ML25127A020

M250513: Slides - Strategic Programmatic Overview of the Fuel Facilities and the Spent Fuel Storage and Transportation Business Lines

ML25127A020
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Issue date:	05/13/2025
From:	NRC/OCM
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M250513
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1 Strategic Programmatic Overview of the Fuel Facilities and Spent Fuel Storage and Transportation Business Lines Commission Meeting Tuesday, May 13, 2025

2 Opening Remarks Mirela Gavrilas, Ph.D.

Executive Director for Operations

3 Fuel Facilities Business Line Overview John Lubinski Director, NMSS

4 NRCs Fuel Cycle Program Overview

5 Anticipated New Fuels Licensing Actions

6 Fuel Facilities Domestic and International Activities

7 Shaping the Future of the Fuel Cycle Program Kimyata Morgan-Butler, Ph.D.

Deputy Director, Division of Fuel Management, NMSS

Improving Licensing and Oversight Processes Licensing Recommendations Oversight Recommendations Encourage the Applicant/Licensee to Identify Potential Issues (Months Before Submitting)

Use Licensing Audits and Clarification Calls Use of Request for Confirmatory Information Eliminate Public Meetings for Fuel Facilities When There Is No Area Needing Improvement Optional Entrance/Exit Meetings for Operational Safety and Safeguards Inspections Extended Time Allowed Without Site Coverage by Resident Inspector 8

9 0%

20%

40%

60%

80%

100%

120%

Cumulative Percent Complete Months to Completion Historical Amendment Completion Times (2017-2025)

Routine Amendments Complex Amendments Data-Driven Metrics to Drive Performance 12 months 24 months 12 months 24 months

Staffing Strategies to Support Licensing &

Oversight Activities

• Coordination with partners to ensure necessary skills sets are available

• Early adoption of the NRC Project Management Initiative 10

11 New Fuels Licensing Accomplishments, Ongoing and Future Casework &

Transparency and Accountability in the Licensing Process Samantha Lav, Chief Fuel Facilities Licensing Branch Division of Fuel Management, NMSS

12 Licensing Casework is Increasing 30 Licensing Actions Completed Since April 2024 2 - Complex Amendments 22 - Routine Amendments 4 - Exemptions 1 - Terminations 1 - Renewal 20 Current Licensing Actions 63 Projected Licensing Actions through 2030 1 - New License 3 - Complex Amendments 13 - Routine Amendments 1 - Exemptions 1 - Renewal 1 - License Transfers 8 - New License Applications 5 - Complex Amendments 44 - Routine Amendments 2 - Exemptions 3 - Renewals 1 - License Transfers

13 Approving Notable Actions while Reducing Schedule and Resources LES Amendment to Increase Enrichment Limits to 10 wt% - supports ATF with increased enrichment Centrus Phase II of the HALEU Demonstration - allows for increased production of HALEU NIST License Renewal - pilots draft GTCM Standard Review Plan 50%

(6 Months) 5%

(2 Weeks) 30%

(65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br />)

TIME SAVINGS FOR ENRICHMENT AMENDMENT REVIEWS SCHEDULE REDUCTION USING REVISED RAI PROCESS RESOURCE SAVINGS FOR REALTED LICENSING REVIEWS

% Savings Major Licensing Action Approvals Signing of LES Amendment to Increase Enrichment Limits to 10 wt%

14 Strategically Adjusting the Licensing Process

• Consider previous agency-wide licensing actions

• Identify similar past reviews

• Facilitate in-depth topical discussions

• Conduct pre-app readiness assessments Pre-Application

• Implement new review guidance using precedents

• Scale reviews

• Focus on new or changed information

• Apply new environmental review process

• Employ streamlined mandatory hearing process Application Review Estimated Impact of Adjustments

• Provide substantive feedback and best practices in pre-application space

• Identify gaps in application early

• Shorter schedules and fewer resources

• Timelier issuance and response to RAIs

• More timely environmental reviews

• Reduction of hearing timeline

15 Using Data for Licensing Accountability and Transparency Internal Accountability Tracking Metrics Schedule Adherence Resource Usage Identifying and Mitigating Project Risks Workload Prioritization Optimizing Schedules Developing Creative Solutions External Transparency Regular Communication with Licensees and Applicants Project Progress vs. Schedule Estimated vs. Expended Resources Schedule Risks RAI Status

16 Imports and Exports of Nuclear Fuel Barry Miller, Senior International Policy Analyst Export Controls & Nonproliferation Branch Office of International Programs

17 The NRCs Export and Import Licensing Program Leverages the Fuel Facilities Business Line NRC licenses exports and imports of nuclear equipment and material under 10 CFR Part 110 Program leverages multiple NRC offices and business lines International safeguards experts in the FF business line review all export licenses and 123 agreements Approximately 50-70 export licenses issued each year 123 Agreements enable U.S. companies to export nuclear material and equipment to partner countries

18 The Prohibiting Russian Uranium Imports Act (Public Law 118-62)

Signed into law May 13, 2024; effective Aug 11, 2024 Prohibits imports of LEU and natural uranium from Russia unless a waiver is granted by DOE NRC has no role in the waiver process No waivers beyond Jan 1, 2028 Did not alter NRCs import licensing authority NRC general license for import will still be used for any DOE-waived imports

