anywhere from $18 million to 3 about $30 million. The corresponding sensitivity 4 analysis we performed concluded there is a very, very 5 high chance of obtaining cost savings from proceeding 6 with this activity. Of course, the rulemaking also 7 achieves other, non-quantifiable benefits, such as 8 public confidence. Next slide.
9 All right. At this point, we'll take 10 your questions and comments. As I said before, please 11 indicate your desire to speak by pressing star-1 on 12 your phone. And I'd like to hand it over to the 13 operator.
14 OPERATOR: Again, we will begin the 15 question and answer session. Just as stated before, 16 if you'd like to ask a question please press star-1 17 and record your name when prompted. If you need to 18 withdraw your question you would press star-2. We 19 will wait for the first question.
20 It looks like our first question comes 21 from Mike. Mike, your line is open.
22 MR. TSCHILTZ: Okay. This is Mike 23 Tschiltz, a consultant at NEI. Can everyone hear me 24 okay?
25 MR. O'DRISCOLL: I can hear you.
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27 1 MR. TSCHILTZ: Okay. Thank you. I think 2 it's appropriate for me to start off the comments on 3 this in recognizing the amount of work that the NRC's 4 put into this. I think our initial impression, I 5 think, from most of the people that I've talked to 6 about this is there are a number of beneficial changes 7 in the rulemaking that take advantage of the lessons 8 learned we have with our experience with Part 52.
9 So we're happy to see that. So, we're in 10 the middle of the review period, and since this draft 11 reg basis is over 400 pages, it's taking us a while 12 to gather the input from everyone on this. It's kind 13 of premature for us to comment on any of this from an 14 industry perspective.
15 I think just a general observation is 16 that there were several changes that the industry was 17 advocating that the NRC, at least in the draft 18 regulatory basis, decided not to include in the 19 rulemaking. So I think we will continue to plead our 20 case for those specific changes and maybe provide 21 some additional justification. We're looking forward 22 to that interaction with the NRC where we can continue 23 to advocate for those specific changes.
24 That's all the comments that I have, 25 thank you.
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28 1 MR. O'DRISCOLL: Thanks, Mike.
2 OPERATOR: And at this time I see no 3 further questions in the queue. However, if there 4 are more questions please press star-1 and record 5 your name when prompted.
6 I see no questions in the queue.
7 MR. FETTER: Hey, Jim, this is Allen 8 Fetter. I know that folks were told to call in to 9 the bridge line, but since I'm presenting the slides 10 I haven't looked at anything anyone's put in the chat.
11 Did you want to take a look in the chat to see if 12 there's anything anybody commented on?
13 MR. O'DRISCOLL: It looks like -- I don't 14 see any technical questions.
15 MR. FETTER: Okay, other than calling 16 into the bridge line.
17 MR. O'DRISCOLL: Yep, yep.
18 MR. FETTER: I just wanted to make sure 19 we didn't let anything fall through the cracks.
20 MR. O'DRISCOLL: Yeah, thank you. I guess 21 we can continue. If somebody thinks of a question, 22 we'll give you another shot at the end of the couple 23 of slides I have left. Does that sound like a 24 reasonable approach there, Allen?
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29 1 and advance to the next slide.
2 MR. O'DRISCOLL: Excellent. The next 3 slide is Slide 33, just going to recap some next steps 4 that we're going to be taking from the NRC side of 5 it. The staff is going to consider comments received 6 on the regulatory basis. We will commence drafting 7 the proposed rule. After concurrence, we're going to 8 submit the proposed rule to the Commission for vote.
9 The staff will hold additional stakeholders meetings 10 during the proposed rule phase as needed. Next slide.
11 We're on Slide 34. This is just a 12 reminder of the schedule for this rule. The staff 13 plans to start drafting the proposed rule at the 14 completion of the public comment period. We are 15 planning to submit the proposed rule to the Commission 16 by May of next year. We expect the final rule to be 17 issued in the fourth quarter of calendar year 2024.
18 Next slide.
19 Here is some contact information. We're 20 on Slide 35. You can reach out to us here if you 21 have need of further information. Next slide.
22 This is a "how did we do?" slide. Thanks 23 very much for your attention and questions. Again, 24 we're going to leave a few minutes for folks to ask 25 a question if they thought of something. But, anyway, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 I just want to thank everybody for their attention to 2 the presentation. We welcome feedback to our public 3 meetings. We want to know if you're satisfied with 4 today's meeting or if you have any suggestions for 5 how we could make it more effective. You can access 6 a link to the online feedback form in the meeting 7 details for this meeting on the NRC's public meeting 8 schedule page. Alternatively, you can scan this QR 9 code that will bring you directly to an online 10 feedback form of the meeting. You can also access 11 the online feedback form for the meeting by going to 12 our public meeting website at the below link. Next 13 slide.
14 This is an important slide. It's how to 15 stay informed and involved. You can find information 16 about this rulemaking activity on regulations.gov.
17 The meeting summary will be posted there soon. The 18 meeting summary will have references to the meeting 19 materials included in this presentation. Thats 20 going to include these slides, the transcript, et 21 cetera. Just search on this docket number, which is 22 Docket ID NRC-2009-0196. So, this is also how you 23 submit your formal comment. You just go into 24 regulations.gov and you can submit your formal 25 comments there. So, there are multiple ways in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 FRN to submit a comment. This is kind of the 2 preferred method, to submit your comments to 3 regulations.gov. Next slide.
4 So that concludes our presentation.
5 Operator, is there anybody on the line 6 that has a question?
7 OPERATOR: At this time I show no 8 questions in the queue.
9 MR. O'DRISCOLL: I am checking chat and 10 I don't see anything here, either. Anyway, I'd just 11 like to thank everybody and hope everybody has a great 12 afternoon. Our meeting is concluded. Thank you.
13 (Whereupon, the above-entitled matter 14 went off the record at 1:42 p.m.)
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