ML25063A073
| ML25063A073 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/26/2025 |
| From: | Hettel W Energy Northwest |
| To: | Mirela Gavrilas NRC/SECY, NRC/EDO |
| References | |
| NRC-2019-0062, RIN 3150-AK31, XO1-25-003, 89FR86918 00108, 89FR92609 00108 | |
| Download: ML25063A073 (1) | |
Text
W. Grover Hettel Executive Vice President / Chief Nuclear Officer P.O. Box 968, Mail Drop PE08 Richland, WA 99352-0968 Ph. 509-377-8311 wghettel@energy-northwest.com 02/26/2025 XO1-25-003 Ms. Mirela Gavrilas Executive Director of Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
ENERGY NORTHWEST ENDORESEMENT OF NEI COMPREHENSIVE INDUSTRY COMMENTS ON NRCS RULEMAKING ON THE POST-SRM PART 53
Reference:
NEI Paper on NRCs Rulemaking on the Post-SRM Part 53, Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors (RIN-3150-AK31; NRC-2019-0062), dated February 14, 2025 Project Number: 689
Dear Ms. Gavrilas:
Energy Northwest appreciates the Nuclear Regulatory Commissions (NRCs) efforts to develop a technology-inclusive, risk-informed, and performance-based regulatory framework for new reactors, referred to as the Part 53 rulemaking. The NRCs incorporation of the Commission directive in the Proposed Rule language published on October 31, 2024, is a step in the right direction, but issues remain that must be addressed prior to publishing the final Rule.
Energy Northwest supports the Nuclear Energy Institutes (NEIs) timely and detailed input on the NRCs Part 53 proposed rule language (Reference). NEIs submittal reflects Energy Northwests views and concerns for Part 53. It highlights the beneficial features the staff has incorporated into Part 53 that should be retained, as well as areas where changes are needed to achieve a Part 53 rule that meets the statutory requirements in the Nuclear Energy Innovation and Modernization Act (NEIMA), the Commission directive in the SRM, and select items from the ADVANCE Act.
To fully address the ADVANCE Act and the Executive Orders for regulatory efficiency, we support NEIs recommendation that NRC should pursue more aggressive changes through Part 53. The NRC should take the opportunity to be bold with Part 53 especially to eliminate regulatory burden for advanced reactors that use passive means to shut down the reactor and dissipate heat and whose fuel cannot melt. These reactors present a very low level of hazard and low potential impact to the public health and safety. This approach should consider establishing performance-based requirements that are capable of being graded appropriately to reactors that achieve site boundary emergency planning zones.
ENERGY NORTHWEST
Energy Northwest Page 2 of 2 Energy Northwest is a member of NEI and has supported NEIs Part 53 Task Force in development of the comprehensive comment package.
Two topics are of particular interest to Energy Northwest: 1) allowing the transfer of safety evaluation(s) from Part 50 to Part 53, especially if the safety case under Part 50 was developed using risk-informed and performance-based methodologies, and 2) reducing requirements for structures, systems, and components classified as non-safety related with special treatment (NSR-ST) when such classification is due solely to ensuring defense-in-depth adequacy.
We are vested in the NRC developing a successful Part 53 that will be used and useful.
The industry has invested significant resources in participating in the public meetings the NRC has held, and in reviewing and commenting on the draft rule language, in the hope of having an inclusive and efficient Part 53. We believe the ability of the nation to reduce carbon emissions and have a robust and reliable electric grid depends on a successful Part 53 rulemaking. We also believe that with relatively straightforward changes to the NRC staffs Part 53 preliminary rule language, the NRC can establish a Part 53 rule that allows the variety of risk-informed licensing approaches that industry plans to use for new reactors on the Commission directed schedule.
Our hope is that the comprehensive comments developed by NEI, in partnership with the industry, will enable the staff to pursue an inclusive and efficient rule. As stated above, the industry stands ready to provide input in the rulemaking process, including the development of necessary guidance. We appreciate the NRCs consideration of these comments in the formation of Part 53. If you have questions concerning our input, please contact Lisa Williams at 509-377-8148 or llwilliams@energy-northwest.com.
Executed this _26__ day of _February, 2025.
Respectfully, W. Grover Hettel Executive Vice President / Chief Nuclear Officer cc: Mr. John Lubinski, NMSS, NRC Mr. John Tappert, NMSS, NRC Ms. Andrea Veil, NRR, NRC Mr. Raymund Furstenau, RES, NRC Mr. Robert H. Beall, NMSS/REFS/RRPB, NRC Mr. Greg Bowman, NRR, NRC Mr. Jeremy Bowen, NRR/DANU, NRC Mr. Anders Gilbertson, NRR/DANU/UARP, NRC Rulemaking.Comments@nrc.gov Regulations.gov