ML21337A137
| ML21337A137 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/2021 |
| From: | NRC/OCM |
| To: | |
| Shared Package | |
| ML21301A174 | List: |
| References | |
| M211209 | |
| Download: ML21337A137 (6) | |
Text
©2021 Nuclear Energy Institute NEI Perspectives Doug True December 9, 2021 Part 53 Rulemaking
©2021 Nuclear Energy Institute 2 U.S. is embarked on an unprecedented effort to decarbonize the electrical sector and the broader economy Utilities being driven to decarbonize and maintain reliable grid Federal policies are encouraging the deployment of advanced nuclear Urgency is rapidly accelerating Efficient and inclusive regulatory framework is a key enabler Could be many applications per year as early as 2025 Can avoid NRC resources and timing of reviews as bottleneck Significance of Part 53 Part 53 is NRCs opportunity to enable safe, reliable advanced nuclear
©2021 Nuclear Energy Institute 3 Licensing of new technologies Enable variety of technologies to be safely and efficiently approved Safety is assured without unnecessary burden Risk-informed, performance-based approach Deployment & operations Improved safety profiles should enable:
Efficient licensing approvals
Greater licensee flexibility
Long-term regulatory stability An Efficient & Effective Part 53 Utilities and developers alike have interest in an efficient and effective Part 53
©2021 Nuclear Energy Institute 4 NRC staff has accomplished a monumental task of creating a preliminary Part 53 framework and requirements NRC has been timely in releasing rule language Effectiveness of stakeholder engagement has not been high Industry has actively engaged Industry has provided timely, clear and extensive feedback Little feedback or explanation has been provided Industrys Nov. 5 letter compiles feedback previously provided, with additional details to provide clarity Progress to Date The preliminary Part 53 provides a foundation for addressing industrys concerns
©2021 Nuclear Energy Institute 5 Part 53 benefits should be available to all advanced reactors Technology-inclusive, performance-based design requirements Part 53 should not Increase regulatory burden, without a commensurate increase in safety. Areas of concern:
Expanding ALARA beyond an operating principle to be an absolute Increased regulatory burden and reduced clarity on non-safety SSCs Inclusion of beyond design basis events in the design basis Proliferation of duplicative and unnecessary programs Facility Safety Program Part 53 should not unnecessarily exclude licensing approaches and technologies Excluding risk-informed licensing approaches Key Issues Productive engagement is needed to address
©2021 Nuclear Energy Institute 6 Comprehensive comments contained in Industrys November 5 letter provide a basis for straightforward changes that build upon the preliminary language Time is now for robust engagement with the industry on important issues Industry has initiated work to develop additional guidance for NRC endorsement on risk-informed approaches Industry remains ready to support in other areas, as needed Next Steps Common Goal: a Part 53 that is Used & Useful