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NRC Staff Slides for October 19, 2022 Fuel Facility Stakeholders Meeting
	ML22290A248
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Issue date:	10/19/2022
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	J Rowley NMSS/DFM/FFLB 301-415-4053
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Fuel Facility Stakeholders Meeting October 19, 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 - October 19, 2022 Topic Time Speakers Jonathan Rowley, Project Manager Introduction (Purpose, Rules for Meeting) 8:30 AM Division of Fuel Management (DFM)

Shana Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards (NMSS)

Opening Remarks 8:35 AM U.S. Nuclear Regulatory Commission Janet Schlueter, Senior Advisor Nuclear Energy Institute (NEI)

Status of Action Items from May 2022 Meeting 8:40 AM Jonathan Rowley, Project Manager, DFM Integrated Schedule and Supplement Updates 8:45 AM Jonathan Rowley, Project Manager, DFM Radioactive Source Security and Accountability 9:30 AM Andrew Carrera, Project Manager, DFM Rulemaking Public Question and Answer 10:15 AM Break 10:20 AM Mirabelle Shoemaker, International Safeguards Tracking of Enriched Uranium 10:30 AM Analyst, DFM Tom Vukovinsky, Sr. Project Manager, Perspectives on On-Site, Hybrid, and Remote Division of Fuel Facility Inspection 11:00 AM Inspections Region II 3

Agenda - October 19, 2022 (cont.)

Topic Time Speakers Public Question and Answer 12:00 Lunch Break 12:05 PM Matthew Bartlett and Osiris Perez-Suirano, Fuel Status of Smarter Licensing Program Facility Licensing Branch, DFM Division Instruction Status and Changes 1:15 PM Industry Early Observations of Recent Janet Schlueter, NEI Licensing Actions Matthew Bartlett, Fuel Facility Licensing Branch, Fuel Facility Business Line Budget DFM 2:15 PM Breakdown Michael Greenleaf, Division of Fuel Facility Inspection, RII Public Question and Answer 3:15 PM Break 3:20 PM Dylannne Duvigneaud, Fuel Cycle Operations Introduction to Category II Inspection Engineer, DFM 3:30 PM Program Michael Greenleaf, Division of Fuel Facility Inspection, RII James Firth, Project Manager Division of Status of Harmonization of Transportation Rulemaking, Environmental, and Financial Safety Requirements with International 4:00PM Support, Office of Nuclear Material Safety and Atomic Energy Agency Standards Safeguards Public Q & A 4:30 PM Jonathan Rowley, DFM Recap of Action Items for the Day 4:35 PM Janet Schlueter, NEI Shana Helton, DFM Closing Remarks and Adjourn 4:40 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 from May 2022 Fuel Facility Stakeholders Public Meeting Jonathan Rowley Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 6

Action Items - May 2022 Stakeholders Meeting Action Item 1 Action Item 2 Action Item 3 The NRC and NEI/Industry shall exchange any meeting The NRC staff was requested to place the corrected NEI/Industry suggested that the integrated schedule of presentation materials at least one week prior to the integrated schedule of regulatory activities chart on the regulatory activities chart include the draft interim staff scheduled meeting date. NRC public website for the fuel facility stakeholders guidance (ISG) on security for facilities possessing meeting. Category II special nuclear material.

NRC Staff Resolution DFM developed new guidance for planning and NRC Staff Resolution NRC Staff Resolution conducting the bi-annual fuel facility stakeholders meeting. The website was updated on November 16, 2021, and on The NRC staff concluded that the draft ISG did not warrant The guidance will ensure that information will be available May 6, 2022. (On-going Periodic Action) being on the integrated schedule chart and would not be to the public at least 7 days prior to the meetings. (On- included. The document was not associated with a public going Periodic Action) rulemaking and the document was not publicly available (Note: after the October 2021 meeting, it was determined that this action item was incorrectly captured.

NEI/Industry did not ask that a security ISG be added to the integrated schedule as they do not believe that a draft ISG or final ISG is needed). (Closed)

Action Item 4 Action Item 5 Action Item 6 The NRC staff is to inquire how the industry was able to The NRC staff will consider the NEI/Industry suggestion of The NRC will work to make as many licensing division obtain two different versions of draft NUREG-2159. having a public meeting by the end of 2021 to discuss the instructions publicly available as possible.

tracking of higher enriched material.

