ML23116A190

From kanterella
Jump to navigation Jump to search
NRC Staff Slides for May 3, 2023 Fuel Facility Stakeholders Meeting
ML23116A190
Person / Time
Issue date: 05/03/2023
From: Rowley J
NRC/NMSS/DFM/FFLB
To:
Shared Package
ML23116A188 List:
References
Download: ML23116A190 (1)
v • d • e


Text

Fuel Facility Stakeholders Meeting May 3, 2023 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.

2

Agenda - May 3, 2023 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 October 2022 Meeting 8:40 AM Jonathan Rowley, Project Manager, DFM Integrated Schedule and Supplement Updates 8:45 AM Jonathan Rowley, Project Manager, DFM Fiscal Year 2023 Fee Rule/Fiscal Year 2024 9:30 AM Samantha Lav, Branch Chief, DFM Congressional Budget Justification Public Question and Answer 10:15 AM Public Break 10:20 AM Fuel Facility Business Line Budget Breakdown 10:30 PM Matthew Bartlett, Project Manager, DFM 3

Agenda - May 3, 2023 (cont.)

Topic Time Speakers Construction Inspection Program Update for Benjamin Karmiol, Fuel Cycle Operations Part 70 Facilities/Smarter Inspection 11:00 AM Engineer, DFM Program Self-Assessment Public Question and Answer 11:45 AM Public Lunch Break 11:50 AM Status of Controlled Unclassified Information Jonathan Feibus, Director, Governance and 1:00 PM Program Enterprise Management Services Matthew Bartlett, Project Manager, DFM Status of Smarter Licensing Program 1:30 PM Janet Schlueter, Senior Advisor, NEI Public Question and Answer 2:30 PM Public Break 2:35 PM Clarification on RIL-2022-08 2:45 PM John Grasso, Reliability and Risk Analyst, RES Options for Rulemaking on Security for 3:15 PM Marshall Kohen, Technical Advisor, NSIR Special Nuclear Material Public Q & A 3:45 PM Public 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 from October 2022 Fuel Facility Stakeholders Public Meeting Jonathan Rowley Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 6

Action Items - October 2022 Stakeholders Meeting Action Item 1 Action Item 2 Action Item 3 The NRC and NEI/Industry shall exchange any meeting The NRC staff will maintain a current integrated schedule The NRC will consider linking the publicly available presentation materials at least one week prior to the of regulatory activities chart on the NRC public website for Division Instructions on the public webpage.

scheduled meeting date. the fuel facility stakeholders meeting.

NRC Staff Resolution NRC Staff Resolution NRC Staff Resolution The four publicly available Division Instructions were linked DFM developed new guidance for planning and The integrated schedule is updated at least twice a year on the Fuel Cycle Facility Regulations Guidance, conducting the bi-annual fuel facility stakeholders meeting. prior to each stakeholders meeting and as needed when Communications, and Fuel Facility Stakeholders Meetings The guidance will ensure that information will be available new items are added. (Ongoing Periodic Action) webpage. (Closed) to the public at least 7 days prior to the meetings.

(Ongoing Periodic Action)

Action Item 4 Action Item 5 Action Item 6 The industry has a continued interest in having discussion Industry and NRC to consider leveraging the capabilities of Consideration was to be given to including Integrated Low-on NRC fee billing. the BOX file sharing platform to enhance licensing review Level Waste Disposal Rulemaking and Enhanced related communications. Weapons Rulemaking on the agenda for the Spring 2023 NRC Staff Resolution meeting.

Fee billing is on the agenda for the May 3, 2023 meeting. NRC Staff Resolution (Closed) Industry and NRC evaluating extent of the use of BOX. NRC Staff Resolution (Ongoing) Separate, individual meetings are being arranged to discuss those rulemakings. Not included on the agenda for the Spring 2023 stakeholders meeting. (Closed)

Action Item 7 Action Item 8 Action Item 9 Interest was expressed in future public discussions on fuel Interest was expressed in having a presentation on Web- Industry expressed interest in future public discussions facility license renewal process. Based Licensing during a future stakeholders meeting. regarding NUREG-2212 prior to its issuance.

