ML17300A154

Reg Con, October 31 Through November 1, 2017, Presentation: Efficient Transition to Reactor Decommissioning, M. Richter, NEI

ML17300A154
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Site:	Nuclear Energy Institute
Issue date:	11/01/2017
From:	Richter M Nuclear Energy Institute
To:	Office of Nuclear Material Safety and Safeguards
Lindsay H
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ML17300A135	List: ML17300A154
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Mark RichterDivision of Spent Fuel Management Regulatory Conference November 1, 2017Efficient Transition to Reactor Decommissioning This is an explanation of the main ideaOverviewIndustry ChallengesBackground and Current LandscapeEfficiency Opportunities in Transition Rulemaking This is an explanation of the main ideaDecommissioning LandscapeNRC has a proven regulatory framework for decommissioning activities Regulations for Permanent Defueling, SAFSTOR, Radiological

Decommissioning, & Spent Fuel Management are well established11 plants have safely completed decommissioning19 plants are in the process of decommissioning7 plants planning near term shutdownThere currently is no regulatory framework to govern

the transition from operations to decommissioning NATIONAL NUCLEAR ENERGY STRATEGYCREATE THE NUCLEAR IMPERATIVE 4Appropriately value nuclear generationCreate sustainability via improved regulatory framework and reduced burdenInnovate, commercialize, and deploy new nuclearCompete globallyPRESERVESUSTAININNOVATETHRIVE This is an explanation of the main ideaNRC Rulemaking ObjectiveAs stated in the NRC's 2015 Advanced Notice of Proposed Rulemaking (ANPR"The primary objective-..is to implement appropriate regulatory changes that reduce-.licensing actions during decommissioning"NRC further affirms in the ANPR"The need for--rulemaking is not based on any identified safety concerns" This is an explanation of the main ideaOur Industry Vision--A more efficient regulatory framework that:Governs efficient transition from operating to decommissioning Eliminates unnecessary barriers and licensing

actionsImposes no additional regulatory burden on

licensees that have completed transition to decommissioning This is an explanation of the main idea-.A More Efficient Regulatory FrameworkA more efficient regulatory framework that:Provides certainty, efficiency and transparencyLeverages lessons learned from the transition to decommissioning processAffirms there are no safety issues to be addressed This is an explanation of the main ideaEfficiency OpportunitiesNEI agrees with the NRC that there is a sound regulatory basis for rule changes to improve efficiency in the areas of Emergency Preparedness

,Physical SecurityDecommissioning Trust FundsFinancial Protection/IndemnityBackfittingR uleNRC's recommendations are generally consistent with the rulemaking proposal that NEI submitted in its March 17, 2016 comments on the NRC's ANPR.

This is an explanation of the main ideaEfficiency ImpedimentsNEI notes that NRC is recommending rulemaking in two areas not previously addressed in the ANPR: C ontents of the Post

-Shutdown Decommissioning Activities Report (PSDAR)D o not agree with proposed new requirements for the PSDAR to contain a description of how spent fuel managed pursuant to a general independent spent fuel storage installation (ISFSI) will be removed from the reactor siteL icense amendments for non

-power reactors. A gree that the regulations should be amended to clarify that the requirement for a license amendment prior to commencement of decommissioning activities applies only to non

-power reactors This is an explanation of the main ideaEfficient Regulatory TransitionOngoing NRC rulemaking is generally headed in right directionNRC's Draft regulatory basis soundly supports

changes to improve the efficiency of transition

-but leaves open door for other changesProgress has been slow This is an explanation of the main ideaEfficiency and Safety Do Co

-ExistNEI strongly urges NRC to C ontinue on a path of completing a rulemaking to improve the efficiency of the transition from operations to decommissioning as expeditiously as possible. U tilize the proposal we submitted in response to the ANPR in developing the final rule language. NRC staff remain committed to the timely review of exemptions and license amendments that are necessary until this rulemaking can be completed.

Industry Challenge Develop innovative approaches to reduce regulatory burden and improve efficiency in decommissioning transition rulemaking in partnership with the NRC