Licensing Issues

1
Licensing Issues

• Dan Collins

2
Concerns

• Concerns we have heard
• Free/open communication between NRC and RTR
  community
• NRC Public Meeting Policy
• Staffing/ Knowledge Management of NRC staff
• Relicensing Process

3
Routine Communications

• General Concern
• NRC trying to drive routine communications
• into hearings, public meetings, or publication in
• Federal Register.

4
Routine Communications

• NRC Position
• NRC approach to routine communications with
  licensees is unchanged.
• NRC recognizes that free communication is vital
  to ensuring and enhancing safety
• PMs Inspectors still a phone call away
• NRC policy on publication of Federal Register
  notifications is unchanged.
• NRC policy on creation and preservation of
  records is unchanged.

5
Public Meeting Policy

• General Concern
• NRC trying to drive substantive discussions on
• issues into public forum.

6
Public Meeting Policy

• NRC Position
• Not trying to push day-to-day interactions into
  public meetings
• If a meeting to be held, Commission Policy
  provides guidance on whether meeting should be
  open to public observation
• Predominantly, open meetings are at NRC and
  discussions are
• not just a general exchange, and
• not subject to withholding per 10 CFR 2.390

7
Public Meeting Policy

• A public meeting IS NOT
• A formal hearing
• Opportunity for public to put licensee on the
  spot
• Opportunity for public to demonstrate,
  grandstand, or otherwise interfere with orderly
  conduct of NRC business.

8
Public Meeting Policy

• A public meeting IS
• Opportunity for public to observe NRCs
  regulatory process
• Opportunity for public to address
  questions/comments to the NRC staff
• Opportunity for NRC and licensees to communicate
  safety messages to the public

9
Staffing/Knowledge Management

• Concern presented in a variety of ways
• Background of staff
• Training of staff
• Issues with specific staffing decisions
• Overall Implication
• Concern that NRC is losing sight of unique
  nature of RTRs and headed toward treating RTRs
  like mini power reactors.

10
Staffing/Knowledge Management

• NRC Position
• Not trying to turn RTRs into mini power
  reactors.
• Are trying to develop new staff into
  highly-trained, professional project managers
  who
• understand RTR technology
• understand RTR unique circumstances
• understand RTR regulatory requirements
• are well versed in NRC regulatory processes
• are able to explain how/why RTR regulatory
  requirements differ from power reactors

11
Staffing/Knowledge Management

• Depth Diversity of Skill Sets Needed
• RTR knowledge (technology licensing)
• Regulatory knowledge
• Area(s) of technical competence
• Project Management skills
• Over past few years, NRC has had difficulty
  filling existing vacancies few applicants have
  had RTR experience.

12
Staffing/Knowledge Management
13
Staffing/Knowledge Management
14
Staffing/Knowledge Management

• Diversity of skill sets in younger staff enables
  some cross-training to occur
• Lessens burden on senior staff, who still act in
  consulting role
• Training of newer staff to include
• Mentoring by very experienced senior staff
• RTR - specific training
• Regulatory PM qualifications
• Site visits

15
Relicensing

• Current process can be
• lengthy,
• resource intensive,
• cumbersome
• Staff has done some internal work to explore what
  latitude exists to change process
• Kicked around ideas such as
• Inspection or audit-based process
• Focus on areas such as ALARA, EP, Security,
  Training
• Greater credit for operating history
• PRA based approach

16
Relicensing

• Process challenges to overcome
• Completeness depth of SARs varies
• Some SARs no longer reflect facility
• Relicensings completed in 1980s varied in quality
• Some regulations have evolved since facilities
  last licensed
• Some relicensing reviews partially completed

17
Relicensing

• Potential Next steps
• Stake holder input
• Policy paper
• Draft revised guidance and issue for comment
• Address stakeholder comments and revise guidance
• Flexible implementation

18
Looking Forward

• Workload Challenges
• Staff training development
• HEU/LEU Conversions
• Re-licensing backlog
• Security-related activities
• GAO
• Rulemaking
• New license application (?)
• Dept. of Navy and Naval Reactors Support
• International Support
• Routine requests

19
Looking Forward

• Licensing Program Attributes
• Continued dedication to safety security,
  consistent with AEA provision on minimum
  regulation
• Open communication with stakeholders
• Highly-trained professional staff
• Consistency and predictability in regulatory
  actions
• Stable regulatory environment

20

• Backup Slides

21
Public Meeting Policy

• If you are having a public meeting
• NRC Project Manager responsible for
• Coordinating with licensee/applicant to set an
  agenda
• Lining up needed NRC staff
• Arranging for appropriate security, if needed
  to the extend it can be predicted
• Introductory remarks clearly setting ground
  rules wrt public involvement
• Smooth orderly conduct of meeting agenda
• Taking public questions/comments
• Followup