[Federal Register Volume 90, Number 156 (Friday, August 15, 2025)]
[Rules and Regulations]
[Pages 39308-39312]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-15565]


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NUCLEAR REGULATORY COMMISSION

10 CFR Part 72

[NRC-2025-0064]


Interim Enforcement Policy for Enforcement Discretion for General 
Licensee Adoption of Certificate of Compliance Holder-Generated Changes

AGENCY: Nuclear Regulatory Commission.

ACTION: Policy statement; issuance.

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SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is issuing an 
Interim Enforcement Policy (IEP) titled, ``Enforcement Discretion for 
General Licensee Adoption of CoC Holder-Generated Changes.'' This IEP 
allows enforcement discretion for certain general licensee violations 
related to their adoption of a change generated by the Certificate of 
Compliance holder.

DATES: The policy statement is effective on August 15, 2025.

ADDRESSES: Please refer to Docket ID NRC-2025-0064 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-2025-0064. Address 
questions about NRC dockets to Helen Chang; telephone: 301-415-3228; 
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

[[Page 39309]]

this document are provided in the ``Availability of Documents'' 
section.
     NRC's PDR: The PDR, where you may examine and order copies 
of publicly available documents, is open by appointment. 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 
a.m. and 4 p.m. ET, Monday through Friday, except Federal holidays.

FOR FURTHER INFORMATION CONTACT: Gerond A. George, Office of Nuclear 
Material Safety and Safeguards, telephone: 301-415-3882, email: 
[email protected], U.S. Nuclear Regulatory Commission, Washington, 
DC 20555-0001.

SUPPLEMENTARY INFORMATION:

I. Background

    The Certificate of Compliance (CoC or certificate) is the NRC 
approved design for each dry cask storage system. Title 10 of the Code 
of Federal Regulations (10 CFR) 72.48, ``Changes, tests, and 
experiments,'' establishes the conditions under which a general or 
specific licensee, and a spent fuel storage cask certificate holder may 
make changes to their independent spent fuel storage installation 
(ISFSI) or monitored retrievable storage installation facility (MRS), 
spent fuel storage cask design, or procedures, and under which they may 
conduct tests or experiments, without prior NRC approval. In addition 
to the 10 CFR 72.48 change review process, paragraph (b)(7) of 10 CFR 
72.212, ``Conditions of general license issued under 10 CFR 72.210,'' 
also requires the general licensee to evaluate any changes to written 
evaluations required by paragraphs (b)(5) and (6) of 10 CFR 72.212, 
using the requirements of 10 CFR 72.48(c). Moreover, there are various 
provisions in 10 CFR 72.212, such as paragraphs (a)(2), (b)(3), 
(b)(5)(i), and (b)(11), that require general licensees to ensure they 
use casks that conform to the terms, conditions and specifications of a 
CoC listed in 10 CFR 72.214, ``List of approved spent fuel storage 
casks.''
    Therefore, if a general licensee wishes to adopt a change initiated 
by the CoC holder under the CoC holder's 10 CFR 72.48 change authority, 
the general licensee must perform a separate 10 CFR 72.48 review as 
required by the regulations. Additionally, if a general licensee adopts 
a CoC holder's change made under 10 CFR 72.48 and that change is later 
determined to be noncompliant, the general licensee would also be in 
noncompliance with provisions of 10 CFR 72.48 and 10 CFR 72.212.
    The NRC is implementing a more efficient process in which the staff 
addresses CoC holders' apparent violations of the 10 CFR 72.48 change 
control process without pursuing an enforcement action against the 
general licensee for an apparent violation that is strictly due to the 
general licensee's adoption of a noncompliant change made under Sec.  
72.48 by the CoC holder. The NRC is also implementing a more efficient 
process for general licensees to review and adopt changes made by a CoC 
holder, pursuant to the CoC holder's Sec.  72.48 change authority, as 
long as the general licensee does not need to make any site-specific 
technical changes. Accordingly, the staff is considering rulemaking, 
including potential interpretation of the applicable regulations, and 
revision of the implementation guidance.

