ML20236Q249
| ML20236Q249 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1998 |
| From: | Prato R NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9807200096 | |
| Download: ML20236Q249 (45) | |
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N A c-OFFICE OF NUCLEAR REA CTOR REGULA TION Office Letter Transmittal TO:
All NRR Employees
SUBJECT:
NRR OFFICE LETTER No. 805,
- LICENSE RENEWAL APPLICATION REVIEW PROCESS" PURPOSE:
The primary purpose of this office letter is to document the license renewal application (LRA) review process. The office letter contains a description of the basic steps, and the roles and responsibilities of the different staff organizations involved in an LRA review. In addition to this guidance, it contains three attached guides that describe the staff-Ittvel process for reviewing an LRA, the process for identifying, tracking and implementing lessons teamed, and the process for controlling licensing items identified during review and inspection activities. This office letter also provides direction for integrating the requirements and guidance contained in the following documents:
the License Renewal Rule promulgated in Title 10, Part 54, of the Code of Federal Regulations revised May 8,1995, the statement of consideration that act,ompanied the License Renewal Rule as published in the Federa/ Register, May 8,1995, ine draft " Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants," issued in September 1997, Draft Regulatory Guide DG-1047, entitled " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses," issued August 1996, the " Industry Guidelines for implemen'.ing the Requirt.mer.ts o-a 10 CFR Part 54 - The License Renewal Rule," issue.d March 1996, the " Environmental Standard Review Plan," issued !n Never.iber
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1997,and the inspection manual chapter and inspection p ocedures that make up the License Renewal inspection Program 8 "i C-o DIVISION OF S ;i
- l ORIGIN:
Division of Reactor Program Management
[ h C.i h g k.*
CONTACT:
Robert J. Prato,415-1147 SN A
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DATE APPROVED: June 19, 1998 ll,;;
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( (fl AVAILABILITY:
Roberta Ingram,415-1219 t r1 g\\
9807200096 900619 PDR ORG NRRA
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l NRR OFFICE LETTER NO. 805 i
LICENSE RENEWAL APPLICATION REVIEWPROCESS i
f>OLICY As required under Title 10 of the Code of Federa/ Regulations, Part 54 (10 CFR Part 54), from hereon referred to as the rule, an applicant requesting an extension to an operating license for a l
commercial nuclear power plant beyond the original licensing term must submit a license renewal application (LRA). Each LRA must contain general information and conforming changes to standard indemnity agreements as specified under 10 CFR 54.19. An application, under.10 CFR 54.21, must also contain an integrated plant assessment, changes to the current licensing basis (CLB) implemented during the LRA review process, evaluations of time-limited aging analyses (TLAAs), evaluations of 10 CFR 50.12 plant-specific exemptions based on TLAAs, and a final safety analysis report (FSAR) supplement that contains a summary description of the programs and activities for managing the effects of aging and the evaluation of TLAAs for the period of extended operation. Each application will also include technical specification changes and justifications necessary to manage the effects of aging, and a supplement to the environmental report that complies with the requirements under Subpart A of 10 CFR Part 51, as required under 10 CFR 54.22 and 54.23, respectively. In addition to the information submitted in the LRA, an applicant shall retain in an auditable and retrievable form, for the term of the renewed operating license, all information and documentation required by, or otherwise necessary to document compliance with, the provisions of the rule.
OBJECTIVES
- To facilitate the implementation of the rule and the review and inspection of programs and activities associated with an LRA, the NRR staff has developed and issued a draft regulatory guide,
- Standard Format and Content for Applications to Renew Nuclear Power Plant Operating -
Licenses (DG-1047)," a draft of a license renewal standard review plan, " Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), and an environmental standard review plan,
- Environmental Standard Review Plan." DG-1047 proposes to endorse the " Industry Guidelines for implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule" (NEl 9510, Revision 0), and contains staff-approved industry guidance for preparing an LRA. The draft SRP-LR contains guidance for the staff review of an LRA and other documents necessary to demonstrate compliance with the provisions of the rule. In addition, the staff is developing a license renewal inspection program (LRIP) for the verification and inspection of documentation, programs, activities, and material condition of structures and components that are within the scope of the rule. Guidance for controlling and implementing the process used to review LRAs is provided in Attachment 1,
" Guide for License Renewal Application Review Process," of this office letter.
As a result of reviewing and inspecting LRA programs and activities, the staff is expected to identify technical and process concems, licensee commitment, and renewal licensing requirements. Technical and process concems will be documented, controlled, and tracked to resolution. The corrective actions for these concems will be incorporated into the development,
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review, and inspection processes and its respective guidance documents. These lessom leamed will be used to revise the SRP-LR and DG-1047, revise existing technical positions, a
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develop new technical positions, and enhance the LRIP, as applicable. The lessons leamed will also be disseminated to the industry for consideration and potential revision of industry guidance. Guidance for identifying, controlling and implementing lessons leamed is provided in, " Guide for Technical and Process Lessons Leamed for License Renewal," of this office letter.
Licensee requirements and commitments substantially relied upon by the staff in making its findings under 10 CFR 54.29 during the review and inspection of an applicant's license renewal programs and activities will be documented in the renewed license or FSAR supplement as license conditions, technical specification requirements, and FSAR commitments. The
' identification, tracking and resolution of these " licensing items for license renewal" (Ll-LR) are essential to the regulatory process, and contribute to the continued public health and safety.
' Therefois, the staff will make every effort to identify, track, ensure resolution, and verify effective completion of these items. Guidance for identifying, coistiviling, and resolving LI-LR is provided in Attachment 3, " Guide for Renewal Licensing items," of this office letter.
This office letter, along with supporting documentation and tracking systems, provides NRR staff members with the basic framework for processing an LRA, a means for identifying technical and programmatic lessons leamed to ensure a continually improving review and inspection process, 1
and a means of identifying and controlling licensing requirements and licensee commitments associated with a renewed license. The goals of this office letter include the following:
Ensure the continued health and safety of the public.
Improve communication and efficiency within NRR, and between NRR and the Regions.
Implement a documented and controlled license renewal review and inspection process.
Provide the staff with a process for identifying and controlling licensing items.
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- Develop a consistent, effective and efficient LRA review process.
Develop complete and consistent LRA safety evaluations.
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Develop a complete, effective and efficient LRIP.
The attached guidance documents, " Guide for License Rene~wal Application Review Process,"
" Guide for Technical and Process Lessons Leamed for License Renewal," and " Guide for Renewal Licensing items," provide a description of the processes used to accomplish th7se specific goals.
RESPONSIBILITY AND AUTHORITIES l
All NRC staff members that participate in the review and inspection of license renewal programs and activities are responsible for reading, understanding, and applying the guidance contained
' in this office letter including the attached gu! des.
r l.
ROLES AND RESPONSIBILITIES FOR THE REVIEW OF LICENSE RENEWAL APPLICATIONS The following information describes the roles and responsibilities for the staff organizations that participate in the technical review of an LRA.
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A.
GENERAL PROCESSING OF A LICENSE RENEWAL APPLICATION
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l Division of Reactor Project Manaaement (DRPM)
The Director DRPM is responsible for the overall development and implementation of the program and activities relating to license renewal.
I License Renewal Proiect Directorate (PDLR)
The license renewal Project Director (PD) is responsible for the general oversight of NRR activities related to processing of an LRA, including LRA acceptance reviews, integrated plant assessment reviews, environmental reviews, and inspection activities.
j The license renewal PD is responsible for providing routine direction and coordination of process development activities, overall regulatory compliance (with assistance from the Office of the General Counsel), and the review and inspection cf license renewal programs and activities.
Generic issues and Environmental Pro _iects Branch (PGEB)
The PGEB Branch Chief with assisstance from technical staff is responsible for license renewal environmental reviews and preparation of supplemental environmental impact statements consistent with regulatory requirements and the license renewal process.
Associate Director for Technical Review (ADT)
The Associate Director is responsible for the overall development of safety evaluations associated with the review of LRA consistent with regulatory requirements and the license renewal process.