NRC Staff Resolution NRC Staff Resolution NRC Staff Resolution NRC staff continues to evaluate the need for additional NRC staff continues to evaluate the request. (Ongoing) A public meeting on NUREG-2212 was held on January public meetings on this topic. (Ongoing) 18, 2023 (ML23018A017). (Closed) 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 The NRC staff is planning a public (SECY-20-0098) 4/14/2023 meeting for Spring 2023.

George Tartal/Cardelia Maupin/Priya Yadav Preparing a notation vote paper with Part 73 - Enhanced Security of SNM (SECY-19-0095) 4/14/2023 *

  • options (the Commission approved a Marshall Kohen/George Tartal one-year extension for the paper).

January 2022, the Commission issued Part 73 - Enhanced Weapons Rulemaking SRM-SECY-18-0058 approving the final (SECY-18-0058) 4/14/2023 rule. The final rule was published on Stewart Schneider March 14, 2023 (88 FR 15864).

Part 73 - Cyber Security Rulemaking (SECY-17-0099) Pending Commission Action extended 4/14/2023 Irene Wu/James Downs to May 2023.

Decommissioning Financial Assurance for Sealed and Unsealed Radioactive Material (PRM-30-66; NRC-2017-0159) - Proposed Rule package is in 4/14/2023 (SECY-19-0125) concurrence.

Greg Trussell/Adam Schwartzman Proposed Rulemaking - Alternatives to the Use of Credit The proposed rule published Janaury 3, Ratings (RIN 3150-AJ92) (SECY-16-0009, SECY-20-0056) 4/14/2023 2023, for a 75-day comment period Greg Trussell ending March 20, 2023.

Harmonization of Transportation Safety Requirements with Public comment on the proposed rule International Atomic Energy Agency Standards (RIN 3150-AJ85;

November 28, 2022.

James Firth ANS 57.11 - Integrated Safety Assessment Standard 4/14/2023 On Hold.

TBD Regulatory Information Conference 4/14/2023 Presentations are available online.

Jonathan Rowley Near-, Mid-Term, and Long-Term recommendations have been implemented via the Division Smarter Licensing Effort Instructions or via additional guidance 4/14/2023 Matt Bartlett development. The NRC staffs Mid Term - Job Aids , implementation is in process as staff Long Term - Turn-over Guidance, SRP for GTCM, Update Near Term - Develop DIs Tem plates , Training, utilize the new divisions instructions and Evaluate Ris k Tool NUREG-1520, Lessons learned, License review road map and guidance.

Guidance development and Very Low Safety Significance Issues 4/24/2023 improvement continues as experience Stephen Koenick is gained.

The staff submitted the draft Radioactive Source Security and Radioactive Source Security and Accountability Accountability proposed rule to the 4/14/2023 Andrew Carrera/Anita Gray Commission on December 19, 2022.

The draft proposed rule is currently under review by the Commission.

The NRCs plans to implement MD 12.6 are delayed. A new date will be identified by OCIO after the National Controlled Unclassified Information Program Security Council (NSC) Interagency 4/14/2023 Tanya Mensah Policy Committee (IPC) completes its efforts to identify Federal-wide CUI implementation challenges and proposed policy solutions.

= 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 9

= Implementation = Non-rulemaking/NRC Activities

  • = Scheduled Meeting l = Marks issuance of SECY V = Site Visit A = ACRS Meeting

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 ML23114A140

- Integrated Schedule Supplement ADAMS Accession Number ML23114A141 Summary of changes to previously listed activities (October 2022 - May 2023)

ADAMS Accession Number ML23114A142 10

Fiscal Year 2023 Fee Rule and Fiscal Year 2024 Congressional Budget Justification Samantha Lav, Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 11

FY 2023 Budget and Fees Timeline*

Commission Review of Congressional Budget Fee Rule Public NRC Collects Internal NRC Justification Publish Final Fees and Fee Analysis Comment Budget (CBJ) Fee Rule Forwards to Calculations Appropriation Period Development Treasury December July -

March - 2021 - January November December March - May - September July 2021 2022 2022 2022 April 2023 June 2023 2023 September January July - March January - July -

2021 2022 November 2023 April 2023 August 2023 2022 Performance NRC provides SECY on Fee Publish Fee Analysis Final Fee Budget to CBJ to Policy Issues Proposed Fee for Final Fee Rule OMB Congress Rule Rule Becomes Effective

  • The dates in the timeline are illustrative and based on generic timelines.

