[Federal Register Volume 87, Number 42 (Thursday, March 3, 2022)]
[Proposed Rules]
[Pages 11986-11990]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-04052]
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Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
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Federal Register / Vol. 87, No. 42 / Thursday, March 3, 2022 /
Proposed Rules
[[Page 11986]]
NUCLEAR REGULATORY COMMISSION
10 CFR Part 50
[Docket No. PRM-50-112; NRC-2015-0213]
Determining Which Structures, Systems, Components and Functions
Are Important to Safety
AGENCY: Nuclear Regulatory Commission.
ACTION: Petition for rulemaking; denial.
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SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is denying a
petition for rulemaking (PRM), dated July 20, 2015, and supplemented on
August 31, 2015, submitted by Kurt T. Schaefer (the petitioner). The
petition was docketed by the NRC on September 4, 2015, and was assigned
Docket No. PRM-50-112. The petitioner requested that the NRC amend its
regulations to define the term ``important to safety'' and provide a
set of specific criteria for determining which structures, systems,
components and functions are ``important to safety.'' The NRC is
denying the petition because the issue raised does not involve a
significant safety or security concern, and the existing NRC
regulations, guidance, and procedures adequately address the issue
raised in the PRM. A prescriptive approach that defines criteria for
structures, systems, components and functions ``important to safety''
would likely have unintended consequences for the licensing bases of
the current operating fleet and could reduce operational flexibility
without providing a clear safety benefit. The NRC's current regulations
continue to provide reasonable assurance of adequate protection of
public health and safety, promote the common defense and security, and
protect the environment.
DATES: The docket for the petition for rulemaking PRM-50-112 is closed
on March 3, 2022.
ADDRESSES: Please refer to Docket ID NRC-2015-0213 when contacting the
NRC about the availability of information for this action. You may
obtain publicly-available information related to this action by any of
the following methods:
Federal Rulemaking Website: Go to https://www.regulations.gov and search for Docket ID NRC-2015-0213. Address
questions about NRC dockets to Dawn Forder; telephone: 301-415-3407;
email: [email protected]. For technical questions, contact the
individual listed in the FOR FURTHER INFORMATION CONTACT section of
this document.
NRC's Agencywide Documents Access and Management System
(ADAMS): You may obtain publicly-available documents online in the
ADAMS Public Documents collection at https://www.nrc.gov/reading-rm/adams.html. To begin the search, select ``Begin Web-based ADAMS
Search.'' For problems with ADAMS, please contact the NRC's Public
Document Room (PDR) reference staff at 1-800-397-4209, 301-415-4737, or
by email to [email protected]. For the convenience of the reader,
instructions about obtaining materials referenced in this document are
provided in the ``Availability of Documents'' section.
NRC's PDR: You may examine and purchase copies of public
documents, by appointment, at the NRC's PDR, Room P1 B35, One White
Flint North, 11555 Rockville Pike, Rockville, Maryland 20852. To make
an appointment to visit the PDR, please send an email to
[email protected] or call 1-800-397-4209 or 301-415-4737, between
8:00 a.m. and 4:00 p.m. (ET), Monday through Friday, except Federal
holidays.
FOR FURTHER INFORMATION CONTACT: Stacy Joseph, Office of Nuclear
Reactor Regulation, telephone: 301-415-3256, email:
[email protected], U.S. Nuclear Regulatory Commission, Washington,
DC 20555-0001.
SUPPLEMENTARY INFORMATION:
I. The Petition
Section 2.802 of title 10 of the Code of Federal Regulations (10
CFR), ``Petition for rulemaking--requirements for filing,'' provides an
opportunity for any person to petition the Commission to issue, amend,
or rescind any regulation. On July 20, 2015, the NRC received a PRM
from Mr. Kurt T. Schaefer (the petitioner), which was supplemented on
August 31, 2015. The NRC assigned this PRM the docket number of PRM-50-
112. On January 6, 2016 (81 FR 410), the NRC published a notice of
docketing and request for comment in the Federal Register. The
petitioner requested that the NRC amend its regulations in Sec. 50.2,
``Definitions,'' of 10 CFR part 50, ``Domestic Licensing of Production
and Utilization Facilities,'' to include a definition with specific
criteria for determining what structures, systems, components (SSCs)
and functions are ``important to safety.'' The petitioner stated that
``[t]he nuclear industry is on its third generation of engineers and
regulators with no clear definition of what is `important to safety' ''
and that ``there is no excuse for not having a concise set of
functional criteria defining such a used term.''