II. Discussion

A. Rulemaking

    The NRC published a final rule on October 4, 1999 (64 FR 53582) 
that revised 10 CFR 72.48 to clarify the specific types of changes, 
tests, and experiments conducted at a licensed facility or by a 
certificate holder that require evaluation, and revised the criteria 
that licensees and certificate holders must use to determine when NRC 
approval is needed before such changes, tests, or experiments can be 
implemented. The Commission approved the publication of the final rule 
in SECY-99-130, ``Final Rule--Revisions to Requirements of 10 CFR parts 
50 and 72 Concerning Changes, Tests, and Experiments.''
    The preamble to the final rule for 10 CFR 50.59 and 10 CFR 72.48 
stated the following in Section O.1, ``Part 72 Changes,'' provided on 
page 53601: ``The Commission envisioned that a general licensee who 
wants to adopt a change to the design of a spent fuel storage cask it 
possesses--which change was previously made to the generic design by 
the certificate holder under the provisions of Sec.  72.48--would be 
required to perform a separate evaluation under the provisions of Sec.  
72.48 to determine the suitability of the change for itself.'' As 
indicated by the rule and supported by the preamble, both the CoC 
holder and general licensee are required to perform an evaluation when 
implementing a change made by a CoC holder pursuant to Sec.  72.48.
    The NRC staff may request that the Commission revise its 
regulations or interpretation of existing regulations to establish that 
CoC holders and general licensees have different obligations. The NRC 
staff may seek this change because both entities have separate quality 
assurance programs, and the NRC staff performs inspections of each 
change control process on a regular basis, which would provide 
reasonable assurance of safety and increase regulatory efficiency. 
Specifically, the efficiency will be realized by streamlining the 
inspections associated with the evaluation of the changes to focus (1) 
on CoC holders and (2) on general licensees only to the extent the 
general licensees make site-specific, technical changes.

B. Summary

    This IEP allows staff to exercise enforcement discretion for 
certain general licensee violations of 10 CFR 72.48 and 10 CFR 72.212 
related to the general licensee's adoption of a CoC holder-generated 
modification. This IEP also allows for better efficiency and 
reliability of spent fuel storage cask inspection oversight, while 
still providing adequate protection of public health and safety. The 
NRC is issuing this IEP due to the NRC's operational experience with 
its inspection and oversight of general licensees' adoption of CoC 
holders' Sec.  72.48 changes. Certificate holders are NRC-regulated 
entities that are required to (1) ensure their storage casks meet NRC 
requirements and the Certificate of Compliance and (2) perform design 
changes in accordance with Sec.  72.48; the NRC inspects their 
processes. In addition, the NRC recognizes that a general licensee who 
wants to adopt a change to the design of a spent fuel storage cask it 
possesses--where the change was previously made by the certificate 
holder under the provisions of Sec.  72.48--must perform a review of 
that change for their site under a variety of other processes other 
than Sec.  72.48, including those set forth in paragraphs (b)(5) and 
(6) of Sec.  72.212, and in the general licensee quality assurance 
program. The combination of these review and oversight processes, 
together with other existing inspection and oversight processes, 
provide confidence that the general licensee has appropriately 
considered changes made by CoC holders and appropriately evaluated the 
potential safety implications of implementing those

[[Page 39310]]

changes at its site. For these reasons, the NRC determined that this 
IEP continues to provide adequate protection of public health and 
safety while enabling the safe and secure use of civilian nuclear 
energy technologies. This approach also aligns with the NRC's mission 
statement and the Principles of Good Regulation.
    Following issuance of the IEP, the NRC will explore a rulemaking 
solution to eliminate the requirement that a GL must always perform a 
10 CFR part 72.48 evaluation when adopting CoC holder-generated 
changes. The NRC plans to review the regulations in 10 CFR part 72 and 
guidance documents to determine whether rulemaking, including potential 
interpretation of the applicable regulations, and/or revising guidance 
is needed to clarify the requirements in 10 CFR part 72.

