Comments, presentations, PUBLICATIONs, WEBINARs
Rani Franovich and N. Prasad Kadambi, Formal Comment Letter (140) on Draft 10 CFR Part 53, “Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors,” [NRC–2019–0062] RIN 3150–AK31, February 28, 2025. https://www.regulations.gov/comment/NRC-2019-0062-0479, https://www.nrc.gov/docs/ML2506/ML25069A167.pdf
Rani Franovich, invited expert testimony and support letter to the Joint Minerals, Business & Economic Development Interim Committee, Wyoming Legislature, for Senate Bill 2025-SF0186 relating to environmental quality; establishing requirements and standards for the storage of nuclear fuel by advanced nuclear reactor manufacturers; providing definitions; making conforming amendments; requiring rulemaking; and providing for effective dates. Oral testimony delivered February 19, 2025. https://www.wyoleg.gov/Legislation/2025/SF0186
Rani Franovich, Formal Comment Letter (072) on NRC’s draft 10 CFR Part 53 rule and proposal: “Service Provider Licensing and Oversight: An Alternative Conceptual Strategy for Regulating Fleet-wide Small and Mobile Reactors,” February 6, 2025. https://www.regulations.gov/comment/NRC-2019-0062-0397, https://www.nrc.gov/docs/ML2503/ML25037A347.pdf
Rani Franovich, Response to NRC’s solicitation of comments on the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act (ADVANCE Act) of 2024, and proposal pursuant to Section 208, “Regulatory requirements for micro-reactors,” February 4, 2025. https://www.nrc.gov/docs/ML2504/ML25049A172.pdf, https://www.nrc.gov/docs/ML2504/ML25042A429.pdf
Rani Franovich, invited expert testimony and support letter to the Joint Minerals, Business & Economic Development Interim Committee, Wyoming Legislature, for Senate Bill 2025-SF0186 relating to environmental quality; establishing requirements and standards for the storage of nuclear fuel by advanced nuclear reactor manufacturers; providing definitions; making conforming amendments; requiring rulemaking; and providing for effective dates, January 31, 2025. https://www.wyoleg.gov/Legislation/2025/SF0186
Rani Franovich, invited expert testimony and support letter to the Joint Minerals, Business & Economic Development Interim Committee, Wyoming Legislature, for House Bill 2025-HB0016 relating to environmental quality; establishing requirements and standards for the storage of used nuclear fuel; amending siting requirements for used nuclear fuel storage facilities; providing definitions; making conforming amendments; repealing obsolete provisions; requiring rulemaking; and providing for effective dates, January 28, 2025. https://wyoleg.gov/Legislation/2025/HB0016
Rani Franovich, Panelist, “A New Start: Central Asia’s Nuclear Potential & Peril.” Webinar explores the safety, security, geopolitical, and geoeconomic implications of commercial nuclear power in Central Asia. Hosted by the International Tax and Investment Center’s Energy, Growth, and Security Program in cooperation with The National Bureau of Asian Research, December 12, 2024. https://www.linkedin.com/feed/update/urn:li:activity:7269400591389319168/
A New Start: Central Asia’s Nuclear Potential & Peril-20241212 1530-1 - Webex, Passcode: XiR2NM2G
Rani Franovich, Comment Letter re “U.S. Nuclear Regulatory Commission (NRC) Staff Options in SECY-24-0083 re Mission Alignment Provision of the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024,” December 6, 2024. https://www.nrc.gov/docs/ML2434/ML24344A271.pdf
Rani Franovich, “Mission: The NRC's North Star.” Blog examines options to update the NRC’s mission statement pursuant to the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024; contemplates them as a weather vane for regulatory modernization; and offers alternatives that better align with the spirit and intended outcomes of the Atomic Energy Act of 1954, the Energy Reorganization Act of 1974, and the ADVANCE Act of 2024. The Nuclear ROSE Blog, October 31, 2024. https://nuclearrosellc.com/the-nuclear-rose-blog/f/mission-the-nrcs-north-star
