ML18086B196

RIC 2018 Richter Session 19 3.14.2018 Final Rev. 1

ML18086B196
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Site:	Nuclear Energy Institute
Issue date:	03/29/2018
From:	Richter M Nuclear Energy Institute
To:	Office of Nuclear Material Safety and Safeguards
B WATSON DUWP NMSS
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ML18086B191	List: ML18086B195 ML18086B196
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Mark Richter U.S. Nuclear Regulatory 2018 Regulatory Information Conference March 14, 2018 © NEI 2018. All rights reserved. NEI Perspectives on Efficient Decommissioning This is an explanation of the main idea Background On November 20, 2017, NRC issued the Regulatory Basis Document (RBD) for rulemaking proposing changes to decommissioning regulations. Stated objective Proposed Rulemaking (ANPR) appropriate regulatory changes that reduce the number of licensing actions needed during decommissioning © NEI 2018. All rights reserved.

This is an explanation of the main idea Industry Position RBD provides sound foundation for regulatory improvements needed but leaves the door open to changes that could add unnecessary regulatory burden Recommendations support replacement of licensing actions for shut down plants with new regulations enhancing efficiency and certainty for NRC and licensees Some concerns with proposal Additional opportunities © NEI 2018. All rights reserved.

This is an explanation of the main idea Industry Concerns Some RBD recommendations could impose burdensome new guidance or requirements not necessary to assure safety or reduce regulatory burden: Post Shutdown Decommissioning Activities Report (PSDAR) and related Guidance Physical Security © NEI 2018. All rights reserved.

This is an explanation of th e main idea PSDAR Environmental Impacts Modified language in 10 CFR 50.82(a)(4) to state that licensees must: Evaluate the environmental impacts of planned decommissioning activities in the PSDAR Evaluate if the impacts are bounded by previous federally issued environmental review documents © NEI 2018. All rights reserved.

This is an explanation of the main idea PSDAR Community Advisory Board Address the creation of community advisory boards including details on frequency, makeup, and topics No increase in public safety or efficiency Community interaction is a site-specific consideration Changes to PSDAR content should be driven by need to decisions No deficiencies noted by NRC in current guidance for PSDARs hindering regulatory decision-making © NEI 2018. All rights reserved.

This is an explanation of the main idea PSDAR Spent Fuel Management Additional discussion in the PSDAR or Spent Fuel Management Plan to address Management of spent fuel before dismantling systems for handling and shipping fuel. Adds new burden to prepare and submit the PSDAR while not adding any safety benefit. © NEI 2018. All rights reserved.

This is an explanation of the main idea Physical Security NRC disposition of NEI comments on minimum number of armed responders diverges from the stated objective of rulemaking. Final RBD proposes no changes to the inefficient process where licensees submit reassessment of the minimum number of armed responders although NRC recognizes the significant reduction in risk and targets Allowing licensee reassessments to be documented in changes to security plans under 10 CFR 50.54(p) lessens the regulatory burden on staff and licensees and streamlines process for adjusting security requirements © NEI 2018. All rights reserved.

This is an explanation of the main idea Value Proposition Decommissioning Rulemaking that addresses inefficiencies without adding burden: Saves 90+/- U.S. operating plants nearly $1.5 billion Reduces transition process time, now 12-18 months Preserves decommissioning trust fund for radiological decommissioning Reduces need to do it prematurely by doing it more efficiently! © NEI 2018. All rights reserved.

This is an explanation of the main idea Conclusion NEI strongly urges NRC to: Complete rulemaking to improve the efficiency of the transition from operations to decommissioning as expeditiously as possible. Utilize NEI response to the ANPR in developing the final rule language Continue timely review of exemptions and license amendments until rulemaking is complete © NEI 2018. All rights reserved.

Questions? © NEI 2018. All rights reserved.