The petitioner noted that the ``NRC staff's current position is
that SSCs `important to safety' consists of two subcategories, `safety-
related' and `non-safety-related.' '' The petitioner stated that while
safety-related SSCs are defined in Sec. 50.2, ``the regulations do not
provide an equivalent set of criteria for determining which non-safety-
related SSCs are `important to safety.' '' The petitioner noted that
there is very little agreement about what ``non-safety-related
structures, systems and components (SSCs) should be categorized as
`important to safety.' '' Furthermore, the petitioner stated that
``there is only a general description of what is `important to safety'
in 10 CFR part 50, appendix A, [`General Design Criteria for Nuclear
Power Plants,'] and the regulations do not provide a specific set of
criteria for determining which SSCs are `important to safety.' '' The
petitioner stated that ``NRC Generic Letter (GL) 84-01, ``NRC use of
the terms, `Important to Safety' and `Safety-Related','' and its
attachments, clarified the NRC staff's use of these terms, but did not
``provide a specific set of criteria for determining which non-safety-
related SSCs are to be categorized as `important to safety.' '' The
petitioner stated that, ``there are regulations, regulatory guidance
and routinely generated regulatory evaluations, based on SSCs with no
specific criteria that determines what are the applicable SSCs.'' In
the petition, the petitioner recommended text and specific criteria for
the definition of ``important to safety.''
[[Page 11987]]
II. Public Comments on the Petition
On January 6, 2016, the NRC requested comments from the public on
the petition. As part of the request for public comments, the NRC also
requested (1) any new information and analysis that could provide the
basis for changes to the NRC's regulations, (2) specific examples where
the lack of a formal NRC definition of the terms ``safety related'' and
``important to safety'' directly resulted in adverse consequences to
external stakeholders, (3) the regulations that would require revision
to reflect the new definition and the nature (objective) of the
revision for each provision of the regulation that must be revised, and
(4) any guidance needed to implement the new definition, including what
the scope should be, level of detail, and content of the guidance.
The comment period closed on March 21, 2016, and the NRC received
12 comment submissions containing a total of 102 individual comments. A
comment submission is a communication or document submitted to the NRC
by an individual or entity with one or more individual comments
addressing a subject or issue. Seven of the public comment submissions
opposed the petition, three supported the petition, and two were
responses from the petitioner to other comment submissions. Three of
the public comment submissions were received after the end of the
comment period, but the NRC considered them in the comment analysis.
All of the comment submissions received on this petition are available
as indicated in the ``Availability of Documents'' section of this
document and on https://www.regulations.gov under Docket ID NRC-2015-
0213.
The NRC addressed the comments in a separate document, ``NRC
Response to Public Comments for PRM-50-112,'' as listed in the
``Availability of Documents'' section of this document. A brief summary
of these comments and the NRC's responses is included here.
Several comment submissions opposing the petition indicate that
nuclear power plant applicants and licensees have an existing
understanding of the safety classification terms as applied to their
nuclear power plants and do not see the need for a specific definition
of ``important to safety'' for SSCs at all nuclear power plants in
Sec. 50.2. Several comment submissions opposing the petition also
assert that the specification of a definition of ``important to
safety'' in Sec. 50.2 might result in confusion among nuclear power
plant applicants and licensees over the classification of the SSCs at
their nuclear power plants. Several comment submissions opposing the
petition also indicate that significant costs might be involved with
the development and implementation of a definition of ``important to
safety'' for SSCs at all nuclear power plants that would outweigh the
benefits of such an effort.
Several comment submissions supporting the petition suggest that a
specific definition for ``important to safety'' in Sec. 50.2 for SSCs
at all nuclear power plants would resolve uncertainty regarding the
scope of SSCs classified as ``important to safety'' and help improve
safety at nuclear power plants. Comment submissions supporting the
petition also stated that a specific definition of ``important to
safety'' in the NRC regulations would help reduce cost for nuclear
power plant applicants and licensees by providing regulatory certainty.
