ML17058A243
| ML17058A243 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/2017 |
| From: | Vonna Ordaz Office of New Reactors |
| To: | Cowan P Nuclear Energy Institute |
| Donna Williams | |
| Shared Package | |
| ML17058A107 | List: |
| References | |
| YT-2017-0031, YT-2017-0064 | |
| Download: ML17058A243 (7) | |
Text
June 16, 2017 Ms. Pamela B. Cowan Vice President, Nuclear Generation Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
THE U.S. NUCLEAR REGULATORY COMMISSION RESPONSE TO THE NUCLEAR ENERGY INSTITUTE 10 CFR PART 52, LICENSES, CERTIFICATIONS, AND APPROVALS FOR NUCLEAR POWER PLANTS, LICENSING LESSONS-LEARNED LETTER, DATED JANUARY 27, 2017
Dear Ms. Cowan:
By letter dated January 27, 2017 (Agencywide Documents Access Management System (ADAMS) Accession Nos. ML17058A334 and ML17058A319), you provided the results of a recent industry workshop on lessons learned from new plant licensing experience. In the letter, you requested U.S. Nuclear Regulatory Commission (NRC) support for actions to improve new reactor licensing efficiency and reduce regulatory impact on the time-to-market for future new plant applicants. You requested action for improving licensing efficiency and predictability in five key lessons-learned areas, noting that most of the improvements could be accomplished through new or revised NRC guidance, without rulemaking, and while leveraging ongoing activities to achieve desired outcomes.
Subsequently, in an e-mail dated February 24, 2017 (ADAMS Accession No. ML17059C937),
Michael Tschiltz of your staff provided suggested priorities for addressing the most frequently cited improvements by the attendees at the industry lessons-learned workshop:
Priority 1. Tier 2* and Standard Inspections, Tests, Analyses and Acceptance Criteria (ITAAC)/First Principles (Nuclear Energy Institute (NEI) Lessons Learned Numbers 3 and 4)
Priority 2. Application level of detail and acceptance reviews/docketing (NEI Lesson Learned Number 1)
Priority 3. Preapplication project plan (NEI Lesson Learned Number 2)
Priority 4. Combined license issuance despite design certification errors (NEI Lesson Learned Number 5)
P. Cowan 2 We appreciate the information from the industrys lessons learned workshop and the recommendations for addressing each of the lessons learned. The activities you suggested are generally consistent with efforts we have underway or planned. The enclosure to this letter summarizes those ongoing and planned NRC activities related to the lessons learned identified in your letter.
We believe that continued engagement with NEI and our other stakeholders is important to improving our processes. We look forward to further engagement on these topics through our public meetings and workshops. The NRC would consider further improvements in its licensing process and prioritize these activities accordingly.
Sincerely,
/RA/
Vonna L. Ordaz, Acting Director Office of New Reactors
Enclosure:
Summary of NRC Ongoing and Planned Activities
ML17058A243 *via e-mail NRO-002 OFFICE LA: NRO/DEIA/NRCB PM:NRO/DEIA/NRCB BC:NRO/DEIA/NRCB D:NRO/DEIA NAME BAbeywickrama* CLauron* JColaccino* RCaldwell*
DATE 04/27/2017 04/27/2017 04/27/2017 05/05/2017 OFFICE D:NRO/DCIP D:NRO/DSRA D:NRO/DNRL QTE*
NAME TMcGinty* JMonninger* FAkstulewicz* CHsu DATE 05/03/2017 05/05/2017 05/02/2017 4/27/2017 OFFICE D:NRO NAME VOrdaz DATE 06/16/2017 NEI Lessons NEI Lessons Learned2 NEI Recommended Actions2 NRC Ongoing and Planned Learned Priority1 Activities Priority 1 Need to simplify the Part 52
- Work closely with Korea The U.S Nuclear Regulatory change process, especially Tier Hydro & Nuclear Power Commission (NRC) staff is Tier 2* & Standard 2* (KHNP) and NuScale to developing a paper to Inspections, Tests, demonstrate that design describe planned actions to Analyses and A principal lesson learned certifications can be improve usage of the Tier 2*
Acceptance Criteria from Part 52 implementation completed without use of designation. This paper is (ITAAC)/First to date is that Tier 2* unduly Tier 2* designations. expected to describe related Principles complicates the 50.59-like
- Work with NRC to reflect efforts to improve the change process, placing KHNP and NuScale descriptions of Tier 1 and undue burden on licensees, outcomes in an updated Tier 2 information as well as and is unnecessary. While SECY paper and the infrastructure updates not eliminating Tier 2*, a associated SRP guidance needed for these improved forthcoming SECY paper is to provide for use of Tier 1 tier descriptions. Nuclear expected to acknowledge the and Tier 2 only in future Energy Institutes (NEI) problem of Tier 2* excess and design certifications. proposed Tier 1, First take steps to limit and control Principles, may be useful in the staffs use of this category these updates.