12

FY23 Fee Rule FY2023 proposed fee rule published March 2023 Public comment period closed April 3, 2023 Seven written comment submissions received Staff will consider comments in the formulation of the FY23 final fee rule to be published this summer 13

Annual Fees FUEL FACILITY ANNUAL FEE (10 CFR PART 171)

$8,000,000 BWXT Nuclear Ops. Group, Inc.

$7,000,000 (Lynchburg, VA)

Nuclear Fuel Services

$6,000,000 (Erwin, TN)

Framatome, Inc

$5,000,000 (Richland , WA)

Global Nuclear Fuel - Americas (Wilmington, NC)

$4,000,000 Westinghouse Electric Co.

(Columbia, SC)

$3,000,000 Centrus-American Centrifuge Operating (Portsmouth, OH)

$2,000,000 Louisiana Energy Services (Eunice, NM)

$1,000,000 Honeywell International (Metropolis, IL)

$0 FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23 (Final) (Proposed)

In FY2021, NEIMA went into effect and required the NRC to recover approximately 100% of the budget from fees 14

FY23 Budget Drives Fees

  • Approximately 19% increase in the fuel facility budget
  • Licensing actions for enrichment and manufacturing of HALEU, advanced reactor fuel, and ATF
  • Functioning as the authorizing official for classified systems
  • Restart activities for Centrus and Honeywell
  • Increased MC&A inspections at Category II facilities
  • Increases in salaries and benefits
  • NRC is required by NEIMA to recover approximately 100% of the budget
  • If licensing and oversight activities are delayed, that portion of the budget will be recovered through annual fees
  • NRCs ability to budget accurately is highly dependent on the schedule information provided to us 15

FY24 CBJ Budget 16

FY24 Major Activities

  • Conduct licensing, oversight, and regulatory activities for nine major fuel facilities and 10 greater-than-critical-mass SNM licensees ($15.2M, 52.7 FTE).
  • Review one new fuel facility license application (TRISO-X) and one new medical isotope facility (Niowave) ($0.5M, 2.2 FTE).
  • Maintain the Nuclear Materials Management and Safeguards System for SNM ($2.0M, 1.0 FTE).
  • Sustain U.S. non-proliferation activities by fulfilling national obligations, implementing international safeguards, and licensing the import and export of nuclear materials and equipment ($0.2M, 1.0 FTE).
  • Support agency-provided training in radiation sciences, security, and other training related to regulatory support. ($0.2M).
  • Maintain a highly qualified workforce through recruitment and staffing of entry-level positions to support the agencys SWP ($0.2M, 1.0 FTE).
  • Support the NRCs work with international counterparts 17

FY24 CBJ Budget Increases

  • Salaries and benefits (+$3.3M);
  • Licensing actions related TRISO-X and Niowave (+$2.7M, +4.1 FTE);
  • Licensing actions related to enrichment and manufacturing of HALEU, advanced reactor fuel, and ATF (+$0.2M, +1.0 FTE);
  • Programmatic oversight and inspection in support of Category II fuel facilities and the anticipated new medical isotope production facility

(+$0.6M, +2.0 FTE); and

  • Potential rulemaking for enhanced security of special nuclear material and guidance development for the security for fuel facilities (+$0.2M,

+1.0 FTE).

18

Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the first three presentations.

