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Nuclear Energy Institute/Industry Recommended Regulatory Efficiency and Oversight Actions by Dfm Staff to Meet the Call to Action in Advance Act Sections 505 and 507
	ML25134A058
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/20/2025
From:	Richter M; Nuclear Energy Institute
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML25134A057	List: ML25134A058; ML25134A059;
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	Download: ML25134A058 (1)
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©2025 Nuclear Energy Institute NEI/Industry Recommended Regulatory Efficiency and Oversight Actions by DFM Staff to Meet the Call to Action in ADVANCE ACT Sections 505 and 507 NEI/NRC Public Meeting Mark Richter - NEI May 20, 2025

establish techniques and guidance for evaluating applications for licenses for nuclear reactors to support efficient, timely and predictable reviews for applications for those licenses to enable the safe and secure use of nuclear reactors ADVANCE ACT 507 Operating Reactor Oversight and Inspection The Commission shall develop a report to:

assess the ability of the Commission, consistent with the mission of the Commission, to enable licensee innovations that may advance nuclear reactor operational efficiency and safety, including the criteria of the Commission for timely acceptance of licensee adoption of advanced technologies..

The United States ADVANCE Act - Call to Action

©2025 Nuclear Energy Institute 3 Eliminate 10 CFR 72.48(c)(2)(viii) to refocus inspections on more safety significant issues 10 CFR 50.59 rationale does not translate well NRC spends significant resources on 72.48 inspections

No safety issues have been identified

Yet Since 2017 75% of 72.48 violations have been of this specific requirement

CBS issue was open for over 2 years NRC otherwise has sufficient oversight of design control

Examination of Part 72 methods of evaluation is the wrong starting point

Introduces ambiguity into an otherwise non-complex system which can backfit the design review (licensing) process through the inspection process,

Better to start with is design change safe?

Cross-Cutting Recommendation (505/507)

©2025 Nuclear Energy Institute 4 Eliminate the requirement in 72.236 (a) which states that: Specifications must be provided for the spent fuel to be stored in the spent fuel storage cask, such as, but not limited to, type of spent fuel (i.e., BWR, PWR, both).and replace it with a simple condition that the CoC holder may not add significantly different fuel typeswithout NRC approval Eliminate 72.214 which provides a list of casks that are approved for storage of spent fuel under the conditions specified in their Certificates of Compliance Recommendations align with the NRR Executive Teams expectations for implementing near-term actions identified during the May 29, 2024, licensing workshop (ML24193A001) and summarized in a January 21, 2025, letter (ML24278A002) from Andrea Veil to NRR Division Directors ADVANCE ACT 505 Nuclear Licensing Efficiency

Specifications must be provided for the spent fuel to be stored in the spent fuel storage cask, such as, but not limited to, type of spent fuel (i.e., BWR, PWR, both).

Industry graded approach pilot examined every TS for possible movement to the UFSAR Graded approach selection criteria locked down eight spent fuel parameters in 72.236(a) - no efficiency increase was possible Replace it with a simple condition that the CoC holder may not add significantly different fuel typeswithout NRC approval ADVANCE ACT 505 Nuclear Licensing Efficiency

Part 71 uses CoCs that are approved and issued with no listing and no rulemaking necessary.

Part 72 storage systems are well-known and understood An opportunity for public observation can be provided in the Federal Register ADVANCE ACT 505 Nuclear Licensing Efficiency

©2025 Nuclear Energy Institute 7 NEI calls on NMSS to implement IMC 2515-11.07 Coordination of Headquarters Technical Support for Regional Inspection Activities Classification of level of regional requests for HQ support Regional support requests greater than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months require Regional Division Director and the respective HQ Division Director approval For HQ support greater than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , HQ staff require Division Directors approval and will charge directly to the licensee If the issue can be closed under the IMC 0612 Very Low Safety Significance Issue Resolution (VLISSR) Process, the reason for spending additional time on the issue should be discussed with the Regional Division Director before exceeding 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of inspection effort to resolve ADVANCE ACT 507 Operating Reactor Oversight and Inspection

©2025 Nuclear Energy Institute 8 Implement and apply VLSSIR, RIPE or other risk tools to close Spent Fuel Storage issues of very low or no safety significance Very Low Safety Significance Issue Resolution (VLSSIR) is a process used to discontinue evaluation of an issue involving a licensing basis question in which the issue cannot be resolved without a significant level of effort and resources, and the issue is expected to be of very low safety significance if found to be valid Risk-Informed Process for EvaluationsMaterials (RIPE-M) a process for the disposition of low safety significance licensing issues. NRR developed the Risk-Informed Process for Evaluations (RIPE), predicated on a probabilistic risk assessment (PRA). NMSS committed 3+ years ago to leverage available risk information in licensing activities across its various business lines ADVANCE ACT 507 Operating Reactor Oversight and Inspection

©2025 Nuclear Energy Institute 9 Assumptions Licensee prep and approval time (technical and licensing) plus RAI response: 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months @ $200/hr NRC review fees: 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months @$300/hr 3 licensee exemptions avoided resulting from the elimination of question 8 of 72.48 ROI/Burden Reduction 80x200 + 60x300 = $34k per exemption x 3 = $102k per year saved by not preparing and processing 3 exemptions (assumed 3 exemptions per year average)

ROI/Burden Reduction: Exemptions

©2025 Nuclear Energy Institute 10 Assumptions CoC amendment technical work, LAR prep, phone calls/meetings, RAI responses: 400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months @200/hr NRC review fees: 300 hours0.00347 days 0.0833 hours 4.960317e-4 weeks 1.1415e-4 months @$300/hr ROI/Burden Reduction 400x200 + 300x300 = $170k per amendment x 2 =$340k per year saved by not preparing and processing 2 CoC amendments Combined ROI/Burden Reduction is $442k per year.

ROI/Burden Reduction: Certificates of Compliance

©2025 Nuclear Energy Institute 11 Revise 10 CFR Part 71 to extend or eliminate the CoC 5-year term NUREG-2125, Spent Fuel Transportation Risk Assessment, published in January 2014 notes that If there were an accident during a spent fuel shipment, there is only about one-in-a billion chance that the accident would result in a release of radioactive material 10 CFR Part 71.38(c) states that renewal packages should include as few documents as possible, focusing on the changes to the CoC itself.

Given that 10 CFR Part 71.107(c) requires NRC approval prior to any changes to the conditions listed in the CoC, CoC renewal is an administrative task providing little to no regulatory value Given the extremely low risk level and with little or no regulatory value, the CoC 5-year term should be extended or eliminated Transportation

PIRTs

Graded Approach

Gross Rupture Ongoing work important to efficiency

Questions?

ML25134A058

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