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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Download: ML17300A154 (12)

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Mark Richter Efficient Transition to Division of Spent Fuel Management Reactor Decommissioning Regulatory Conference November 1, 2017

Overview

• Industry Challenges

• Background and Current Landscape

• Efficiency Opportunities in Transition Rulemaking This is an explanation of the main idea

Decommissioning Landscape

• NRC has a proven regulatory framework for decommissioning activities

• Regulations for Permanent Defueling, SAFSTOR, Radiological Decommissioning, & Spent Fuel Management are well established

• 11 plants have safely completed decommissioning

• 19 plants are in the process of decommissioning This is an

• 7 plants planning near term shutdown explanation of the* main Thereidea currently is no regulatory framework to govern the transition from operations to decommissioning

NATIONAL NUCLEAR ENERGY STRATEGY CREATE THE NUCLEAR IMPERATIVE PRESERVE SUSTAIN INNOVATE THRIVE Appropriately value Create sustainability Innovate, Compete globally nuclear generation via improved commercialize, regulatory framework and deploy and reduced burden new nuclear 4

NRC Rulemaking Objective

• As stated in the NRCs 2015 Advanced Notice of Proposed Rulemaking (ANPR The primary objective..is to implement appropriate regulatory changes that reduce.licensing actions during decommissioning

• NRCThis isfurther an affirms in the ANPR explanation of The need the main idea forrulemaking is not based on any identified safety concerns

Our Industry Vision

• A more efficient regulatory framework that:

• Governs efficient transition from operating to decommissioning

• Eliminates unnecessary barriers and licensing actions

• This Imposes is an no additional regulatory burden on licensees explanation of that have completed transition to the main idea decommissioning

.A More Efficient Regulatory Framework

• A more efficient regulatory framework that:

• Provides certainty, efficiency and transparency

• Leverages lessons learned from the transition to decommissioning process

• Affirms there are no safety issues to be addressed This is an explanation of the main idea

Efficiency Opportunities

• NEI agrees with the NRC that there is a sound regulatory basis for rule changes to improve efficiency in the areas of

• Emergency Preparedness,

• Physical Security

• Decommissioning Trust Funds

• Financial Protection/Indemnity

• Backfitting Rule This isrecommendations

• NRCs an are generally consistent with the explanation of therulemaking main idea proposal that NEI submitted in its March 17, 2016 comments on the NRCs ANPR.

Efficiency Impediments

• NEI notes that NRC is recommending rulemaking in two areas not previously addressed in the ANPR:

• Contents of the Post-Shutdown Decommissioning Activities Report (PSDAR)

• Do 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 site

• This License is an amendments for non-power reactors.

explanation of that the regulations should be amended to clarify that the requirement for a

• Agree the main idea license amendment prior to commencement of decommissioning activities applies only to non-power reactors

Efficient Regulatory Transition

• Ongoing NRC rulemaking is generally headed in right direction

• NRCs Draft regulatory basis soundly supports changes to improve the efficiency of transition - but leaves open door for other changes

• Progress This is an has been slow explanation of the main idea

Efficiency and Safety Do Co-Exist

• NEI strongly urges NRC to

• Continue on a path of completing a rulemaking to improve the efficiency of the transition from operations to decommissioning as expeditiously as possible.

• Utilize the proposal we submitted in response to the ANPR in developing the final rule language.

• NRC staff remain committed to the timely review of This is an explanationexemptions of and license amendments that are necessary until this rulemaking can be completed.

the main idea

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