ML22290A248
| ML22290A248 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/2022 |
| From: | Rowley J NRC/NMSS/DFM/FFLB |
| To: | |
| J Rowley NMSS/DFM/FFLB 301-415-4053 | |
| Shared Package | |
| ML22290A246 | List: |
| References | |
| Download: ML22290A248 (94) | |
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 October 19, 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 - October 19, 2022 Topic Time Speakers Introduction (Purpose, Rules for Meeting) 8:30 AM Jonathan Rowley, Project Manager Division of Fuel Management (DFM)
Opening Remarks 8:35 AM Shana Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards (NMSS)
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 Rulemaking 9:30 AM Andrew Carrera, Project Manager, DFM Public Question and Answer 10:15 AM Break 10:20 AM Tracking of Enriched Uranium 10:30 AM Mirabelle Shoemaker, International Safeguards Analyst, DFM Perspectives on On-Site, Hybrid, and Remote Inspections 11:00 AM Tom Vukovinsky, Sr. Project Manager, Division of Fuel Facility Inspection Region II
4 Agenda - October 19, 2022 (cont.)
Topic Time Speakers Public Question and Answer 12:00 Lunch Break 12:05 PM Status of Smarter Licensing Program Division Instruction Status and Changes Industry Early Observations of Recent Licensing Actions 1:15 PM Matthew Bartlett and Osiris Perez-Suirano, Fuel Facility Licensing Branch, DFM Janet Schlueter, NEI Fuel Facility Business Line Budget Breakdown 2:15 PM Matthew Bartlett, Fuel Facility Licensing Branch, DFM Michael Greenleaf, Division of Fuel Facility Inspection, RII Public Question and Answer 3:15 PM Break 3:20 PM Introduction to Category II Inspection Program 3:30 PM Dylannne Duvigneaud, Fuel Cycle Operations Engineer, DFM Michael Greenleaf, Division of Fuel Facility Inspection, RII Status of Harmonization of Transportation Safety Requirements with International Atomic Energy Agency Standards 4:00PM James Firth, Project Manager Division of Rulemaking, Environmental, and Financial Support, Office of Nuclear Material Safety and Safeguards Public Q & A 4:30 PM Recap of Action Items for the Day 4:35 PM Jonathan Rowley, DFM Janet Schlueter, NEI Closing Remarks and Adjourn 4:40 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 May 2022 Fuel Facility Stakeholders Public Meeting
7 Action Items - May 2022 Stakeholders Meeting 7
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 DFM developed new guidance for planning and conducting the bi-annual fuel facility stakeholders meeting.
The guidance will ensure that information will be available to the public at least 7 days prior to the meetings. (On-going Periodic Action)
Action Item 2 The NRC staff was requested to place the corrected integrated schedule of regulatory activities chart on the NRC public website for the fuel facility stakeholders meeting.
NRC Staff Resolution The website was updated on November 16, 2021, and on May 6, 2022. (On-going Periodic Action)
Action Item 3 NEI/Industry suggested that the 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 NRC staff concluded that the draft ISG did not warrant being on the integrated schedule chart and would not be included. The document was not associated with a public 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 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 2021 version is in ADAMS and industry was able to review the latest version. (Closed)
Action Item 5 The NRC staff will consider the 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) and presentation materials (ML21344A149)]. (Closed)
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) are planned to be available by September 2022 after NRC staff has been trained and has implemented the DIs for a few months:
Licensing Overview (LIC-FM-1), Acceptance Reviews (LIC-FM-2), Requests for Additional Information (LIC-FM-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)
8 Integrated Schedule Chart and Supplement Updates Jonathan Rowley Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards
9 Integrated Schedule Chart Updates 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 9/15/2022 Integrated Low-Level Radioactive Waste Disposal Rulemaking (SECY-20-0098)
Irene Wu/Cardelia Maupin/Priya Yadav 10/3/2022 10/3/2022 Part 73 - Enhanced Security of SNM (SECY-19-0095)
Marshall Kohen/Irene Wu Part 73 - Enhanced Weapons Rulemaking (SECY-18-0058)
Stewart Schneider 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 10/3/2022 Comments Preparing a notation vote paper with options (the Commission approved a one-year extension for the paper).
