ML25065A094

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Public Meeting with Nuclear Energy Institute and General Licensees Discuss EGM 25-001, Enforcement Guidance for Dispositioning Non-compliances Related to a General Licensees Use of Certain Non-Qualified Spent Fuel Casks Presentation Slides
ML25065A094
Person / Time
Issue date: 03/06/2025
From:
Division of Fuel Management
To:
References
Download: ML25065A094 (1)


Text

Public Meeting with Nuclear Energy Institute and General Licensees Discuss Enforcement Guidance Memorandum 25-001, Enforcement Guidance for Dispositioning Noncompliances Related to a General Licensees Use of Certain Non-Qualified Spent Fuel Casks March 7, 2025, at 9:30 am ET

Agenda

  • Introduction and Opening Remarks
  • Path Forward
  • NEI/Industry Discussion
  • Public Comments
  • Adjourn Public Meeting

Path Forward

  • Interim enforcement policy as a bridge to a regulatory change re: general licensees (GLs) adopting cask vendor design changes previously made under §72.48
  • Public comment in early April (initial estimate)
  • IEP to Commission in May 2025 (initial estimate)
  • Expeditiously developing technical rationale for rulemaking to ease requirements for GLs adopting changes made by CoC holders under §72.48
  • Staff is considering potential rulemaking methods (all require Commission approval)
1. Interpretive Rulemaking
2. Direct-Final Rule
3. Notice-and-Comment Rule Explain meaning of existing regulations.

Only viable if no change needed to rule text.

Could be the fastest option

(<1year)

If even one person files a significant adverse comment, the agency must withdraw the rule.

If no significant adverse comments could be done in ~1 year.

Allows for consideration of other changes to the rule Could take longer than options 1 and 2 - but allows for additional stakeholder engagement (2-3 years)

NEI/Industry Discussion on EGM 25-001 A. The general licensee has entered the concern into the corrective action program (CAP), and either:

B. For sites that loaded the HI-STORM FW system, the GLs plans via a 72.48 evaluation to:

- apply changes (MOE) in HI-STORM FW Amendment 7 (ML24199A236), through a 72.212(b) evaluation; or

- adopt Amendment 7 via a 72.212(b) evaluation, that demonstrates the cask conforms to the terms, conditions, and specifications of Amendment 7.

C. For sites that loaded the HI-STORM 100 system*:

- movement of the spent fuel storage casks has been restricted until the cask non-compliance is resolved; and

- the licensees corrective action program includes actions to actively pursue restoring compliance via a 72.212(b) and 72.48 evaluation, license amendment request or an exemption request.

  • Amendment 19 will be published in Federal Register the week of March 10, 2025

Public Comments

  • When prompted for questions and discussion, please indicate your desire to speak by using the Raise Hand button in Teams (or press
  • 5 if participating by phone)
  • Once your name has been called by the facilitator, you will need to unmute yourself (press *6 if participating by phone)
  • To ensure we hear from as many people as possible, please limit yourself to one comment or question to start.

Closing Remarks