Rani Franovich, “Where is the PB in RIPB? The key to nuclear regulatory modernization that will enable innovation,” Blog explores how performance-based (PB) methods can modernize NRC’s licensing frameworks to enable innovation as intended by the Nuclear Energy Innovation and Modernization Act of 2019 (NEIMA) and the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024. The Nuclear ROSE Blog, October 4, 2024. https://nuclearrosellc.com/the-nuclear-rose-blog/f/where-is-the-pb-in-ripb
Rani Franovich, “My Nuclear Pitch to Virginia Tech,” Blog explains why Virginia Tech is perfectly situated and uniquely poised to expand its nuclear engineering program into a preeminent Department of Nuclear Engineering with research reactors at its Blacksburg and Northern Virginia campuses. The Nuclear ROSE Blog, June 12, 2024. https://nuclearrosellc.com/the-nuclear-rose-blog/f/my-nuclear-pitch-to-virginia-tech
Rani Franovich, “Inaugural Blog: What does "Critical Mass" mean?” Blog explores the concept of “critical mass” in nuclear physics to describe the minimum amount of a fissionable material that will support a self-sustaining chain reaction) and in social theory to explain socio-dynamic phenomena that drive actions and behaviors of large segments of the population. The Nuclear ROSE Blog, June 6, 2024. https://nuclearrosellc.com/the-nuclear-rose-blog/f/inaugural-blog-what-does-critical-mass-mean
Rani Franovich and N. Prasad Kadambi, “Where is the PB in RIPB? A Sharing of Perspectives... More Discussion than Presentation,” A Community of Practice webinar; Risk-informed, Performance-based Principles and Policy Committee (RP3C), American Nuclear Society, May 31, 2024. https://doi.org/10.21955/nuclscitechnolopenres.1115143.1
https://www.ans.org/news/article-6182/ripb-regulations-are-we-there-yet/
Rani Franovich, Comment Letter re "Environmental Assessment and Finding of No Significant Impact for the Construction Permits for the Kairos Hermes 2 Test Reactors,” Draft Report [Docket ID NRC-2023-0138], May 24, 2024. https://www.regulations.gov/comment/NRC-2023-0138-0009
Rani Franovich, Speaker, “The Time is Now: Nuclear Energy’s Past, Present, and Promise for the Future,” Nuclear Engineering Program Seminar, Department of Mechanical Engineering, Virginia Tech, March 22, 2024. https://me.vt.edu/news/briefs/rani-franovich-nuclear-seminar-032024.html
To view a recording of the seminar, request access here: https://drive.google.com/file/d/1htiQVeRV_dK-qCrqLsVdBxvzkwuRlc4n/view?ts=6603a0f0&exids=71471483,71471477
Rani Franovich, invited expert testimony and support letter to Senators of the Legislative Resolution (LR) 178 Special Committee, Nebraska Unicameral Legislature, re proposed Interim study to create a Select Committee to examine the feasibility of constructing and operating small modular nuclear reactors to generate electric power in Nebraska, October 26, 2023. https://nebraskalegislature.gov/FloorDocs/108/PDF/Intro/LR178.pdf
Rani Franovich, Speaker, “Legacy Implications of Today’s Regulatory Challenges,” Nebraska Advanced Nuclear Forum (NANF), Lincoln, NE, May 23, 2023. https://advancednuclearcoalition.org/wp-content/uploads/2023/04/2023-NANF-Comp-Agenda-04.24.pdf
Rani Franovich, Speaker, “Reflections on Advocacy, Public Outreach, and Public Education Campaigns,” NANF, Lincoln, NE, May 23, 2023. https://advancednuclearcoalition.org/wp-content/uploads/2023/04/2023-NANF-Comp-Agenda-04.24.pdf
Rani Franovich, Guest Lecturer on career path, advocacy, ethics and leadership: “The Journey From ISE Student to Public Servant and Advocate.” Course ISE 2004: Introduction to Industrial and Systems Engineering (ISE), Virginia Tech, April 21, 2023.
Rani Franovich, Guest Panelist offering career advice, discussing ethical situations, and sharing her perspectives on leadership. Course ISE 2004: Introduction to Industrial and Systems Engineering (ISE), Virginia Tech, April 7, 2023.