T_ echnical Divisions / Branches The technical divisions and branches shall familiarize themselves and perform their reviews consistent with the requirements of the rule, the Commission guidance provided in the statement of consideration that accompanied the rule as published in the Federal Register (Vol.60, No.88) on May 8.1995, the review guidance in the SRP-LR, the
' tandard format and content guidance documented in DG-1047, and the industry s
developed guidance documented ir; NEl 95-10.
M Reoional Administisicra The Regional Administrators are responsible for the overall implementation of license
. renewalinspection activities.
B.
WORK PLANNING PROCESS
- License Renewal Proiect Directorate
' The license renewal PD is responsible for the general oversight and implementation of license renewal work planning activities.
The license renewal PD will provide direction and assistance in the development and approval of work plans to ensure effective allocation of resources, responsiveness to applicants' requests, and the quality of work.
Technical Divisions / Branches The technical branches will work with the license renewal project managers (PMs-LR) and PDLR, Engineering Section, as described in this office letter or as requested by PDLR, to help scope and schedule review activities to ensure an effective,' efficient and timely review of LRA submittals.-
Branch chiefs will assist in the development and approval of work plans, as requested by the PM-LR, to ensure effective allocation of resources, responsiveness to applicants'
- requests, and the quality of work.
. C.
PUBLIC NOTIFICATION AND HEARING PROCESS License Renewal Proiect Directorate The license renewal PD is responsible for general oversight of public notifications and stafi hearing activities as they relate to license renewal. Activities that are part of the public process include the following:
Initiate public notifications of license renewal activities consistent with existing NRC policies and procedures.
Coordinate the resolution of public comments relating to license renewal.
Coordinate staff activities relating to the hearing process.
Technical Divisions / Branches Assist in preparing the Federal Register notifications, resolving public comments, and participating in the hearing process.
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D.
LICENSE RENEWAL APPLICATION REVIEW AND INSPECTION PROCESS License Renewal Project Directorate The license renewal PD is responsible for the overall development and implementation of the processes and activities involved in the staff review of an LRA that includes the following:
Coordinate activities associated with license renewal technical reviews, environmental assessments, and site inspections.
1 Assemble the final SER from the individual SEs and monitor resolutions of issues relating to the technical review.
Coordinate communications among the technical and supporting branches, regions, and the industry.
Track, monitor, and report progress associated with staff review activities.
Develop, maintain, and control license renewal guidance documents used for the review and inspection of license renewal programs and activities such as the SRP-LR and DG-1047.
Ensure that lessons leamed identified during the review and inspection of license
- i renewal programs and activities are incorporated into the license renewal guidance documents and inspection procedures.
Ensure that regulatory bases are clearly articulated in the safety evaluation (SE).
Generic lasues and Environmental Projects Bra 0Gb PGEB is responsible for the following activities:
Perform environmental reviews and prepare supplemental environmental impact statements consistent with the requirements of 10 CFR Part 51 and Part 54, the applicable guidance documents and negotiated work plans.
1 Coordinate communication relating to the environmental review with PDLR.
i Develop, maintain and control license renewal environmental review guidance documents such as the Environmental Standard Review Plan used for the review and inspection of license renewal programs and activities.
Identify process concems and the need for staff positions as a result of participating in license renewal review activities to improve existing requirements and guidance for developing, reviewing and inspecting license renewal programs and activities.
Ensure that the technical bases for staff conclusions are clearly articulated in supplemental environmental impact statements.
Technical Divisions / Branches The technical branches are responsible for the following review activities:
Perform technical reviews and prepare complete and accurate input for SEs or final SER consistent with license renewal guidance documents and negotiated work plans.
Will resolve technicalissues and prepare complete and accurate input for SER supplements.
Coordinate all communication with applicants through PDLR.
Support license renewalinspection activities in areas of expertise as approved by 1
NRR management.
Follow staff guidance documented in this office letter, SRP-LR, DG-1047, and inspection procedures.
Identify process concerns and the need for staff positions as a result of participating in license renewal review activities to improve existing guidance for developing, reviewing and inspecting license renewal programs and activities.
Ensure that the technical bases for staff' conclusions are clearly articulated in SEs and SERs.
Reaions The regions will perform inspections of license renewal programs and activities consistent with the requirements of the rule and guidance documents.
NRR Manacement Division directors, PDs, branch chiefs, and the regions will assist in resolving issues and concems relating to the license renewal review process including the scope of reviews, schedules, resource allocation, priorities and technicalissues.
E.
SAFETY EVALUATION REPORT REVIEW PROCESS License Renewal Project Directorate The license renewal PD is responsible for the following SER Activities:
t Ensure that the review and concurrence chain is complete and correct.
Ensure that the SER status is monitored through the review and concurrence process.
Ensure concerns are identified and resolved in a timely manner.
Ensure that the Office of the General Counsel (OGC) reviews all SEs for legal sufficiency.
Ensure that each LRA and associated SER is referred to the Advisory Committee on Reactor Safeguards (ACRS) for reviews and reports as required under 10 CFR 54.25. ACRS license renewal reports will be recorded and available to the public to the extent security classification allows.
Offices / Divisions / Branches Other offices, divisions, and branches are responsible for reviewing and concurring in a timely manner consistent with the established schedule.
II.
PREPARING A FINAL STAFF RECOMMENDATION FOR A RENEWED LICENSE The license renewal coordination, review, and inspection activities performed by DRPM, ADT and the regions are used in preparing a final staff recommendation for a renewed license. The staff's recommendation to grant or deny an application for a renewed license will be based on the review of the general information submitted under 10 CFR 54.19 and the technical review of the integrated plant assessment submitted under 10 CFR 54.21. The technical review will result in an SER that typically will be divided into systems, structures, components and/or commodity groups, sod will evaluate the completeness of the scope of systems, structures, and components, the aging effects identified, the adequacy of aging management programs, and the demonstration of the effectiveness of each program. The technical review will also evaluate CLB changes implemented during the LRA review process, TLAAs as defined under 10 CFR 54.3, TLAA exemptions granted under 10 CFR 50.12, and the FSAR supplement submitted under 10 CFR 54.21(d). in addition to the technical review, the environmental review, inspection activities, and the public hearing process will play a major role in granting or denying a renewed license REVIEW PROCESS An LRA can be formatted in a number of different ways. The format used by an applicant can affect the process used to review and inspect the license renewal programs and activities. As the staff pains experience reviewing these programs and activities, the lessons learned will be incorporated in the staff and iric'mtry guidance to ensure that an effective, efficient and consistent process is implemented for the review of LRAs, and that applications are eventually submitted in a standardized format.
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Table 1 is a listing of the basic steps involved in the review of an LRA and the groups primarily responsible for each step. More complex systems or commodity groups may require additional activities. The schedule for a review may vary based on the complexity of the review, staff priorities at the time of the review, and the number of active applications. A single submittal of a completed application may be handled in a number of ways depending on the format of the LRA, but is expected to result in a series of reviews by the different technical branches that will be
. collated into a single SER.
License renewal inspection activities will not begin unti! si sufficient portion of the technical review is completed.. The PMs-LR will coordinate schedulirg of inspection activities based on the progress of the technical reviews. Scheduling inspection activities will require coordination
~ with regional staff as well as headquarters support. The inspection process is described in the inspection manual chapter and inspection procedures for license renewal.
All scheduling activities should be negotiated among the PM-LR, the technical branch chiefs, and the region assigned inspection responsibilities. Schedules will be based on the staff priorities at the time of review, and the overall schedule for the review of an LRA, as approved by NRC management, is on the order of 3 years or less.
STAFF ACTIVITIES The guides attached to this office letter describe the LRA review process; the process that will be used to control the " feedback" of general information, lessons learned, and staff positions into the license renewal guidance documents; and the identification and tracking of renewal licensing items associated with the granting of a renewed license.