III. Summary of Public Comments on Draft Interim Enforcement Policy

    The NRC published a draft version of the IEP in the Federal 
Register on April 7, 2025 (90 FR 14917). The public comment period 
closed on April 28, 2025. The NRC received public comment submissions 
from the Nuclear Energy Institute (NEI) and the Decommissioning Plant 
Coalition (DPC). Both are generally supportive of prompt issuance of 
the IEP. The NEI provided four comments (identified as comments 1-1 
through 1-4). The DPC provided three comments (identified as comments 
2-1 through 2-3). These comments are summarized in the following 
paragraphs, including the NRC's resolution of the comments, and a 
summary of how the NRC revised the IEP, as applicable.
    In comment 1-1, the NEI commented that the IEP reaches the correct 
conclusion about how 10 CFR 72.48 should be applied to general 
licensees. The NEI agreed with the position articulated with the IEP's 
method of addressing apparent violations of the 10 CFR 72.48 change 
control process by a CoC holder, without pursuing separate enforcement 
actions against general licensees for alleged violations of Sec.  72.48 
that are due to the general licensee's adoption of a noncompliant 
change made by the CoC holder.
    The NRC agrees with comment 1-1. The NRC did not make any changes 
to the final IEP based on this comment.
    In comment 1-2, the NEI commented that the approach for applying 
Sec.  72.48 to general licensees described in the IEP is not new. As 
the NEI explained in its comments on EGM 25-001, the NEI stated that 
the position reflected in the IEP is the approach that has been 
endorsed by the NRC, also reflected in the relevant NRC inspection 
procedure, and consistently followed by the industry for the past 24 
years. The NEI added that the IEP takes the position that the approach 
prescribed in NEI 12-04 and Appendix B to NEI 96-07 for adoption of CoC 
holder changes by general licensees--and which the NRC ``seeks to 
implement'' under the IEP--is inconsistent with the requirements of 
Sec.  72.48. Thus, the NEI concludes that the draft IEP seems to reach 
the conclusion that the NRC has endorsed a method of compliance for 
nearly two-and-a-half decades that, in fact, violates Sec.  72.48.
    The NRC disagrees with comment 1-2 that the NRC endorsed a method 
of compliance that violates Sec.  72.48. The NRC continues to endorse 
the industry guidance for implementing Sec.  72.48 as provided in the 
NRC's Guidance for Implementation of 10 CFR 72.48, ``Changes, Tests, 
and Experiments,'' Regulatory Guide 3.72, Revision 1, and the NRC 
continues to inspect in accordance with that endorsement. The NRC 
disagrees that the endorsed guidance (or NRC's implementation of it) 
removed general licensees' responsibility under Sec.  72.48 for 
noncompliances that are due to the adoption of a noncompliant change 
made by the CoC holder. The NRC did not make any changes to the final 
IEP based on this comment.
    In comment 1-3, the NEI commented that it endorsed continued 
adherence to the approach provided in NEI 12-04, and that the position 
in the IEP does not compel changes to Sec.  72.48. The NEI added that 
the interpretation of the general licensee's responsibilities in this 
situation provided in NEI 12-04 and endorsed by the NRC in Regulatory 
Guide 3.72 is a reasonable interpretation of the text of Sec.  72.48 
and is consistent with the overall general licensing framework 
established in 10 CFR part 72. Further, the NEI added that the IEP 
points to language in the preamble of the 1999 final rule promulgating 
10 CFR 72.48 to support its interpretation, but, according to the NEI, 
the Commission did not articulate what the ``separate evaluation'' a 
general licensee was to use to ``determine the suitability of the [CoC 
holder's] change for itself'' should entail. The NEI further commented 
that the NRC endorsed Appendix B to NEI 96-07 in Regulatory Guide 3.72, 
which appropriately provided the necessary clarity on this issue, 
incorporating a rational approach that a general licensee's review of 
changes incorporated by a CoC holder focused on the site-specific 
impacts of such changes.
    The NRC disagrees in part with comment 1-3. As noted above, the NRC 
continues to endorse the industry guidance for implementing Sec.  72.48 
as provided in Regulatory Guide 3.72, Revision 1. NRC agrees with the 
NEI about the regulatory benefit of focusing a general licensee's 
review of changes incorporated by a CoC holder on the site-specific 
impacts of such changes; the NRC is pursuing the IEP in order to better 
facilitate that approach. However, NRC disagrees that the endorsed 
guidance and regulatory history supports the NEI's interpretation of 
the current regulatory requirement. Nevertheless, the NEI's description 
of the existing guidance highlights an opportunity for additional 
clarity in this IEP. Therefore, the NRC updated paragraphs (4) and (5) 
of the IEP to further clarify the general licensees' responsibilities 
for complying with 10 CFR 72.212 (b)(5), (b)(6), and (b)(7), when 
either initiating a change or adopting a CoC-holder change that leads 
to a site-specific, technical change.
    In comment 1-4, the NEI commented that the NRC's subsequent 
endorsement of NEI 12-04 specifically addressed consistency with the 
preamble of the 1999 final rule. The comment further asserts that the 
NRC consistently interpreted the 10 CFR 72.48 regulation as allowing 
the approach suggested as the desired resolution path in the IEP.
    The NRC partially agrees with comment 1-4 that the NRC's 
endorsement of NEI 12-04 addressed consistency with the preamble of the 
1999 final rule. However, as noted above, the NRC disagrees that the 
endorsement of industry guidance removed general licensees' 
responsibility for noncompliances that are due to the adoption of a 
noncompliant change made by the CoC holder. This is the subject of the 
IEP. The NRC did not make any changes to the IEP based on this comment.
    In comment 2-1, the DPC commented that it is imperative the staff 
perform a specific review of the regulation that led to the use of this 
policy and any subsequent enforcement policies at ISFSIs under 
Commission direction and produce a plan to change regulations governing 
issues that have such negligible safety significance that led to its 
use. The DPC further commented that this direction/commitment should be 
included in the final IEP.