Rani Franovich, Speaker, “Putting the ‘Reasonable’ Back into ‘Reasonable Assurance of Adequate Protection,’” Regulatory Information Conference (RIC), U.S. Nuclear Regulatory Commission (NRC), March 16, 2023. https://nrc.rev.vbrick.com/#/videos/6a490216-6846-4e5a-8e39-0fd66e3c653a
Rani Franovich and Matthew Wald, “Advanced Nuclear is Good for the World, But Is It Good for the Regulator?” February 6, 2023. https://thebreakthrough.org/issues/energy/advanced-nuclear-is-good-for-the-world-but-is-it-good-for-the-regulator
Rani Franovich, Comment Letter re “Reporting Requirements for Nonemergency Events at Nuclear Power Plants” [Regulation Identifier Number RIN-3150-AK71; Docket ID NRC-2020-0036],” January 6, 2023. https://www.nrc.gov/docs/ML2301/ML23011A311.pdf
Rani Franovich, Spoken Comment re “Draft Environmental Impact Statement for the Construction Permit for the Kairos Hermes,” November 16, 2022. https://www.nrc.gov/docs/ML2232/ML22329A011.pdf, pp. 33-41
Rani Franovich. Spoken Comment to NRC’s Advisory Committee on Reactor Safeguards (ACRS) regarding the proposed rulemaking language for 10 CFR Part 53 and why it failed to provide a risk-informed, performance-based and technology-inclusive regulatory framework for commercial nuclear power plants as mandated by the Nuclear Energy Innovation and Modernization Act of 2019 (NEIMA), November 2, 2022. https://www.nrc.gov/docs/ML2234/ML22347A191.pdf, pp. 102-104
Rani Franovich, Comment Letter re “Comments on NRC’s Staff’s Preliminary Part 53 Rule Package and October 18-19 ACRS Sub-committee Meeting,” November 1, 2022. https://www.nrc.gov/docs/ML2300/ML23006A081.pdf
Rani Franovich. Spoken Comment to NRC’s Advisory Committee on Reactor Safeguards, Radiological Rulemaking Policies and Procedures Part 53 Subcommittee, re the Committee’s review of the NRC staff’s proposed Draft Part 53 rule, October 18-9, 2022. https://www.nrc.gov/docs/ML2229/ML22299A184.pdf, pp. 272-283
Rani Franovich, Speaker, “Challenges with 10 CFR Part 53,” World Nuclear Association’s Law Working Group Meeting, London, UK, September 6, 2022. https://img1.wsimg.com/blobby/go/9a69d3ad-86ba-441e-82f2-9d352bba0396/downloads/f4e2b819-8975-4ebe-a63f-b3d41d54b246/Challenges%20with%2010%20CFR%20Part%2053%2C%20WNA%E2%80%99s%20Law%20Work.pdf?ver=1728752994810
Rani Franovich, Comment Letter re “Comments on Preliminary 10 CFR Part 53, ‘Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors’ [Regulation Identifier Number RIN-3150- AK31; Docket ID NRC-2019-0062],” August 31, 2022. https://www.nrc.gov/docs/ML2225/ML22255A008.pdf
Rani Franovich and Prasad Kadambi, Comment Letter re “Comments on Preliminary 10 CFR Part 53, “Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors” [Regulation Identifier Number RIN-3150-AK31; Docket ID NRC-2019-0062],” August 29, 2022. https://www.nrc.gov/docs/ML2225/ML22250A615.pdf
Rani Franovich, “What Society Needs from 10 CFR Part 53,” A Community of Practice webinar; Risk-informed, Performance-based Principles and Policy Committee (RP3C), American Nuclear Society, August 26, 2022. https://doi.org/10.21955/nuclscitechnolopenres.1115120.1
https://www.youtube.com/watch?v=erEG4SkHHxI
Rani Franovich, Comment Letter re “Regulatory Issue Summary (RIS), ‘Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants’ (NRC-2022-0119),” August 12, 2022. https://www.nrc.gov/docs/ML2222/ML22228A137.pdf
Rani Franovich, Spoken Comment re “Public Meeting on the NRC's Draft Regulatory Issue Summary (RIS) Clarification of Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants,” August 9, 2022. https://www.nrc.gov/docs/ML2225/ML22252A174.pdf, pp. 36-46
Lindsey Walter, Kristn Zaitz, Danielle Delesroth, Isabele Boemke, Rani Franovich and Ryan Norman “Build Nuclear Now,” Webinar launch, August 2, 2022. (Video-recording not publicly available.)
N. Prasad Kadambi and Rani Franovich, "A Performance Based Approach for 10 CFR Part 53," A Community of Practice webinar; Risk-informed, Performance-based Principles and Policy Committee (RP3C), American Nuclear Society, July 29, 2022. https://doi.org/10.21955/nuclscitechnolopenres.1115119.1
https://www.youtube.com/watch?v=V-d_r__XBY0
Rani Franovich, Presentation, "What Society Needs from Part 53," NRC Public Meeting on 10 CFR Part 53, July 28, 2022. https://www.nrc.gov/docs/ML2220/ML22209A004.pdf, Slides 2-13
Rani Franovich and Steve Burns, Comment Letter re “Subsequent Comment from Stakeholder Groups on Letter Submitted by the American Nuclear Society (ANS) and the Breakthrough Institute (BTI) to the U.S. Nuclear Regulatory Commission on Developing a ‘Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors’ (Regulation Identifier Number RIN-3150-AK31; Docket ID NRC-NRC-2019-0062),” July 22, 2022. https://www.nrc.gov/docs/ML2220/ML22206A212.pdf