January 2022, the Commission issued SRM-SECY-18-0058 approving the final rule. The final rule is currently in the second phase of post-SRM production (Office of Management and Budget review). Final rule is expected to be published by the end of CY 2022.
Awaiting Commission direction.
Developing proposed rule package.
2023 2022 2021 Proposed rule published on September 12, 2022. Public comment on the proposed rule and draft regulatory guide ends November 28, 2022.
The regulatory basis was published for a 60-day public comment period on April 28, 2022.
The proposed rule package was approved by the Commission on July27, 2022. Secy signature on the federal register notice is on hold pending OMB approval of Information Collection estimated to happen in Janary 2023.
Part 73-Cyber Security Rulemaking (SECY-17-0099)
Irene Wu/James Downs 10/3/2022 9/20/2022 NUREG-2159 - MC&A Guidance for SNM of Moderate Strategic Significance Suzanne Ani Proposed Rulemaking - Alternatives to the Use of Credit Ratings (RIN 3150-AJ92) (SECY-16-0009, SECY-20-0056)
Greg Trussell 9/20/2022 Decommissioning Financial Assurance for Sealed and Unsealed Radioactive Material (PRM-30-66; NRC-2017-0159) -
Greg Trussell/Cardelia Maupin Presentations prepared for sessions of fuel cycle interest are available online.
10/3/2022 Near-and Mid-Term recommendations resolved via the Division Instructions.
Long-Term recommendations in process.
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 TBD 10/5/2022 NMSS is reappointing new staff to lead the project due to staff turnover/promotion/hiring.
Regulatory Information Conference Jonathan Rowley 10/3/2022 Smarter Licensing Effort Matt Bartlett Very Low Safety Significance Issues Stephen Koenick 10/3/2022 9/23/2022 Final rule was published July 28, 2022.
Guidance development and improvement continues as experience is gained.
Radioactive Source Security and Accountability Andrew Carrera/Anita Gray 10/3/2022 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.
Final issuance in Federal Register: July 8, 2022 Parts 11, 25, and 95 - Increased Access Authorization Fees Emily Robbins 10/13/2022
10 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
11 Radioactive Source Security and Accountability Rulemaking Andrew Carrera Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 11
12 Rulemaking process 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:
require safety and security equipment and facilities to be in place for all applicants before 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 Key Messages
13 Rulemaking process 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 identified by the 2016 Government Accountability Office report (GAO-16-330) regarding security and 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.
Key Messages
14 Rulemaking process SRM-COMJMB-16-0001 - Directed NRC staff to evaluate the NRC regulations governing source protection and accountability for category 3 quantities of radioactive material 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 RSSA Rulemaking Background
15 Rulemaking process 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)
Help ensure the legitimacy of license applicants and their intent Proposed RSSA Revisions:
Safety and Security Equipment and Facilities
16 Rulemaking process Requirements for license verification for transfers of category 3 quantities of radioactive materials License Verification System (LVS) or by contacting the license-issuing authority 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 Proposed RSSA Revisions: License Verification
17 Rulemaking process Provide new definition Provide new Appendix F to 10 CFR Part 30 Revise recordkeeping requirements Proposed RSSA Revisions:
License Verification (cont.)
18 Rulemaking process Remove obsolete verification method Administrative, clarifying and conforming changes to various provisions in 10 CFR Proposed RSSA Revisions: Other Changes
19 Rulemaking process Website with frequently asked questions (FAQ) to provide guidance o
Safety and security equipment and facilities requirements o
License verification requirements Provide accelerated guidance update to licensees Proposed RSSA Revisions: Guidance
20 Rulemaking process Next Steps Submit RSSA proposed rule to Commission (December 2022)
Publish in the Federal Register in 2023 (assuming approval by the Commission)
Conduct further stakeholder engagements
21 Rulemaking process Please contact:
- Andrew Carrera, 301-415-1078, Andrew.Carrera@nrc.gov, or
- Anita Gray, 301-415-7036, Anita.Gray@nrc.gov.
