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MONTHYEARML24016A2372024-01-17017 January 2024 NEI Environmental Reviews Slides Public Meeting 1-17-24 ML24008A0442024-01-0909 January 2024 NEI - Slides for NRC Workshop 1 on Revision to RG 1.183 R1 - Final - ML24008A044 ML23342A0262023-12-14014 December 2023 December 14, 2023, Presentation on NEI 23-01 Operator Cold Licensing Training Plan for Advanced Nuclear Reactors ML23347A1782023-12-13013 December 2023 12-14 NEI EPRI Presentation NRC Public Meeting 16-03 R1 ML23303A1922023-10-30030 October 2023 NEI Slides for SLR Public Meeting - Oct 31 2023 ML23324A2392023-10-24024 October 2023 S1P6 - Hilary Lane - NRC AMT Workshop - Oct. 2023 ML23258A1992023-09-20020 September 2023 NEI 99-02 Draft Rev. 8 Update for Sept 2023 ROP Public Meeting ML23242A0782023-08-30030 August 2023 Hbu Workshop IV Industry Presentation: Drive to Deploy ATF with Increased Enrichment and Higher Burnup ML23230A0142023-08-22022 August 2023 Industry Slide Presentation for 8-22-23 Meeting on ARCAP-TICAP and DG-1404 Guidance Documents ML23191A0632023-07-0707 July 2023 NEI Cybersecurity Presentation for July 2023 ROP Public Meeting ML23191A0662023-07-0707 July 2023 NEI 99-02 Draft Rev. 8 Update for July 2023 ROP Public Meeting ML23160A1512023-06-15015 June 2023 25 - Industry - Industry Perspectives on ASME III and XI Pre-Service Inspection ML23160A1422023-06-15015 June 2023 20 - Industry - Industry Perspective on Performance Monitoring ML23116A1892023-05-31031 May 2023 Industry Observations of NRC Licensing Program (NEI Slides May 2023) ML23136A5912023-05-18018 May 2023 NEI Safety Culture Presentation for May 2023 ROP Public Meeting ML23125A3192023-05-0909 May 2023 NEI Presentation for May 9, 2023, Public Meeting on NEI 22-05, Revision a ML23115A0302023-04-27027 April 2023 NEI Perspective on Performance Monitoring in Use of Probabilistic Fracture Mechanics for Optimizing Inspections of Non-RPV Pressure Vessels, April 27, 2023 ML23088A0822023-03-30030 March 2023 NEI Presentation - March 30, 2023 PRA Configuration Control Public Meeting ML23082A0572023-03-28028 March 2023 Proposal to Establish Alternate Requirements for Components Commensurate with Safety and Risk ML23079A2642023-03-23023 March 2023 General Visual Examination of Containment Surfaces Covered by Insulation - March 23, 2023 Public Meeting Slides from NEI ML23210A0042023-03-15015 March 2023 Destination: Termination, NRC Regulatory Information Conference ML23045A2892023-03-14014 March 2023 RIC 2023 - 03/14/2023 to 03/16/2023 Regulatory Information Conference (Ric).Operational and Safety Benefits of Risk Informed Applications ML23061A0292023-03-0202 March 2023 NEI Presentation - Advanced Reactor Digital I&C Licensing Workshop 1 ML23013A0782023-01-13013 January 2023 PI&R Inspection Discussion for January 2023 ROP Public Meeting ML23041A4342022-12-15015 December 2022 NEI Presentation for December 15, 2022 Industry Spent Fuel Activities Prioritization Meeting ML22291A4442022-10-11011 October 2022 NEI 22-01 License Termination Plan Process Presentation at October 11 2022 Meeting on NUREG-1757 Vol. 2 ML22266A2632022-09-28028 September 2022 Session 2 - Advanced Reactor Developers Perspectives on Codes and Standards ML22250A7122022-09-21021 September 2022 NEI 22-03 Presentation Slides for NRC Public Meeting (Sept. 21, 2022) ML22235A7032022-08-24024 August 2022 NEI Presentation for Aug 26, 2022 Public Meeting - Source Terms and Radiological Consequence Analyses ML22194A0682022-07-18018 July 2022 NEI Presentation for NEI 22-02 Rsi Response ML22174A2822022-06-22022 June 2022 NEI Presentation for Public Meeting with NMMSS Users Community to Discuss Foreign Obligation Reporting Requirements for Low Enriched Uranium ML22172A1352022-06-21021 June 2022 NEI Presentation for Public Meeting Industry Perspectives on Rulemaking for Greater than 5 Percent Enrichment ML22143A8542022-05-20020 May 2022 Nuclear Energy Institue (NEI) Presentation Slides to ACRS Subcommittee on CCF Secy Paper, May 20, 2022 ML22136A1162022-05-11011 May 2022 Presentation 5 - Utilizing the Nuclear Energy Institute (NEI) 07-07 Industry Groundwater Protection Initiative as a Foundation for Addressing Subsurface Site Assessments ML22088A0342022-03-29029 March 2022 Public Meeting Presentation by NEI Regarding Part 53 Rulemaking: Selected Topics ML22077A4012022-03-23023 March 2022 NEI INL Presentation March 23, 2022, NRC Workshop Isv Hfe Issue ML22070B1212022-03-16016 March 2022 Industry Perspective on IEEE Std -1819 ML22140A3612022-03-10010 March 2022 mccullumr- hv-th29 ML22060A0022022-03-0101 March 2022 Dt Public Meeting - 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Adversary Timeline Methodology (Final- 6.24.21) - Updated ML21173A2862021-06-21021 June 2021 NEI 20-07 Systematic Approach to CCF NRC 2024-01-09