The staff activities for processing an LRA include the following:
work planning process, which includes developing resource estimates, developing schedules, assigning review responsibilities, and coordinating review activities involving different divisions and branches within NRR, the regions, and other NRC offices public notification and comment resolution technical review
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environmental review SE development supplemental environmental impact statement development SE/SER review and concurrence activities license preparation and issuance 8-l i
Table 1 License Renewal Process Process activities Responsible Receive Renewal Application PDLR Notice Application Tendered PDLR Complete Acceptance and Docketing PDLR Public Meeting & EIS Scoping PDLR/PGEB Staff Complete Technical RAls Technical Branches Staff Complete Environmental RAls PGEB Applicant Complete Technical RAI Response Applicant Applicant Complete Environmental RAI Response Applicant Staff Complete SER and identify Open items NRR Staff issue DES for Comment PGEB/SCSB/SPSB Public Meeting PDLR Complete DES Comments Applicant Applicant Complete Response to Open items Applicant Staff issue SER and FES NRR Staff Complete inspection Activities Regions /NRR Staff ACRS Meeting NRR Staff Hearing Support NRR Staff Commission Decision Commission' Issue Renewed License NRC
.g.
The license renewal Lessons Leamed Process (LLP) is used to document, control, track and bring to final resolution license renewal related lessons leamed and staff positions. The LLP includes the following activities: documenting staff positions, revising existing guidance, or providing additional guidance within the guidance documents for developing, reviewing and inspecting an LRA.
The Renewal Licensing items Process is used to document, track, and ensure that all licensing items are addressed in the renewed license.
EFFECTIVE DATE This office letter is effective immediately.
REFERENCES 1.
10 CFR Part 54, " Requirement for Renewal of Operating Licenses for Nuclear Power Plants
- 2.
- Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions" 3.
" Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants," draft 4.
DG-1047, " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses" 5.
" Environmental Standard Review Plan
- 6.
NEl 95-10, " Industry Guidelines for implementing the Requirements of 10 CFR Part 54 -
The License Renewal Rule" Attachments
- 1. " Guide for License Renewal Application Review Process"
- 2. ' Guide for Technical and Process Lessons Leamed for License Renewal *
- 3. ' Guide for Renewal Licensing items" cc:
L.J. Callan, EDO OGC H.L. Thompson, Jr., DEDR Public A.C. Thadani, DEDE ClO P.G. Norry, DEDM CFO Regional Administrators SECY United States Nuclear Regulatory Commission I
i
'l Guide for License Renewal i
Application Review Process
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I i
License Renewal Project Directorate Office of Nuclear Reactor Regulation March 1998 i
Anachment i
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1.0 Introduction This guide, along with supporting documentation and tracking systems, provides Nuclear Reactor Regulation (NRR) staff members with a basic framework for the review of a license renewal application (LRA). This guidance is for use by Project Directors (PDs), Project Managers (PMs), and technical staff and management. This guide provides a general description and the basic requirements for the process that is expected to be followed.
However, it is recognized that flexibility in planning and executing the review of an LRA is needed. This guide is intended to allow that necessary measure of flexibility.
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1.1 Objectives
' The objective of this guide is to enhance NRR effectiveness, efficiency, and consistency in responding to the needs of both the public and the licensee as it relates to the technical and environmental review of LRAs. Inspection guidance is provided in the applicable inspection manual chapter and inspection procedures and will not be addressed in this office letter.
Specific objectives include the following:
Ensure the continued health and safety of the public.
Improve communication and efficiency within NRR.
Provide the staff with an improved framework for processing LRAs.
Develop a consistent, effective and efficient method for developing LRA safety evaluations (SEs) and supplemental environmental impact statement.
1.2 Process Overview
- The LRA review process is administered by NRR, Division of Reactor Program Management (DRPM) under the License Renewal Project Directorate (PDLR) and the Generic issues and Environmental Branch (PGEB). This process is primarily implemented by NRR, Associate Director for Technical Review (ADT) and PGEB with PDLR support. Contractors, other NRR divisions, Office of the General Counsel (OGC), and potentially other NRC offices may also be asked to support an LRA review.
The LRA review process has been estimated to be a 3-year process involving the technical and environmental reviews of an LRA, and the inspection and verification of site-specific programs and activities, and the material condition of structures and components within the scope of the l
rule. LRA reviews are performed by NRR headquarters and include the review of the integrated i
plant assessment (IPA), the supplemental environmental report, changes to an applicant's current licensing basis (CLB) implemented during the LRA review process, time-limited aging analyses (TLAAs) as defined under 10 CFR 54.3, and the final safety analysis report (FSAR) supplement that contains a summary description of the programs and activities for managing the effects of aging and the evaluation of TL.AAs for the period of extended operation. In addition, the reviews of an applicant's scoping methodology is a necessary activities associated with the review of LRAs.
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l The project managers for license renewal (PMs LR) and applicants should be in regular contact to discuss NRC's ongoing review activities. The PM-LR role is to coordinate all activities
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associated with the staff's review of an application. The PM-LR will ensure that the guidelines i
associated with this office letter and the principles of good regulation are adhered to throughout the process.
An applicant is expected to submit a complete LRA at the time of application, but the NRC has l
the option to accept partial submittals. In the early stages of implementing 10 CFR Part 54 for l
the first group of applicants, the staff may accept partial submittals that address license renewal for individual systems, structures, components or commodity groups. As the license renewal process matures, the staff expects an applicant to submit an almost complete application with a schedule for submitting any missing information. For applicants that ultimately meet the requirements of 10 CFR Part 54, the staff will work toward developing a final safety evaluation report (SER) and a supplemental environmental impact statement that contain the staff's recommendation and justification for approving a renewed license. For LRAs that are submitted in small portions, a number of intermediate steps may be added to the process including the development of individual SEs, and public meetings between the staff and the applicant on individual SEs that will eventually serve as input into the final SER.
I The process employed for the review of an LRA can be characterized by the activities shown in Figure 1 that include the following:
acceptance review and docketing work planning public notification.
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environmental review
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technical review review and concurrence a
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issuance of a final SER and supplemental environmental impact statement ACRS review and report i
public hearings
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Figure 1. LRA Review Process Industry / Applicant Applicant: Tender
),
Activities Application wP 1r Obtain TAC (s) 1r eject IP c Acceptance Review Return to Applicant
.A w
Accept Notification &
IP Environmental Review Opportunity for "j
Public Hearing 1r 1r Develop Contractor W rk Planning Scope, Schedule, and Public Hearing S0W Resources ir u
ir DSSA IPA /TLAA DE IPA /TLAA Review
> PLDR Support +- r >
Review (SRP LR)
(SRP LR) t Gontractor Support IP 4
- 9 u
RAls v
IP Response to RAls u
SER Development v
LILR Final SER
.lssue Points IP lg IP ACRS Review / Report b
t
%c gj7
\\:
License Renewal Action LlLR Renewed License items ti.tn xff wu 3-
These steps are described in more detail throughout this guide. Section 2.0 discusses the work planning process, which includes the acceptance review, docketing requirements and develooing a work plan; Section 3.0 discusses the public notification process; Section 4.0 dis-cusses the SE process; Section 5.0 discusses the review and concurrence process; and Section 6.0 discusses the ACRS review and reporting requirement. The guidance for the review of the environmental portion of the LRA is contained in Office Letter 906. The technical and environmental reviews are described in detail in the respective standard review plans.
2.0 Work Planning Process Planning the review activities for an LRA is a critical step in ensuring that the work is completed in a timely and effective manner. The environmental review will be performed by PGEB with coordination required between PDLR and PGEB. T.".e IPA portion of an LRA typically will be divided into sections and distributed to the different technical branches for review by staff members with expertise in the areas addressed by each section. An IPA is expected to be submitted by systems, structures, components and/or commodity groups. The manner in which the application is formatted can significantly affect the staff's review activities, and a good work plan is especially important to maximize the effective use of staff resources. Figure 2 displays the basic steps that need to be performed by PMs-LR in developing a work plan for the review of an LRA. The basic steps are as follow:
1.
Upon an applicant tendering an LRA, the PM-LR will obtain technical assignment control (TACs) numbers through the Workload Information and Scheduling Program (WISP).