Have Questions?
22 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
23 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
24 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.
25 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.
26 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
27 27 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.
28 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
29 Phased Approach for this Assessment Self Assessment of Covid related inspections conducted in 2021 Self-Assessment Report available at ADAMS Accession No. ML21158A231 Phase B report ML21294A368 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
30 Inspector Feedback Remote vs. on-site inspections Hybrid remote/on-site inspections
31 Inspection Examples:
Westinghouse Dirty Dissolver 24-hour contaminated area at URENCO Honeywell PMA inspection August 2022 Radiological postings
32 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
33 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
34 Division of Fuel Management Guidance Development Osiris Siurano-Pérez Project Manager Fuel Facility Licensing Branch 34
35 Need to develop or update procedures 35 Division of Spent Fuel Management (DSFM)
Fuel Cycle
- Safety, Safeguards, and Environmental Review (FCSE)
Division of Fuel Management (DFM)
Division Instructions
36 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
37
- 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
38
- 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.
38 Division Instructions
39
- 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
40
- 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
41
- 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 Instructions
42
- 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 Instruction
43
- 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
44
- 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
45
- 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 Instructions
46 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 Other Guidance
47 47 QUESTIONS/COMMENTS Division of Fuel Management Guidance Development
48 Smarter Licensing Program Matthew Bartlett, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
49
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)
Smarter Licensing Program
50 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.
Smarter Licensing Program
51 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)
52 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.).
Smarter Licensing Program
53 QUESTIONS/COMMENTS Smarter Licensing Program
54 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
55 Budget vs. Utilization (FY2022)
Product Line Total Budget (FTE)
Total Used (FTE)
Non-Billable (FTE)
Billable (FTE)
PL-1 Event Response 2.0 1.3 1.3 0.0 PL-2 Generic Homeland Security 3.0 2.0 2.0 0.0 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 Supervision 14.0 16.9 16.9 0.0 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
56 FY2022 Budget
- (Budgeted - Actual)
Business Line 38 - FY22 Budgeted Items by FTE 3%
4%
10%
27%
35%
20%
1%
PL-1 Event Response (2 - 1.3)*
PL-2 Generic Homeland Security (3 - 2.1)*
PL-3 International Activities (7 - 5.9)*
PL-4 Licensing (19.5 - 20.8)*
PL-5 Oversight (24.5 - 24.7)*
PL-7 Rulemaking (0.0 - 2.2)*
PL-M Mission Support and Suppervision (14 - 16.8)*
PL-N Training (1.0 - 0.8)*
57 Budget vs. Utilization (FY2022)
Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 2.0 1.3 1.3 0
Product Line 1 - Event Response 84%
16%
HQ Event Response (1.1)
RII Event Response (0.2)
58 Budget vs. Utilization (FY2022)
Product Line 2 - Generic Homeland Security 45%
30%
21%
4%
Intelligence Liaison and Threat Assessment (0.9)
International Safeguards (0.6)
Physical Security (0.4)
Other (0.1)
Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 3.0 2.0 2.0 0
59 Budget vs. Utilization (FY2022)
Product Line 3 - International Activities Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 7.0 5.9 5.9 0
54%
17%
15%
14%
Conventions and Treaties (3.2)
International Liaison Activities (1)
International Cooperation (0.9)
Export-Import Licensing and Consultation (0.8)
