ML22130A131
| ML22130A131 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/2022 |
| From: | Rowley J NRC/NMSS/DFM/FFLB |
| To: | |
| J ROWLEY NRC/NMSS/DFM/FFLB 3014154053 | |
| Shared Package | |
| ML22130A130 | List: |
| References | |
| Download: ML22130A131 (54) | |
Text
1 Jonathan Rowley, Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards Email: Jonathan.Rowley@nrc.gov Phone: 301-415-4053 Fuel Facility Stakeholders Meeting May 17, 2022 Public Meeting With Nuclear Energy Institute and Members from the Nuclear Fuel Facility Industry
2 Meeting Category and Public Participation This is an Observation Meeting. This is a meeting in which attendees will have an opportunity to observe the NRC performing its regulatory function or discussing regulatory issues. Attendees will have an opportunity to ask questions of the NRC staff or make comments about the issues discussed following the business portion of the meeting; however, the NRC is not actively soliciting comments towards regulatory decisions at this meeting.
3 Agenda - May 17, 2022 Topic Time Speakers Introduction (Purpose, Rules for Meeting) 9:30 AM Jonathan Rowley, Project Manager Division of Fuel Management (DFM)
Opening Remarks 9:35 AM Shana Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards (NMSS)
U.S. Nuclear Regulatory Commission Janet Schlueter Nuclear Energy Institute (NEI)
Status of Action Items from October 2021 Meeting 9:40 AM Jonathan Rowley, Project Manager, DFM Integrated Schedule and Supplement Updates 9:45 AM Jonathan Rowley, Project Manager, DFM Industry Priorities 10:25 AM NEI/Industry Break 10:50 AM Fuel Facility Oversight
- Introduction and Region II Priorities
- Status of Early Implementation of Smarter Inspection Program COVID-19 Public Health Emergency Oversight Activities Assessment 11:00 AM Anthony Masters, Director DFFI, Region II Leira Cuadrado, Senior Project Manager, Division of Materials Safety, Security, State, and Tribal Programs
4 Agenda - May 17, 2022 (cont.)
Topic Time Speakers Hybrid Inspection = Pros and Cons 11:25 AM NEI/Industry Public Q & A 11:55 AM Lunch Break 12:00 PM Discussion on Various Regulatory Initiatives:
NRC Position on Safety Margin and Forthcoming NRC Letter Transformation Survey Implementation of the IAEA Additional Protocol in the U.S.
1:30 PM 1:50 PM Dylannne Duvigneaud, Fuel Cycle Operations Engineer, DFM Aida Rivera, Executive Technical Assistant, Office Executive Director of Operations Santiago Aguilar, International Safeguards Analyst DFM Break 2:30 PM Be Risk Smart Framework 2:40 PM Mirabelle Shoemaker, International Safeguards Analyst, DFM Tracking of Enriched Uranium 3:10 PM Mirabelle Shoemaker, International Safeguards Analyst, DFM Public Q & A 3:45 AM Recap of Action Items for the Day 3:50 PM Jonathan Rowley, DFM Janet Schlueter, NEI Closing Remarks and Adjourn 3:55 PM Shana Helton, DFM Janet Schlueter, NEI
5 Opening Remarks Shana Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards Janet Schlueter, Senior Director Fuel and Radiation Safety Nuclear Energy Institute
6 Jonathan Rowley Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards Action Items from October 2021 Fuel Facility Stakeholders Public Meeting Action Item 1 The NRC and NEI/Industry shall exchange any meeting presentation materials at least one week prior to the scheduled meeting date.
NRC Staff Resolution Division of Fuel Management (DFM) developed new guidance for planning and conducting the bi-annual Fuel Facility Stakeholders Meeting. The guidance will assure that information will be ready to provide NEI at least 7 days prior to the meetings.
Action Item 2 The NRC staff was requested to place the corrected integrated schedule of regulatory activities chart on the NRC public Web site for the fuel facility stakeholders meeting.
NRC Staff Resolution The website was updated on November 16, 2021.