I This provides a means for fee recovery and tracking resources and work activities.
2.
The PM-LR will coordinate an acceptance review of the LRA submittal (s) within 30 days of the date the materialis tendered by the applicant.
3.
If the application contains the necessary information, the PM-LR will docket the application and make a public notification of the applicant's intent to renew its license.
4.
After determining that an application contains the required information, the PM-LR will develop a plan that defines the scope, resources, and schedule for the remaining work.
5.
The PM-LR will coordinate with the technical branches to achieve and document a mutually agreed-upon work plan. The PM-LR should ensure that key elements of the work plan are captured in the WISP system. This information may be documented in a work request.
l 6.
The PM-LR will coordinate the activities documented in the work plan and monitor the progress of these activities.
The remainder of this section provides additional guidance for performing the activities for the planning process identified above.
Figure 2. License Renewal Application Work Planning Process l
l Obtain TAC Number 1r Review Application Retum to Licensee a
No i
1r Complete and No issues Resolved Acceptable?
Yes 1r Docket Application ir Work Activities 1r Coordination and Monitor 1
6 _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - _ _
2.1 TAC Numbers Technical Assignment Control numbers are used to categorize work and determine fee recovery, The information Management Branch (PIMB) within NRR routinely issues guidance for obtaining TAC numbers. Procedures and responsibilities for obtaining TAC numbers through WISP are detailed in the "NRR Office Workload Procedures Manual" attached to Office Letter
- 303, 2.2 Acceptance Review An initial review of a completed application or partial submittals for a renewed license to determine acceptability for review is expected to be completed within 30 days from the date of receipt. The minimal acceptance requirements for applications are described in 10 CFR 54.19, 54.21, 54.22, and 54.23, the " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses" (DG-1047), and the draft of the standard review plan,
- Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR). DG-1047 proposes to endorse the " Industry Guidelines for implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule" (NEl 95-10, Revision 0), and contains staff approved guidance for preparing an LRA that needs to be considered when assessing an application for completeness. Speedic items that must be included in an LRA are
- identified in the SRP-LR, Table 1.1-1, " Review Checklist for Docketing of Timely and Sufficent Renewal Application." For partial application submittals for individual structural, component, or commodity group reports, Table 1.1-1 should be used as appropriate for the material being submitted.
If the application does not contain the necessary information, the PM-LR should contact the licensee and arrange for'the information to be submitted. If the missing information cannot be provided in a timely manner, or if a sufficient amount of information is missing, the staff can reject the application and retum it to the applicant.
If the necessary information is submitted, the PM-LR will send the applicant a letter of acceptance and docket the application. At the time an LRA is determined to be acceptable, public notification of the applicant's intent to renew its license needs to be made. Public notification is described in more detail in Section 3.0 of this guide.
2.3 Work Plan Upon accepting the application for docketing, the PM-LR will develop and document a plan for processing the application. This plan is intended to define the scope of the rev'ew, resources needed for the review, and the schedule for completion of the review. Because the technical branches will be preparing the individual SE and the SER, the technical branches should be
- directly involved in preparing the work plan, and must concur with the estimates of scope, resources, and schedule.
PMs-LR should give special attention to those reviews that involve multiple branches. PMs-LR j
need to ensure that the scope and schedule for each reviewer are well defined and understood.
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Each work plan should include a listing of the technical branches that will provide input into the i '-
i
d SE. Disagreements relating to the scope, schedule and/or assignments of reviews need to be identified and resolved early in the work planning process.
i The work plan will clearly identify the need to perform SEs based on the requirements of the rule, the SRP-LR and other license renewal guidance documents, as applicable. NRR employees involved in LRA reviews are required to document all concems cr the need to enhance the guidance documents using the Lessons Leamed Process (LLP) defined in
' Attachment 2 of the office letter.
2.3.1 Scope of Review The technical review of an IPA will, in most cases, represent the bulk of the technical effort that will be expended in processing an LRA. The SRP-LR should be used as guidance in determining the scope of the review. Thus, carefulidentification of what will be addressed in this review is central to effective planning. The basic scope of a technical review required for an j
LRA includes the review of the following license renewal requirements:
a description and justification for the methodology used to determine the scope of j
systems, structures, and components within the scope of the renewal the identification and listing of the structures and components requiring an aging management review and its intended functions that are shown to fulfill the functions under 10 CFR 54.4 without moving parts or a change in configuration or properties the identification of aging effects applicable to those structures and components requiring a
an aging management review a demonstration that the effects of the aging will be managed during the period of extended operation i
an evaluation of TLAAs and applicable 10 CFR 50.12 exemptions t
i an FSAR supplement that provides a summary description of the programs and activities used to manage the effects of aging 2.3.2 Resources The primary resource requirements for the myiew process include the time expended by the
- PMs-LR and PDLR's Engineering Section, NRR technical branches, and contractor support. To ensure the efficient and effective use of these resources, initial estimates of staff resources for the individual review and support activities are required.
The overall coordination of all LRA review activities is the responsibility of the PM-LR. The primary responsibility for preparing individual SEs and/or SERs will be assigned to the technical branc.hes within NRR, as applicable. The environmental report supplement review will be performed by PGEB.
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l.
PDLR, Engineering Section, will perform the review of the applicant's IPA methodology with I
assistance from the technical branches within NRR. In addition, PDLR, Engineering Section, will serve as the focal point for implementation issues relating to license renewal, and will maintain the guidance documents such as the SRP-LR and DG-1047. The Engineering Section will also serve as the focal point for coordinating activities relating to OGC interpretation of the rule.
l NRR technical branches will perform the technical reviews, develop RAls, and provide.
l technically complete and accurate input for applicable SEs and/or the final SER. The technical l
branches will also resolve technical issues and provide input into supplemental SER.. PMs-LR are to coordinate team meetings with the reviewers to ensure each member understands the.
scope of their assignment and the expectations for their input into the final SE. A member from l
PDLR, Engineering Section. should be included as a team member to provide implementation guidance associated with the rule and guidance documents.
2.3.3 Scheduling The technical branches will review all applicable IPA material, and develop SEs and/or an SER as agreed upon during the work planning process. Schedules agreed upon will be met, or the l
PM-LR will be notified of any needed charges in the schedule as early in the review process as practical. Scheduling will be based on NRR pnorities and work load. Conflicts between pnonties and schedule need to be identified as early in the process as possible and may require NRR management involvement to resolve.
l 2.3.4 - Documentation The SEs will be prepared in accordance with the SRP-LR. The level of detail of a review should l'
be commensurate with the requirements of the rule and the guidance provided in the SRP-LR l
and DG-1047. Information substantively relied upon by the staff in making a finding under ~
10 CFR 54.2g must be submitted on the docket, and the bases for the staff's conclusion should be appropriately documented in the SE. However, information that exists on the docket or that is available in the public domain may be referenced by the applicant and need not be resubmitted for the purpose of the LRA review. Some information may be more appropriately verified by the inspection program. Accordingly, site visits may be necessary to determine the amount and kind of information that is necessary.and sufficient to support the findings in an SE. This experience should also be considered as possible improvements to the SRP-LR.
l 2.4 Work Request Form A sample of a Work Request Form is presented in Attachment A to this guide. Work Request Forms may be used to coordinate the planning of LRA reviews performed by technical branch L
personnel. PMs-LR are responsible for initiating work requests when applicable. PMs-LR will i
submit work requests to the appropriate technical branches that are partially filled-in with the
. following information: (1) the administrative information, (2) the background information and (3) the description of work being requested. Those portions of _the work request that involve scheduling and assigning resources will be filled out after the PM-LR and the technical branch chief (s) meet and negotiate a schedule and resource allocation that are mutually agreeable. If an agreement cannot be reached, the concems will be elevated and r6 solved by NRR
, l l
i i
l management. Additional guidance for the completion of work requests is provided in Attachment A.
