ML17311A379

Reg Con, October 31 Through November 1, 2017, Presentation: the Imperative of Used Fuel Regulatory Efficiency, P. Cowan, NEI

ML17311A379
Person / Time
Site:	Nuclear Energy Institute
Issue date:	10/31/2017
From:	Cowan P Nuclear Energy Institute
To:	Office of Nuclear Material Safety and Safeguards
Lindsay H
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ML17311A374	List: ML17311A379
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The Imperative of Used Fuel Regulatory Efficiency Pamela Cowan Vice President, Nuclear Generation NRC Regulatory Information Conference October 31, 2017 1

NEED TO PRESERVE PLANTS AT RISK Profile of fleet in 2020s shaped by ability for marginal plants to remain viable 120,000 100,000 80,000 60,000 40,000 20,000 Operating SLR Concern Declared Announced

NEED TO PRESERVE PLANTS AT RISK Profile of fleet in 2020s shaped by ability for marginal plants to remain viable 120,000 100,000 80,000 60,000 40,000 20,000 Operating SLR Concern Declared Announced

SCALE OF NEW BUILD With SLR, 20% market share requires adding ~90 GW 140,000 120,000 100,000 80,000 60,000 40,000 20,000 Operating SLR Concern Declared Announced Lg LWR SMR Advanced

SCALE OF NEW BUILD Adding 34 GW results in 12% of generation 140,000 120,000 100,000 80,000 60,000 40,000 20,000 Operating SLR Concern Declared Announced Lg LWR SMR Advanced

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 6

NATIONAL IMPERATIVES 7

USED FUEL REGULATORY EFFICIENCY OPPORTUNITIES

• Risk appropriate license renewal framework

• Graded approach to license and CoC content

• Safety focused change control process

• Best use of NRC inspection resources

RISK APPROPRIATE LICENSE RENEWAL FRAMEWORK

• NRC and Industry have developed a learning approach to aging management

- NUREG 1927 Rev. 1

- NEI 14-03

- AMID database

- NRC MAPS Report (GALL for dry casks)

• Approach has successfully been applied to 2 site specific licenses and 2 Certificates of Compliance (covering 22 sites)

• Concurrent finalization of MAPS report and endorsement of NEI 14-03 needed to assure lasting success 9

GRADED APPROACH TO LICENSE AND COC CONTENT

• Excessive level of detail in dry storage licenses and Certificates of Compliance (CoCs) creates considerable unnecessary workload for NRC and Industry - diverting resources away from more safety significant tasks

• NRC and Industry have agreed on criteria for a pilot approach to correct this (RIRP I-16-01)

• TN Americas Pilot CoC Amendment is under NRC review

• Criteria for graded approach will finalized based on pilot results in 2018

• Goal is 50% reduction in license/CoC content and 50% reduction in Amendments needed 10

SAFETY FOCUSED CHANGE CONTROL PROCESS

• Graded approach dry storage CoCs/Licenses will place non-safety significant information under industry control

• Industry must manage this information under a change control process in which NRC has confidence (10 CFR 72.48)

• NRC and Industry have engaged to develop effective change control guidance (NEI 12-04)

- 10 of 11 fundamental/key issues resolved

- Method of Evaluation now being addressed

• Closure on NEI 12-04 in 2017 and endorsement in 2018 is a must 11

USE OF RESOURCES

• A safety focused NRC inspection program will oversee effective industry implementation of the 10 CFR 72.48 process to manage graded approach licenses/CoCs

• Industry ownership and NRC oversight assures safety within this process

• Effectiveness of process and relatively low risk of dry storage should be factored into determining inspection frequency 12

Resources not unnecessarily committed to dry storage licensing can be devoted to building Improved Dry Storage the nuclear industry Regulatory Process of the future 13

QUESTIONS?