Action Item 3 NEI/Industry suggested that integrated schedule of regulatory activities chart include the draft interim staff guidance (ISG) on security for facilities possessing Category II special nuclear material.
NRC Staff Resolution The Office of Nuclear Security and Incident Response (NSIR) concluded that the working draft of the ISG did not warrant being on the integrated schedule chart. The document is not associated with a public rulemaking and the document is not publicly available. The document is official use only and has a need-to-know aspect, given the site specific, case-by-case nature of the interaction with applicants/licensees and the site-specific nature of the supplemental security measures.
Action Item 4 The NRC staff is to inquire how the industry was able to obtain two different versions of draft NUREG-2159.
NRC Staff Resolution Additional discussion with NEI determined that the industry was reviewing the 2018 version of the draft NUREG. The staff confirmed that the ADAMS accession number was linked to the 2021 version and industry is working with the current version.
Action Item 5 The NRC staff will consider NEI/Industry suggestion of having a public meeting by the end of 2021 to discuss the tracking of higher enriched material.
NRC Staff Resolution A public meeting on tracking of higher enriched material was held on December 14, 2021; meeting notice (ML21335A329), presentation (ML21344A149).
Action Item 6 The NRC will work to make as many licensing division instructions publicly available as possible.
NRC Staff Resolution The following four division instructions (DIs) should be available by September 2022 after NRC staff has been trained and has implemented the DIs for a couple months:
Licensing Overview (LIC-FM-1), Acceptance Reviews (LIC-FM-2), Requests for Additional Information (LIC-FM-3), Safety Evaluation Reports (LIC-FM-4).
Action Item 7 The NRC and NEI/Industry will work to have the dates for the 2022 Fuel Facility Stakeholders Public Meetings (Spring and Fall) set by the end of January 2022 to help assist all parties with planning and preparation.
NRC Staff Resolution The Spring 2022 meeting date was set on December 28, 2021, for May 17 and 18, 2022.
Action Items - October 2021 Stakeholders Meeting
7 Integrated Schedule Chart and Supplement Updates Jonathan Rowley Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards
8 Integrated Schedule Chart Updates See Portable Document Format (PDF) under ADAMS Accession Number ML.
See ADAMS Accession Number ML for a detailed summary of the changes.
Regulatory Activity Revised Jan Febr Marc April May June July Aug Sept Oct Nov Dec Jan Febr Marc April May June July Aug Sept Oct Nov Dec Jan Febr Marc April May June July Aug Sept Oct Nov Dec
= Final Rule/Final Guidance
= Public Interaction
= ANPR Development
= Issue Draft Guidance
= Final Report/Closure Memo
= Pending Commission Action
= Guidance Development
= ANPR Issued
= Denied by Commission
= Marks issuance of SRM
= Pilot Program
= Pre-rulemaking Activities
= Reg. Basis/Draft Guidance
= Proposed Rule/DG Development
= Implementation
= Non-rulemaking/NRC Activities
= Scheduled Meeting l = Marks issuance of SECY V = Site Visit A = ACRS Meeting 5/6/2022 Integrated Low-Level Radioactive Waste Disposal Rulemaking (SECY-20-0098)
Irene Wu/Cardelia Maupin/Priya Yadav 5/6/2022 5/6/2022 Part 73 - Enhanced Security of SNM (SECY-19-0095)
Marshall Kohen/Irene Wu Part 73 - Enhanced Weapons Rulemaking (SECY-18-0058)
Martha Barillas/Phil Brochman Harmonization of Transportation Safety Requirements with International Atomic Energy Agency Standards (RIN 3150-AJ85; NRC-2016-0179) - Part 71 (SECY-16-0093 and SECY-20-0102)
James Firth 5/6/2022 Comments The Commission disapproved discontinuation of rulemaking. Per Commission direction, the staff is preparing a notation vote paper containing options. Notation vote paper scheduled to go to Commission by end of September 2022.
January 2022, the Commission issued SRM-SECY-18-0058 approving the final rule. Final rule expected to be published by end of September 2022.
Awaiting Commission direction.
The Commission approved integrating the greater-than-Class C waste and Part 61 low-level radioactive waste disposal rulemaking activities and to issue a new proposed rule.