A. Stein, J. Messinger, S. Wang, J. Lloyd, J. McBride and R. Franovich, “Advancing Nuclear Energy: Evaluating Deployment, Investment, and Impact in America's Clean Energy Future,” July 6, 2022. https://thebreakthrough.org/articles/advancing-nuclear-energy-report
Rani Franovich, Presentation, "Part 53 - Stakeholder Perspectives on Framework B, Framework A, and NRC Stakeholder Engagement Process," NRC Advanced Reactor Stakeholder Meeting, June 30, 2022. https://www.nrc.gov/docs/ML2218/ML22180A296.pdf, Slides 36-47
Rani Franovich, “Advanced Nuclear: What’s Stopping Us?” Speaking Engagement at Breakthrough Dialogue 2022: Progress Problems, June 23, 2022. https://thebreakthrough.org/events/bti-dialogue-progress-problems
Rani Franovich, Spoken Comment re “Public Meeting to Discuss the Part 53 Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors Rulemaking,” June 16, 2022. https://www.nrc.gov/docs/ML2217/ML22179A011.pdf, pp. 81-86 and 115-116
Rani Franovich and Steve Nesbit, Comment Letter re “Joint NGO Concerns Regarding the NRC’s Regulatory Engagement in Developing a ‘Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors’” [Regulation Identifier Number RIN-3150-AK31; Docket ID NRC-2019-0062],” June 15, 2022. https://www.nrc.gov/docs/ML2217/ML22172A195.pdf
https://www.ans.org/news/article-4053/breakthrough-institute-letter/
Rani Franovich, Comment Letter re Submittal of supplemental comments on draft ISG “Safety Review of Light-Water Power-Reactor Construction Permit Applications,” 87 Federal Register 27195 [Docket ID: NRC-2021-0162], May 23, 2022. https://www.nrc.gov/docs/ML2215/ML22152A064.pdf
Rani Franovich and Steve Nesbit, Comment Letter re “Preliminary Proposed Rule Language Part 73 of Title 10 of the Code of Federal Regulations (10 CFR)” (RIN-3150-AK19; NRC-2017-0227), April 27, 2022. https://www.nrc.gov/docs/ML2212/ML22122A218.pdf
Rani Franovich and Jonah Messinger, “Saving Palisades Nuclear Power Plant To Secure Michigan’s Clean Energy Future.” Blog argues shutting down the clean energy source will be the equivalent of tearing down almost every wind turbine in the State, April 4, 2022. https://thebreakthrough.org/blog/saving-palisades
Rani Franovich, “One Thing the WaPo's Op-ed on Nuclear Safety Wasn't Built to Survive: Scrutiny.” Blog rebuts a Washington Post op-ed on wartime nuclear power plant safety, March 25, 2022. https://thebreakthrough.org/blog/one-thing-this-op-ed-on-nuclear-safety-wasnt-built-to-survive-scrutiny
Rani Franovich, Spoken Comment re NRC’s “Forthcoming Public Outreach Meeting on the Proposed Kairos Hermes Test Reactor with Designated Period for Receipt of Environmental Scoping Comments,” March 23, 2022. https://www.nrc.gov/docs/ML2209/ML22091A000.pdf, pp. 57-60
Rani Franovich, “Take a Deep Breath.” Blog rebuts National Public Radio coverage of Zaporizhzhia nuclear power plant firefight, March 17, 2022. https://thebreakthrough.org/blog/ukraine-nuclear-power-plant-firefight
A. Trembath, S. Wang, J. Messinger, J. Lloyd, V. Ramachandran and R. Franovich, “Energy Security and Decarbonization in Response to Russian Aggression,” March 16, 2022. https://thebreakthrough.org/issues/energy/report-energy-security-and-decarbonization-in-response-to-russian-aggression
Adam Stein and Rani Franovich, "WAR IN UKRAINE: Breakthrough Institute Analysts Dr. Stein and Franovich Release Statements on Loss of Offsite Power at Chernobyl," March 10, 2022. https://thebreakthrough.org/press/war-in-ukraine-breakthrough-institute-analysts-dr-stein-and-franovich-release-statements-on-loss-of-offsite-power-at-chernobyl
Adam Stein and Rani Franovich, “NRC revises previously issued subsequent license renewal for existing nuclear power plants.” Blog assesses the basis for and impact of NRC Commissioner votes on the Generic Environmental Impact Statement (GEIS) for reactor license renewal, February 16, 2022. https://thebreakthrough.org/blog/blog-nrc-revises-previously-issued-subsequent-license-renewal-for-existing-nuclear-power-plants
Rani Franovich, Speaker, “Reactor Oversight Process Enhancement Project,” Regulatory Information Conference, U.S. Nuclear Regulatory Commission, March 13, 2014. https://www.flickr.com/photos/nrcgov/13270661675/in/photostream/
Rani Franovich, Speaker, “NRC and Licensee Safety Culture Activities,” Regulatory Information Conference, U.S. Nuclear Regulatory Commission, March 12, 2009. https://www.slideserve.com/quang/ric-2009-nrc-and-licensee-safety-culture-activities
T. Bloomer, R. Franovich, P.T. Kuo, and S, Lee, “License Renewal Guidance Documents,” Conference Proceedings, 16th International Conference on Structural Mechanics in Reactor Technology (IASMiRT-16), August 12, 2001. https://repository.lib.ncsu.edu/handle/1840.20/30551