19

Current and Future Activities Recovered Through Annual Fees Matthew Bartlett, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 20

Fiscal Year (FY) 2023 Congressional Budget Justification Total Budget Excluded Product Line Part 170 Part 171 ML22089A188 Activities

$M FTE PL-1 Event Response $0.5 2.0 PL-2 Generic Homeland

$2.5 3.0 Security PL-3 International

$1.7 7.5 Activities PL-4 Licensing $6.3 22.8 (Universities)

PL-5 Oversight $5.9 25 PL-7 Rulemaking $0.2 1 PL-M Mission Support

$3.0 14.0 and Supervision PL-N Training $0.4 1.0 Travel $0.7 0 TOTAL $21.2 76.3 21

FY2023 Congressional Budget Justification 0.2 0.4 0.5 PL-7 Rulemaking*

0.7 PL-N Training*

1.7 6.3 PL-1 Event Response*

Travel*

2.5 PL-3 International Activities*

PL-2 Generic Homeland Security*

3.0 PL-M Mission Support and Suppervision*

PL-5 Oversight*

5.9 PL-4 Licensing*

  • based on full-time equivalent, contract and training support ($Millions) from the FY2023 Congressional Budget Justification (NUREG-1100 Volume 38 (ML22089A188))

22

Product Line 1 - - Example Activities for FY 2023 Total Budget Excluded Product Line Part 170 Part 171 ML22089A188 Activities PL-1 Event Response $0.5 (M) 2.0 (FTE)

This product line includes:

  • Incident Response Exercises for Fuel Facilities
  • Event Response Support for Fuel Cycle
  • M=Million 23

Product Line 4 - Example Activities for Fiscal Year 2023 Total Budget Excluded Product Line Part 170 Part 171 ML22089A188 Activities PL-4 Licensing $6.3 (M*) 22.8 (FTE)

(Universities)

Part 171 examples in this product line include:

  • Annual budget development, fee rule, contract oversight
  • Guidance development (Greater than Critical Mass, Division Instructions, Qualification Plans, NUREG-1748 revisions, etc.)
  • Hearings (Atomic Safety And Licensing Board Panel Reviews)
  • Knowledge management (seminars, training, lessons learned)
  • Licensing assistants
  • Material control and accounting program infrastructure
  • Metrics and Congressional reporting
  • Security policy and infrastructure (e.g., HALEU gap analysis)
  • Generic (web-based licensing, infrastructure, policy outreach, review, and stakeholders meetings)
  • M=Million 24

Product Line 5 - Example Activities for Fiscal Year 2023 Total Budget Excluded Product Line Part 170 Part 171 ML22089A188 Activities PL-5 Oversight $5.9 (M*) 25 (FTE)

Part 171 examples in this product line include:

  • Allegations and investigations
  • Construction inspection program development
  • Enforcement guidance/policy development for fuel cycle
  • Headquarters MC&A and inspection oversight programs
  • Meetings on general topics (i.e., not specific to a facility)
  • Technical assistant
  • M=Million 25

Product Line 7 - Example Activities for Fiscal Year 2023 Total Budget Excluded Product Line Part 170 Part 171 ML22089A188 Activities PL-7 Rulemaking $0.2 (M*) 1 (FTE)

Part 171 examples in this product line include:

  • Enhanced weapons rulemaking
  • Development of options to address enhanced security of SNM
  • M=Million 26

Product Line M - Example Activities for Fiscal Year 2023 Total Budget Excluded Product Line Part 170 Part 171 ML22089A188 Activities PL-M Mission Support

$3.0 (M*) 14.0 (FTE) and Supervision Part 171 examples in this product line include:

  • Administrative assistants
  • General staff meetings
  • Supervisory support (branch chiefs and other managers)
  • Generic (time and labor, non-supervisory actors, etc.)
  • M=Million 27

Product Line N - Example Activities for Fiscal Year 2023 Total Budget Excluded Product Line Part 170 Part 171 ML22089A188 Activities PL-N Training $0.4 (M*) 1.0 (FTE)

Part 171 examples in this product line include:

  • Nuclear Regulator Apprenticeship Network Training Program
  • Staff training, qualification and development
  • M=Million 28

