ML23130A062
| ML23130A062 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/2023 |
| From: | NRC/OCM |
| To: | |
| Shared Package | |
| ML23067A030 | List: |
| References | |
| M230516, 10 CFR Part 53, NRC-2019-0062, RIN 3150-AK31 | |
| Download: ML23130A062 (8) | |
Text
©2023 Nuclear Energy Institute
©2023 Nuclear Energy Institute l 1 Part 53:
A Generational Opportunity Presented to:
U.S. Nuclear Regulatory Commission May 16, 2023
©2023 Nuclear Energy Institute 2 Draft proposed Part 53:
1.Too complex 2.Overly burdensome 3.Fails to meet the moment Main Points Industrys Key Issues Unchanged From 18 Months Ago
©2023 Nuclear Energy Institute 3 1,300 pages Including guidance level detail in the rule Two frameworks - prescribing methods
- e.g., replacing reasonable assurance of adequate protection with new legal standards Too Complex
©2023 Nuclear Energy Institute 4 Some, but relatively little modernization
- Technology inclusive safety characteristics (Framework A)
- Some performance-based approaches for security and fitness for duty Aggregated Regulatory Analysis hides regulatory burdens Unjustified additional burden Facility Safety Program ALARA in Design Design for the Beyond Design Basis Overly Burdensome
©2023 Nuclear Energy Institute 5 No Need for Two Frameworks Remove QHOs as Performance Criteria in Rule Remove ALARA as a Design Requirement Remove Requirements to Design to Protect Against and Withstand BDBEs Remove Facility Safety Program Reconcile New Programs and Terminology Key Issues Unchanged November 2021 Letter: ML21309A578 August 2022 Letter:
©2023 Nuclear Energy Institute 6 NEI/USNIC survey of industry
- 18 of 21 do not plan to use rule in current form Efficiency must become a priority Significant areas did not receive updates
- Siting
- Manufacturing licenses (removed in proposed rule)
- Improvements to process efficiencies Fails to Meet the Moment
©2023 Nuclear Energy Institute 7 Issuing proposed rule as-is for comment not efficient
- NRC has the information it needs to resolve stakeholder concerns Industry committed to a successful Part 53
- NEI will continue to remain fully engaged
- Member interest has waned due to frustrations Path Forward Re-Direction Needed
©2023 Nuclear Energy Institute 8 ALARA - As Low As Reasonably Achievable BDBE - Beyond Design Basis Event NEI - Nuclear Energy Institute PRA - Probabilistic Risk Assessment QHO - Quantitative Health Objective USNIC - United States Nuclear Industry Council Acronyms