ML17229B558

Part 52 Licensing Lessons Learned

ML17229B558
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/27/2017
From:	Cowan P Nuclear Energy Institute
To:	Vonna Ordaz Document Control Desk, Office of New Reactors
Shared Package
ML17229B556	List: ML17229B558 ML17229B560
References
Download: ML17229B558 (2)

Text

PAMELA B. COWAN Vice President, Nuclear Generation 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8093 pbc@nei.org nei.org January 27, 2017 Ms. Vonna L. Ordaz Acting Director Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Part 52 Licensing Lessons Learned Project Number: 689

Dear Ms. Ordaz:

It is vitally important to the future of our industry that the licensing process for new nuclear plants be as efficient, effective, timely and predictable as possible to encourage future applicants to bring forward innovative designs, while continuing to assure public health and safety. As indicated in the NRCs Vision and Strategy document for non-light water reactors, we appreciate that the NRC shares the goal of efficient, effective new reactor licensing. With that objective in mind, the purpose of this letter is to provide the results of a recent industry workshop on lessons learned from new plant licensing experience, and to request NRC support for actions to improve new reactor licensing efficiency and reduce regulatory impact on the time-to-market for future new plant applicants. We recognize that the NRC has performed its own lessons-learned evaluations and implemented improvements to both the licensing process and post-licensing implementation.

The results of these NRC efforts were considered as inputs to the industry workshop discussions.

We support the NRCs efforts to develop and implement regulatory changes in this area. The time is right for the NRC and the industry to take action to address new plant licensing lessons learned, while recent and ongoing licensing experience is fresh, and key industry and NRC staff are available for the task. Near term improvements to NRCs licensing process and guidance would clearly benefit the next wave of applicants and NRC reviewers, and will complement other forward-looking activities the NRC has underway, including development of guidance for staged licensing and non-LWRs.

Ms. Vonna L. Ordaz January 27, 2017 Page 2 NRC senior management and Commission support will be needed to improve licensing efficiency, effectiveness, timeliness and predictability. Most of the improvements targeted can be accomplished through new or revised NRC guidance, i.e., without rulemaking, and ongoing activities can be leveraged to achieve desired outcomes in key areas. The needed improvements most frequently cited by attendees at the industry licensing lessons learned workshop were:

1. Stemming the growth in application scope and level of detail and clarifying the threshold for information necessary to support required NRC safety findings;

2. Clarifying of NRCs application acceptance review process, application docketing criteria, and the integration of pre-application interactions with NRC staff safety reviews;

3. Simplifying the Part 52 change process by eliminating Tier 2*;

4. Establishing Tier 1/ITAAC First Principles and developing standardized ITAAC; and

5. Avoiding undue combined license delays when the need for changes in a completed design certification is identified Addressing these issues will enable demonstrable improvements in licensing efficiency, effectiveness and predictability, and position the industry and NRC for the future. The industry looks forward to working with the NRC staff and stakeholders to achieve these improvements. The attachment to this letter provides additional discussion of these key lessons learned, and associated recommendations for improving licensing efficiency and predictability going forward.

We will follow up with you and your staff concerning implementation of licensing lessons learned activities.

Please contact me or Russ Bell (202.739.8087; rjb@nei.org) if you have any questions.

Sincerely, Pamela B. Cowan Attachment c: Mr. Michael E. Mayfield , NRO/DEIA, NRC Mr. Michael C. Cheok, NRO/DCIP, NRC Mr. Frank M. Akstulewicz, NRO/DNRL, NRC NRC Document Control Desk