NRC Staff Resolution NRC Staff Resolution Additional discussion with NEI determined that the industry NRC Staff Resolution The following four division instructions (DIs) are planned to was reviewing the 2018 version of the draft NUREG. The A public meeting on tracking of higher enriched material be available by September 2022 after NRC staff has been staff confirmed that the 2021 version is in ADAMS and was held on December 14, 2021 [meeting trained and has implemented the DIs for a few months:

industry was able to review the latest version. (Closed) Licensing Overview (LIC-FM-1), Acceptance Reviews notice(ML21335A329) and presentation materials (LIC-FM-2), Requests for Additional Information (LIC-FM-(ML21344A149)]. (Closed) 3), Safety Evaluation Reports (LIC-FM-4). (Closed)

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 date for the Spring 2022 meeting was set on December 28, 2021, and was set for May 17 and 18, 2022. (On-going Periodic Action) 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 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 Integrated Low-Level Radioactive Waste Disposal Rulemaking (SECY-20-0098) 10/3/2022 Developing proposed rule package.

Irene Wu/Cardelia Maupin/Priya Yadav Preparing a notation vote paper with Part 73 - Enhanced Security of SNM (SECY-19-0095) 10/3/2022 *

options (the Commission approved a Marshall Kohen/Irene Wu one-year extension for the paper).

January 2022, the Commission issued SRM-SECY-18-0058 approving the final Part 73 - Enhanced Weapons Rulemaking rule. The final rule is currently in the (SECY-18-0058) 9/15/2022 second phase of post-SRM production Stewart Schneider (Office of Management and Budget review). Final rule is expected to be published by the end of CY 2022.

Part 73-Cyber Security Rulemaking (SECY-17-0099) 10/3/2022 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) -

9/20/2022 a 60-day public comment period on (SECY-19-0125)

April 28, 2022.

Greg Trussell/Cardelia Maupin The proposed rule package was approved by the Commission on Proposed Rulemaking - Alternatives to the Use of Credit July27, 2022. Secy signature on the Ratings (RIN 3150-AJ92) (SECY-16-0009, SECY-20-0056) 9/20/2022 federal register notice is on hold Greg Trussell pending OMB approval of Information Collection estimated to happen in Janary 2023.

Proposed rule published on Harmonization of Transportation Safety Requirements with September 12, 2022. Public comment International Atomic Energy Agency Standards (RIN 3150-AJ85;

10/3/2022 on the proposed rule and draft NRC-2016-0179) - Part 71 (SECY-16-0093 and SECY-20-0102) regulatory guide ends James Firth November 28, 2022.

NMSS is reappointing new staff to lead ANS 57.11 - Integrated Safety Assessment Standard 10/5/2022 the project due to staff TBD turnover/promotion/hiring.

Regulatory Information Conference Presentations prepared for sessions of 10/3/2022 Jonathan Rowley fuel cycle interest are available online.

Near- and Mid-Term recommendations Smarter Licensing Effort resolved via the Division Instructions.

10/3/2022 Matt Bartlett Mid Term - Job Aids , Long-Term recommendations in Long Term - Turn-over Guidance, SRP for GTCM, Update process.

Near Term - Develop DIs Tem plates , Training, and Evaluate Ris k Tool NUREG-1520, Lessons learned, License review road map NUREG-2159 - MC&A Guidance for SNM of Moderate Final issuance in Federal Register: July Strategic Significance 9/23/2022 8, 2022 Suzanne Ani Guidance development and Very Low Safety Significance Issues 10/3/2022 improvement continues as experience Stephen Koenick is gained.

Parts 11, 25, and 95 - Increased Access Authorization Fees 10/13/2022 Final rule was published July 28, 2022.

Emily Robbins The staff intends to submit a draft proposed rule to the Commission for Radioactive Source Security and Accountability approval by December 2022. Assuming 10/3/2022 Andrew Carrera/Anita Gray approval by the Commission, the NRC plans to publish the proposed rule in the Federal Register in early 2023.

= 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 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 ML22287A053

- Integrated Schedule Supplement ADAMS Accession Number ML22287A054 Summary of changes to previously listed activities (May 2022 - October 2022)

ADAMS Accession Number ML22287A055 10

Radioactive Source Security and Accountability Rulemaking Andrew Carrera Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 11

Key Messages

Consistent with Commissions direction in SRM-SECY-17-0083, the staff is conducting a rulemaking to revise the radioactive source security and accountability (RSSA) regulations in 10 CFR

The RSSA rulemaking would:

Rulemaking require safety and security equipment and facilities to be in place for all applicants before process NRC would issue a license license verification for licensees transferring category 3 quantities of radioactive material through the License Verification System (LVS) or by contacting the license-issuing authority for the licensee 12

Key Messages

The rulemaking would affect applicants for a radioactive material license and licensees who transfer category 3 quantities of radioactive material.

