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Slides (External) - ACRS Full Committee Presentation - Industry IE Rulemaking Feedback - Fc - February 5, 2025
	ML25031A397
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/31/2025
From:	Csontos A; Nuclear Energy Institute
To:	Weidong Wang; Advisory Committee on Reactor Safeguards
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Industry Feedback January 16, 2025

©2025 Nuclear Energy Institute 2 LARs for uprates and/or advanced fuels are on the way IE rule and schedule are vital to industry strategic plans Draft IE Rule from the recent ACRS meetings has many appropriate improvements, but major concerns remain Industry feedback remains consistent with recent NEI letters:

March 2023 (ML23107A230)

January 2024 (ML24023A604)

ACRS should allow the draft IE rule for Commission review Workshops needed for industry engagement on concerns IE Rulemaking Key Messages ADVANCE Act alignment for a modern, risk-informed, and efficient IE Rule

Allows increase enrichments to LEU+

Allows existing UF6 packages to ship with up to 10 wt% U-235

Improved risk-informed control room dose design criteria

RG 1.183 revisions permit some units to move forward with strategic plans

More realistic modeling of potential release paths

NRC workshops yielded a more predictable, durable, and stable RG

Openness to LBLOCA as BDBA has potential for significant improvements

NUREG-2266 for up to 10 wt% U-235 and 80 GWd/MTU burnup Specific areas remain deterministic, prescriptive, and not risk-informed with additional burdens and inefficiencies resulting in high uncertainty to implementation IE Rulemaking Key Messages

©2025 Nuclear Energy Institute 4 Enabling Advanced Fuel Technologies SAFELY SUSTAIN THE FLEET Enhanced Fuel Performance Enhanced Fuel Reliability Improved Operational Flexibility Fuel Cycle Optimization Accelerate ATF Fuel Transition 20% Less Waste &

$3.5 Billion Savings

$9.4 Billion in Industry Fuel Savings 24 Month Refueling Cycles ATF/LEU+/HBU fuels are complementary to uprates and enabling in some cases Modern advanced fuel technologies can:

Enable 24-month fuel cycles for PWRs

Less waste = improved safety/fuel efficiency

Improve plant resiliency and performance

Increase potential for power uprates

Improve economics for fleet sustainment On track to meet industrys goal to deploy batch quantities in the mid-to-late 20s:

Applications for 24-month cycles submitted

Efficient NRC licensing for advanced fuels and uprates by 2027 with the IE rule needed

>70% of sites have a level of interest/planning for one or more power uprates with a combined capacity increase of 3 GWe

Nearly 50% of sites have varying interest/plans for one or more of the enabling changes (ATF/

LEU+, Extended Fuel Cycles, and/or RI LOCA) https://www.nei.org/resources/reports-briefs/the-future-of-nuclear-power-2024-survey 2024 NEI Future of Nuclear Power Survey

Does not reflect improvements, efficiencies, and learnings gained from fleet-wide risk informed change programs since 2010:

RIEP duplicates requirements for implementing risk informed change programs already communicated in RG-1.200 and RG-1.174

DG-1428 still requires plant specific seismic analyses even though the industry addressed seismic risk per NRC 50.54 order after Fukushima More stringent criteria with additional unnecessary burdens than currently required, e.g. change control, inspections, reporting, etc.

Prioritized Concern: Implementation

May not be applicable or readily implementable for many LWR sites

May lead to future rulemaking and/or numerous exemption requests

Assumes that BDBA LOCA treatment is sufficient to address FFRD Rule should allow alternative approaches for defining and implementing TBS with prescriptive requirements moved to RGs Minimal changes in rule language provide more flexibility and durability capable of supporting future regulatory improvements without need for exemption requests, e.g. EPRI ALS, Alt. #4, etc.

Prioritized Concern: Flexibility & Durability

Technical areas open to interpretation can lead to analysis paralysis

Industry appreciates staff returning LOCA definition to historical norms What is meant by best estimate LOCA for breaks above TBS?

NRC expectations for true best estimate are not clear or predictable

BDBA analyses should not be obscured by artificial biasing Need a clear and predictable path forward for addressing dispersal Forward fit and backfit guidance needed for this voluntary rule regarding future licensing actions not involving LEU+/HBU Prioritized Concern: Stability & Predictability

NEI March 2023 letter (ML23107A230)

Rules should be technology neutral wrt approved cladding alloys:

Exemptions would be required for several existing approved alloys Prescriptive augmented inspections result in unnecessary additional occupational dose to plant staff and is not risk-informed Legacy reporting requirements should be updated and/or removed, especially for BDBA LOCA considerations Prioritized Concern: Modernization

©2025 Nuclear Energy Institute 10 IE rule with 50.46a/c would enable more realistic operational margins for advanced fuels and additional power uprates as incentivized in the IRA Alignment of the combined draft rule to Commission direction and intent of the ADVANCE Act for a modern, risk-informed, and efficient regulatory process Industry feedback remains consistent with recent NEI letters:

Combined/modernized rule with modified 50.46a/c - Mar 23 (ML23107A230)

IE Rulemaking Regulatory Basis industry comments - Jan 24 (ML24023A604)

Development of a clear, efficient, and durable rule with draft regulatory guides needs full consideration of the holistic implementation pathway for licensees NRC workshops would enable an open and transparent dialogue on the Industrys implementation, efficiency, predictability, and durability concerns Summary

ML25031A397

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