ML25002A270
| ML25002A270 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/2025 |
| From: | Jack Parrott Reactor Decommissioning Branch |
| To: | John Marshall Division of Decommissioning, Uranium Recovery and Waste Programs |
| References | |
| Download: ML25002A270 (1) | |
Text
MEMORANDUM TO:
Jane E. Marshall, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards FROM:
Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF THE PUBLIC MEETING ON THE ADVANCE ACT SECTION 507 NUCLEAR MATERIALS OVERSIGHT AND INSPECTION PROGRAMS IMPROVEMENTS UNDER CONSIDERATION HELD ON DECEMBER 12, 2024 On December 12, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a public meeting with interested members of the public and external stakeholders to discuss the staffs ideas under consideration on the implementation of Section 507 of the ADVANCE Act of 2024.
The meeting notice and agenda are located at Agencywide Documents Access and Management System (ADAMS) Accession No. ML24337A216.
NRC ADVANCE Act Presentation The NRC staff described the scope of the meeting and background for Section 507 of the ADVANCE Act along with how the public can track NRC implementation of the ADVANCE Act and provide input. The staff then described how input was gathered from NRC staff and staff review of the Nuclear Energy Institutes (NEI) October 28, 2024, letter to NRC (ML24302A311).
Based on that input, the ideas under consideration fall under five topic areas: ideas for credit for sustained higher performance; ideas for revisions to inspection manual chapters and procedures; consideration of organizational structures; ideas for technology and inspection reports; and ideas for enforcement process documentation and panels. The public comments that were within the scope of the meeting notice are summarized below.
CONTACTS:
Jack Parrott, NMSS/DUWP 301-415-6634 Jeanette Arce, NMSS/DFM 301-286-9053 Jennifer Dalzell, NMSS/MSST 630-829-9607 Eucherius Rosario, NMSS/DFM 630-829-9577 January 8, 2025 Signed by Parrott, Jack on 01/08/25
J. Marshall Decommissioning Plant Coalition Comments The Decommissioning Plant Coalition suggested that, specifically for decommissioning and Independent Spent Fuel Storage Installations (ISFSIs), there be an increased review of inspection program resources based on licensee performance. Based on risk, inspection schedules should be sharply reduced at ISFSIs and decommissioning sites in safe storage.
Another area of granting inspection credit is to reduce inspection of decommissioning trust funds. With respect to risk at ISFSIs, NRC too frequently focuses on compliance matters when the safety significance is low. NRC should review the Very Low Safety Significance Issue Resolution (VLSSIR) process to grant credit for performance.
Organizationally, the Commission should recognize that with the end of premature reactor shutdowns, NRC has the opportunity to centrally manage inspection resources for decommissioning and ISFSIs. Decommissioning and ISFSI inspection resources could report to NRC headquarters or through one of the regions.
NEI Comments NEI supports streamlining NRC inspection processes by reducing the frequency, size, and content of inspections for high-performing licensees and curtailing low-value reviews of minor violations. Inspection redundancies should be minimized, and NRC headquarters' support to regions should be limited to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per issue. Using checklists for entrance and exit meetings, focusing inspection scopes, and employing virtual exit meetings can improve efficiency.
Reporting for materials inspections should be streamlined through the NRC Deputy Executive Director for Operations to address inconsistencies. Technological advancements, including artificial intelligence, could reduce time spent on reporting and travel, with baselines established to measure improvements. For decommissioning, performance-based inspection plans leveraging historical success should be adopted, while oversight of trust funds should be reduced due to demonstrated financial health. Enhanced communication between licensees, NRC headquarters, and regions is needed, along with annual resource schedules and tailored training to improve oversight. ISFSI inspections should utilize performance margins for better scheduling and planning, and fuel facility inspections require standardized onboarding and safety analysis training to align expectations across varying inspector backgrounds.
Other Public Comments A comment was received regarding providing additional clarity in the meeting notice on the purpose of the meeting as there are a number of public meetings being held related to the ADVANCE Act.
Additional comments were received regarding the NRCs enforcement program. Specifically, there were suggestions to improve the NRC review of violations with low safety significance and to determine if changes in rules or policies may be needed. In addition, there was a suggestion to the expand the use of the VLSSIR program and to incorporate risk insights for decommissioning and ISFSI licensees. Another comment was provided related to non-cited violations and the burden on the licensees. The concern is that non-cited violations do not help industry as they are treated as violations and require corrective actions.
A comment was made that the inspection procedures for estimating waste disposal costs, relative to the adequacy of decommissioning trust fund amounts, should allow for consideration of alternate disposal pathways. This would allow disposal of low risk radioactive waste at other
J. Marshall than radioactive waste disposal sites (e.g., hazardous waste cells) thus lowering the estimated costs of waste disposal and the corresponding amount of money to be set aside for waste disposal in decommissioning trust funds.