Several comment submissions supporting the petition recommend that a
definition of ``important to safety'' should be consistent or
compatible with the safety classification methods developed, or under
development, by other organizations.
III. Reasons for Denial
The NRC is denying the petition because the issue raised in the
petition does not involve a significant safety or security concern and
because the existing NRC regulations, guidance, and procedures
adequately address the issue raised in the petition. More specifically,
the NRC is denying the petition because the proposed rulemaking effort
to define ``important to safety'' in Sec. 50.2 for SSCs and their
functions at all nuclear power plants does not have a safety benefit
for nuclear power plants under 10 CFR part 50 and part 52, ``Licenses,
Certifications, and Approvals for Nuclear Power Plants.'' The NRC
maintains that a strong regulatory framework including a clear
understanding of regulatory terminology is important to provide
adequate protection of public health and safety. The NRC's current
regulatory framework is supported by the well-established understanding
of terminology such as ``important to safety,'' as documented in
regulatory guidance, policy, and licensee and applicant documentation.
The NRC agrees with the petitioner that a specific definition of
``important to safety'' for SSCs and their functions at all nuclear
power plants is not provided in Sec. 50.2. As noted by the petitioner,
the history of the terms ``important to safety'' and ``safety-related''
has not been straightforward. However, a rulemaking effort to define
``important to safety'' in Sec. 50.2 for SSCs and their functions at
all nuclear power plants does not present a safety benefit for nuclear
power plants under 10 CFR parts 50 and 52 and the existing regulatory
framework provides adequate protection.
Historic Guidance and Rulemaking Activity on Defining ``Important to
Safety''
The evolution of the different uses of safety classification terms
at the NRC has a lengthy, complicated regulatory history. For example,
the meaning of ``important to safety'' and ``safety-related'' was a
topic of discussion following the accident at the Three Mile Island,
Unit 2 (TMI-2) nuclear power plant in 1979 and during the subsequent
litigation. Specifically, in the Atomic Safety and Licensing Appeal
Board Decision in the Matter of Metropolitan Edison Company, et al.
(Three Mile Island Nuclear Station, Unit No. 1) dated May 26, 1983
(ALAB-729, 17 NRC 814 (1983)), the Appeal Board confirmed the
distinction between the use of the terms ``important to safety'' and
``safety-related'' during the litigation of the restart of the TMI-1
nuclear power plant.
After the TMI-2 accident evaluation, numerous NRC documents
addressed the distinction between the ``important to safety'' and
``safety-related'' classifications of SSCs at nuclear power plants. For
example, the NRC documented its position on the meaning of ``important
to safety'' in a staff memorandum dated November 20, 1981, from Harold
R. Denton, Director, Office of Nuclear Reactor Regulation (NRR), to all
NRR personnel. This memorandum specifies the proper use of ``important
to safety'' and ``safety-related'' by the NRC staff. Specifically, the
1981 Denton memorandum states that `` `important to safety' encompasses
the broad class of plant features, covered (not necessarily explicitly)
in the General Design Criteria, that contribute in [an] important way
to safe operation and protection of the public in all phases and
aspects of facility operation (i.e., normal operation and transient
control as well as accident mitigation).'' The 1981 Denton memorandum
further states that ``important to safety'' includes ``safety-related''
as a subset. Subsequently, in December 1983, Harold R. Denton wrote a
letter to the Utility Safety Classification Group restating the
position taken in the 1981 memorandum and explaining the historical
acceptance of the distinction between these terms. The 1983 Denton
letter also stated that ``NRC regulatory
[[Page 11988]]
jurisdiction involving a safety matter is not controlled by the use of
terms such as `safety related' or `important to safety.' '' Generic
Letter 84-01 reiterated this distinction in terminology to nuclear
power plant applicants and licensees and included the 1983 Denton
letter as an enclosure.
Relatedly, in NUREG-0660, Volume 1, ``NRC Action Plan Developed as
a Result of the TMI-2 Accident,'' dated May 1980, the NRC staff
proposed numerous TMI-2 Action Plan items to provide assurance of
nuclear power plant safety, including Item I.F, ``Quality Assurance,''
to improve the quality assurance (QA) program for design, construction,
and operations to provide greater assurance that plant design,
construction, and operational activities are conducted in a manner
commensurate with their importance to safety. In Item I.F.1, ``Expand
QA list,'' the NRC staff proposed the development of guidance for
licensees to expand their QA lists to cover equipment ``important to
safety'' and rank the equipment in order of its importance to safety.