[[Page 39311]]

    The NRC disagrees with comment 2-1 with respect to including a 
commitment to explore rulemaking in the IEP, as the IEP is not the 
appropriate document to reach a conclusion on pursuing rulemaking. The 
NRC did not make any changes to the IEP based on this comment.
    In comment 2-2, the DPC believes the NRC staff is communicating 
that there needs to be a change to the current method of making 
licensee changes to certificates of compliance and ISFSI operations. 
The DPC recommended changing ISFSI regulations to mirror 10 CFR 50.59.
    The NRC determined that comment 2-2 was outside the scope of the 
IEP. The IEP establishes an enforcement policy concerning general 
licensees' adoption of noncompliant changes made by CoC holders under 
Sec.  72.48. A broader regulatory review of 10 CFR part 72 is beyond 
the scope of this IEP. The NRC did not make any changes to the IEP 
based on this comment.
    In comment 2-3, the DPC commented that the underlying violations 
that will be given discretion have minimal safety significance, and 
suggested this may be a new interpretation of regulations and endorsed 
industry guidance.
    The NRC disagrees with comment 2-3. The NRC has not changed its 
interpretation of the regulations or the endorsed industry guidance. 
The IEP provides for an efficient approach for dispositioning a 
specific set of noncompliant changes made under Sec.  72.48. The NRC 
expects CoC holders and GLs to maintain current Sec.  72.48 processes 
and quality assurance programs to correct nonconformances. The NRC did 
not make any changes to the IEP based on this comment.

IV. Clarifications Made to the Final Interim Enforcement Policy

    After the NRC published the aforementioned draft version of the IEP 
in the Federal Register, because of public comments, it recognized that 
the IEP needed more clarity for the responsibilities of general 
licensees when initiating changes or when adopting CoC holder changes 
made under 10 CFR 72.48 that lead to a site-specific, technical change. 
The NRC updated paragraphs (4) and (5) of the IEP to further clarify 
the general licensees' responsibilities for compliance with 10 CFR 
72.212 (b)(5), (b)(6), and (b)(7), when either initiating a change or 
adopting a CoC holder change that leads to a site-specific, technical 
change.

