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Industry SLR Lessons Learned Meeting April 7 Final
	ML20092K606
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/01/2020
From:	Aitken P, Blocher E, Earls C, Gallagher M, Nadar R, Warfel D; Nuclear Energy Institute
To:	William Burton; NRC/NRR/DNRL
	William Burton - 301-415-6332
References
	Download: ML20092K606 (11)
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Industry SLR Lessons Learned Chris Earls Paul Aitken Rounette Nadar Eric Blocher Mike Gallagher Don Warfel April 7, 2020

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 RT 5 1 E N V I R O N M E N TA L S U M M A RY

Pre-Submittal Activities NRC-Industry SLR phone calls have been effective to increase applicant understanding of SLR related issues 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 is helpful Industry suggests assignment of only 1 Safety PM to reduce costs or 2nd Safety PM is classified as In-Training

Sufficiency Review Costs associated with the Sufficiency Review are significantly higher than first license renewal (FLR)

Several Tech Staff reviewers may have started the technical reviews during the Sufficiency Review based on man-hour reports Industry recommends that the assigned PMs complete the SRP Checklist since this is an administrative review and not a technical review

OPEX Audit The OE audit setup used for the Lead Plants was extensive and expensive. It is not clear if the desired benefit for this effort was realized An established and refined set of search terms (e.g. 30) needs to be established to eliminate unproductive time during the development of the SLRA and the OE Audit Reduce OE range to 5 years in lieu of the current 10-year range Based on the Lead Plants OPEX audits, consider having a smaller sub-set of NRC staff (e.g. 1 or 2 staff) work at the station (or the corporate office) to minimize expense burden of remote audit location Industry proposes closing E-Portal access to OPEX information following issuance of the NRC OPEX Audit Report or 60 days following Audit completion.

In-Office Audit The conduct of the In-Office Audit remotely was effective and more efficient than the model used in FLR 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 developed with Applicant input prior to issuance and available 4 weeks prior to start of breakout sessions Consider a graded approach to the In-Office Audit - AMP breakout sessions and prioritize based on:

Reduction of time on previously approved Fleet AMPs

Coverage by current regulatory oversight process

Number and complexity enhancements (none, few, many)

Significance and occurrence of operating experience

Exceptions: standard (e.g. head bolts), configuration,

In-Office Audit (continued)

Earlier engagement on TLAA topics in audit schedule is critical to allow additional time if outside vendor support is needed Timely question availability is essential to best breakout session outcomes (no follow-ups, focused RAIs, etc.)

Last week of breakout sessions should be reserved to address follow-up questions or provide follow-up information.

Use of Clarification Calls is viewed as critical to the overall success of the In-house audit

In-Office Audit (Breakout Sessions)

NRC draft 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 Propose use of E-Portal to post questions and provide follow-up Skype was helpful to orient reviewers to information but not always available for all the break-out sessions Use of various input methods (i.e. Supplement, 4D, RAI) for issues was good use of resources Close Portal following issuance of In-house Audit Report

Request for Additional Information (RAI)

Draft RAI discussions very beneficial and focused Periodic conference calls were very important in maintaining open lines of communications Clarification call participation should be minimized to those that are directly involved in the issue Time period from initial topic review until official RAI of 3-4 months seems excessive Consider use of E-Portal information during In-Office Audit to provide issue clarity for use in SER without the need for RAI Combining the ACRS Full/Sub-committee together if the SER has no Open Items

Part 51 Environmental 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

Use of Environmental Assessment process

Summary Reducing number of assigned PMs Streamlining the Sufficiency Review process Clarifying the purpose and needs during the OE Audits Prioritizing the In-Office Audit reviews based on a graded approach for AMPs Standardizing NRC Audit questions to improve meeting efficiency Improving the In-Office Audit session scheduling Continuing to use all methods of transmitting information in support of SER development Timely availability of NRC questions is essential to ER review Consolidating ACRS Full/Sub-Committee meetings with a SER with no Open Items

ML20092K606

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