The rulemaking would address vulnerabilities Rulemaking identified by the 2016 Government Accountability Office report (GAO-16-330) regarding security and process accountability of category 3 quantities of radioactive material.

The staff intends to submit a draft proposed rule to the Commission for approval by December 2022.

Assuming approval by the Commission, the NRC plans to publish the proposed rule in the Federal Register in early 2023.

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RSSA Rulemaking Background

SRM-COMJMB-16-0001 - Directed NRC staff to evaluate the NRC regulations governing source protection and accountability for category 3 quantities of radioactive material Rulemaking process

SECY-17-0083 - Recommended rulemaking to enhance the security and accountability of category 3 quantities of radioactive material

SRM-SECY-17-0083 - Approved to initiate rulemaking 14

Proposed RSSA Revisions:

Safety and Security Equipment and Facilities Requirements for safety and security equipment and facilities to be in place before NRC issues a license

10 CFR 30.33(a), 40.32(c), and 70.23(a)

Rulemaking process

Help ensure the legitimacy of license applicants and their intent 15

Proposed RSSA Revisions: License Verification Requirements for license verification for transfers of category 3 quantities of radioactive materials

License Verification System (LVS) or by contacting the license-issuing authority Rulemaking process

10 CFR 30.41(d), 40.51(d), and 70.42(d)

Help address the concerns:

o altering a valid license o use of counterfeit license 16

Proposed RSSA Revisions:

License Verification (cont.)

Provide new definition

Provide new Appendix F to 10 CFR Part 30 Rulemaking

Revise recordkeeping requirements process 17

Proposed RSSA Revisions: Other Changes

Remove obsolete verification method

Administrative, clarifying and conforming Rulemaking changes to various provisions in 10 CFR process 18

Proposed RSSA Revisions: Guidance

Website with frequently asked questions (FAQ) to provide guidance Rulemaking o Safety and security equipment and facilities requirements process o License verification requirements

Provide accelerated guidance update to licensees 19

Next Steps

Submit RSSA proposed rule to Commission (December 2022)

Publish in the Federal Register in 2023 Rulemaking (assuming approval by the Commission) process

Conduct further stakeholder engagements 20

Have Questions?

Please contact:

- Andrew Carrera, 301-415-1078, Andrew.Carrera@nrc.gov, or Rulemaking process - Anita Gray, 301-415-7036, Anita.Gray@nrc.gov.

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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:

- Status of Action Items from May 2022 Meeting

- Integrated Schedule and Supplement Updates

- Radioactive Source Security and Accountability Rulemaking 22

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 23

Summary of Industry Requests on Reporting Foreign Obligations on LEU enriched <10%

Industry has requested that the NRC expand the definition of E1 material to include all LEU enriched

<10%.

During June 22, 2022 public meeting, industry also expressed interest in combining E1 and E2 material under one material type code for all LEU.

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Summary of NRC Actions Related to Industrys Request

NRC held a public meeting in December 2021 to present the interagency recommendation for requesting prior approval (ML22003A048).

NRC held a public meeting in June 2022 to receive industry comments and questions about tracking LEU enriched <10% (ML22264A295).

During these public meeting, NRC presented the process for requesting one-time U.S. Government prior approval for assigning foreign obligations across E1 and E2 material types.

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Status of U.S. Government Prior Approvals

GNF-A submitted a request for one-time U.S.

Government Prior Approval on June 30, 2022.

U.S. Government confirmed prior approval on September 28, 2022 in letter to GNF-A (ML22259A200) 26

Process for Requesting One-Time Prior Approval from the U.S. Government

NRC-licensed facilities may submit written request to the NRC with the following information:

- Proposed date to exchange obligations

- Quantities of the materials to be exchanged (element weight; isotope weight, if applicable)

- Material type and associated obligation(s) of the materials to be exchanged

- Chemical and physical form of the materials to be exchanged

- Purpose for conducting the exchange

- RIS code(s) to be involved in the proposed change

Written requests can be copied to Foreign.Obligations@nrc.gov.

Other special requests related to NMMSS reports of any nature can be submitted to NMMSS@nnsa.doe.gov or NMMSS.Resource@nrc.gov.