V. Paperwork Reduction Act

    This policy statement does not contain any new or amended 
collections of information subject to the Paperwork Reduction Act of 
1995 (44 U.S.C. 3501 et seq.). Existing collections of information were 
approved by the Office of Management and Budget (OMB), approval numbers 
3150-0132 and 3150-0136.

Public Protection Notification

    The NRC may not conduct or sponsor, and a person is not required to 
respond to, a collection of information unless the document requesting 
or requiring the collection displays a currently valid OMB control 
number.

VI. Regulatory Planning and Review

    Executive Order (E.O.) 12866, as amended by E.O 14215, provides 
that the Office of Information and Regulatory Affairs (OIRA) will 
determine whether a regulatory action is significant as defined by E.O. 
12866 and will review significant regulatory actions. OIRA has 
determined that this action is not a significant regulatory under E.O. 
12866.

VII. Congressional Review Act

    This final rule is a rule as defined in the Congressional Review 
Act (5 U.S.C. 801-808). However, the Office of Management and Budget 
has not found it to be a major rule as defined in the Congressional 
Review Act.

VIII. Availability of Documents

    The documents identified in the following table are available to 
interested persons as indicated.

------------------------------------------------------------------------
                                                 ADAMS Accession No./
                  Document                     Federal Register citation
------------------------------------------------------------------------
Final Rule: ``Changes, Tests, and             64 FR 53582
 Experiments,'' October 4, 1999.
SECY-99-130, ``Revisions to Requirements of   ML992810140
 10 CFR Parts 50 and 72 Concerning Changes,
 Tests, and Experiments,'' May 12, 1999.
Staff Requirements Affirmation Session, June  ML003751724
 22, 1999.
NEI 12-04, ``Guidelines for 10 CFR 72.48      ML18250A255
 Implementation,'' Revision 2, September
 2018.
NEI 96-07, Appendix B, ``Guidelines for 10    ML010670023
 CFR 72.48 Implementation,'' March 5, 2001.
Regulatory Guide 3.72, ``Guidance for         ML20220A185
 Implementation of 10 CFR 72.48, Changes,
 Tests, and Experiments,'' Revision 1,
 September 2020.
Enforcement Guidance Memorandum (EGM) 25-     ML24303A436
 001, ``Enforcement Guidance for
 Dispositioning Noncompliances Related to a
 General Licensee's Use of Certain Non-
 qualified Spent Fuel Casks,'' February 11,
 2025.
NRC Enforcement Policy, August 12, 2025.....  ML25224A097
Principles of Good Regulation, April 6, 1990  ML15083A026
Proposed Interim Enforcement Policy for       90 FR 14917
 Comment, April 7, 2025.
Public Comment Submission #1, Rodney          ML25118A058
 McCullum on behalf of Nuclear Energy
 Institute, April 25, 2025.
Public Comment Submission #2, Wayne A.        ML25122A203
 Norton on behalf of Decommissioning Plant
 Coalition on PR-72, April 29, 2025.
------------------------------------------------------------------------

    The text of the Interim Enforcement Policy is attached.

    Dated: August 13, 2025.

    For the Nuclear Regulatory Commission.
Carrie Safford,
Secretary of the Commission.