19 Impact of the Prohibition on Imports of Russian Uranium In recent years, Russian uranium imports have accounted for up to 20% of U.S. fuel supply The prohibition law unlocked funds for DOE to award contracts to spur increased domestic enrichment capacity These actions are directly contributing to additional licensing work for NRC

20 Fuel Facility Inspector Training, Qualifications, and Readiness Ravi Penmetsa, Deputy Director Division of Fuels, Radiological Safety, and Security Region II

21 Smarter Fuel Cycle Inspection Program (SIP) Implementation and Realized Benefits

• Stable industry trends = Good foundation for ADVANCE ACT

• SIPs clarified guidance = 67% reduction in variance from resource estimates (from +/-30% to +/-10%)

• Standardized report templates = Improved consistency, traceability, and alignment with inspection procedures

22 Developing a Skilled and Qualified Workforce

• Oversight Capability: Maintaining operational continuity and depth by ensuring adequate number of qualified and trainee inspectors.

• Strategic Cross-Qualification: Leveraged cross-qualification to enhance inspection coverage and agility.

23 Closing Remarks Mirela Gavrilas, Ph.D.

Executive Director for Operations

24 Opening Remarks Mirela Gavrilas, Ph.D.

Executive Director for Operations

25 Spent Fuel Storage and Transportation Business Line Overview John Lubinski Director, NMSS

SFST Program Overview 97 Transportation Packages (Domestic) 82 ISFSIs in 36 States 50 Transportation Packages (International) 26

Driving Results to Meet the Mission - Today and for the Future Committed to Process Improvement and Risk Based Decision-making Focused on Resource Utilization Enabling Safe Deployment of New Technologies 27

28 Shaping the Future of the Spent Fuel Storage and Transportation Program Cinthya Roman-Cuevas Deputy Director, Division of Fuel Management, NMSS

Timeliness Goals:

Ensuring Accountability in SFST

< 6 months, 53%

6-12 months, 11%

12-18 months, 20%

18-24 months, 8%

24-36 months, 8%

100%

of licensing actions completed within NEIMA schedules 85 Tracked Under NEIMA 96 Licensing Actions Completed 29

Spent Fuel Storage & Transportation:

Navigating the Next Five Years

• Workload remains steady. Nature of work evolves.

• Decreasing workload areas:

• Currently, 1 renewal application for a site specific Independent Spent Fuel Storage Installation (ISFSIs) in house - no additional renewal applications are expected.

• 2 Storage CoC Renewals in the next 5 years.

• Increasing Workload Areas:

• Storage cask amendments.

• Renewals of existing Transportation packages.

• Licensing actions for the transportation of higher enrichment, new fuels, and higher burnup.

• CoC applications for the transportation of fueled microreactors.

• DOT Revalidations.

AI generated images 30

Readiness for Regulating New Fuels Is One of Our Top Priorities Increased Enrichment Rulemaking Support transportation campaigns of UF6 enriched up to 10%

Responsive to stakeholder feedback Regulatory Framework Scan Existing regulations support new fuels and new technologies

/conservatisms needed to address uncertainties Scan will prioritize research and data needs, code updates, and potential guidance updates TRISO Phenomena Identification Ranking Table (PIRT)

TRISO and Metal Spent Nuclear Fuels Workshop in December 2024 to discuss PIRT

+300 participants/Targeted outreach to subject matter experts 31

32 Applying Risk Insights to Improve Resource Utilization

• Chloride Induced-Stress Corrosion Cracking (CISCC)

• Leverage research and operating experience to reduce in-service inspection frequency from 20 years to 40 years (Regulatory Guide 3.78)

• Resulting in savings of ~$26 Millions in 40 years

• Additional short-term research could result in additional savings with a high return on investment

• Refining Decommissioning Funding Plan Review Process

• Expected savings up to ~50% of resources

33 Storage and Transportation Licensing Activities, Ongoing and Future Casework Coordination with Federal Partners on Transportation of Radioactive Materials Yoira Diaz-Sanabria Chief, Storage and Transportation Licensing Branch Division of Fuel Management, NMSS

34 Improving Licensing and Rulemaking Processes Expediting Dry Cask Storage Safety Reviews

• Immediate operational needs by general licensees (GLs) to conduct loading campaigns at 20 sites

• Safety review completed in approximately 4 months Saving about 8 months (Baseline Scheule: 12 months)

Approximately 60% schedule savings

• Accomplished by:

Holding early pre-application meetings Conducting audits with licensees for timely resolution of issues Using risk-informed insights and lessons from previous reviews Improving Storage Certificates of Compliance (CoCs) Rulemaking Timeline

• Supporting GLs operational need dates by expediting rulemaking CoCs

• Completed the rulemaking review in 18 weeks Saving up to 8 weeks (Baseline Schedule: 26 weeks)

Approximately 30% on schedule savings

• Accomplished by:

Early alignment with rulemaking center of expertise, overlapping safety and rulemaking process steps while developing rulemaking package Consistency in the Federal Register Notice language Core Team Approach in Transportation CoCs

• Immediate shipment needs of TRISO compacts to support advance reactors

• Completed the review in over 13 months and approximately 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> Saving about 12 months and approximately 800 hrs. (Baseline: 2 years and estimated 1,300 hrs.)