of design certification information. The NRC staff has not continued its review efforts of the Standardized ITAAC Need to standardize ITAAC and within NEI 15-02 at this time.
establish Tier 1/ITAAC First The NRC does not consider Principles
- Leverage the KHNP and this a priority because there NuScale design are no forthcoming users for Lack of guidance has led to certification applications to this type of guidance. The unnecessary and inconsistent resolve remaining issues NRC staff discussed and ITAAC being included in related to the scope and subsequently issued letters design certifications. language of standard with a set of standard ITAAC Inconsistent, unnecessary ITAAC. to NuScale3 and KHNP4 for and poorly crafted ITAAC add
- Revise and resubmit NEI possible use in their burden and the potential for 15-02 for NRC review, applications. The NRC staff ITAAC closure and hearing including a complete set of will re-engage with NEI to issues. Efforts begun in 2013 standard ITAAC together resume the review of to develop Tier 1 First with Tier 1/ITAAC First Standardized ITAAC if and Principles and standardized Principles on which they when the appropriate ITAAC via NEI 15-02, are based. prioritization and available Industry Guideline for the
- Achieve a common resources allow.
Development of Tier 1 and understanding on standard ITAAC under 10 CFR Part ITAAC and Tier 1/ITAAC 52, offer the opportunity to First Principles, and establish needed clarity and document NRC consistency concerning the endorsement in a level of detail required for Tier regulatory guide.
1/ITAAC.
1 Priorities identified in an e-mail from M. Tschiltz to M. Mayfield and J. Segala, dated February 24, 2017, ADAMS Accession No. ML17059C937.
2 Lessons learned identified in a letter from P. Cowan to V. Ordaz, dated January 27, 2017, ADAMS Accession Nos. ML17058A334 and ML17058A319.
3 Letter from F. Akstulewicz to T. Bergman dated June 21, 2016, ADAMS Accession No. ML16160A109.
4 Letter from D. Williams to J. Y. Lee dated August 11, 2016, ADAMS Accession No. ML16208A536.
ENCLOSURE
2 NEI Lessons NEI Lessons Learned NEI Recommended NRC Ongoing and Planned Learned Priority Actions Activities Priority 2 Growth in application content and
- NRC workshop(s) for NRC Over the past 2 years, the level of detail staff and stakeholders to NRC staff conducted several Application level of explore the reasons public meetings to discuss a detail and The growth in application underlying the growth in revision to its guidance for acceptance content is potentially application scope and level new reactor license reviews/docketing unsustainable and frequently of detail, strategies and applications found in cited as a major obstacle to opportunities to stem this Regulatory Guide (RG) 1.206, future new plant applicants. growth, and ways to clarify Combined License Recent new plant experience the threshold for Applications for Nuclear can and should be examined information necessary to Power Plants. The proposed to understand and stem the support required NRC revision to the regulatory continued growth in safety findings. guide (Draft Regulatory Guide application scope and level of
- Reflect identified DG-1325) addresses the detail and associated NRC clarifications and lessons learned the NRC staff reviews. improvements in the SRP identified during its new or other appropriate reactor licensing reviews.
guidance. The proposed revision also
- These activities would be responds to feedback and in addition to, and will comments from public complement, ongoing interactions, including from efforts to develop new NEI.
application and review guidance for non-LWRs. The NRC staff made DG-1325 publically available on June 9, 2017 (ADAMS Accession No. ML15233A056). The NRC staff expects to continue working with members of the public, industry, and NEI on the guidance.