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Inspectors Perspective on Hybrid Inspections Division of Fuel Facility Inspection Presented by: Tom Vukovinsky, Senior Fuel Facility Project Inspector Division of Fuel Facility Inspection Region II U.S. Nuclear Regulatory Commission Thomas.Vukovinsky@nrc.gov 28

Phased Approach for this Assessment Phase B (April 2021 - November 2021)

Gather additional feedback internally and externally Self Assessment of Covid related inspections conducted in 2021

Expanded on best practices and challenges Self-Assessment Report available at ADAMS Accession No. ML21158A231 *Developed recommendations for the routine implementation of inspection Phase B report ML21294A368 programs 29

Inspector Feedback

Remote vs. on-site inspections

Hybrid remote/on-site inspections 30

Inspection Examples:

Westinghouse Dirty Dissolver

24-hour contaminated area at URENCO

Honeywell PMA inspection August 2022

Radiological postings 31

Inspection Key Messages:

On-site inspections continue to be the most effective and preferred method of inspection

Inspection Efficiencies:

- Remote entrance/exit/debrief meetings

- Use of electronic documents and e-rooms for inspection preparation

IMC 2600 guidance updated to allow flexibilities in conducting inspections (i.e.,

remote, hybrid, in-office reviews of records),

when appropriate 32

Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topics:

- Tracking of Enriched Uranium

- Perspectives on On-Site, Hybrid, and Remote Inspections 33

Division of Fuel Management Guidance Development Osiris Siurano-Pérez Project Manager Fuel Facility Licensing Branch 34

Division Instructions Division of Spent Fuel Management (DSFM)

Division of Need to Fuel develop or Management update procedures (DFM)

Fuel Cycle Safety, Safeguards, and Environmental Review (FCSE) 35

Division Instructions

Guidance and recommendations considered and incorporated

- FCSE Licensing Handbook

- SFST DIs

- Smarter Licensing Task Group Recommendations

- Management Expectations on Licensing and Certification Process

- General Accounting Office Report (GAO-20-362)

Recommendations

- Inspector General Report (OIG-21-A-08)

Recommendations 36

Division Instructions

Update of four DIs prioritized to include Smarter Licensing Recommendations

- LIC-FM-1, Overview and Expectations of the Certification and Licensing Process

- LIC-FM-2, Acceptance Review Process

- LIC-FM-3, Requests for Additional Information

- LIC-FM-4, Safety Evaluation Reports 37

Division Instructions

LIC-FM-1, Overview and Expectations of the Certification and Licensing Process

- Sample changes Consider applicants schedule needs when developing a review schedule Consider conducting pre-application meetings, site visits, and/or audits to better understand administrative and technical aspects of application.

Inform applicants about schedule delays or exceeding the level of effort provided in the acceptance letter.

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Division Instructions

LIC-FM-1: Current Status

- Revision 0 issued for staff use/implementation December 23, 2021

- Revision 1 released to public May 12, 2022 ADAMS Accession Number ML22130A659 Addresses 21 SLR recommendations (see Appendix C of DI) 14 Near-term 6 Mid-term 1 Long-term 39

Division Instructions

LIC-FM-2, Acceptance Review Process

- Sample changes Provide schedule milestones and estimated level of effort (hours) in the acceptance letter Consider conducting post submittal meetings during the acceptance review to better understand administrative and technical aspects of application.

Issuance of observations during the acceptance review or in the acceptance letter.

Applicants have the option respond (or not) to observations Observations are initial questions from the staff during the acceptance review Observations may or may not go away during the detailed technical review Observations may become RAIs 40

Division Instructions

LIC-FM-2: Current Status Revision 0 issued for staff use/implementation January 21, 2022 Revision 1 released to public June 30, 2022 ADAMS Accession Number ML22161B042 Addresses 15 SLR recommendations (see Appendix C of DI) 10 Near-term 5 Mid-term 0 Long-term 41

Division Instruction

LIC-FM-3, Requests for Additional Information

- Sample changes Offer opportunity to applicants to discuss draft requests for additional information (RAI) prior to issuance to confirm understanding of request Applicants level of effort needed to develop response Option for conducting site visits (specially for major license amendments, renewals, and new applications)

Ensure consistent structure and clarity of RAIs:

Information needed Justification Regulatory requirement 42

Division Instructions

LIC-FM-3: Current Status Revision 0 issued for staff use/implementation January 31, 2022 Released to public July 27, 2022 ADAMS Accession Number ML22208A272 Addresses 8 SLR recommendations (see Appendix C of DI) 6 Near-term 2 Mid-term 0 Long-term 43

Division Instructions

LIC-FM-4, Safety Evaluation Reports

- Sample changes Use of job aids and templates for drafting SERs Facilitate inspector involvement early in the licensing review process, where and when appropriate 44

Division Instructions

LIC-FM-4: Current Status Revision 0 issued for staff use/implementation March 23, 2022 Revision 1 released to public September 30, 2022 ADAMS Accession Number ML22273A029 Addresses 4 SLR recommendations (see Appendix C of DI) 2 Near-term 2 Mid-term 0 Long-term 45

Division of Fuel Management Other Guidance Draft NUREG-2212, Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but Not Subject to the Requirements in 10 CFR Part 70, Subpart H

- Manuscript completed September 21, 2022

- Authorized for publication September 26, 2022 Transmittal to Office of Administration for further processing and subsequent publication in Federal Register on October 4, 2022, for 60-day comment period Expected by end of 2022

- Final document published by summer 2023 46

Division of Fuel Management Guidance Development QUESTIONS/COMMENTS 47 47

Smarter Licensing Program Matthew Bartlett, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 48

Smarter Licensing Program

Background:

1. The smarter fuel cycle licensing program has been ongoing since 2019, see Charter - April 26, 2019, (ADAMS Accession No. ML19115A016)

2. Several recommendations were identified and grouped as Near-Term, Mid-Term and Long-Term, based on the time for implementation, see Recommendations - April 30, 2020 (ADAMS Accession No. ML20099F354)

3. The status of NRC implementation of the recommendations is documented in the May 18, 2022 Smarter Licensing One Pager (ML22179A081) 49

Smarter Licensing Program Accomplishments

1. Near- and Mid-Term recommendations are incorporated into the following NRC Division Instructions (DI):

LIC-FM-1 Licensing Overview (ML22130A659),

LIC-FM-2 Acceptance Review Process (ML22161B042),

LIC-FM-3 Requests for Additional Information (ML22208A272), and

LIC-FM-4 Safety Evaluation Reports (ML22273A029).

2. NRC completed staff training on the DIs prior to issuance.

3. Redacted versions of the DIs are publicly available.

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Smarter Licensing Program Status of Long-Term Recommendations:

Develop a standard review plan for reviews of greater than critical mass licensees/applicants (Draft will be issued for comment)

Capture and use lessons learned on major licensing actions (Incorporated into Division Instruction - LIC-FM-1, Section 2.24)

Formalized guidance on management turnover to facilitate smoother leadership transitions

Create a roadmap for each type of license and major activity (Captured in multiple internal fuel cycle desk guides)

Update NUREG-1520 (Under consideration)

Develop a central repository of licensing basis documents (Tracked in Web Based Licensing) 51

Smarter Licensing Program Next Steps

1. A status update will be published to the NRC public website at: https://www.nrc.gov/materials/fuel-cycle-fac/regs-guides-comm.html#building.

2. Consider issuing a close out memo for Smarter Licensing

3. Long-Term recommendations would continue to be worked (e.g., roadmap for major licensing actions, NUREG-1520 update, repository of licensing documents, etc.).

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Smarter Licensing Program QUESTIONS/COMMENTS 53

Current and Future Non-fee Billable Activities Matthew Bartlett, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 54

Budget vs. Utilization (FY2022)

Total Budget Total Used Non-Billable Billable Product Line (FTE) (FTE) (FTE) (FTE)

PL-1 Event Response 2.0 1.3 1.3 0.0 PL-2 Generic Homeland 3.0 2.0 2.0 0.0 Security PL-3 International Activities 7.0 5.9 5.9 0.0 PL-4 Licensing 19.5 20.9 12 8.9 PL-5 Oversight 24.5 24.8 15.1 9.7 PL-7 Rulemaking 0.0 2.1 2.1 0.0 PL-M Mission Support and 14.0 16.9 16.9 0.0 Supervision PL-N Training 1.0 0.8 0.8 0.0 TOTAL 71.0 74.7 56.1 18.6 Fiscal Year (FY) = October 2021-September 2022 55