3.0 Public Notification The public notification process is the primary mechanism for the NRC to meet its goal regarding openness to the public. The staff is required to make a number of public notifications relative to the receipt of an LRA, the docketing of that application, and opportunity for hearing as part of the l
process for granting or denying the issuance of a renewed license. As required under 10 CFR 2.101(a)(4), the tendering of an application for an operating license for a utilization facility will be formally docketed upon receipt and made available for public inspection. The regulation under 10 CFR 2.101(d) requires that notice of docketing (of the public health and l
safety, common defense and security, and environmental parts) of an application for a license be published in the Federa/ Registerthat states the purpose of the application and the location at which the proposed activity would take place. Generally, within 30 days from the receipt of an application for a renewed license, the staff will make a determination as to the completeness and acceptability of the application. Upon determining the completeness and acceptability of the application for a renewed license as required under 10 CFR 2.101 (a)(3), a notice of proposed action to accept the application and to give notice of opportunity for hearings will be published in the Federa/ Register as soon as practical as required under 10 CFR 2.105(a)(10). Historically, i
for license applications, the notice to accept an application and the notice of opportunity for l
hearing is made at the same time. 'However, these notices can be made separately based on l
the Commission's determination as to the timing required under 10 CFR 2.105(a)(10). All public notifications will be reviewed by OGC.
In addition to public notification of an applicant's intent to renew its operating license and i
associated hearing, notifications of public meetings that take place during the LRA review process also need to be made in accordance with the guidance in Management Directive 3.5.
4.0 Safety Evaluations l
The final SER will provide the technical, safety, and legal basis for the NRC's disposition of a l
license application. Individual SEs and the final SER should provide suffic.ient information to explain the staff's rationale to someone unfamiliar with the licensee's request. SEs must include a description of the proposed areas of review, the regulatory requirements related to the area under review, and an evaluation that describes how the applicant satisfies the applicable l
regulatory requirements.
Given that the final SER serves as the record of the staffs position on the information relating to the requirements for a renewed license, the information relied upon in the SER must be placed on the docket. This is not meant to hamper questions and clarifications by telephone or in meetings. However, if the information is important in the staff's decision-making process, it must be formally provided by the licensee. Specific guidance for performing a safety evaluation is l
provided in the SRP-LR and will not be addressed in this guidance document. The remaining i
guidance will address general guidance regarding SE planning and control, and the recom-mended format of SE reports.
-g.
4
- 4.1 Evaluation Process individual SEs and SERs will be prepared by technical staff personnel, with or without contractor assistance. The process for planning and controlling SE work was provided in Section 2.0 of this guide.
Initial development, negotiation, and agreement of evaluation work plans are addressed in -
Section 2.3. Changes to the sgreed upon work plan are sometimes necessary due to changes in scope, priorities and work loads. As soon as possible after determining that a revision to the schedule is necessary, the PM-LR or technical branches should contact the other party to discuss the proposed revision to the plan. The revision should be documented in a Work Request or the work plan. In order to minimize surpnses, the PM-LR should also remain cognizant of the status of ongoing reviews by monitoring WISP and having periodic discussions with the technical branches. For those cases in which the PM-LR and technical staff cannot agree on a revised schedule, the problem should promptly be brought to the attention of management, as appropriate.
Occasionally, contractors will be needed to provide technical expertise to support technical branch reviews or to perform independent SEs. Statements of Work for contractor support will be developed during the initial planning process or during the revision of an existing plan. PDLR or technical branches (depending on who is funding the contract support) should treat the '
contractor as a technical staff reviewer with respect to scoping, scheduling, resources and coordination activities. PMs-LR have to keep in mind that all communications with a contractor need to involve the staff member designated as the contract technical monitor. PMs-LR need to w6rk with the technical monitor to establish the level of review, schedule, and the statement of
' work..
4.2 Safety Evaluation Format The technical review of an LRA will result in a final SER. If an applicant submits a complete or partial LRA, the review process can differ significantly. A complete application typically will result in multiple SEs incorporated into a single final SER. The partial submittal approach will result in multiple SEs that will be used to support the final SER. The latter will result in a number of additional steps. For partial submittals, individual draft SEs may be developed and forwarded to the applicant for ' review and resolution of outstanding items. Final SEs are eventually issued j
for each application reviewed. Upon completing the review of all the individual SEs associated
- with a complete LRA, an SER is drafted. Comments are resolved and the SER is forwarded to the ACRS for review and report. Upon resolution of any final comments or agreements between the staff and applicant to delay the resolution of an item, the SER will be revised and sent -
- through the review and concurrence process for final approval.
The basic format of a final SER is expected to follow the SRP-LR. In addition, Attachment B of this guide, " Safety Evaluation Form and Content Template," contains a template for a typical SE including the titles for the sections / subsections, a description of the content, and the primary responsible group for that section/ subsection. Attachment B will be included in each work plan i
or work request and should be followed unless determined not to be applicable to the application under review. This determination should be discussed during the planning process, if the 10-1
. format is found to be not applicable after the planning process, the reviewer needs to contact the PM-LR to discuss a change or omission to the deccribed format. Additions to the format need not be discussed unless the reviewer desires to do so. The sections and subsections and its description will be used by the PM-LR to quickly assess the completeness of the SE during his initial review.
4.3 Safety Evaluation Content An SE will be performed in accordance with the requirements of the rule and the guidance provided in the SRP-LR. Currently, the SRP-LR is a draft and will be updated as corrections, additions, and enhancements are identified. Technical staff members shall submit concems and recommendations to PDLR using the guidance in this office letter, Attachment 2,
- Guide for Technical and Process Lessons Learned for License Renewal." In addition to the rule and the SRP-LR, reviewers need to be familiar with the statement of consideration that accompanied the -
publication of the rule (60 FR 22461, dated May 8,1995), the draft regulatory guide,
- Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses" (DG-1047), and the " Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule" (NEl 95-10, Revision 0).
5.0 Review and Concurrence l
Review and concurrence is the process by which the quality and consistency of SEs and SERs l
are verified. Concurrence involves obtaining the approved signatures required for issuance.
The PM-LR is responsible for ensuring that appropriate concurrences are received for the l
renewed license. When an SE/SER is prepared by multiple technical branches, the PM-LR has the responsibility for integrating it into a single evaluation package. If, during this integration, the l
PM-LR makes substantial changes to any ir.put from other branches, the technical reviewer involved in the preparation of the original input should be an early reviewer in the concurrence chain to ensure that there is no change in technical content or original intent. In any case, the concurrence page should indicate the technical branches that contributed to the final package (consistent with the concurrence requirements in office letter 101). Input from a technical branch which is used with only minor editorial changes does not need additional concurrence from the
- originator (s). When originator concurrence is not necessary, include the appropriate originators in a concurrence block with a note indicating the date input was provided and that no major changes were made. Upon completing the integration and technical review process, the initial SE will be forwarded to the PM-LR for final approval.
Figure 3 diagrams the considerations that should be made in determining who should be l
included on the concurrence chain for the final approval process. When the concurrence chain is determined, the name, title, and organization of each individual should be entered on the SE transmittal letter routing form. SEs prepared by technical branches will be reviewed by the PM-LR and PDLR, Engineering Section. The PM-LR may request that a technical editor review the SEs. Comments typically will be incorporated by the technical reviewer for the SE. If a substantive change (s) is made to an SE, it will be routed back to the appropriate technical branch chief (s) for reconcurrence with a description of the change (s), and the reason for the change (s).
1 _ _ -________- _ ___ ___
l Figure 3. Review and Concurrence Process l
^
\\
l initial SER 1r LA Concurrence
....................l l
........Y........
Y Technical Editor PM Concurrence Review l
I J
+
1 PDLR Technical Section Concurrence 1
1r Special Concurrence Guidance ?
l l
No Yes y
l Obtain Additional Concurrences i
1r l
OGC Concurrence l
l 1r PD Concurrence 1r FSER 1r ACRS Review / Report 1r Renewed License I
l An LA should perform an initial review and concurrence before sending the SE to other NRR organizations. During this review, the LA ensures that the SE is complete, in the correct format I
for text and graphics, and that all the required steps have been completed.