[Table view] Category:Slides and Viewgraphs
MONTHYEARML24016A2372024-01-17017 January 2024 NEI Environmental Reviews Slides Public Meeting 1-17-24 ML24010A0202024-01-11011 January 2024 Public Meeting on SLR Efficiencies - NEI Presentation ML24008A0442024-01-0909 January 2024 NEI - Slides for NRC Workshop 1 on Revision to RG 1.183 R1 - Final - ML24008A044 ML23342A0262023-12-14014 December 2023 December 14, 2023, Presentation on NEI 23-01 Operator Cold Licensing Training Plan for Advanced Nuclear Reactors ML23347A1782023-12-13013 December 2023 12-14 NEI EPRI Presentation NRC Public Meeting 16-03 R1 ML23303A1922023-10-30030 October 2023 NEI Slides for SLR Public Meeting - Oct 31 2023 ML23324A2392023-10-24024 October 2023 S1P6 - Hilary Lane - NRC AMT Workshop - Oct. 2023 ML23261C3792023-09-27027 September 2023 NEI 22-04 Pre-Submittal Meeting with NRC - September 27, 2023 ML23258A1992023-09-20020 September 2023 NEI 99-02 Draft Rev. 8 Update for Sept 2023 ROP Public Meeting ML23242A0782023-08-30030 August 2023 Hbu Workshop IV Industry Presentation: Drive to Deploy ATF with Increased Enrichment and Higher Burnup ML23242A1662023-08-30030 August 2023 the Future of Nuclear Power: 2023 Baseline Survey (Slides) ML23230A0142023-08-22022 August 2023 Industry Slide Presentation for 8-22-23 Meeting on ARCAP-TICAP and DG-1404 Guidance Documents ML23228A0042023-08-18018 August 2023 NEI Slides for Public Meeting to Discuss Possible Efficiencies on the Subsequent License Renewal Review - August 18, 2023 ML23191A0162023-07-11011 July 2023 NEI Comments on Risk-Informed Process for Evaluation (RIPE) DORL TSG - 7/11/23 Public Meeting Slides from NEI ML23191A0632023-07-0707 July 2023 NEI Cybersecurity Presentation for July 2023 ROP Public Meeting ML23191A0662023-07-0707 July 2023 NEI 99-02 Draft Rev. 8 Update for July 2023 ROP Public Meeting ML23160A1512023-06-15015 June 2023 25 - Industry - Industry Perspectives on ASME III and XI Pre-Service Inspection ML23160A1422023-06-15015 June 2023 20 - Industry - Industry Perspective on Performance Monitoring ML23116A1892023-05-31031 May 2023 Industry Observations of NRC Licensing Program (NEI Slides May 2023) ML23136A5912023-05-18018 May 2023 NEI Safety Culture Presentation for May 2023 ROP Public Meeting ML23125A3192023-05-0909 May 2023 NEI Presentation for May 9, 2023, Public Meeting on NEI 22-05, Revision a ML23117A3712023-05-0202 May 2023 NEI Lessons Learned Meeting Slides, May 2, 2023 ML23115A0302023-04-27027 April 2023 NEI Perspective on Performance Monitoring in Use of Probabilistic Fracture Mechanics for Optimizing Inspections of Non-RPV Pressure Vessels, April 27, 2023 ML23088A0822023-03-30030 March 2023 NEI Presentation - 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November 2022 - Final Presentation to NRC ML22318A3032022-11-16016 November 2022 NEI-22-01 License Termination Process Pre-Submittal Meeting November 16, 2022 (Presentation) ML22291A4442022-10-11011 October 2022 NEI 22-01 License Termination Plan Process Presentation at October 11 2022 Meeting on NUREG-1757 Vol. 2 ML22250A7122022-09-21021 September 2022 NEI 22-03 Presentation Slides for NRC Public Meeting (Sept. 21, 2022) ML22235A7032022-08-24024 August 2022 NEI Presentation for Aug 26, 2022 Public Meeting - Source Terms and Radiological Consequence Analyses ML22216A1152022-08-0404 August 2022 August 4, 2022 Rislr Public Meeting Presentation by Nuclear Energy Institute ML22194A0682022-07-18018 July 2022 NEI Presentation for NEI 22-02 Rsi Response ML22174A2822022-06-22022 June 2022 NEI Presentation for Public Meeting with NMMSS Users Community to Discuss Foreign Obligation Reporting Requirements for Low Enriched Uranium ML22172A1352022-06-21021 June 2022 NEI Presentation for Public Meeting Industry Perspectives on Rulemaking for Greater than 5 Percent Enrichment ML22152A0942022-06-0202 June 2022 NEI Slides - 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[Table view] |