2023 2022 2021 Coordinating publication with Department of Transportation, with publication expected in late Spring 2022 (after DOT proposed rule is approved for publication).
The regulatory basis was published for a 60-day public comment period on April 28, 2022.
The proposed rule package was submitted to the Commission on April 28, 2022.
Rulemaking denied by Commission in April 2022.
Part 73-Cyber Security Rulemaking (SECY-17-0099)
Irene Wu/James Downs 5/6/2022 5/6/2022 Proposed Rulemaking - Alternatives to the Use of Credit Ratings (RIN 3150-AJ92) (SECY-16-0009, SECY-20-0056)
Greg Trussell 5/6/2022 Decommissioning Financial Assurance for Sealed and Unsealed Radioactive Material (PRM-30-66; NRC-2017-0159) -
Greg Trussell/Cardelia Maupin Part 51 - Rulemaking Plan - Transforming the NRC Environmental Review Process (SECY-21-0001)
Yanely Malavé 5/6/2022 Presentations prepared for sessions of fuel cycle interest are available online.
5/6/2022 Working Group Recommendations Final Report - April 30, 2020; Public Version of Smarter Licensing Action Plan and Project Status - July 10, 2020
- See supplement.
Near Term - Develop DIs Mid Term - Job Aids, Templates, Training, and Evaluate Risk Tool Long Term - Turn-over Guidance, SRP for GTCM, Update NUREG-1520, Lessons learned, License review road map ANS 57.11 - Integrated Safety Assessment Standard Marilyn Diaz 5/6/2022 The Nonreactor Nuclear Facilities Consensus Committee selected a new Working Group Chair.
Parts 11, 25, and 95 - Increased Access Authorization Fees Emily Robbins 5/6/2022 NUREG-2159 - MC&A Guidance for SNM of Moderate Strategic Significance Suzanne Ani Regulatory Information Conference Jonathan Rowley 5/6/2022 Smarter Licensing Effort Matt Bartlett Very Low Safety Significance Issues Stephen Koenick 5/6/2022 5/6/2022 Congressional Review Act review in progress. Final issuance: August 2022 Final rule is going through concurrence.
Guidance development and improvement continues as experience is gained.
9 Updates to Integrated Schedule Chart and Supplement
- Updated information
- Fuel Facility Stakeholders Meeting https://www.nrc.gov/materials/fuel-cycle-fac/regs-guides-comm.html#cumeffects
- Integrated Schedule (Chart)
ADAMS Accession Number ML Summary of changes to previously listed activities (October 2021 - April 2022)
- Integrated Schedule Supplement ADAMS Accession Number ML
10 INDUSTRY PRIORITIES NEI/INDUSTRY
11 Introduction Region II Priorities Status of Early Implementation of Smarter Inspection Program Anthony Masters, Director Division of Fuel Facility Inspection Region II
12 Inspection Lessons during the COVID-19 Pandemic Office of Nuclear Material Safety and Safeguards Presented by: Leira Cuadrado, Sr. Project Manager Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Leira.Cuadrado@nrc.gov
13 Phased Approach for this Assessment Phase A (August 2020 - April 2021)
- Gather initial internal feedback on the implementation of inspection program during the COVID-19 pandemic
- Shared feedback, challenges, and good practices (Report available at ADAMS Accession No. ML21158A231)
Phase B (April 2021 - November 2021)
- Gather additional feedback internally and externally
- Expanded on best practices and challenges
- Developed recommendations for the routine implementation of inspection programs
14 Feedback Mechanisms Internal survey(s) to inspection staff and program office staff Interviews to inspection staff and management (Branch Chiefs, Division Directors, and Regional Administrators/Office Directors)
Public meetings to obtain external feedback in July and August 2021 Government to Government Meeting in October 2021
15 Assessment Key Messages:
- On-site inspections continue to be the most effective and preferred method of inspection
- Keep the option to employ flexibilities (i.e. remote, hybrid, in-office reviews of records), when appropriate
- Specific inspection guidance is warranted for pandemic preparedness Report is available here
16 Upcoming Activities Each inspection program will evaluate their current guidance to identify needed revisions.
The agency will ensure consistency in the development of inspection guidance for pandemic preparedness.
