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
Fuel Facility Stakeholders Meeting May 17, 2022 Public Meeting With Nuclear Energy Institute and Members from the Nuclear Fuel Facility Industry Jonathan Rowley, Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards Email: Jonathan.Rowley@nrc.gov Phone: 301-415-4053 1
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.
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Agenda - May 17, 2022 Topic Time Speakers Jonathan Rowley, Project Manager Introduction (Purpose, Rules for Meeting) 9:30 AM Division of Fuel Management (DFM)
Shana Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards (NMSS)
Opening Remarks 9:35 AM 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 Anthony Masters, Director DFFI, Region II
- Status of Early Implementation of Smarter 11:00 AM Inspection Program Leira Cuadrado, Senior Project Manager, COVID-19 Public Health Emergency Oversight Division of Materials Safety, Security, State, and Activities Assessment Tribal Programs 3
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: 1:30 PM Dylannne Duvigneaud, Fuel Cycle Operations
- NRC Position on Safety Margin and Engineer, DFM Forthcoming NRC Letter Aida Rivera, Executive Technical Assistant,
- Transformation Survey Office Executive Director of Operations Implementation of the IAEA Additional Santiago Aguilar, International Safeguards Protocol in the U.S. 1:50 PM Analyst DFM Break 2:30 PM Mirabelle Shoemaker, International Safeguards Be Risk Smart Framework 2:40 PM Analyst, DFM Mirabelle Shoemaker, International Safeguards Tracking of Enriched Uranium 3:10 PM Analyst, DFM Public Q & A 3:45 AM Jonathan Rowley, DFM Recap of Action Items for the Day 3:50 PM Janet Schlueter, NEI Shana Helton, DFM Closing Remarks and Adjourn 3:55 PM Janet Schlueter, NEI 4
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 5
Action Items - October 2021 Stakeholders Meeting Action Item 1 Action Item 2 Action Item 3 The NRC and NEI/Industry shall exchange any NEI/Industry suggested that integrated schedule of The NRC staff was requested to place the corrected meeting presentation materials at least one week Action Items from October 2021 Fuel integrated schedule of regulatory activities chart on regulatory activities chart include the draft interim staff prior to the scheduled meeting date. guidance (ISG) on security for facilities possessing the NRC public Web site for the fuel facility Category II special nuclear material.
NRC Staff Resolution stakeholders meeting.
Facility Stakeholders Public Meeting Division of Fuel Management (DFM) developed new NRC Staff Resolution NRC Staff Resolution The Office of Nuclear Security and Incident Response guidance for planning and conducting the bi-annual The website was updated on November 16, 2021. (NSIR) concluded that the working draft of the ISG did not Fuel Facility Stakeholders Meeting. The guidance will assure that information will be ready to provide warrant being on the integrated schedule chart. The NEI at least 7 days prior to the meetings. 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 Action Item 5 Action Item 6 The NRC staff is to inquire how the industry was The NRC staff will consider NEI/Industry suggestion The NRC will work to make as many licensing division able to obtain two different versions of draft of having a public meeting by the end of 2021 to instructions publicly available as possible.
NRC Staff Resolution Jonathan Rowley discuss the tracking of higher enriched material.
NRC Staff Resolution NRC Staff Resolution The following four division instructions (DIs) should be available by September 2022 after NRC staff has been Additional discussion with NEI determined that the A public meeting on tracking of higher enriched Project Manager trained and has implemented the DIs for a couple months:
industry was reviewing the 2018 version of the draft material was held on December 14, 2021; meeting Licensing Overview (LIC-FM-1), Acceptance Reviews NUREG. The staff confirmed that the ADAMS notice (ML21335A329), presentation (LIC-FM-2), Requests for Additional Information (LIC-FM-accession number was linked to the 2021 version (ML21344A149). 3), Safety Evaluation Reports (LIC-FM-4).
Division of Fuel Management and industry is working with the current version.
Action Item 7 The NRC and NEI/Industry will work to have the Office of Nuclear Material Safety and Safeguards 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.
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Integrated Schedule Chart and Supplement Updates Jonathan Rowley Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 7
Integrated Schedule Chart Updates 2021 2022 2023 Comments Dec Nov Oct Sept Aug July June May Regulatory Activity Revised April Marc Febr Jan Dec Nov Oct Sept Aug July June May April Marc Febr Jan Dec Nov Oct Sept Aug July June May April Marc Febr Jan The Commission approved integrating Integrated Low-Level Radioactive Waste Disposal Rulemaking the greater-than-Class C waste and (SECY-20-0098) 5/6/2022 Part 61 low-level radioactive waste Irene Wu/Cardelia Maupin/Priya Yadav disposal rulemaking activities and to issue a new proposed rule.