Text
Review of'Operational Programs in a, Combined License Application
-,z NRh REG CoV June 8, 2005 1:
'Agenda
- Goals and Objectives for Combined License Operational Program Review,
- Proposed Approach for- Combined License Operational Program Review
- Key Challenges for Review of Operational Programs
- Challenges with Operational Program Implementation
- Changes to Safety Analysis Report after COL is Issued
- Some Suggested NRC Processes Which may Mitigate Challenges
- Range of ImplementationdOptions to Address Concerns
- Option 2: Informative License Condition
- Illustrative Example: Radiation Protection 2
__ I aML.
Goals and Objectives for
?Combined License Operational Program Review
- Include acceptable implementation of operational programs as part of the combined license
- Ensure that key elements of operational programs are included in the safety analysis report to allow the NRC to make a reasonable assurance finding on the operational program when the combined license is issued
- For programs which do not have inspections, tests, analyses, and acceptance criteria, ensure that these programs and their implementation are fully described in the safety analysis report
- Ensure that operational programs can be inspected by the NRC prior to implementation 3
Background
0**I Operational Programs Included in SECY-02-0067
> Originally identified in NEI letter dated May 14, 2001 U Emergency planning
- Physical Security U Quality Assurance
- Fire Protection U Radiation Protection
- Training U Licensed Operator
- Reportability U Containrment Leak Rate Testing
- Maintenance Rule U Inservice Inspection and Inservice
- Equipment Qualification Testing
- SRM-SECY-02-0067 endorsed inspections, tests, analyses, and acceptance criteria (ITAAC) for emergency planning 4
Background (continued)
- SRM-SECY-02-0067 stated the following:
Although the NRC inspe'ction process does not replace a particular ITAAC, an ITAAC should not be necessa'ry if the program and its implementation are fully'described in'the application and found to be' acceptable by the NRC -atthe COL [combined license] stage. The burden is'on the applicant to provide the necessary and sufficient programmatic information for approval of the COL without ITAAC 5 -,
Background (continued)
SRM-SECY-04-0032 provided additional clarification:
'fully described' should be understood to mean that the program is clearly and sufficiently described in terms of the scopeiand level of detail to allow a reasonable assurance finding of acceptability.
Required programs should always be described at a functional level' and at an increased level of detail where implementation choices could materially and negatively affect the program effectiveness and acceptability. -
6
- - -IJIL-
+ Rto 4. Proposed Approach for Combined License Operational Program Review
- COL application would contain the following related to operational programs:
Safety Analysis Report (SAR) level information
> Additional information for operational programs'where implementation choices could materially and negatively affect the program effectiveness and acceptability
- Discussion of the applicant's implementation plans, including schedule
- NRC final safety evaluation report to include staff evaluation of operational programs
- COL to include, where necessary, license conditions on implementation of operational programs, as described in the SAR (i.e., for programs that will not be implemented at the time the COL is issued) 7
^RtO>~ Proposed Approach for
' Combined License Operational
, Program Review (continued)
- Approach consistent with current process of including license conditions in renewed operating licenses
- Approach assumes that operational programs do not need ITAAC unless'the' staff determines that an implementation issue is inseparable from the finding on program acceptability, and an ITAAC is necessary
- COL applicants may propose ITAAC for implementation of any operational program
- Program must be fully described in SAR in order for NRC to make a reasonable assurance finding 8
Key Challenges for Review of Operational Programs Make a reasonable assurance finding on an operational program before a plant is constructed and operated
> SAR needs to include level of detail sufficient to make a reasonable assurance finding. .