NRR is undergoing a similar lessons learned effort and the offices are collaborating.
17 Hybrid Inspections Pros and Cons Janet Schlueter, NEI
18 Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topics:
- Status of Action Items from October 2021 Meeting
- Integrated Schedule and Supplement Updates
- Industry Priorities
- Fuel Facility Oversight
- Hybrid Inspection - Pros and Cons
19 Status of NRC Letter on Safety Margin DyLanne Duvigneaud Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
20 Status of NRC Letter on Safety Margin In two letters, submitted by NEI, dated July 24, 2020 (ML20211L714) and April 20, 2021 (ML21236A302 ), the industry discussed their position on safety margin and suggested edits to Inspection Manuel Chapter 0616 By letter dated December 29, 2021 (ML21336A763), the NRC staff stated that it will perform a backfit assessment of changes to IMC 0616, as identified in NEIs July 24, 2020, letter.
The staff is developing a response letter providing the backfit assessment outcome
- Deferred due to staffing and other priorities
- Letter and update to IMC 0616 expected by end of FY 2022 20
21 Transformation Survey Update Aida Rivera Executive Technical Assistant Office of the Executive Director for Operations
22 Implementation of the IAEA Additional Protocol in the U.S.
Santiago Aguilar Material Control and Accounting Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
23 Background of the Additional Protocol The IAEA applies safeguards around the world pursuant to comprehensive safeguards agreements (CSA)
United States: INFCIRC/288 or Voluntary Offer Agreement (1977)
After the 1st Gulf War, discoveries in Iraq highlighted the limitations of traditional IAEA safeguards International community recognized the need for strengthened safeguards Model Additional Protocol (INFCIRC/540)
Focuses on materials and activities, related to the nuclear fuel cycle, that were not previously covered by comprehensive safeguard agreements 23
24 History of the U.S. Additional Protocol U.S. Additional Protocol Signed by the U.S. on June 12, 1998 Entered into force on January 6, 2009 Initial declaration submitted in 2009 Two primary impacts of the U.S. Additional Protocol Broader reporting requirements including additional aspects of the nuclear fuel cycle and related activities
- Includes initial declaration, annual updates, and quarterly export reports Complementary Access (CA) to facilities 24
25 U.S. Safeguards Implementation 25 U.S. Nuclear Regulatory Commission Department of Commerce Department of State Department of Defense Department of Energy
26 Complementary Access (CA)
Complementary Access is an essential aspect of the IAEAs expanded authorities Complementary Access allows the IAEA to:
Verify the absence of undeclared nuclear materials and activities Resolve a question or inconsistency Access for IAEA with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> advance notice 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if IAEA is already onsite CAs are rare in the U.S.
Only 2 CAs have been conducted in the U.S.
(2010)
Framatome Inc., Fuel Fabrication Facility (Lynchburg, VA)
Global Advanced Metals (Boyertown, PA) 26
27 Reporting Requirements Annual reporting requirements (10 CFR Part 75.6)
(2.a.i) Nuclear fuel cycle research and development Approximately 75% of the total number of U.S. declarations are 2.a.i. declarations (2.a.iii) Site declaration including description of activities Only relevant for facilities that are currently or have previously been selected for IAEA safeguards Not applicable to a vast majority of the industry (2.a.iv) Nuclear fuel cycle related manufacturing and assembly Annex I items from the U.S. Additional Protocol (2.a.v) Uranium and thorium mines, mills, and concentration plants (2.a.vi) Possession of large quantities of impure source material Source material that is not yet suitable for fuel fabrication or enrichment (2.a.x) Ten-year plan Input is not requested from the industry Quarterly reporting requirements [10 CFR Part 110.54(a)(1)]
(2.a.ix) Exports of Annex II items 27
28 Snapshot of Licensees Who Report Under the U.S. APand many more!
28 Additional Protocol
29 Snapshot of Licensees Who Report Under the U.S. AP Agreement States!
29 Additional Protocol
30 Quarterly Export Reports Explained (2.a.ix)
For licensees using NRC general or specific license authorizations for exports of specified equipment and non-nuclear material as listed in Annex II of the Additional Protocol.