[[Page 39312]]

Attachment--Interim Enforcement Policy--Section 9.4, Enforcement 
Discretion for General Licensee Adoption of CoC Holder-Generated 
Changes Under 10 CFR 72.48

Interim Enforcement Policy--Section 9.4, Enforcement Discretion for 
General Licensee Adoption of CoC Holder-Generated Changes Under 10 CFR 
72.48

9.4 Enforcement Discretion for General Licensee Adoption of 
Certificate of Compliance Holder-Generated Changes Under 10 CFR 
72.48

    This section sets forth the Interim Enforcement Policy (IEP) 
that the NRC will use to exercise discretion for the disposition of 
violations involving a General Licensee's (GL's) adoption of a 
Certificate of Compliance (CoC) holder-generated change made under 
the CoC holder's change authority of Section 72.48 of title 10 of 
the Code of Federal Regulations (10 CFR), ``Changes, tests, and 
experiments.'' The current NRC regulations state:
     10 CFR 72.212, ``Conditions of general license issued 
under 10 CFR 72.210,'' in a number of regulatory provisions, such as 
72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), and 72.212(b)(11), 
requires a GL to ensure it uses casks that conform to the terms, 
conditions and specifications of a CoC listed in 10 CFR 72.214, 
``List of approved spent fuel storage casks.''
     10 CFR 72.212(b)(5) requires that the GL, before use 
and before applying changes authorized by an amended CoC to a cask 
loaded under the initial CoC or an earlier amended CoC, perform 
written evaluations to establish that the storage cask, once loaded, 
will conform to terms and conditions of the CoC.
     10 CFR 72.212(b)(6) requires that the GL review, and 
document the review of, the Safety Analysis Report referenced in the 
CoC or amended CoC and the related NRC Safety Evaluation Report, to 
determine whether or not the reactor site parameters are enveloped 
by the cask design bases considered in these reports.
     10 CFR 72.212(b)(7) requires the GL to evaluate any 
changes to written evaluations required by paragraphs (b)(5) and (6) 
of 10 CFR 72.212, using the requirements of 10 CFR 72.48(c).
     10 CFR 72.48, as published on October 4, 1999 (64 FR 
53582) and amended on February 26, 2001 (66 FR 11527), has 
provisions under which general and specific licensees and CoC 
holders may make changes to the facility or spent fuel storage cask 
design as described in the Final Safety Analysis Report without 
obtaining NRC review and approval. Change means a modification or 
addition to, or removal from, the facility or spent fuel storage 
cask design or procedures that affects a design function, method of 
performing or controlling the function, or an evaluation that 
demonstrates that intended functions will be accomplished.
    Under the current NRC regulations, if a GL chooses to adopt a 
change the CoC holder made pursuant to a CoC holder's change 
authority under 10 CFR 72.48 (referred to herein as a ``CoC holder-
generated change''), a GL must perform a separate review using the 
requirements of 10 CFR 72.48(c). This is in addition to the 
requirement that the GL evaluate any additional resulting site-
specific, technical changes the GL makes to written evaluations 
required by paragraphs (b)(5) and (6) of 10 CFR 72.212 using the 
requirements of 10 CFR 72.48(c), when adopting the CoC holder's 
change. Further, the GL is required, by various provisions of 10 CFR 
72.212, to only use casks that conform to the terms, conditions and 
specifications of a CoC listed in 10 CFR 72.214.
    Accordingly, when a GL chooses to adopt a CoC holder-generated 
change, and that change results in a non-conforming cask, there is a 
violation of 10 CFR 72.48 and certain provisions of 10 CFR 72.212 by 
the GL, in addition to a CoC holder violation of 10 CFR 72.48. And, 
when a GL chooses to adopt a CoC holder-generated change without 
performing a separate 10 CFR 72.48 analysis, the GL is in violation 
of 10 CFR 72.48.
    Absent this IEP, these requirements could lead to enforcement 
actions being issued against both the GL's 10 CFR 72.48 program (as 
well as certain 10 CFR 72.212 violations) and CoC holder's 10 CFR 
72.48 program for changes that originated with the CoC holder. The 
NRC has concluded that this enforcement approach would be 
inconsistent with efficiency, which is one of the NRC's Principles 
of Good Regulation, and NRC's mission of efficient and reliable 