Future Fuel Facility Part 171 Work FY 2023-2024

  • Commission meetings and drop-in meetings
  • Guidance Updates and Assessment

- Advanced Reactors

- Accident Tolerant Fuel

- NUREG-1748 - Environmental Review

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

- Authorizing Official and Classified Networks

- Construction Inspection Program Development

  • Operating Experience Review
  • Staff Qualification, Training, and Development
  • Rulemaking Activities

- Potential rulemaking for enhanced security of special nuclear material and guidance development for the security for fuel facilities

- Cyber Security 29

Current and Future Activities Recovered Through Annual Fees QUESTIONS/COMMENTS 30

Construction Inspection Program Update for 10 CFR Part 70 Facilities and Smarter Inspection Program Self-Assessment Benjamin Karmiol, Fuel Cycle Operations Engineer Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 31

Construction Inspection Program IMC 2694 and associated IPs

- Updates include but are not limited to:

  • Lessons learned from recent construction oversight projects
  • Technology neutral guidance relying on prioritization of IROFS
  • Guidance for creating site specific master inspection plans
  • Guidance for oversight of applicants constructing 'at-risk 32

Construction Inspection Program Construction is defined in 10 C.F.R. 70.4, and states, in part:

- Construction means:

  • the installation of foundations, or
  • in-place assembly, erection, fabrication, or testing for any structure, system, or component of a facility or activity subject to the regulations in this part that are related to radiological safety or security.

33

Construction Inspection Program Construction at-risk:

- When a licensee or applicant commences construction prior to the Director of NMSS (or his/her designee) making a 10 C.F.R. § 70.23(a)(7) determination, construction is at its own risk (i.e.,

at-risk).

- These risks include NRCs denial of the application, the need for design changes in response to the NRCs Requests for Additional Information, construction rework, additional inspections, and project delays.

34

Construction Inspection Program

  • Next Steps and Schedule

- Issue letters to applicants and licensees that will be commencing construction

- Workshop on Construction:

  • A workshop dedicated to discussing the structure of the IMC and how construction inspections will be completed
  • Staff expects the workshop to take place this summer

- IMC 2694 and associated IP updates completed by the end of the summer 35

Smarter Inspection Program Assessment

  • The self-assessment of the changes made by the SIP initiative will be completed in 2024

- The assessment will evaluate the effectiveness of the changes implemented by the smarter inspection program

- Waiting until 2024 allows staff to gather and assess three full years of data

  • Most inspection procedures will have been performed at most sites 36

Questions/Feedback 37

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

- Fuel Facility Business Line Budget Breakdown

- Construction Inspection Program Update for Part 70 Facilities 38

NRC Controlled Unclassified Information (CUI) Program Implementation Status Jon Feibus, Director Governance and Enterprise Management Services Division Office of the Chief Information Officer Email: Jonathan.Feibus@nrc.gov Phone: 301-415-0717 39

Key Messages Effective April 2023, the NRCs plans to transition to a CUI program on November 1, 2023, have been delayed.

The NRC is awaiting the outcome of the CUI Interagency Policy Committee (IPC) prior to identifying a new CUI transition date.

For additional information, refer to NARA CUI Notice 2022-01.

This delay will support the NRCs overall readiness to transition to CUI, while working towards minimizing the burden on NRC employees and external stakeholders, where practicable.

Once a new transition date is established, the NRC will communicate the new date to all stakeholders well in advance.

All NRC employees and contractors will continue to follow the existing agency policy for Sensitive Unclassified Non-Safeguards Information (SUNSI), which remains in effect until CUI is implemented.

The NRC is committed to minimizing the impact of its transition to CUI for NRC internal and external stakeholders, to the extent practicable. 40 40

Current Status

  • On December 8, 2023, the NRC issued Regulatory Issue Summary (RIS) 2022-03, NRC Plans to Establish Controlled Unclassified Information-Sharing Agreements with Non-Executive Branch Entities, and to inform all NRC external stakeholders of its plans to transition to CUI and of plans to establish formal CUI information-sharing agreements with non-executive branch entities.
  • On January 10, 2023, the NRC held a CUI closed meeting with licensees and other external stakeholders to demonstrate and discuss the view only option described in RIS 2022-03.
  • In light of the NRCs decision to delay its transition to CUI, all licensee comments and questions are being held pending the outcome of the CUI-IPC efforts.
  • On February 3, 2023, the NRC published the information collection request for the NRCs CUI information-sharing agreement in the Federal Register for public comment.
  • On April 4, 2023, NEI formally submitted industry comments on the information collection request.
  • In light of the NRCs decision to delay its transition to CUI, the information collection request is currently on hold.