60 Budget vs. Utilization (FY2022)
Product Line 4 - Licensing 24%
19%
12%
10%
8%
7%
6%
5%
4% 3% 2%
Technical and Licensing Assistant (2.9)
Legal Support (2.3)
Training, Budget, Generic, etc. (1.4)
Guidance and Knowledge Management (1.2)
Material Control and Accounting (1)
Security (0.8)
Universities (0.7)
Stakeholders Meeting (0.6)
Information Security (0.4)
Advisory Committee On Reactor Safeguards (0.4)
Environmental (0.3)
Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 19.5 20.9 12 8.9
61 Budget vs. Utilization (FY2022)
Product Line 5 - Oversight 25%
17%
16%
11%
10%
9%
5%
5%
2%
Inspection Program Oversight (3.8)
Office Tasks (2.6)
Enforcement (2.4)
Meetings (1.6)
Technical Assistant (1.5)
Other - Audits, Generic, etc. (1.3)
Allegations (0.8)
Guidance and Predures (0.8)
Legal Support (0.3)
Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 24.5 24.8 15.1 9.7
62 Budget vs. Utilization (FY2022)
Product Line 7 - Rulemaking 37%
33%
14%
11%
5%
Enhanced Security for SNM (0.8)
Proposed Rules (0.7)
Legal Support (0.3)
Environmental (0.2)
Cyber Security (0.1)
Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 0.0 2.1 2.1 0.0
63 Budget vs. Utilization (FY2022)
Product Line M - Mission Support and Supervisors 83%
13%
3%
1%
Supperviosry Support (13.9)
Administrative Assistants (2.2)
Staff Meetings (0.6)
Time and Labor Reporting (0.2)
Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 14.0 16.9 16.9 0.0
64 Budget vs. Utilization (FY2022)
Product Line N - Training 100%
Training Program (0.8)
Budget (FTE)
Utilized (FTE)
Total Non-Billable Billable 1.0 0.8 0.8 0.0
65 Future Non-Billable Work in the Fuel Facilities Business Line FY 2023-2024 Guidance Updates and Assessment
- Advanced Reactors
- 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
66 QUESTIONS/COMMENTS Current and Future Non-fee Billable Activities
67 Regional Budget and Utilization Michael Greenleaf, PhD Technical Assistant Division of Fuel Facility Inspection Region II
68 General DFFI Expenditure by Product 104 - Allegations, 4%
124 - Enforcement, 2%
139 - Inspection, 66%
186 - Security, 9%
190 -
Supervisors, 15%
202 - Admin Assistants, 3%
179 - Emergency Response, 1%
Business Line Produc t Line Product Description 38 1
179 Emergency
Response
38 5
104 Allegations 38 5
124 Enforcement 38 5
139 Inspection 38 5
186 Security 38 M
190 Supervisors 38 M
202 Admin Assistants
69 39%
24%
23%
14%
DFFI Office Tasks DFFI Meetings DFFI TA Tasks Oversight Office Tasks & Oversight (6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s/wk.)
Technical, Docket unspecific:
internal policy, procedure, and guidance reviews, revisions, and adjustments SME consultation Comms preparation core program review future work planning secure room maintenance, technical working group Agency project participation Non-technical, business required:
Travel planning & vouchers Business tool maintenance (report generation, calendars, scheduling, personnel accountability)
Office correspondence Agency culture participation Time & Labor Meetings (2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s/wk.)
Regional Status Call (daily)
Division-Coordination (weekly)
All-hands meetings (varies)
Public/Stakeholder meetings (varies)
Regional Open-Door (bi-weekly)
Branch meetings (bi-weekly/monthly)
Counterpart meetings (semi-annual)
DFFI TA Tasks Program development Management briefings Budget and FTE Planning &
Analysis Division-director assigned duties Office coordination Organizational Effectiveness Regional tasking Improvement projects Agency metrics 6.5 FTE Inspection Product - Non-Fee-Billable Breakdown
70 Resident Inspector Expenditure Prep/Doc, 26%
Plant Status, 33%
ISA, 6%
Fire Prot, 2%
PMT, 1%
Surveillance, 2%
Indirect, 30%
Per 10 CFR 170.12, fees will be assessed to recover full cost for each resident inspector and senior resident inspector assigned to a specific plant.
Indirect Activities:
all training attendance technical and non-technical management or supervisory activities plant-or specific performance reviews and assessments evaluations and incident investigations all other indirect time not related to specific inspections Meetings KM Internal Assessments Etc.