This reporting requirement is also reflected in 10 CFR Part 110.54(a)(1) for Agreement State licensees.
Most NRC licensees should report as a location using AP-13 form found on www.AP.gov. Report directly to Department of Commerce (DOC),
Bureau of Industry and Security (BIS) every quarter (forms are joint DOC/NRC forms).
Quarterly deadlines to BIS are January 15, April 15, July 15, and October 15 of each year.
Exporters should check if any of the items exported under Part 110.26 -
exports of components under General License - may also need to be reported under the AP (Part 110.54(c).
30
31 Additional Protocol-Annex II
- Examples of equipment to be reported under 10 CFR 110.54(a)(1)
- Reactor Control Rods (Annex II, 1.4)
- Zirconium tubes (Annex II, 1.6)
- Reactor Primary Coolant Pump (Annex II, 1.7) 31
32 Additional Protocol Reporting Process Information is sent to DOC by Jan 31st Can be sent via facsimile, mail, or email NRC receives licensees declarations from DOC and performs a review NRC compiles data and submits a report to DOC for inclusion in the overall U.S.
Government declaration U.S. declaration must sit before Congress for a 60-day review period (for annual report only) 32
33 Additional Protocol Webpage
- The Department of Commerce manages a webpage that contains the handbooks and forms for the U.S. Additional Protocol Handbooks and forms are joint use for both DOC and NRC The majority of companies use the Report Handbook for Locations.
http://www.AP.gov 33
34 Additional Protocol Webpage 34
35 Questions
- Please ask questions early and often!
- NRC - Office of Nuclear Material Safety and Safeguards (NMSS);
Material Control and Accounting Branch (MCAB)
Santiago Aguilar Santiago.Aguilar@nrc.gov Eduardo Sastre Eduardo.Sastre@nrc.gov
- Department of Commerce, Treaty Compliance Division, Bureau of Industry and Security, U.S. Department of Commerce Hung Ly Hung.Ly@bis.doc.gov
- Additional resource:
- http://www.nrc.gov/about-nrc/ip/intl-safeguards.html 35
36 Mirabelle Shoemaker, International Safeguards Analyst Material Control and Accounting Branch Division of Security Operations Office of Nuclear Security and Incident Response
37 3
38 Benefits of Be riskSMART Framework
- Allows NRC to make decisions in the presence of uncertainty
- Using all available information to make a decision
- Reveals the entire toolbox for risk assessment and risk management
39 Benefits of Be riskSMART Framework (cont.)
- Facilitates early alignment on risks
- Enables the adoption of new technology
- Refines processes & allows NRC to select the best option
40 Can the NRC conduct an on-site inspection of Prairie Island Independent Spent Fuel Storage Installation (ISFSI) operations during the spent fuel loading campaign?
Additional background about the problem statement
- This evolution is performed ~2 years and was due within a year at the time the problem statement was identified.
- If the inspection were postponed, NRC would miss its only opportunity to evaluate license performance during cask loading operations (most risk significant activity at an ISFSI) prior to the inspection due date.
41 What could happen? (right/wrong)
What could go right?
- NRC conducts remote inspection or an on-site inspection adhering to CDC guidelines.
- In either case, an inspection is completed by the due date and in compliance with CDC guidelines.
What could go wrong?
- The inspection is postponed or delayed and the NRC misses the only opportunity to directly inspect dry cask operations for 2 years.
- A remote inspection may fail to identify safety issue.
- An onsite inspection greatly increases the risk of all involved personnel contracting COVID-19.
42 What could happen? (consequences)
What are the consequences?
- NRC cant complete the remote inspection and provide reasonable assurance that operations were conducted safely, potentially resulting in fuel damage, inadvertent release of radioactive material, unexpected exposure to workers/public, injury;
- NRC cannot conclude whether operations were conducted safely/within regulatory requirements through remote inspection; or,
- NRC can conclude that operations were conducted safely and no personnel contract COVID-19 through onsite inspection
43 What could happen? (likelihood)
How likely is it?