41 41

Fuel Cycle Licensee Challenges

  • On January 10, 2023, during the NRCs CUI closed meeting, several fuel cycle facility licensees provided the following feedback (shown below in bold italics) to the NRC:

- Due to limited resources, we cannot meet NIST SP 800-171 requirements.

  • This is why the NRC demonstrated the view only alternative during the closed meeting so that licensees would understand any limitations associated with this approach.

- We do not plan to sign the information-sharing agreement once provided by the NRC.

  • The NRC cannot compel licensees to sign an agreement. However, without a signed agreement in place, the NRC will need to default to sharing CUI via view only (or hard copy) when CUI that requires dissemination is not owned by the licensee.

- View only is insufficient to meet our needs to retain records to meet certain regulatory requirements.

  • Following the closed meeting, NEI submitted a number of follow-up questions to the NRC for additional clarification.
  • The industry questions, including the NEI use cases discussed on January 10, 2023, are currently being evaluated by the NRC.
  • The NRC expects to provide an update to NEI in mid-April 2023 regarding an estimated timeline to respond to the NEI uses cases and follow-up questions.
  • The NRC is sharing and discussing these challenges with the CUI-IPC.

42

Conclusion 1 2 3 4 Await the outcome Maintain Hold the Hold the industry of the CUI-IPC to communications information- questions and assess any future regarding the sharing agreement comments plans that would NRCs plans to to consider the provided on reduce burden on transition to CUI outcome of the January 10, 2023, the NRC staff and and following the CUI-IPC. pending the external transition to CUI. outcome of the stakeholders. CUI-IPC.

43

For Additional Information

  • NRC CUI Program Contact

- Jon Feibus, NRC CUI Senior Agency Official

- Tanya Mensah, NRC CUI Program Manager

- Email: CUI@nrc.gov

- CUI Registry

- Policy & Guidance

- Training (NARA CUI videos)

- CUI Blog

- CUI Program Update To Stakeholders Meeting

- CUI FAQs now available 44

Smarter Licensing Program Overview Matthew Bartlett, Sr. Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 45

Smarter Licensing Program

Background:

1. The smarter fuel cycle licensing program started in 2019, see Charter - April 26, 2019 (ADAMS Accession No. ML19115A016)
2. A number of recommendations were identified and grouped as Near-Term, Mid-Term and Long-Term, see Recommendations - April 30, 2020 (ML20099F354)
3. Staffs implementation of the recommendations were documented in the October 19, 2022, Smarter Licensing One Pager (ML23013A286) 46

Smarter Licensing Program Accomplishments

1. The Near- and Mid-Term recommendations have been incorporated into the following NRC Division Instructions (DI):
  • LIC-FM-3 Requests for Additional Information (ML22208A272), and
2. The NRC provided staff training on the DIs.
3. Redacted versions of the DIs are publicly available.

47

Examples Smarter Licensing Improvements

- NT-1, 1 & 2: Acceptance letter incorporate hour estimates and dates NRC staff incorporate hour estimates and estimated completion dates in the acceptance letter. These dates become the established schedule tracked by the metrics.

NT-2, 4 & 7(b): NRC staff hold pre-application meetings with the applicant The NRC staff visit the site, discuss application plans, talk about guidance, etc. in advance of the application

- NT-4, 9 & 11: NRC staff hold technical calls to inform the review The NRC staff hold technical calls on an as needed basis to better understand the application and to discuss draft RAIs

- NT-4, 13(a): Transitions are supported by overlapping reviewers When possible, the technical reviewers are assigned with a back-up reviewer or a person to shadow the reviewer prior to transition.