71 Region II Budget - Fuels (Historical Perspective) 22 24 26 28 30 32 34 36 38 40 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 FTE Fiscal Year Hisorical Budget MOX CIP ends and SIP reductions
72 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
73 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
74 Development of the Core Inspection Program for Category II Fuel Facilities DyLanne Duvigneaud Inspection and Oversight Branch Division of Fuel Management
75 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.
76 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.
77 Procedures Applicable to Cat II Facilities (Complete)
Procedure Number Title Procedure Number Title 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 National Security Information (NSI) and Restricted Data (RD)
IP 85407 Assessment Program IP 85408 Recordkeeping Program IP 86740 Inspection of Transportation Activities
78 Procedures Applicable to Cat II Facilities (In Process)
Procedure Number Title Procedure Number Title 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 Special Nuclear Material of Moderate Strategic Significance (SNM-MSS)
IP 81421 Fixed Site Physical Protection of Special Nuclear Material of Moderate Strategic Significance
79 Procedures Applicable to Cat II Facilities (In Process)
Procedure Number Title Procedure Number Title IMC 2600 Fuel Cycle Facility Operational Safety and Safeguards Inspection Program IMC 2600 App A Guidance for Conducting Fuel Cycle Inspections Fuel Cycle Facility Terminology IMC 2600 App B NRC Core Inspection Requirements... Tables 1 & 2 IMC 2683 Material Control and Accounting IMC 0616 Fuel Cycle Safety and Safeguards Inspection Reports
80 Construction Inspection Program Development Michael Greenleaf, PhD Technical Assistant Division of Fuel Facility Inspection (DFFI)
US NRC Region II
81 Construction Inspection Program Development IDENTIFY Applicable IMCs and IPs:
QA, Construction, Pre-Op REVIEW Consideration to:
Lessons Learned SME Input Oversight Programs REVISE IMC Generic IMC:
Purpose Objectives, Definitions, etc.
Specific Appendices:
SNM Category (I, II, III)
Fuel Cycle Facility Type REVISE IPs Inclusive of:
Scopes Resource Estimates etc.
Incorporate Lessons Learned INITIAL ITERATIVE INTENDED PROCESS
82 Construction Inspection Program Development IMC 2694 APPENDICES A
B C
Z
IP XXXX (QA)
IP XXXX (CONST)
IP XXXX (PRE-OP)
INSPECTION PROCEDURES INSPECTION MANUAL CHAPTER CAT II FUEL FAB MED ISO CAT II ENRICH CAT Z FACILITY TYPE CURRENT STATUS
83 Questions/Feedback
84 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
85 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
86 International Atomic Energy Agency Harmonization Fissile material exemptions Revise insolation requirements for package evaluations Revise units for insolation for normal conditions of transport Include insolation for Hypothetical Accident Conditions Include Definition for Radiation Level Delete Low Specific Activity-III Leaching Test*
Include New Definition for Surface Contaminated Object*
Revise Uranium Hexafluoride Package Requirements Include Evaluation of Aging Mechanisms and a Maintenance Program Revise Transitional Arrangements*
Include Head Space for Liquid Expansion*
Revise Tables Containing A1 and A2 Values and Exempt Material Activity and Consignment Limits*
- Changes to harmonize with U.S. Department of Transportation and International Atomic Energy Agency
87 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
88 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
89 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
90 Related Documents Supporting & Related Material
- Draft Regulatory Analysis (ML22209A039)
- Draft Environmental Assessment (ML22209A045)
Guidance Document
- Draft Regulatory Guide DG-7011, Standard Format and Content of Part 71 Applications for Approval of Packages for Radioactive Material (ML22223A085) 90
91 Questions?
91
92 Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topics:
- Introduction to Category II Inspection Program
- Harmonization of Transportation Safety Requirements with IAEA Standards
93 Jonathan Rowley, Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards Recap of Action Items
94 Closing 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