- That NRC conducts inspection remotely to meet at least minimum sampling-LIKELY;
- That a significant safety issue missed during a remote inspection-UNLIKELY, two previous dry cask campaigns using same vendor were successful;
- That no personnel contract COVID UNLIKELY, given the increasing infection rate; and
44 What can I manage?
What can NRC do?
- Discuss remote inspection capability and experience with peers/other regions.
- Discuss opportunity to do a follow-on onsite portion of the inspection when conditions improve under PHE.
- Assess capabilities/limitations using cameras for remote inspection.
- Assess close-contact risks encountered during inspection to reduce chances of contracting COVID-19.
- Review changes to PI dry cask storage program to weigh the risk of the changes resulting in a potential safety issue.
45 What actions will I take?
What will NRC do?
- NRC decides to conduct a remote inspection with onsite follow-up because:
NRC confirmed the ability to: remotely monitor ISFSI operations using a camera system; relay real-time (2 second delay) camera observations to the licensee; review other videotaped footage; and conduct daily discussions with the licensee.
When the PHE conditions allow, NRC will be able to conduct onsite inspection of material and radiological conditions.
- Considerations that led to this action included that:
The site had no findings of significance during last ISFSI inspection in 2018; The site had no process changes since previous ISFSI campaigns; and Onsite inspection addresses public perception of risk and lack of NRC oversight.
46 What happened when I acted?
What were the results of NRCs decision to conduct a remote inspection?
- As a result of NRCs decision to conduct a remote inspection with onsite inspection follow-up, the Biennial Prairie Island ISFSI Cask Loading Campaign Inspection was conducted in a timely manner.
- Conducting a remote inspection yielded a secondary benefit where multiple simultaneously occurring activities could be observed for longer periods of time, with reduced exposure to the inspector.
47 How can I teach others?
Following the inspection:
- Staff planned to share lessons learned from the remote inspection with other inspectors;
- Staff suggested using public meetings to discuss use of remoted inspections in NRC oversight during the Covid-19 Public Health Emergency; and,
- The example was highlighted as a success story during the 2022 RIC Session for Be riskSMART: Real Examples and Real Impacts.
48 Tracking of Enriched Uranium:
NRC update on the industrys request related to tracking foreign obligations of uranium enriched <10%
Mirabelle Shoemaker, International Safeguards Analyst Material Control and Accounting Branch Division of Security Operations Office of Nuclear Security and Incident Response
49 Engagement with Industry on Reporting Foreign Obligations on LEU enriched <10%
- Industry has requested that the NRC expand the definition of E1 material to less than 10%, to match the special nuclear material description of Cat III material.
- Under this change, licensees would be able to manage foreign obligations on uranium up to 10% enrichment without the need for prior approval, in the same manner as they currently manage obligations on uranium up to 5% enrichment.
50 Engagement with Industry on Reporting Foreign Obligations on LEU enriched <10% (cont.)
- NRC conferred with Interagency Partners and presented a solution at public meeting in December 2021. The Interagency proposed that fuel facilities submit a one-time request for prior approval of obligation reassignment for their licensed blending operations.
- NRC and the interagency will consider each request as received and will have the ability to grant prior approval for obligation reassignments between E1 and E2 material.
51 Continued Pathway to Resolution
- Following the December 2021 public meeting, NRC continued dialogue with POCs at fuel facilities responsible for NMMSS reporting.
- NRC also conferred with NMMSS to identify potential impacts to other licensees.
- A public meeting is scheduled for June 22, 11am ET - 2pm, to provide details about reporting E1 material.
51
52 Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topics:
- Safety Margin Letter
- Transformation Survey Status
- Operational Event program
- Filing System for Additional Protocol
- VLSSIR
- Be riskSmart
- Tracking of Enriched Uranium
53 Jonathan Rowley, Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards Recap of Action Items - Day 1
54 Closing Remarks - Day 1 Shana Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards Janet Schlueter, Senior Director Fuel and Radiation Safety Nuclear Energy Institute