3 NEI Lessons NEI Lessons Learned NEI Recommended NRC Ongoing and Planned Learned Priority Actions Activities Priority 3 Need for more effective pre-
- NRC workshop(s) for NRC As noted in the response application interactions and staff and stakeholders to above, the NRC staff made Pre-application acceptance review process discuss recent acceptance DG-1325 publically available project plan review experience and on June 9, 2017. This draft Experience with the TVA identify opportunities to regulatory guide addresses Clinch River early site permit improve efficiency and the lessons learned the NRC and NuScale design effectiveness e.g., staff identified during its new certification applications clarification of NRO-REG- reactor licensing reviews and pointed up a lack of common 100. considers feedback and understanding and
- Reflect identified comments received from consistency regarding clarifications and public interactions on the application of existing improvements in durable proposed revisions.
guidance on application guidance for future acceptance reviews. This applicants and NRC staff The NRC staff is currently experience can be applied to such as Regulatory Guide working with NEI and other develop and/or clarify 1.206, Combined License stakeholders to develop guidance on the NRCs Applications for Nuclear guidance and best practices application acceptance review Power Plants. RG 1.206 for preapplication interactions process, application docketing contains sections on Pre- with developers of advanced criteria, and the integration of application Activities, reactor designs. The staff is pre-application interactions Readiness Assessment, developing a flexible with NRC staff safety reviews. and Application approach to accommodate Acceptance Review, and is developers at different stages currently being updated by of the reactor design and will the NRC. include various plans for
- Reflect updated guidance licensing and deployment.
in the Regulatory Review Roadmap for non-LWRs The NRC staff is revising the being developed by the draft regulatory roadmap the NRC staff and in agency made available in envisioned guidance on October 2016 to capture developing licensing feedback from periodic project plans. stakeholder meetings and recent interactions with advanced reactor developers.
On April 24, 2017, NEI submitted a report titled Clarifying Major Portions of a Reactor Design in Support of a Standard Design Approval, for NRC review and comment. The staff will provide feedback to NEI on this report during a June 22, 2017, public meeting to support NEI completing its report. The staff plans to incorporate this information into the draft roadmap before finalizing it in the Fall of 2017.
4 NEI Lessons NEI Lessons Learned NEI Recommended NRC Ongoing and Planned Learned Priority Actions Activities Priority 3 A key to effective interactions (continued) is the development of licensing project plans and Pre-application associated NRC review plans.
project plan The staff is continuing to discuss the format and content of licensing project plans with individual developers and during the periodic stakeholder meetings. Insights and best practices identified by NEI and others will be helpful in developing NRC and industry guidance in this area.
Priority 4 Avoid delay in COL issuance due
- Discuss options for In DG-1325, the NRC staff to required design certification addressing this issue in a incorporated DC/COL-ISG-11, Combined license changes public meeting, as Finalizing Licensing Basis (COL) issuance proposed in the NRCs Information, to address errors despite design A process solution is needed to letter to NEI dated in design certifications certification (DC) avoid unnecessary delays in July 18, 2016. referenced by combined errors licensing when the need for
- Identify a preferred process licenses. The NRC staff changes in a referenced design solution and codify it in a considered feedback and certification is identified while a Commission SRM or comments during the COL application is under appropriate regulatory development of DG-1325 and review. Issuance of COLs guidance, or via made it pubically available on without delay is appropriate rulemaking if necessary. June 9, 2017 (ADAMS because existing change Accession No.
processes assure that errors ML15233A056). The NRC identified in a referenced staff also expects to continue design certification will be working with members of the corrected prior to construction public, industry, and NEI to of affected SSCs. ensure that the agencys processes are open, transparent, and do not result in undue licensing delays.
With respect to the proposed public meeting discussed in the referenced letter, the NRC staff believes that additional opportunities to discuss this item and industry options will be available when DG-1325 is published in the Federal Register on June 20, 2017, for public comment.