Conclusion The industry representatives expressed appreciation for the opportunity to provide additional comments and input related to the ADVANCE Act Section 507. The NRC management encouraged anyone with additional ideas to submit them through the online portal by January 15, 2025.
The enclosure provides the attendance list for this meeting.
Enclosure:
As stated
ML25002A270 OFFICE NMSS/DUWP/RDB/PM NMSS/DUWP/RDB/BC NMSS/DUWP/DD NMSS/DUWP/RDB/PM NAME JParrott SAnderson JMarshall JParrott DATE 1/3/2025 1/7/2025 1/8/2025 1/8/2025
Enclosure U.S. Nuclear Regulatory Commission Public Meeting on ADVANCE Act Section 507: Office of Nuclear Material Safety and Safeguards Oversight and Inspection Programs Improvements Under Consideration December 12, 2024 Participant List Name Affiliation Aaron McCraw NRC Allison Wood NRC Andrea Johnson NRC Anthony Jones NRC Benjamin Karmiol NRC Bill Lin NRC Binesh Tharakan NRC Booma Venkataraman NRC Brett Klukan NRC Cameron Ubben NRC Celimar Valentin-Rodriguez NRC Chris Allen NRC Christian Einberg NRC Cinthya Roman NRC Cynthia Taylor NRC Dan Bradley NRC David Decker NRC David Hills NRC Derek Widmayer NRC Douglas Bollock NRC Duane White NRC Edward Harvey NRC Eric C Michel NRC Esther Bryan NRC Eucherius Rosario NRC Farrah Gaskins NRC Gordon Curran NRC Grace Pennington NRC Hector Rodriguez NRC Jack Freeman NRC Jack Parrott NRC Jane Marshall NRC Jeanette Arce NRC Jennifer Dalzell NRC Jeremiah Rey NRC Jeremy Tapp NRC Jesse Carlson NRC
2 John Monninger NRC Katherine Tapp NRC Kimyata Morgan-Butler NRC Kyle Lei NRC LaDonna Suggs NRC Latif Hamdan NRC Lee Brookhart NRC Leelavathi Sreenivas NRC Lindsey Cooke NRC Lynnea Wilkins NRC Marlone Davis NRC Martha Poston-Brown NRC Martin Ortiz Gonzalez NRC Matthew Hill NRC Meg Day NRC Mike King NRC Michele Burgess NRC Nate Fuguet NRC Neil Sheehan NRC Philip McKenna NRC Roland Womack NRC Sara Taylor NRC Shana Helton NRC Shaun Anderson NRC Shawn Lichvar NRC Suzanne Ani NRC Tony Brown NRC Yilia Vega Claudio NRC David Slaughter Aerotest Operations Kathy (Aerotest)
Aerotest Operations Joy Jiang Breakthrough Institute Think Tank Daniel J. Watts Centrus Energy Jesse S. Brown Constellation Nuclear Deann Raleigh Curtiss-Wright Mike Callahan Decommissioning Plants Coalition (DPC)
Laura McManniman Electric Power Research Institute (EPRI)
Maris Hanson Flibe Timothy Tate Framatome Doug Weaver General Matter Frank Koren Mirion Heath Baldner NAC International (NAC)
Jay Wellwood NAC George Carver NAC
3 Andrew Mauer Nuclear Energy Institute (NEI)
Bruce Montgomery NEI Greg Core NEI Mark Richter NEI Tim Riti NEI Ashley Morris Nuclear Fuel Services (NFS)
Timothy S. Uehling Omaha Public Power District (OPPD)
Donis Shaw Orano USA Coleman Miller Pacific Gas & Electricity Company (PG&E) as individual Ernie Leonard Miller Sacramento Municipality Utilities District (SMUD)
Christopher Warren South Texas Project Electric Generating Station (STPEGS)
Mark E. Morgan Southern California Edison (SCE)
Ira Schneider State of California Kevin Quach State of California Robert Custodio State of California Meghan Cromie State of Colorado Brenda Tubbs State of Indiana Kaci Studer State of Indiana Kevin Stahl State of Indiana Patrick Turner State of Indiana Becki Harisis State of Nebraska Beth Shelton State of Tennessee Matthew Torrico State of Tennessee Sheila Nelson State of Virginia Yifan Lyu Trine University Maddie Blalock U. S. Senate Committee on Environment &
Public Works Kim Medved Vistra Robert Karr Vistra Andrew Bowman Westinghouse Stephen G. Subosits Westinghouse Kalene Walker No Affiliation Joe Faldowski Not Available Phillip Peterson Not Available Brian G Not Available Heather P Not Available