- No inspection, tests, analyses, acceptance criteria (ITAAC) needed if program and its implementation can be fully described Ensure that the key elements of the operational program used by NRC to make reasonable assurance finding are included in the implementation of the operational program
- Assurance provided by inspection of operational program prior to implementation 9
- QOR REQb@4 z u Challenges with Operational Program Implementation
- Time period between COL issuance and program implementation
> Could be several years after license is issued 10 '
LJIL-0t Changes to SAR after COL is Issued
- Allowed by 10. CFR 50.54 or 50.59
- Periodic reporting requirements to NRC
- Current regulations do not account for fact that will have final SAR years before a plant is built and operated 11 Some Suggested NRC Controls D Which May Mitigate Challenges
- Controls on changes to operational program descriptions in SARs after COL is issued
- Timely exchange of information on changes to SARs that impact operational programs
- Ability to perform inspections of operational programs prior to implementation
- Process to resolve findings from these operational program inspections 12
Range of Implementation
/ Options to Address Concerns Option 1: Restrictive License Condition Changes in SAR on operational program information will require NRC approval until operational program fully implemented ('Tier 2*for Operational Programs")
Requires NRC notification prior to operational program implementation
- Verification of acceptable .- I ' a Restrictive operational program implementation in license , Increased burden on NRC to
.'review any changes
- Ensures that key elements of operational program remain in SAR until program implemented
- Program and its implementation remain fully described
- NRC informed of operational program implementation in preparation for inspection 13 Range of Implementation Options to Address Concerns (continued)
- Option 2: Informative License Condition Requires NRC notification prior~to operational program implementation
' Licensee submits most recent SAR changes related to operational programs since'last report to NRC
- Verification of acceptable operational
- No restrictions on program implementation in license I changes ..
- Allows NRC to review changes in timely
- NRC only reviews manner to ensure that key elements of changes prior to operational program supporting reasonable implementation of assurance finding have not been removed -operational program from SAR before implementation,--,.-
- Allows NRC to review changes to ensure program and its implementation remain fully described before implementation
- NRC informed of operational program implementation in preparation for inspection
I WI fi RE014 Range of Implementation
' Options to Address Concerns (continued)
- Option 3: No License Condition
> Implementation of operational programs only discussed in SAR
- No requirements for licensee to submit information or inform NRC of operational program implementation
- Verification of acceptable operational
- No restrictions on changes program implementation not in license
- No regulatory means to ensure that after required periodic key elements supporting reasonable updates submitted assurance finding remain in SAR when program implemented
- Program and its implementation may no longer be fully described when implemented
- No assurance that inspection may be performed before program is implemented 15 Option 2:
5 Informative License Condition (continued)
License Condition Implementation:
- Notify NRC when program is about to be implemented
- Provide NRC with changes to SAR since last update required by 10 CFR 50.71 (e)that impact the operational program being implemented
- Condition ends on specific operational program when either Commission provides authorization to load fuel or program required to be fully implemented
Purpose:
- Ensure that program is implemented as described in SAR
- Ensure that SAR fully describes operational program and its implementation
- Ensure that key elements used to reach reasonable assurance finding on operational program at COL remain in place
- Allow sufficient time to schedule and prepare for NRC inspection of operational program prior to implementation 16
&,E4' Option 2:
, Informative License Condition (continued)
Attributes:
- Licensee informs NRC that a operational program will be implemented in X months
- Licensee provides any additional changes to SAR implemented after last change report required by 10 CFR 50.71 (e), which are related to the operational program, X months before implementation
- For programs with phased implementation, licensee reports on implementation milestone and relevant 10 CFR 50.71 (e) reports X months before that phase of operational program is implemented 17 o / Illustrative Example NEt 04-01, Section 4.3.9.12:
FSAR Chapter 12, Radiation Protection
- Example Health Physics Program Description
> Example taken from current operating plant FSAR Inadequate information to review radiation protection operational program in COL application
- Parallel effort currently underway to work with NEI to modify this section in NEI 04-01
- Need to ensure that all operational programs described in SAR receive this level of consideration by COL applicants 18