FY2022 Budget Business Line 38 - FY22 Budgeted Items by FTE 1% 3%

PL-1 Event Response (2 - 1.3)*

4%

PL-2 Generic Homeland Security (3 - 2.1)*

20% 10%

PL-3 International Activities (7 - 5.9)*

PL-4 Licensing (19.5 - 20.8)*

27% PL-5 Oversight (24.5 - 24.7)*

35% PL-7 Rulemaking (0.0 - 2.2)*

PL-M Mission Support and Suppervision (14 - 16.8)*

PL-N Training (1.0 - 0.8)*

(Budgeted - Actual) 56

Budget vs. Utilization (FY2022)

Product Line 1 - Event Response Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 2.0 1.3 1.3 0 16%

HQ Event Response (1.1)

RII Event Response (0.2) 84%

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Budget vs. Utilization (FY2022)

Product Line 2 - Generic Homeland Security Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 3.0 2.0 2.0 0 4%

Intelligence Liaison and Threat Assessment (0.9) 21% International Safeguards (0.6) 45%

Physical Security (0.4) 30%

Other (0.1) 58

Budget vs. Utilization (FY2022)

Product Line 3 - International Activities Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 7.0 5.9 5.9 0 14% Conventions and Treaties (3.2)

International Liaison Activities (1) 15%

54% International Cooperation (0.9) 17%

Export-Import Licensing and Consultation (0.8) 59

Budget vs. Utilization (FY2022)

Product Line 4 - Licensing Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 19.5 20.9 12 8.9 3% 2%

4% Technical and Licensing Assistant (2.9)

Legal Support (2.3) 5% Training, Budget, Generic, etc. (1.4) 6% 24% Guidance and Knowledge Management (1.2)

Material Control and Accounting (1) 7% Security (0.8)

Universities (0.7) 8% Stakeholders Meeting (0.6) 19%

10% Information Security (0.4) 12% Advisory Committee On Reactor Safeguards (0.4)

Environmental (0.3) 60

Budget vs. Utilization (FY2022)

Product Line 5 - Oversight Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 24.5 24.8 15.1 9.7 2%

Inspection Program Oversight (3.8) 5%

5% Office Tasks (2.6) 25%

Enforcement (2.4) 9%

Meetings (1.6)

Technical Assistant (1.5) 10%

Other - Audits, Generic, etc. (1.3) 17% Allegations (0.8) 11%

16%

Guidance and Predures (0.8)

Legal Support (0.3) 61

Budget vs. Utilization (FY2022)

Product Line 7 - Rulemaking Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 0.0 2.1 2.1 0.0 5% Enhanced Security for SNM (0.8) 11%

Proposed Rules (0.7) 37%

14% Legal Support (0.3)

Environmental (0.2) 33%

Cyber Security (0.1) 62

Budget vs. Utilization (FY2022)

Product Line M - Mission Support and Supervisors Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 14.0 16.9 16.9 0.0 3% 1%

Supperviosry Support (13.9) 13%

Administrative Assistants (2.2)

Staff Meetings (0.6) 83%

Time and Labor Reporting (0.2) 63

Budget vs. Utilization (FY2022)

Product Line N - Training Utilized (FTE)

Budget (FTE)

Total Non-Billable Billable 1.0 0.8 0.8 0.0 Training Program (0.8) 100%

64

Future Non-Billable Work in the Fuel Facilities Business Line FY 2023-2024

Guidance Updates and Assessment

- Advanced Reactors

- Accident Tolerant Fuel

- NUREG-1520 - Standard Review Plan

- NUREG-1748 - Environmental Review

- NUREG-2212 - New Applications For Greater Than Critical Mass

- Authorizing Official and Classified Networks

- Staff Training and Qualifications

- Construction Inspection Procedures for Two New Facilities

Renew existing license for a university and pre-application engagement with one new university

Operating Experience Review

Rulemaking Activities

Commission meetings and drop-in meetings 65

Current and Future Non-fee Billable Activities QUESTIONS/COMMENTS 66

Regional Budget and Utilization Michael Greenleaf, PhD Technical Assistant Division of Fuel Facility Inspection Region II 67

General DFFI Expenditure by Product 104 - Allegations, 4% 124 - Enforcement, 2%

179 - Emergency Business Produc Product Description Response, 1% Line t Line Emergency 38 1 179 202 - Admin Response Assistants, 3%

38 5 104 Allegations 190 - 38 5 124 Enforcement Supervisors, 15%

38 5 139 Inspection 139 - Inspection, 38 5 186 Security 186 - Security, 66%

9%

38 M 190 Supervisors Admin 38 M 202 Assistants 68

Inspection Product - Non-Fee-Billable Breakdown Office Tasks & Oversight (6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s/wk.)