Approximately 50% schedule savings

• Accomplished by:

Conducting early pre-application and post-application engagements with applicant Using core team approach to achieve early alignment on technical issues Issuing one round of requests for additional information Receiving timely responses and quality information

35 Working with Partners to Achieve Results

• Supported Nuclear National Security Administrations (NNSA) to remove self-shielded irradiators by 2027.

• Collaborated with NRCs and Federal partners Addressing technical challenges Streamlining the regulatory process Ensuring safe and secured transport of radioactive material Removal of self-shielded irradiator at NRC-licensed facility

• DOEs MARVEL microreactor project

• DOEs Foreign Research Reactor Program

• NNSA source recovery program under National Defense Authorization Act 2019 Transportation revalidation reviews supporting programs

36 Maximizing Relationships with Federal Partners M-290 package NRC approved December 2014 (max. height 30 ft., weight 260 tons) 2024 NAVAL Emergency Preparedness Demonstration NRC observed real-life emergency preparedness example.

New staff getting insights on collaboration among Federal, Tribal, and local officials.

DOE High Burnup (HBU) cask project at North Anna Transportation of High Burnup Research Cask Project In 2027, DOE will ship cask to Idaho National Laboratory.

Fuel stored for 10 years.

Data will provide additional insights on fuel performance while in transport.

37 Regional Insights and Measures to Achieve Consistency in our Spent Fuel Storage Oversight Programs Jeff Josey Chief, Decommissioning, ISFSI, and Operating Reactor Branch Region IV

38 Achieving Consistency through Collaboration and Dialogue 82 Independent Spent Fuel Storage Licenses 36 States 4 Regions

39 ISFSI Program Enhancements and Realized Benefits Photo Credit: Holtec International Projected FTE Savings:

• 0.4 FTE for Inspection Procedure 60855 change.

• 0.5-1 FTE for change to IMC 0610, ISFSI report process.

• ISFSI security inspection procedure changes.

40 Preparing the Spent Fuel Storage and Transportation Oversight Program Response to the ADVANCE Act Initiatives Under Consideration:

Not doing on-site inspections for sites expanding their ISFSI pad.

Eliminating on-site inspections for not-important-to-safety concrete pad inspections.

We estimate these 2 changes would result in a combined savings of 1 FTE.

41 Strategic Research to Support Current and Future Regulatory Needs Nathanael Hudson, Reactor Systems Engineer Fuel & Source Term Code Development Branch Division of Safety Analysis Office of Nuclear Regulatory Research

42 RES Simulation Codes Support Fuel Cycle Licensing DN30-X SCALE Model VersaPac SCALE Model NRCs approval of ORANOs DN30-X for UF6 up to 20 wt.% U-235 NRCs approval of NACs Optimus-L for TRISO compacts Strategic Planning Implementation Benefits to NRC Licensing Future Licensing Support HTGR - February 28, 2023 SFR - September 20, 2023 MSR - July 11, 2024 NRC Fuel Cycle Demonstration Public Workshop

43 RES Preparations to Support Microreactor Licensing Section 208 of the ADVANCE Act focuses on regulatory requirements for micro-reactors, directing the NRC to develop risk-informed and performance-based strategies and guidance for licensing (including focus on the transportation of fueled micro-reactors and source term )

Microreactor Source Term and Fuel Cycle Public workshop videos, slides, reports at the NRC advanced reactor source term webpage Radiation dose map during hypothetical accident conditions Radiation dose map during normal conditions of transport March 26, 2025, NRC Public Workshop

44 RES Collaborations Strengthen Licensing

• DOE/NRC Criticality Safety for Commercial-Scale HALEU fuel cycle and transportation (DNCSH) fills in gaps to reduce criticality uncertainty in advanced fuels

• Radiochemical Assay (RCA) programs result in high quality validation data for SCALE for LWRs and for LEU+, HBU, non-LWRS

• RES ran experiments of dry cask configurations for CFD validation and reviewing thermal design of SFST and transportation casks

• RES is supporting the Integrated Safety Analysis (ISA) review of TRISO-X and GLE fuel facility license applications Advanced Drying Cycle Simulator Experiment &

CFD Predictions Research programs are driven by licensing needs and informed by engagement through domestic programs and international collaborations Radiochemical Assay Programs National Criticality Experiments Research Center for DNCSH

45 RES Programs Are Informed by Industry Advancements RES is forward-looking and aligns research programs and code development priorities with industry Extended Storage Collaboration Program (ESCP) provides insight into industry plans for long-term fuel storage and future transportability Recent work on criticality uncertainty significantly improved the validation basis, allowing additional margin for licensing without negatively impacting safety RES supported the NMSS workshop in December, engaging industry on NRC analysis capabilities for advanced fuels in fuel performance and neutronics (RIL 2025-04)

46 Closing Remarks Mirela Gavrilas, Ph.D.

Executive Director for Operations