4 The OGC must concur on all license renewal SEs, unless an explicitly defined exception is documented in a memorandum of understanding between NRR and OGC. The OGC reviews the SE and/or SER for legal defensibility and completeness.
The license renewal PD will approve all SEs unless designated otherwise in the work planning process. All SE licensing items that result in a license condition, technical specification requirement, or FSAR commitment will be documented and controlled by the License Renewal Items Process.
6.0 Public Hearings The hearing process is approximately a 16-month process. The OGC is primarily responsible for coordinating the activities associated with the hearing process but will require technical support from the staff. The hearing process will also involve the public, the applicant, an Atomic Safety and Licensing Board (ASLB), and the Commission.
The hearing process begins with a public notice of an opportunity for a hearing. If hearing requests are filed, an ASLB is appointed. The staff and applicant then respond to the petition for hearing. Contentions are filed, and the staff and applicant respond to the contentions. A
~
prehearing conference is held, and the ASLB rules on the intervention. If denied intervention, appeals to the Commission may be filed by interveners. If a hearing is to take place, the l
following legal steps are taken: discovery, pre-file testimony, and pre-trial briefings. These steps are followed by the hearing, the identification of proposed findings, and the post-trial briefings.
The applicant responds to the proposed findings filed by the intervener. The ASLB then issues its initial decision. Petitions for Commission review of the ASLB decision may be filed. The i
l Commission makes a decision on the ASLB decision and decides whether to issue the renewed I
license.
i
't.0 ACRS Review As required under 10 CFR 54.25, each LRA is to be referred to the ACRS for review and report.
The associated SER will also be referred to the ACRS. ACRS license renewal report will be recorded and available to the public to the extent security classification allows.
I i (
J
s SAMPLE WORK REQUEST Date Prepared: January 14,1998 Raouested Target Date: June 30,1998 WORK REQUEST TO:
Goutam Bagchi, Chief. ECGB M/S: 0-7H15 Ledyard B.(Tad) Marsh, Chief. SPLB M/S: O-8001 TttRU.
Christopher 1. Grimes Director, PDLR
' FROM:
David Solorio, Project Manager, PDLR 415-1973 M/S: 0-11D23 YAnston Liu, Technical Lead, PDLR 415-3148 M/S: 0-11D23 TITLE / TAC:
Calvert Chffs Component Supports, Sechon 3.1, commodity report for license renewal: MA0291 -Unit 1, MA0292 -Unit 2, and M99204 -generic Deectlption of Review Raquested:
Review the subject BG&E report to determine if the scope of components, aging effects, and aging management activibes proposed satisfy the requirements of Part 54 such that a $54.29 finding can be made with any necessary conditions or open items. Prepare a safety evaluaton (SE) input according to your branch technical review responsibilities and the draft SRP-license renewal to describe and justify the basis for the staffs condusion (note: Sechons 2.0 and 3.0 are applicable to all reports). Your SE will be formatted in accordance with the attached template. Requests for additionalinformabon necessary to prepare the SE or to prepare for site reviews, will be coordinated through the PDLR Project Manager. The PDLR Project Manager & PDLR Technical Lead will assemble a complete draft of the SE for management review and comment. Separately, provide any comments on any programmatic lessons that should be included in the SRP and inspechon Procedure for License Renewal to PDLR.
Priority: 2 Bases for Priority: License Renewal Technical R6 mrt Review Picase indicate your acceptance of the Work Request and Target Date by signature and assignment of reviewer (s). Work packages should be retained by reviewer (s).
Priority Determination Acceptable: YES,_ NO_ ALTERNATIVE PRIORITY Target Date Acceptable: YES _,, NO _ ALTERNATIVE TARGET DATE
/
/
Estimated levelof effort:
staff 4mrs Assigned Reviewer (s):
Phone:
Phone:
Sechon Chief Signature:
Date:
I /
l Branch Chief Signature:
Date:
/ /
l RETURN TO PM WITHIN 5 WORKING DAYS OF REClilPT l
If a revision to previously approved schedule:
New Completion Date:
/
/
or New Priority-Reason for Revision:
l
- Section Chief Signature:
Date:
/
/
Branch Chief Signature:
Date:_,,,,f._f_,._
l Attachment A
ATTACHMENT B SAFETY EVALUATION FORM AND CONTENT TEMPLATE 1.0 introduction -by PDLR Project Manager Summary description of the subject matter and the purpose of the report, along with a standard description of the applicable requirements in Part 54.
2.0 Summary of Renewal Report Provide an introductory description of the scope and applicability of the report. -by PDLR Technical Contact 2.1 Components and intended functions -by ADT responsible review branch (es)
Provide a brief description of the subject structures, systems and/or components and its intended functions.
2.2 Effects of aging -by ADT responsible review branch (es)
Provide a summary description of the aging effects for which aging management programs are needed.
2.3 Aging management programs -by ADT responsible review branch (es)
Provide a summary description of the aging management program or programs proposed by the applicant.
2.4 TLAAs -by ADT responsible review branch (es)
Provide a summary description of existing or revised time-limited aging analyses, as applicable to the scope of structures, systems or components addressed in the report.
3.0 Staff Evaluation Provide an irdioductory description of staff review procedures and the scope of its review. - by the PDLR Technical Contact [from SRP]
3.1 Scope of structures, systems, components - ADT responsible review branch (es)
Provide the evaluation of the applicant's information used to identify structures, systems and/or components subject to aging management. Determine the technical adequacy of the information and the completeness of the component list, and provide the basis for the Staff's determination. Attachment B
l 3.2 Intended functions -by ADT responsible review branch (es)
Provide the evaluation of the applicant's information used to identify the intended functions of the structures, systems or components identified in Section 3.1.
Determine the technical adequacy of the information and the completeness of the resulting intended functions, and provide the basis for the Stafs determination.
3.3 Effects of aging -by ADT responsible review branch (es) l Provide the evaluation of the applicant's information regarding the methodology or process used to identify potential aging effects for the identified structures, l
systems or components requiring aging management. Determine the technical adequacy of the process and the completeness of the resulting aging effects.
Ensure that operating experience relevant to a specific system, structure, or component was property considered in the nature and extent of the poten;ial aging effects. Determine the completeness of the aging effects and provide the basis for the Stafs determination.
3.4 Aging management programs -by ADT responsible review branch (es)
Provide the evaluation of the proposed aging management programs for the identified components needing aging management, for the period of extended operation (renewal term). Determine if 1) the program properly addresses the identified aging effect and 2) the program is effective in managing the identified aging effect under all CLB design conditions for the period of extended operation.
Ensure that the applicant adequately demonstrates the effectiveness of the program using relevant operating experience from an existing program or committing to a process to verify its effectiveness in case of a new program.
Determine whether the applicant has adequately demonstrated the effectiveness of the aging management program for the period of extended operation, and provide the basis for the Stafs determination. Draft SRP-LR Section 3.0 contains elements of an acceptable aging management program for renewal.
3.5 TLAAs -by ADT responsible review branch (es)
Provide the evaluation of the TLAAs, as or if noolicable, and the basis for the stafs determination in accordance with the usual review guidelines for such analyses in the SRP, as applicable to the period of extended operation.
. 4.0 Conclusions - by the PDLR Technical Contact Provide the overall conclusions of the subject report based on the inputs from various responsible review branches. Ensure that any limitations or conditions associated with the conclusions are clearly delineated. Include standard legallanguage and findings.
4.1 Renewal applicant action items -by the PDLR Technical Contact I )
J
List any action items to be taken by a renewal applicant who references this I
technical report, and any conditions of acceptability that the staff specifically relied on to conclude that the proposed aging management programs or TLAAs l
provide reasonable assurance ofpublic health and safety for the period of l
extended operation [ consistent with evolving guidance for license amendment SE content and commitment management).
