ML19086A036

Industry Slides for the March 28, 2019 Public Meeting on SLR Lessons Learned

ML19086A036
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/26/2019
From:	Blocher E, Lach D, Maher W, Piha A, Ranek N Nuclear Energy Institute
To:	William Burton Division of Materials and License Renewal
Burton W, DMRL/MRPB, 415-6332
References
Download: ML19086A036 (11)

Text

Industry SLR Lessons Learned Albert Piha Eric Blocher David Lach William Maher Nancy Ranek March 28, 2019

©2019 Nuclear Energy Institute

AGENDA P R E - S U B M I T TA L A C T I V I T I E S SUFFICIENCY REVIEW OPEX AUDIT IN-OFFICE AUDIT R E Q U E S T F O R A D D I T I O N A L I N F O R M AT I O N PA R T 5 1 E N V I R O N M E N TA L TECHNICAL ISSUES

Pre-Submittal Activities (Safety & Environmental)

NRC-Industry SLR phone calls have been effective to increase applicant understanding SLR related issues NRC Lessons Learned Memos dated 12/13/2017 was important for understanding NRC expectations Pre- application meetings 6-12 months prior to submittal were a useful forum for common understanding of important issues to be addressed in the SLRA Assignment of the NRC PMs well before the LRA submittal date

©2019 Nuclear Energy Institute 3

Sufficiency Review (Safety & Environmental)

Some sufficiency review issues were unexpected. New technical & environmental content requirements should be communicated during the pre-submittal activities

©2019 Nuclear Energy Institute 4

OPEX Audit (Safety)

The OE audit setup is extensive and expensive for the applicant. It is not clear if a desired benefit for this effort is achieved.

Standardized key word list should be developed and made available prior to the audit (i.e. pre-application)

E-Portal/OPEX information orientation provided by Applicant to Staff reviewers was useful

©2019 Nuclear Energy Institute 5

In-Office Audit (Safety)

The conduct of the In-Office Audit remotely was effective and efficient in addressing NRC questions Use of the E-Portal improved and focused the NRC Staffs review of Applicant support information. However, there may be too much information and should be evaluated.

In-Office Audit session schedule development should be improved and adhered to Timely question availability is essential to best breakout session outcomes (no follow-ups, focused RAIs, etc.)

Use of pre-breakout session calls is a good practice and should continue

©2019 Nuclear Energy Institute 6

In-Office Audit (Breakout Sessions)

(Safety)

NRC questions would benefit from standardization

• Fire Water questions are a good model (timeliness, OE, content, background, AMRs, etc) -i.e., Mechanical Reviews

• Note efficiencies of NRC Electrical Team Review

• Ensures GALL-SLR comment items addressed (Industry &

NRC)

• TLAA/Structural AMPs need to be moved to audit front end Propose use of E-Portal to post and status questions Skype was helpful to orient reviewers to information Use of various input methods (i.e. Supplement, 4D, RAI) for issues was good use of resources

©2019 Nuclear Energy Institute 7

Request for Additional Information (RAI)

(Safety)

Draft RAI discussions very beneficial and focused Time period from initial topic review until official RAI of 3-4 months seems excessive Consider use of Portal information to provide issue clarity for use in SER without the need for RAI Periodic conference calls were very important in maintaining open lines of communications

©2019 Nuclear Energy Institute 8

Environmental Review NEI/NRC development of 17-04 guidance for assessing SAMA new and significant information was useful

• Additional NEI/NRC discussions are recommended to resolve inconsistent interpretations of NEI 17-04 Efficiency improvement measures recommended for On-site Environmental Audits

• More timely delivery of NRC questions/audit needs list to allow pre-Audit preparation of responses

• Better definition of tour needs to improve planning for tour content and resources ©2019 Nuclear Energy Institute 9

Technical Issues (Safety)

Timeliness of supporting NRC reviews:

• MRP-227, Rev. 1

• PWROG Topical Report Reviews (EMA, Material properties, etc.)

• Part 50 reactor surveillance capsule schedule change

• Other plant specific changes (e.g. CFRP Relief)

Interim Staff Guidance Recommended:

• RPV Support Steel/Sacrificial Shield Wall Steel

• EPRI Chemistry Revisions

• Structural Stainless Steel/Aluminum cracking

• Cu (Zn>15%) Cracking Inspection

• M27 Table note 7, IWE UFSAR, etc.

©2019 Nuclear Energy Institute 10

Industry SLR Lessons Learned Summary Pre-submittal activities and meetings were useful Are there more efficient ways to achieve OPEX Audit outcomes?

E-Portal/OPEX information orientation was useful Remote in-office Audit improved and focused NRC Staffs review of Applicant support information In-Office Audit session scheduling should be improved Use of various input methods was good use of resources NRC Audit questions would benefit from standardization Improve NRC timelines in reviewing documents related to the SLRA Timely availability of NRC questions is essential to ER review

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