DFFI TA Tasks Technical, Docket unspecific:

Program development

internal policy, procedure, and

Management briefings guidance reviews, revisions, and

Budget and FTE Planning & adjustments Analysis

SME consultation

Division-director assigned

Comms preparation duties

core program review

Office coordination 23% 14%

future work planning

secure room maintenance,

Organizational Effectiveness

technical working group

Regional tasking

Agency project participation

Improvement projects 6.5 FTE Non-technical, business required:

Agency metrics

Travel planning & vouchers 24% 39%

Business tool maintenance (report generation, calendars, scheduling, personnel Meetings (2.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months s/wk.)

accountability)

Regional Status Call (daily)

Office correspondence

Division-Coordination (weekly) DFFI Office Tasks

Agency culture participation

All-hands meetings (varies) DFFI Meetings

Time & Labor

Public/Stakeholder meetings (varies)

Regional Open-Door (bi-weekly) DFFI TA Tasks

Branch meetings (bi-weekly/monthly) Oversight

Counterpart meetings (semi-annual) 69

Resident Inspector Expenditure PMT, 1% Surveillance, 2% Per 10 CFR 170.12, fees will be assessed to Fire Prot, 2% recover full cost for each resident inspector and senior resident inspector assigned to a ISA, 6%

specific plant.

Indirect, 30%

Indirect Activities:

all training attendance technical and non-technical

management or supervisory activities

plant-or specific performance reviews and Plant Status, assessments 33%

evaluations and incident investigations

all other indirect time not related to specific Prep/Doc, 26% inspections

Meetings

KM

Internal Assessments

Etc.

70

Region II Budget - Fuels (Historical Perspective) 40 38 36 34 32 FTE 30 28 26 MOX CIP ends and SIP reductions 24 22 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Fiscal Year Hisorical Budget 71

Looking Ahead Hiring & Training New hires to meet long term strategic needs New Facilities Potential new facilities in various stages of licensing and construction New Technologies Potential changes to existing facilities 72

Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topics:

- Status of Smarter Licensing Program

- Division Instruction Status

- Fuel Facility Business Line Budget Breakdown 73

Development of the Core Inspection Program for Category II Fuel Facilities DyLanne Duvigneaud Inspection and Oversight Branch Division of Fuel Management 74

Background

The current fuel cycle inspection program, as established in IMC 2600, is applicable to Category I and Category III facilities.

New fuel cycle facilities are in various stages of the pre-licensing and licensing process, and existing fuel facilities are exploring changes to their licenses - that require authorization to possess different types and quantities of special nuclear material.

The possession of the types and quantities of special nuclear material that are being explored, are designated as Category II (Cat II) in accordance with the regulations in 10 CFR Part 73 and Part 74.

Therefore, the current inspection program needs to be expanded to include the requirements for Cat II facilities.

75

Development Plan

All fuel cycle Inspection Manual Chapters (IMCs) and Inspection Procedures(IPs) will be reviewed for Category II applicability and revised, as necessary.

The most revisions are expected for certain inspection guidance documents:

- IMC 2600 Appendix B NRC Core Inspection Requirements

- *Proposed* New column added to IMC 2600 Appendix B

- IPs for the MC&A and physical security functional areas

The Category II fuel facility core inspection program is scheduled to be complete by Spring 2023.

76

Procedures Applicable to Cat II Facilities (Complete)

Procedure Title Procedure Title Number Number IP 88015 Nuclear Criticality Safety IP 88020 Operational Safety IP 88030 Radiation Protection IP 88045 Effluent Control and Environmental Protection IP 88050 Emergency Preparedness IP 88051 Evaluation of Exercises and Drills IP 88055 Fire Protection (Annual) IP 88070 Plant Modifications IP 81815 Authorization for Access to IP 85407 Assessment Program National Security Information (NSI) and Restricted Data (RD)

IP 85408 Recordkeeping Program IP 86740 Inspection of Transportation Activities 77

Procedures Applicable to Cat II Facilities (In Process)

Procedure Title Procedure Title Number Number IP 85203 Management Structure and Controls IP 85205 Item Control Program IP 85207 Measurement Systems IP 85209 Measurement Control Program IP 85211 Inventory Program IP 85213 Resolution Program IP 81810 Protection of Safeguards Information IP 81820 Physical Protection Facility Approval and Safeguarding of National Security Information and Restricted Data IP 81335 Physical Protection of Shipments of IP 81421 Fixed Site Physical Protection of Special Nuclear Material of Special Nuclear Material of Moderate Strategic Significance Moderate Strategic Significance (SNM-MSS) 78

