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    Nuclear Energy Institute, Nuclear Industry Council Issue Public Comment to NRC


    September 6, 2022 - Targeted News Service

     

      TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com

      WASHINGTON, Sept. 5 -- The Nuclear Energy Institute and U.S. Nuclear Industry Council have issued a public comment to the Nuclear Regulatory Commission. The comment was written on Aug. 31, 2022, and posted on Sept. 2, 2022.

      The comment, on Docket No. NRC-2019-0062, was sent to Dan Dorman, executive director of operations.

      Here are excerpts:

      * * *

      The Nuclear Energy Institute (NEI),/1 the U.S. Nuclear Industry Council (USNIC),/2 and our members want to express our appreciation for the Nuclear Regulatory Commission's (NRC) efforts, over the course of the last 2-3 years, in developing a new licensing framework for advanced reactors, commonly referred to as the Part 53 rulemaking, as outlined by statutory requirements in the Nuclear Energy Innovation and Modernization Act (NEIMA) and subsequently, the Commission direction in SRM-SECY-20-0032. While a significant effort has been made by the NRC staff to develop Part 53 rule language and elicit stakeholders' perspectives, the current preliminary rule is unlikely to provide the foundation needed to enable the scale of nuclear deployment that the U.S. needs to meet energy, environmental, climate, economic and national security goals.

      The critical concerns that industry has with the current form of Part 53 are related to NRC proposed requirements that increase complexity and regulatory burden without any increase in safety and reduce predictability and flexibility through the inclusion of prescriptive details that are typically found in guidance.

      1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

      2 The United States Nuclear Industry Council (USNIC) advances the development and implementation of new nuclear technology and services, and the American supply chain, globally. USNIC's members include 80 organizations engaged in nuclear innovation and supply chain development, including technology developers, manufacturers, construction engineers, key utility movers, and service providers.

      * * *

      The success of Part 53 will be measured by whether it efficiently enables the licensing and operation of safe advanced reactors at a rate and scale necessary to support U.S. decarbonization needs. Since many designs will first be licensed under Parts 50 and 52, Part 53 must demonstrate a degree of efficiency that encourages applicants to switch regulatory frameworks.

      At a high level, the six most significant industry concerns and proposed resolutions are embodied in the following six topics. While industry has comments to improve many other areas within Part 53, it is believed that the NRC would need to address all of the following six areas to create a viable Part 53.

      Table omitted.

      The industry has worked diligently to review and analyze the current state of the entire Part 53 framework. Our goal, as stated in past public forums, is a framework that is used and useful. Our collective comments herein are an effort to shape a successful framework.

      Addressing these six most significant industry concerns to achieve a regulatory framework that achieves a similar level of safety as Parts 50 and 52 more predictably, clearly, and efficiently, would result in a Part 53 that is more likely to be used by potential applicants. The details of the industry concerns and proposed solutions on these and many other topics are included in the following:

      * Explanation of The Six Significant Industry Concerns - See Attachment A

      * Framework A Detailed Comments - See NEI and USNIC Letter dated November 5, 2021 (ML21309A578). It is noted that NRC's second iteration of Framework A (released May 2022) addresses a few of the more minor concerns identified by industry, but there are many more concerns that remain unaddressed and the second iteration also introduces new concerns.

      * Framework B Detailed Comments - See Attachment B

      * Comments on Operations Requirements - Framework A (Subpart F) and Framework B (Subpart P) - See Attachment F

      * Comprehensive List of Industry Comment Submissions and Presentations on Part 53 Rule Language - See Attachment E

      * Comments on DG-1413, "Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants" - See Attachment C

      * Comments on DG-1414, "Alternative Evaluation for Risk Insights (AERI) Framework" - See Attachment D

      At this critical juncture of the closing of the preliminary proposed rule stage, it is incumbent on all stakeholders to reflect upon the progress made to date, milestones reached, and the strategic direction that is needed from this point forward, to achieve the efficient and useable Part 53 rule that is needed.

      We encourage the NRC to continue engaging stakeholders, with a focus on responding to these critical concerns before the next formal phase of the rulemaking process - issuance of the proposed rule in summer 2023. The volume and need for multiple attachments for our comments reflects the complexity of the NRC preliminary rule text, which could create barriers to public understanding. Our comments, especially those requesting a single framework, are intended to simplify the rule, which would also make it more accessible to the public. It is our hope that these comments can be used to inform the finalization of the proposed rule, such that Part 53 moves towards a usable rule that enables the vast deployment of advanced nuclear.

      We look forward to working with the staff to answer any questions or provide additional context on the comments that we have provided. If you have questions concerning our input, please contact Marc Nichol at NEI at mrn@nei.org, or Cyril Draffin at USNIC at cyril.draffin@usnic.org.

      Sincerely,

      ________________________

      Doug True, Sr. VP and Chief Nuclear Officer, Nuclear Energy Institute

      ________________________

      Jeffery Merrifield, Chair, Advanced Nuclear Working Group, U.S. Nuclear Industry Council

      Attachment A - Explanation of Significant Industry Concerns

      Attachment B - Framework B Detailed Comments

      Attachment C - Comments on DG-1413, "Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants"

      Attachment D - Comments on DG-1414, "Alternative Evaluation for Risk Insights (AERI) Framework"

      Attachment E - Comprehensive List of Industry Comment Submissions and Presentations

      Attachment F - Comments on Operations Requirements - Framework A (Subpart F) and Framework B (Subpart P)

      Cc: Ms. Marian Zobler, General Counsel, NRC

      Mr. Darrell Roberts, DEDO, NRC

      Ms. Catherine Haney, DEDO, NRC

      Mr. John Lubinski, NMSS, NRC

      Mr. John Tappert, NMSS, NRC

      Mr. Robert H. Beall, NMSS/REFS/RRPB, NRC

      Ms. Andrea Veil, NRR, NRC

      Mr. Rob Taylor, NRR, NRC

      Mr. Mohamed K. Shams, NRR/DANU, NRC

      Mr. William D. Reckley, NRR/DANU/UARP, NRC

      Ms. Meena Khanna, NRR/DRA, NRC

      * * *

      Original text including attachments here: https://downloads.regulations.gov/NRC-2019-0062-0242/attachment_1.pdf

      TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com

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