ML17229B560
| ML17229B560 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 01/27/2017 |
| From: | Nuclear Energy Institute |
| To: | Office of New Reactors |
| Shared Package | |
| ML17229B556 | List: |
| References | |
| Download: ML17229B560 (2) | |
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Attachment New Plant Licensing Lessons Learned and Recommended Actions Lessons Learned Recommended Actions
- 1. Growth in application content and level of detail NRC workshop(s) for NRC staff and stakeholders to explore the reasons underlying the growth in The growth in application content is potentially application scope and level of detail, strategies and unsustainable and frequently cited as a major opportunities to stem this growth, and ways to obstacle to future new plant applicants. Recent new clarify the threshold for information necessary to plant experience can and should be examined to support required NRC safety findings.
understand and stem the continued growth in Reflect identified clarifications and improvements in application scope and level of detail and associated the SRP or other appropriate guidance.
NRC reviews. These activities would be in addition to, and will complement, ongoing efforts to develop new application and review guidance for non-LWRs.
- 2. Need for more effective pre-application interactions NRC workshop(s) for NRC staff and stakeholders to and acceptance review process discuss recent acceptance review experience and identify opportunities to improve efficiency and Experience with the TVA Clinch River early site effectiveness e.g., clarification of NRO-REG-100.
permit and NuScale design certification applications Reflect identified clarifications and improvements in pointed up a lack of common understanding and durable guidance for future applicants and NRC staff consistency regarding application of existing such as Regulatory Guide 1.206, Combined License guidance on application acceptance reviews. This Applications for Nuclear Power Plants. RG 1.206 experience can be applied to develop and/or clarify contains sections on Pre-application Activities, guidance on the NRCs application acceptance Readiness Assessment, and Application Acceptance review process, application docketing criteria, and Review, and is currently being updated by the NRC.
the integration of pre-application interactions with Reflect updated guidance in the Regulatory Review NRC staff safety reviews. Roadmap for non-LWRs being developed by the NRC staff and in envisioned guidance on developing licensing project plans.
- 3. Need to simplify the Part 52 change process, Work closely with KHNP and NuScale to demonstrate especially Tier 2* that design certifications can be completed without use of Tier 2* designations.
A principal lesson learned from Part 52 Work with NRC to reflect KHNP and NuScale implementation to date is that Tier 2* unduly outcomes in an updated SECY paper and associated complicates the 50.59-like change process, placing SRP guidance to provide for use of Tier 1 and Tier 2 undue burden on licensees, and is unnecessary. only in future design certifications.
While not eliminating Tier 2*, a forthcoming SECY paper is expected to acknowledge the problem of Tier 2* excess and take steps to limit and control the staffs use of this category of design certification information.
Attachment Lessons Learned Recommended Actions
- 4. Need to standardize ITAAC and establish Leverage the KHNP and NuScale design certification Tier 1/ITAAC First Principles applications to resolve remaining issues related to the scope and language of standard ITAAC.
Lack of guidance has led to unnecessary and Revise and resubmit NEI 15-02 for NRC review, inconsistent ITAAC being included in design including a complete set of standard ITAAC together certifications. Inconsistent, unnecessary and poorly with Tier 1/ITAAC First Principles on which they crafted ITAAC add burden and the potential for are based.
ITAAC closure and hearing issues. Efforts begun in Achieve a common understanding on standard 2013 to develop Tier 1 First Principles and ITAAC and Tier 1/ITAAC First Principles, and standardized ITAAC via NEI 15-02, Industry document NRC endorsement in a regulatory guide.
Guideline for the Development of Tier 1 and ITAAC under 10 CFR Part 52, offer the opportunity to establish needed clarity and consistency concerning the level of detail required for Tier 1/ITAAC.
- 5. Avoid delay in COL issuance due to required design Discuss options for addressing this issue in a public certification changes meeting, as proposed in the NRCs letter to NEI dated July 18, 2016.
A process solution is needed to avoid unnecessary Identify a preferred process solution and codify it in delays in licensing when the need for changes in a a Commission SRM or appropriate regulatory referenced design certification is identified while a guidance, or via rulemaking if necessary.
COL application is under review. Issuance of COLs without delay is appropriate because existing change processes assure that errors identified in a referenced design certification will be corrected prior to construction of affected SSCs.