NUREG-0737, ``Clarification of TMI Action Plan Requirements,'' dated
November 1980, provided the list of TMI-2 Action Plan items that were
subsequently approved by the Commission for implementation (which did
not include Item I.F.1). As noted in NUREG-0933, ``Resolution of
Generic Safety Issues,'' Section 1, ``TMI Action Plan Items,'' Item
I.F.1 was considered resolved, with any further guidance to be
addressed through the normal processes. Therefore, the list and ranking
of ``important to safety'' equipment proposed in Item I.F.1 was not
created because the NRC determined it was not needed at the time.
In Memorandum and Order (CLI-84-9), ``In the Matter of Long Island
Lighting Company (Shoreham Nuclear Power Station, Unit 1),'' June 5,
1984, the Commission recognized that ``the history of the use of the
terms `important to safety' and `safety-related' is tortuous and
somewhat inconsistent.'' The Commission directed the NRC staff to
proceed with rulemaking on the use of the terms ``important to safety''
and ``safety-related.'' In SECY-85-119, ``Issuance of Proposed Rule on
the Important to Safety Issue,'' dated April 5, 1985, the NRC staff
provided to the Commission a proposed rule to define ``important to
safety'' for SSCs at nuclear power plants. In the staff requirements
memorandum (SRM) for SECY-85-119, ``Issuance of Proposed Rule on the
Important-to-Safety Issue,'' dated December 31, 1985, the Commission
disapproved SECY-85-119 and provided direction to NRC staff for
redrafting a proposed definition of ``important to safety.'' In SECY-
86-164, ``Proposed Rule on the Important to Safety Issue,'' dated May
29, 1986, the NRC staff provided a revised version of a proposed
definition of ``important to safety'' for Commission consideration, and
also reviewed the existing use of this term in the NRC's regulations.
By June 1987, three of four Commissioners voted 2-1 to disapprove the
proposed rule, but no further action was taken. As documented in a
memorandum dated June 24, 1991, from Samuel J. Chilk, SECY closed SECY-
86-164 on the basis that informal discussions between the staff in the
NRC Office of the Executive Director for Operations (OEDO) and Office
of the Secretary indicated that there may no longer be any need for the
Commission to address the issues in SECY-18-164. Since that time, the
NRC staff has not engaged in further rulemaking action to define
``important to safety.''
Use of ``Important to Safety'' in NRC Regulations
The term ``important to safety'' first appeared in appendix A to 10
CFR part 50, published as a final rule in the Federal Register on
February 20, 1971 (36 FR 03255). However, when appendix A and appendix
B, ``Quality Assurance Criteria for Nuclear Power Plants and Fuel
Reprocessing Plants,'' to 10 CFR part 50 were developed in the late
1960s and early 1970s, the NRC focused its regulatory activities on a
deterministic approach for safety-related SSCs, and allowed licensees
to address much of the design and treatment of other SSCs in licensee
documents. For example, final safety analysis reports (FSARs) for
nuclear power plants typically have described some SSCs that are
``important to safety'' but are not classified as ``safety-related''
and that have a reduced amount of NRC regulatory treatment compared
with ``safety-related'' SSCs. Over time, the NRC developed regulations
that address SSCs beyond those classified as ``safety-related.'' For
example, the NRC specifies requirements for a wide range of SSCs,
including SSCs that are important to safety but not classified as
``safety-related,'' in Sec. 50.49, ``Environmental qualification of
electric equipment important to safety for nuclear power plants'';
Sec. 50.62, ``Requirements for reduction of risk from anticipated
transients without scram (ATWS) events for light-water-cooled nuclear
power plants''; Sec. 50.63, ``Loss of all alternating current power'';
and Sec. 50.65, ``Requirements for monitoring the effectiveness of
maintenance at nuclear power plants.''
In addition, the term ``important to safety'' appears in several
reactor fire protection regulations. The NRC regulations in Sec.