4.2 Open items by the PDLR Technical Contact List any open items which must be resolved on a plant-specific basis, or as a condition of referencing in an application.
l 5.0 References - by the PDLR Project Manager List all relevant correspondence and references used for the staff review.
i 6.0 Appendix - PDLR Technical Contact with input from all ADT responsible review i
branch (es)
Provide a summary of the staffs on-site review activities, reference any relevant inspection reports, and specifically identify any results which were used, in part, as the basis for the staffs conclusions.
l l
United States Nuclear Regulatory Commission Guide for Technical and Process Lessons Learned for License Renewal i
l i
l License Renewal Project Directorate t
Office of Nuclear Reactor Regulation j
l March 1998 l
4 1.0 Introduction This guide, along with supporting documentation and tracking system, provides the framework for incorporating lessons loamed into the license renewal review and inspection programs. This
' guidance is for use by Project Directors (PDs), Project Managers (PMs), technical reviewers,
- Regions, and staff management. Although it is an intemal NRC process, concems identified by the public and industry will also be managed using this process. This guide describes the overall process and the individual steps that will be used to identify, track, and implement lessons loamed related to license renewal programs and activities and the guidance documents that are expected to be followed.
1.1 Objectives.
k The objective of this guide is to help NRR enhance its effectiveness, efficiency and consistency in responding to the needs of both the public and license renewal applican's as it relates to the technical requirements and the license renewal application (LRA) review process. Specife j
objectives include the following Ensure the continued health and safety of the public.
h Provide a means for identifying, documenting, controlling and implementing lessons leamed from the LRA review procer,.
Provide a means for identifying, documenting, controlling and implementing staff positions for license renewal.
Provide a means of revising license renewal guidance documents to ensure that adequate guidance is in place for preparing an LRA.
. Provide a means of revising license renewal guidance documents to ensure an effective, i
efficient, and consistent review process for LRAs..
i Provide the staff with a framework for keeping NRR management and the Commission
.~
l informed of staff positions and processes affecting license renewal.
l Provide a means to incorporate lessons leamed from LRA review and inspection activities into the LRIP.
1.2 Process Overview The key elements of the LRA review process are performed by NRR headquarters and include reviews of integrated plant assessments (IPA) and supplemental environmental report, changes to the current licensing basis (CLB) implemented during the LRA review process, evaluations of time-limited aging analyses (TLAAs) as defined under 10 CFR 54.3, and final safety analysis report (FSAR) supplements that contain summary descriptions of programs and activities used to manage the effects of aging and to evaluate TLAAs for the period of extended operation. The required content and the technical review guidance are contained in the rule, the statement of i i
1 1
consideration (SOC) that accompanied the rule (60 FR 22461, issued May 8,1995), the draft regulatory guide, " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses (DG-1047)," and the draft standard review plan,
- Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR).
In addition to the technical review of an LRA, a series of on-site inspections will be performed to verify the following: (1) the license renewal programs and activities are being documented consistently with the requirements of the rule, quality assurance requirements, and site-approved procedures; (2) the aging management programs are being implemented consistently 1
with information provided in the LRA and the staff safety evaluation (SE); and (3) the aging manegement programs are effectively managing the effects of aging throughout the period of j
extended operation. An inspection manual chapter and a series of inspection procedures have
{
been developed to support the License Renewal inspection Program ( LRIP).
j Finally, the staff has developed general guidance for the overall review of an LRA documented in this office letter and other supporting guidance documents. This general guidance includes a process to address lessons learned and staff technical and process positions that will contribute to the effective, efficient, and consistent review of LRAs. This process, the License Renewal Lessons Leamed Process (LLP), has been developed to correct, improve, and add guidance to the existing guidance documents used to develop and review an application for license renewal.
2.0 Lessons Learned Process The LLP provides the framework for identifying and controlling technical and pc:vess lessons learned relating to the development and review of LRAs. This process will be und to document, track, implement and verify staff positions and revisions to guidance documents relating to license renewal.
2.1
- Lessons Learned Overview L
i The LLP is administered and controlled by NRR, Division of Reactor Program Management l
under the License Renewal Project Directorate (PDLR). Primary contributors to the process are expected to be NRR, Associate Director for Technical Review (ADT) and PDLR, the regions, contractors, other NRR divisions, and potentially other NRC offices that may be asked to support on LRA review and/or the LRIP. Participating offices, divisions, and regions involved in license renewal review and inspection activities are required to participate in the LLP.
L The technical review of an LRA is primarily performed under the guidance of the SRP-LR.
However, reviewers must also be familiar with the rule, the SOC that accompanied the rule,
- DG-1047, and NEl 95-10. During the implementation of these guidance documents, missing, incorrect, or incomplete guidance may be identified. Correcting and adding to existing guidance will be documented and controlled in accordance with the process described below.
The technical reviewers will also be challenged with technical and process issues requiring staff assessment that may result in staff positions. These technical and process issues also need to be documented and processed in accordance with the LLP.
j 2.2 ~
Processing Lessons Learned
^
The LLP is displayed in Figure 1. The basic steps that need to be performed include the following:
identify and document lessons teamed and technical and process issues track lessons learned issues plan and schedule evaluate issues and identify options / resolution review and approve positions and resolutions incorporate the lessons learned and staff positions into guidance documents verify lessons leamed issues are resolved 2.2.1 Identifying and Documenting Lessons Learned The industry and the staff have expended significant resources to document guidance for developing, reviewing and inspecting license renewal programs and activities and its related documentation. The key documents that need to be used and improved throughout the LRA development, review and inspection process include the following:
SRP-LR DG-1047 NEl 95-10 Office Letter No. 805 h
Inspection manual chapter M Inspection Procedures M, M, M, m, M The primary sources of input into the LLP include the following:
PDLR coordination and review activities technical branches and contractor review activities OGC guidance
Figure 1 - LR Lessons Learned issue Documented &
IP Forwarded to issue Coordinator (IC) 1 r IC Enters issue in Tracking System &
Assign to issues Responsible Individual (IRI) 1r IRI Plans & Schedules PD/ Branch Assignment Resolve Priorities i r Management involvement Pro osed Branch Level t DivWon Level t Options Evaluation Process:
Executive Team Level Determine Options /
Resolution As Needed to Resolve issue Resolution, 1 r 1 r Commission Level Issue Resolution issues Review & Approval Approval 3r 3 r IRI Coordinates Policy /Rulemaking t
Changes / Process Positions i
i i
i SRP LR Coordmator:
RG Coordinator:
IP LR Coordinator:
PDLR Revise OL 805 Revise SRP LR as Revise DG 1047 & NEl Revise MC & IPs as as Necessary Necessary 9510 as Necessary Necessary I
\\
4 Revision (s) Verified by IRI
\\
t IC Closes issue i I t
public comment industry input ACRS review and report J
LRA implementation and review activities that result in lessons leamed will be documented by the reviewer that identifies the concem (the originator) on the Lessons Leamed Tracking Form (LLTF) and fonvarded to the issues Coordinator (IC) in PDLR. The LLTF is provided as Attachment A to this guide.
In addition to lessons leamed, other technical and process concems will be identified during the development and review of LRAs. These concems will require staff attention and may result in documented staff positions and/or revisions to guidance documents such as the SRP-LR.
Technical and process concems also will be documented on the LLTF and forwarded to the IC.
t This form will be used to track and process staff positions relating to license renewal that eventually will be incorporated into the DG-1047, SRP-LR, this office letter, and/or the LRIP.
Blank copies of the LLTF will be attached to each work request and work plan. Additional copies can be obtained from the IC.
2.2.2 Tracking Lessons Learned issues Upon receiving an LLTF, the IC will determine if the lesson leamed is applicable, already identified, t nelear or not applicable. Lessons leamed that have already been identified will be retumed to the originator with an explanation. Lessons leamed and position determined to be outside the scope of the license renewal LLP or not clearly documented will be discussed with the originator to determine if the lessons leamed will be added to the program. The IC will meet with the license renewal PD to review all new lessons leamed issues and to discuss those issues that the originator and the IC cannot agree upon. The license renewal PD will make all final decision on issues to be included in the LLP. The license renewal PD will also determine the priority and schedule for each issue during his initial review. The IC will enter all new issues into the LLP data base. A PDLR staff member will be assigned responsibility for each lessons leamed issue, as the issue Responsible Individual (IRl).