Procedures Applicable to Cat II Facilities (In Process)

Procedure Title Procedure Title Number Number IMC 2600 Fuel Cycle Facility Operational IMC 2600 Guidance for Conducting Fuel Cycle Safety and Safeguards Inspection App A Inspections Fuel Cycle Facility Program Terminology IMC 2600 NRC Core Inspection IMC 2683 Material Control and Accounting App B Requirements... Tables 1 & 2 IMC 0616 Fuel Cycle Safety and Safeguards Inspection Reports 79

Construction Inspection Program Development Michael Greenleaf, PhD Technical Assistant Division of Fuel Facility Inspection (DFFI)

US NRC Region II 80

Construction Inspection Program Development INTENDED PROCESS Generic IMC:

IDENTIFY REVIEW REVISE IMC - Purpose

- Objectives, Consideration to: - Definitions, Applicable IMCs and IPs:

- Lessons Learned - etc.

- (MOX, SHINE, LES, etc.)

- SME Input Specific Appendices:

- QA, Construction, Pre-Op

- Oversight Programs - SNM Category (I, II, III)

- Fuel Cycle Facility Type Inclusive of:

REVISE IPs - Scopes

- Resource Estimates

- etc.

INITIAL ITERATIVE Incorporate Lessons Learned 81

Construction Inspection Program Development CURRENT STATUS INSPECTION MANUAL IMC 2694 CHAPTER INSPECTION PROCEDURES IP XXXX (QA)

APPENDICES IP XXXX (CONST)

A B C Z IP XXXX (PRE-OP)

CAT II MED CAT II CAT Z FUEL FAB ISO ENRICH FACILITY TYPE 82

Questions/Feedback 83

Proposed Rule: Harmonization of Transportation Safety Requirements with International Atomic Energy Agency Standards (Status)

James Firth, Project Manager Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards 84

Part 71: Rulemaking Purpose and Types of Changes

Harmonize the NRCs regulations with those of the International Atomic Energy Agency

- International Atomic Energy Agency Safety Standards Regulations (2012 and 2018 Editions)

Harmonize the NRCs regulations with changes made in a concurrent U.S. Department of Transportation rulemaking

Make other NRC-initiated changes 85

International Atomic Energy Agency Harmonization

Fissile material exemptions

Revise Uranium Hexafluoride Package

Revise insolation requirements for Requirements package evaluations

Include Evaluation of Aging Mechanisms

- Revise units for insolation for normal and a Maintenance Program conditions of transport

Revise Transitional Arrangements*

- Include insolation for Hypothetical

Include Head Space for Liquid Accident Conditions Expansion*

Include Definition for Radiation Level

Revise Tables Containing A1 and A2

Delete Low Specific Activity-III Leaching Values and Exempt Material Activity and Test* Consignment Limits*

Include New Definition for Surface Contaminated Object*

Changes to harmonize with U.S. Department of Transportation and International Atomic Energy Agency 86

Part 71: NRC-Initiated Changes

Biennial quality assurance reporting (§ 71.106)

Remove Type A limits from general license requirements (§§ 71.22, 71.23)

Revise the determination of the mass limits containing mixed quantities of fissile material when uranium-233 is present (§ 71.22)

Revise compatibility category designations for quality assurance requirements (Subpart H)

Remove duplicative reporting (§ 71.95)

Revise the definition of Low Specific Activity (LSA) Material (§ 71.4)

Remove references to irradiated reactor fuel in the advance notification requirements (§ 71.97) 87

Part 71 Proposed Rule: Status

Publication Notes

- Published September 12, 2022 day comment period

- Comment period closes: November 28, 2022

Proposed rule

Draft regulatory guide

- Comment period closes: November 14, 2022

Information Collection

- Public meeting scheduled for October 26, 2022 88

Proposed Rule and Related Documents

Regulations.gov Docket: NRC-2016-0179

- https://www.regulations.gov/docket/NRC-2016-0179

Proposed Rule

- Citation: 87 FR 55708 (September 12, 2022)

- Regulations.gov:

https://www.regulations.gov/document/NRC-2016-0179-0072

- Govinfo.gov:

https://www.govinfo.gov/content/pkg/FR-2022-09-12/pdf/2022-18520.pdf 89

ML22290A248

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