50.48, ``Fire protection,'' require that each operating nuclear power
plant have a fire protection plan that satisfies General Design
Criterion (GDC) 3, ``Fire protection,'' of appendix A to 10 CFR part
50. GDC 3 requires that SSCs that are ``important to safety'' be
designed and located to minimize, consistent with other safety
requirements, the probability and effect of fires and explosions.
Section II.A of appendix R, ``Fire Protection Program for Nuclear Power
Facilities Operating Prior to January 1, 1979,'' to 10 CFR part 50 in
states that the fire protection program shall extend the concept of
defense-in-depth to fire protection in fire areas that are ``important
to safety,'' with the objectives of dealing with prevention, detection,
and protection.
For conformance with fire protection requirements, Sec. 50.48(c)
permits operating plants to voluntarily transition their deterministic
fire protection program to one based on risk-informed and performance-
based requirements using National Fire Protection Association Standard
(NFPA) 805, ``Performance-Based Standard for Fire Protection for Light
Water Reactor Electric Generating Plants,'' 2001 Edition. Section
50.48(c) also establishes an alternative regulatory structure for fire
protection and permits licensees to voluntarily adopt NFPA 805, which
would allow licensees the option to use a risk-informed, performance-
based approach to change the deterministic fire protection
configurations and procedures of their operating reactors. Licensees
adopting a risk informed approach for conformance with fire protection
programs did not change the safety classification of their equipment--
rather, they maintained fire protection areas that are considered
``important to safety'' under a deterministic approach within the scope
of the program. Almost all nuclear power plants that transitioned to
the Sec. 50.48(c) regulatory structure performed plant modifications
that resulted in a decrease in the plant core damage frequency. If the
modifications required installation of non-safety-related equipment,
the additional modifications were considered ``important to safety,''
as the equipment was required to safely shutdown the plant following a
fire event but not required to mitigate the consequences of an
accident.
More recently, the NRC regulations in Sec. 50.69, ``Risk-informed
categorization and treatment of structures, systems and components for
nuclear power
[[Page 11989]]
reactors,'' allow nuclear power plant licensees to request, in a
license amendment, the implementation of risk-informed categorization
and treatment of SSCs at their nuclear power plants. The scope of Sec.
50.69 extends beyond safety-related SSCs and addresses the wider range
of SSCs, i.e., SSCs that would be considered ``important to safety'' at
the specific nuclear power plant. Further, the NRC requires in Sec.
50.55a(b)(3)(iii)(D) that certain licensees assess the operational
readiness of pumps, valves, and dynamic restraints within the scope of
the Regulatory Treatment of Non-Safety Systems (RTNSS) that are not
classified as safety-related, but provide defense-in-depth for new
reactors with passive cooling systems (such as the AP1000 reactor
design) (see 82 FR 32934; July 18, 2017). The RTNSS components in new
reactors with passive cooling systems would be considered ``important
to safety'' at those specific nuclear power plants.
In sum, these issues provide additional examples of the consistent
understanding and treatment of ``important to safety'' in the existing
regulatory framework, and illustrate how licensees and applicants may
identify the safety characterization of SSCs in their documentation
without a set of prescriptive criteria for determining which SSCs are
important to safety. As illustrated in the previous discussion, the NRC
has over time addressed SSCs classified as ``important to safety'' in
different ways in its requirements, and in doing so, has established a
framework that uses this safety classification terminology without the
need for a prescriptive definition in Sec. 50.2.
Basis for Denial
Based on many years of experience with the current safety
classification terminology, nuclear power plant applicants and
licensees under 10 CFR part 50 and part 52 have an established
understanding of the importance to safety for all SSCs in nuclear power
plants as documented in their specific licensing basis documentation
(e.g., Final Safety Analysis Reports or Design Control Documents). In
addition, the NRC and licensees have a common understanding of the
foundation of what constitutes ``important to safety'' as demonstrated
in the guidance documents and generic communications discussed
previously (e.g., the 1981 memorandum from Harold R. Denton to the NRR
staff, 1983 letter from Harold R. Denton to the Utility Safety
Classification Group, and Generic Letter 84-01). Moreover, the NRC
reviews safety classification information in applications on a case-by-
case basis. The petitioner has not provided, and NRC staff has not
identified, a safety reason to create criteria, either prescriptive or
performance based, defining ``important to safety'' in Sec. 50.2.