oversight.
    The NRC staff will review the regulations in 10 CFR part 72, 
``Licensing Requirements for the Independent Storage of Spent 
Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related 
Greater Than Class C Waste,'' and guidance documents to determine 
what changes are needed to focus requirements on the entity that 
initiated the change. Until such time as regulatory changes are 
developed, the Interim Enforcement Policy will be:
    (1) The NRC will exercise enforcement discretion and not issue 
an enforcement action to a GL, for a noncompliance with the 
requirements of paragraphs (c)(1) and (2) and (d)(1) of 10 CFR 72.48 
and with provisions of 10 CFR 72.212 that require GLs to ensure use 
of casks that conform to the terms, conditions and specifications of 
a CoC listed in 10 CFR 72.214, when the noncompliance results from a 
CoC holder's failure to comply with 10 CFR 72.48 for a CoC holder-
generated change. In granting this discretion, the GL will be 
expected to come into compliance with the 10 CFR 72.212 provisions 
that require each cask to conform to the terms, conditions, and 
specifications of a CoC or an amended CoC listed in Sec.  72.214 
using established processes after NRC disposition of the 
noncompliance for a CoC holder-generated change. The NRC staff will 
monitor the GL's actions to determine if additional regulatory 
actions will be necessary.
    (2) The NRC will exercise enforcement discretion and not issue 
an enforcement action to the GL for failure to perform a 10 CFR 
72.48 screening and/or evaluation when the GL adopts a CoC holder-
generated change. Enforcement discretion does not apply to CoC 
holder-generated changes that result in the GL making a change to 
the site-specific, technical aspects of the GL's 10 CFR 72.212 
report.
    (3) When the GL adopts a CoC holder-generated change and the 
accompanying 10 CFR 72.48 screening and/or evaluation that was 
performed by the CoC holder, the GL does not have to perform a 
separate 10 CFR 72.48 evaluation of CoC holder-generated changes. 
The GL only needs to review the CoC holder's change for 
applicability to their spent fuel storage cask and for impact on the 
site-specific, technical evaluations and analyses described in the 
10 CFR 72.212 report, and site programs and procedures. The NRC's 
inspections of the GL and enforcement actions against the GL will 
focus on the GL's assessment for the site-specific applicability of 
the CoC holder-generated change to its spent fuel storage cask.
    (4) The GL is responsible for performing written evaluations to 
establish that the storage cask conforms to terms and conditions of 
the CoC, in accordance with paragraphs (b)(5) and (6) of 10 CFR 
72.212. If the GL chooses to adopt a CoC holder-generated change, 
the GL does not need to follow the requirements of 10 CFR 
72.212(b)(7) unless the GL determines that site-specific, technical 
changes are needed to the GL's written evaluations required by 
paragraphs (b)(5) and (b)(6) of 10 CFR 72.212. Additionally, the GL 
is responsible for ensuring compliance with applicable requirements 
of Appendix B to 10 CFR part 50, ``Quality Assurance Criteria for 
Nuclear Power Plants and Fuel Reprocessing Plants,'' and Subpart G 
to 10 CFR part 72, ``Quality Assurance''; and the GL is responsible 
for ensuring compliance with 10 CFR 72.48 when making GL-initiated 
changes.
    (5) NRC enforcement actions will focus on the entity that 
initiated the change. The CoC holder will be accountable for a 
noncompliance identified within CoC holder-generated 10 CFR 72.48 
screenings and/or evaluations of a change made pursuant to the CoC 
holder's 10 CFR 72.48 change authority. The GL will be accountable 
for any noncompliance identified either with GL-initiated changes 
made under 10 CFR 72.48 or with any site-specific, technical changes 
required by paragraphs (b)(5) and (b)(6) of 10 CFR 72.212.
    An enforcement panel is not required to disposition a 
noncompliance using this discretion; however, each time discretion 
is granted, an enforcement action number will be assigned to 
document the use of discretion under this IEP.
    This IEP will remain in place until the underlying regulatory 
issue is dispositioned through rulemaking or other regulatory 
action.

[FR Doc. 2025-15565 Filed 8-14-25; 8:45 am]
BILLING CODE 7590-01-P