The Commission disapproved discontinuation of rulemaking. Per Commission direction, the staff is Part 73 - Enhanced Security of SNM (SECY-19-0095)
- 5/6/2022 preparing a notation vote paper Marshall Kohen/Irene Wu containing options. Notation vote paper scheduled to go to Commission by end of September 2022.
January 2022, the Commission issued Part 73 - Enhanced Weapons Rulemaking SRM-SECY-18-0058 approving the final (SECY-18-0058) 5/6/2022 rule. Final rule expected to be Martha Barillas/Phil Brochman published by end of September 2022.
Part 73-Cyber Security Rulemaking (SECY-17-0099) 5/6/2022 Awaiting Commission direction.
Irene Wu/James Downs Decommissioning Financial Assurance for Sealed and The regulatory basis was published for Unsealed Radioactive Material (PRM-30-66; NRC-2017-0159) -
5/6/2022 a 60-day public comment period on (SECY-19-0125)
April 28, 2022.
Greg Trussell/Cardelia Maupin Proposed Rulemaking - Alternatives to the Use of Credit The proposed rule package was Ratings (RIN 3150-AJ92) (SECY-16-0009, SECY-20-0056) 5/6/2022 submitted to the Commission on April Greg Trussell 28, 2022.
Part 51 - Rulemaking Plan - Transforming the NRC Rulemaking denied by Commission in Environmental Review Process (SECY-21-0001) 5/6/2022 April 2022.
Yanely Malavé Coordinating publication with Harmonization of Transportation Safety Requirements with Department of Transportation, with International Atomic Energy Agency Standards (RIN 3150-AJ85; 5/6/2022 publication expected in late Spring 2022 NRC-2016-0179) - Part 71 (SECY-16-0093 and SECY-20-0102)
(after DOT proposed rule is approved James Firth for publication).
The Nonreactor Nuclear Facilities ANS 57.11 - Integrated Safety Assessment Standard 5/6/2022 Consensus Committee selected a new Marilyn Diaz Working Group Chair.
Regulatory Information Conference Presentations prepared for sessions of 5/6/2022 Jonathan Rowley fuel cycle interest are available online.
Working Group Recommendations Final Report - April 30, 2020; Public Smarter Licensing Effort 5/6/2022 Version of Smarter Licensing Action Matt Bartlett Mid Term - Job Aids ,
Long Term - Turn-over Guidance, SRP for GTCM, Update Plan and Project Status - July 10, 2020 Near Term - Develop DIs Tem plates , Training, and Evaluate Ris k Tool NUREG-1520, Lessons learned, License review road map - See supplement.
NUREG-2159 - MC&A Guidance for SNM of Moderate Congressional Review Act review in Strategic Significance 5/6/2022 progress. Final issuance: August 2022 Suzanne Ani Guidance development and Very Low Safety Significance Issues 5/6/2022 improvement continues as experience Stephen Koenick is gained.
Parts 11, 25, and 95 - Increased Access Authorization Fees 5/6/2022 Final rule is going through concurrence.
= 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
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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 9
INDUSTRY PRIORITIES NEI/INDUSTRY 10
Introduction Region II Priorities Status of Early Implementation of Smarter Inspection Program Anthony Masters, Director Division of Fuel Facility Inspection Region II 11
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 12
Phased Approach for this Assessment Phase B (April 2021 - November 2021)
Phase A
- Gather additional feedback internally and externally (August 2020 - April 2021) *Expanded on best practices and
- Gather initial internal feedback on challenges the implementation of inspection program during the COVID-19 *Developed recommendations for the pandemic routine implementation of inspection programs
- Shared feedback, challenges, and good practices (Report available at ADAMS Accession No. ML21158A231) 13
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 14
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 15
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.
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Hybrid Inspections Pros and Cons Janet Schlueter, NEI 17
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 18
Status of NRC Letter on Safety Margin DyLanne Duvigneaud Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 19
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
Transformation Survey Update Aida Rivera Executive Technical Assistant Office of the Executive Director for Operations 21
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 22
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
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
U.S. Safeguards Implementation U.S. Nuclear Regulatory Commission Department Department of of Energy Commerce Department Department of Defense of State 25
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
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
Snapshot of Licensees Who Report Under the U.S. APand many more!
Additional Protocol 28
Snapshot of Licensees Who Report Under the U.S. AP Agreement States!
Additional Protocol 29
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).
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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
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
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
Additional Protocol Webpage 34
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
Mirabelle Shoemaker, International Safeguards Analyst Material Control and Accounting Branch Division of Security Operations Office of Nuclear Security and Incident Response 36
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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 38
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 39
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.
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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.
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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 42
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
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.
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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.
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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.
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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.
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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 48
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.
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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.
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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.
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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 52
Recap of Action Items - Day 1 Jonathan Rowley, Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 53
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 54