As a result, a rulemaking effort to add a definition for
``important to safety'' for SSCs and their functions in Sec. 50.2 does
not have a safety benefit for nuclear power plants under 10 CFR parts
50 and 52. Further, the NRC's current regulatory framework is supported
by the well-established understanding and application of terminology
such as ``important to safety,'' as documented in regulatory guidance,
policy, and licensee and applicant documentation.
IV. Availability of Documents
The documents identified in the following table are available to
interested persons through one or more of the following methods, as
indicated.
----------------------------------------------------------------------------------------------------------------
Document ADAMS accession No./Federal Register citation
----------------------------------------------------------------------------------------------------------------
Generic Letter 1984-01, ``NRC Use of the Terms, ML031150515.
`Important to Safety' and Safety Related','' dated
January 5, 1984.
Letter dated December 19, 1983, from Harold R. Denton, ML17150A235.
Director, Office of Nuclear Reactor Regulation, to
T.S. Ellis, III, Esq., on behalf of the Utility Safety
Classification Group.
NUREG-0660, Volume 1, ``NRC Action Plan Developed as a ML072470526.
Result of the TMI-2 Accident,'' dated May 1980.
NUREG-0737, ``Clarification of TMI Action Plan ML051400209.
Requirements,'' dated November 1980.
NUREG-0933, ``Resolution of Generic Safety Issues,'' https://www.nrc.gov/sr0933/.
Section 1, ``TMI Action Plan Items''.
Staff memorandum dated November 20, 1981, from Harold ML111230453.
R. Denton, Director, Office of Nuclear Reactor
Regulation, to all NRR Personnel.
SECY-85-119, ``Issuance of Proposed Rule on the ML15322A002.
Important-To-Safety Issue,'' dated April 5, 1985.
SRM-SECY-85-119, ``Issuance of Proposed Rule on the ML15322A003.
Important-To-Safety Issue,'' dated December 31, 1985.
SECY-86-164, ``Proposed Rule on the Important-To-Safety ML15322A005.
Issue,'' dated May 29, 1986.
Memo from the Secretary of the Commission dated June ML15322A006.
24, 1991, withdrawing the proposed rulemaking in SECY-
86-164.
Federal Register Notice: PRM-50-112, Determining Which ML15266A002.
Structures, Systems, Components and Functions are
Important to Safety, Petition for Rulemaking; Notice
of Docketing and Request for Comment.
PRM-50-112 Petition from Kurt Schaefer Determining ML15278A208.
Which Structures, Systems, Components and Functions
are Important to Safety.
PRM-50-112 Supplement to Petition from Kurt Schaefer ML15278A211.
Determining Which Structures, Systems, Components and
Functions are Important to Safety.
Memorandum and Order (CLI-84-9), ``In the Matter of ML20091K598.
Long Island Lighting Company (Shoreham Nuclear Power
Station, Unit 1),'' June 5, 1984.
Three Mile Island Nuclear Station, Unit No. 1) dated ML16357A784.
May 26, 1983 (ALAB-729, 17 NRC 814 (1983)).
National Fire Protection Association Standard (NFPA)- https://www.nfpa.org/.
805, ``Performance-Based Standard for Fire Protection
for Light Water Reactor Electric Generating Plants,''
2001 Edition.
Incorporation by Reference of American Society of 82 FR 32934.
Mechanical Engineers Codes and Code Cases (July 18,
2017).
NRC Responses to Public Comments for PRM-50-112........ ML21123A223.
----------------------------------------------------------------------------------------------------------------
The NRC may post materials related to this document, including
public comments, on the Federal rulemaking website at https://www.regulations.gov under Docket ID NRC-2015-0213.
V. Conclusion
For the reasons cited in this document, the NRC is denying PRM-50-
112. The petition did not present
[[Page 11990]]
any significant new information or arguments that would warrant the
requested amendment. Current requirements continue to provide
reasonable assurance of adequate protection of public health and
safety, promote the common defense and security, and protect the
environment.
Dated: February 22, 2022.
For the Nuclear Regulatory Commission.
Annette L. Vietti-Cook,
Secretary of the Commission.
[FR Doc. 2022-04052 Filed 3-2-22; 8:45 am]
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