- MT-15, 1: The NRC staff utilize an interdisciplinary review team The NRC staff seek to involve the entire review team, including non-technical staff in bi-weekly meetings, technical calls, and public meetings.

48

Smarter Licensing Program Status of Long-Term Recommendations:

- LT-1, 13(b): Formalized guidance on management turnover Completed December 20, 2021 (ML21334A377 non-public)

- LT-2, 14: Capture and use lessons learned on major licensing actions Completed May 12, 2022, LIC-FM-1, section 2.24 (ML22130A659)

- LT-2, 23: Update NUREG-1520 On hold, pending existing work priorities

- LT-3, 20: Develop a draft standard review plan greater than critical mass licensees/applicants (DRAFT - NUREG-2212),

In Progress Comment period ended March 31, 2023 (ML22335A087),

project issuance by end of 2023

- LT-4, 25: Create a roadmap for each type of license and major activity Completed June 20, 2021, Desk Guides - (ML21201A294 non-public)

- LT-4, 25: Develop a central repository of licensing basis documents Completed 2022, FFLB SharePoint Repository - non-public

- LT-5, 26: Institutionalize post-review lessons learned An ongoing effort to maintain guidance up to date 49

Smarter Licensing Program QUESTIONS/COMMENTS 50

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

- CUI

- Status of Smarter Licensing Program 51

Clarification on RIL 2022-08 Human Reliability Analysis of See-and-Flee Actions using Integrated Human Event Analysis System for Event and Condition Assessment John Grasso & James Chang Division of Risk Analysis Office of Nuclear Regulatory Research Email: John.Grasso@nrc.gov James.Chang@nrc.gov 52

What is a RIL?

  • RILs are not intended to be used in place of guidance documents, such as Regulatory Guides or Standard Review Plans.
  • In general, RILs should be issued to provide the user offices:
  • research results regarding a significant research TEC-003 Rev.

program or project 2

  • information to support a regulatory decision
  • results of generic regulatory or technical analyses
  • results of research about, or resolution of a problem of interest to the nuclear industry at large
  • team report on a specific topic
  • proceedings of a conference or workshop 53

Background of RIL 2022-08

  • IDHEAS-ECA = the Integrated Human Event Analysis System for Event and Condition Assessment
  • Human Reliability Analysis (HRA) Methodology
  • See-and-Flee = Human Action Administrative Item Relied on for Safety (IROFS)
  • Little instruction on assessing reliability of human IROFS 54

Why was this RIL produced?

  • To demonstrate IDHEAS-ECA to NMSS staff:
  • Identify where the methodology may be useful
  • Provide feedback to improve IDHEAS-ECA
  • To demonstrate IDHEAS-ECA abilities and level of effort
  • To evaluate and assess the reliability of see-and-flee actions 55

How will this RIL be used?

  • As an informative document for NMSS ISA reviewers:
  • IDHEAS-ECA concepts, terms, and how to use
  • As a demonstration to NMSS staff:
  • IDHEAS-ECA uses a sound technical basis to assesses the reliability of see-and-flee actions not in the current review guidance.
  • IDHEAS-ECA could assess the reliability of administrative IROFS to support decision-making.

56

RIL 2022-08 and Industry

  • RIL 2022-08 is not regulatory guidance, just information
  • IDHEAS-ECA is an NRC-developed HRA methodology
  • RIL 2022-008 explores a potential use for IDHEAS-ECA outside of NPP operation
  • NMSS reviewers may choose to use IDHEAS-ECA to support HRA of human action IROFS for ISAs
  • Industry does not have to use RIL 2022-08 57

Questions?

58

NRC Staffs Consideration of Options for a Potential Rulemaking on Security for Special Nuclear Material (SNM)

Marshall Kohen, Technical Advisor Office of Nuclear Security and Incident Response 59

Background

  • January 2015 - Final regulatory basis on Enhanced Security for SNM (ML14321A007)
  • April/June 2016 - Direction to suspend rulemaking activities
  • August 2018 - Direction to staff to complete expedited, limited-scope rulemaking
  • October 2019 - SECY-19-0095, Discontinuation of Rulemaking -

Enhanced Security of Special Nuclear Material (ML19157A084)

  • August 2021 - SRM-SECY-19-0095 - Provide a notation vote paper with options on enhanced security of SNM and the potential regulatory, resource, and timing impacts of the options (ML21217A065) 60

What are the proposed issues to be considered in the Commission paper?

A. Security for Category II quantities of SNM B. Consideration of 1 gray/hr at 1 meter external radiation level threshold exemption C. Security for spent nuclear fuel (use and storage /

transportation)

D. Security for alternate nuclear material (ANM)

E. Security for Categories I and III quantities of SNM 61

Schedule

  • 1/30/23 - Public meeting on Category II SNM (Issue A)
  • 2/28/23 - Public meeting on Category I and III SNM and ANM (Issues D & E)
  • 4/11/23 - Public meeting on spent fuel, including 1 gray/hr at 1 meter external radiation level threshold exemption (Issues B & C)
  • 10/2/23 - Commission paper due 62

Current NRC SNM Categorization Category I Category II Category III Plutonium and U-233 2 kg < 2 kg and > 500 g 500 g and > 15g U-235 20% enriched 5 kg < 5 kg and > 1 kg 1 kg and > 15g U-235 < 20% and 10%

10 kg < 10 kg and > 1 kg enriched U-235 < 10% enriched 10 kg

63

What is meant by Attractiveness?

  • Dilution Factor - measure of attractiveness
  • The mass of the fissile material divided by the total mass of the fissile material and non-fissile materials (that are not mechanically separable from the fissile material, for solids)
  • Non-dilute
  • Moderately dilute
  • Highly dilute
  • Risk-informed concept
  • The less dilute the material, the more attractive it is to adversaries 64

What are the options the staff is considering for physical protection of Category II quantities of SNM (Issue A)?

NO RULEMAKING RULEMAKING RULEMAKING Take into No FOR CATEGORY consideration consideration of II SNM material material attractiveness attractiveness Option 1 Option 2 Option 3 65

What are the options the staff is considering for the external radiation level threshold (Issue B)?

NO RULEMAKING TO RULEMAKING REVISE THE EXTERNAL Revise the external RADIATION LEVEL radiation level THRESHOLD threshold in 10 CFR 73.6(b) and conforming requirements Option 1 Option 2 66

What are the options the staff is considering for physical protection of SNF (Issue C)?

NO RULEMAKING NO RULEMAKING RULEMAKING FOR SNF FOR SNF Revise facility &

Continue case-by- Develop guidance transport security case approach to assist licensees requirements for in calculating SNF storage casks external radiation & transportation level packages Option 1 Option 2 Option 3 67

What are the options the staff is considering for physical protection and MC&A for ANM (Issue D)?

OPTION 1A OPTION 2A Status Quo - No Rulemaking for Rulemaking for PP and MC&A either PP or RULEMAKING for ANM MC&A FOR ANM NO IMMEDIATE RULEMAKING FOR ANM Options 1A & 1B OPTION 1B Options 2A & 2B OPTION 2B Defer rulemaking Rulemaking for until there is an PP of ANM; Defer application for MC&A reprocessing 68

What are the options the staff is considering for physical protection of Category I and Category III SNM (Issue E)?

OPTION 2A Consider SNM attractiveness, Category I and III NO orders, and RULEMAKING INFCIRC/225/Rev.

FOR CATEGORY 5 I OR CATEGORY RULEMAKING III SNM Options 2A and 2B OPTION 2B Option 1 Performance-based regulations for Category I SNM; account for security orders and SNM attractiveness 69

Summary

  • All options, definitions and physical protection measures are pre-decisional and are subject to change
  • Further opportunity for stakeholder review and input if Commission directs rulemaking 70

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

- Clarification on RIL-2022-08

- Options for Rulemaking on Security for SNM 71

Recap of Action Items Jonathan Rowley, Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 72

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 73

Retrieved from "https://kanterella.com/w/index.php?title=ML23116A190&oldid=3534842"