2.2.3 Planning and Scheduling i
The IRI will interface with the originator to ensure that the issue is clearly identified and to determine what needs to be done to resolve each issue. Based on a clear understanding of the issue and the priority and schedule assigned, the IRI will determine what actions are needed to address the lessons leamed.
The IRI may or rr ay not be responsible for resolving an issue. For example, staff technical positions will tr~ tt likely be developed by the technical branches, and process positions will most likely be developed by PDLR. In situations where another organization outside of PDLR is responsible for resolving a lesson learned issue, the IRI will coordinate the review and _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -
implementation activities for PDLR. Other issues may require a team effort involving multiple NRR branches and other NRC offices (e.g., OGC) to resolve.
Lessons leamed issues involving multiple branches and/or offices may result in scheduling / priority conflicts. Schedule conflicts will be brought to management's attention for resolution.
2.2.4 Evaluating Lessons Learned and identifying Options and Resolutions The actions required to address lessons leamed or staff positions will vary. Most lesson leamed issues are expected to result in commonly agreed upon resolutions. In those cases where the staff cannot agree upon a common resolution, options are to be developed and presented to management for resolution. Options will be documented and presented to the license renewal PD, and he will attempt to resolve them on the branch level. If agreement is reached, the resolution is processed through the remainder of the LLP, if agreement cannot be reached, the options will be passed up to the next level of management. This process will be repeated until it reaches the NRR Office Director whose decision is final.
Some issues may require Commission involvement. These issues can be identified anywhere in I
the planning and evaluation process, and need to be discussed with the license renewal PD as soon as the potential for a Commission-level issue is identified. The staff will document the lesson leamed, the proposed options, and a staff recommendation prior to presenting it to management for discussion with the Commission. Issues raised to the Commission can result in l
rulemaking, a policy statement or a Staff Requirement Memorandum. The Commission may also return an issue for staff resolution.
For those issues retumed to the staff from the Commission, additional management guidance should lead to a final resolution. For those issues resolved by the Commission, other actions or staff positions may be initiated to implement the requirements, position, or required actions initiated by the Commission.
)
2.2.5 Review and Approval Upon determining a resolution to a lesson leamed issue, it needs to go through review and concurrence. The IRI, originator, and any appropriate technical reviewers and their branch chiefs need to be identified and agreed upon by the license renewal PD. OGC concurrence may also be needed. The license renewal PD typically will have final approval authority unless otherwise specified by the license renewal PD or management.
A transmittal memorandum with the appropriate concurrences will be attached to the LLTF and routed appropriately. Any delays with the review or conflicts with the final resolution need to be l
l discussed with the license renewal PD for further actions.
2.2.6 Implementation of Resolution For lessons leamed issues resulting in staff positions, the IRI will coordinate the addition of the resolution to the SRP-LR, DG-1047, this office letter, the inspection manual chapter, and/or l
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inspection procedures, as applicable. The IRI will coordinate and track the revision to those documents. When the revision is developed, the IRi will review the resolution with the originator.
Upon agreement that the revision satisfies the resolution, the IRI will enter the specific reference,
. the revision number, and declare the issue complete. All completed issues will be forwarded to the Nuclear Energy Institute for information and dissemination to potential applicants.
The 10 will be placed on concurrence for all revisions of the SRP-LR, DG-1047, this office letter,
. and license renewal inspection manual chapter and procedures. The IC will verify that the changes initiated by the LLP are included in the designated revision as intended. Upon verification, the IC will close the issue.
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1 LICENSE RENEWAL LESSONS LEARNED TRACKING FORM 1
issue Number:
Originator:
Alternate No:
Date initiated :
Title:
Lessons Learned
Description:
Logged in ITS-LR:
Date Assigned:
IRl:
Actions:
Scheduled Completion:
Priority:
Status:
i Revienwer:
Reviewer:
Reviewer:
j Organization:
l Branch Chief:
Evaluation / Options:
1 Resolution / Recommendation:
Date Resolved:
Resolution Approved By:
Corrective Actions Assigned To:
Date Assigned :
Document Revised:
Revision # :
Specific
Reference:
Revision Due Date:
Date Revised:
Revised By:
Date Verified:
Verified By :
Date Closed:
Closed By :
Attachment A
United States Nuclear Regulatory Commission t
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Guide for Renewal Licensing items License Renewal Project Directorate Office of Nuclear Reactor Regulation March 1998 r
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1 1.0 Introduction This guide, along with supporting documentation and the Renewal Licensing items Database (RLID), provides the Office of Nuclear Reactor Regulation (NRR) with a basic framework for identifying and tracking licensing items relating to license renewal (LI-LR). This guide is for use j
by the License Renewal Project Directorate (PDLR), license renewal Project Managers (PMs-LR), technical reviewers, Regional Administrators (ras),' Resident inspectors (Ris), Reactor
- Project Managers (RxPMs) and NRR management.
1.1 Objectives i
' The objective of this guide is to help NRR and the regions enhance its efficiency and i
consistency in responding to the needs of both the public and the staff as it relates to required actions associated with the issuance of a renewed license. Specific objectives include the following:
Ensure the continued health and safety of the public.
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Improve communication and efficiency within NRR, and between NRR and the Regions for identifying, documenting, and controlling LI-LR.
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1 Provide the staff with a means of keeping NRC management informed of the status of Ll-LR.
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- Provide a means of verifying that the substantive information contained in a license renewal application (LRA) is incorporated in the renewed license and/or FSAR
. supplement.
. Provide input into the Inspection Program for License Renewal ( LRIP) for resolution J Lis-LR.
o 1.2 Renewal Licensing items Process Overview The LI-LR process provides a means to ensure that the information substantively relied upon by i:
the staff in making a finding under 10 CFR 54.29, and any condition the staff may attach to its l
findings, are incorporated into the renewed license in the form of a license condition, technical specification (TS) requirement, or FSAR commitment. The process can be characterized by the
(
activities shown in Figure 1.
The scope of this process includes the key elements of the programs and activities required to manage the effects of aging and evaluate time-limited aging analyses (TLAAs), licensee commitments, and staff identified open items (items identified by the staff during the review or inspection of the applicant's programs and activities). These licensing items must be documented within a renewed license in one of the following forms: (1) summary descriptions,
. within the FSAR supplement, that describe the key elements of the aging management programs and activities, and TLAA evaluations; (2) license conditions; (3) TS requirements; 1 _ _ _ _ _. _ _ _ _ _ _. _.. _ _ _
Figure 1. License Renewal Action item Process l
LRA Review &
Verification 1r
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\\
LI-LR 1r bl 1r Originator Fills Out Ll.
LR Tracking Form Documented in SER i
1P PM Input Ll-LR into f
RLID FSAR Supplement Input
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License Condition PM Reviews Final Licensing Documents to Verify All LI LR are Addressed input TS Requirement IP-LR inspection Input m
m Report 1r PM Forward Renewed Verified
?
License for Final Approval LI-LR Tracking Forms Sent to File j
Copies of RLID Sent to input into Operating m
PM and Regions Reactor Program 2
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or (4) commitments within the FSAR supplement. Some Lis-LR may require verification of information or activities prior to the approval of a renewed license. Verification will normally be performed through inspection activities conducted in accordance with the inspection Manual,
" Policy and Guidance for the License Renewal Inspection Program."- In the interest of focusing the scope of the inspection verification,to those matters that are most important to the bases for
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granting a renewed license, it may be appropriate to conduct site visits to determine the appropriate documentation in the license renewal application and the associated safety evaluation to establish appropriate detailin the licensing basis for future routine inspection activities. However, expanding the documentation and level of detail in the licensing basis for renewal should also be decided carefully because it may cause additional burdens on the review and inspection staff. Therefore, these actions should also be reviewed for possible improvements in the SRP guidance, as described the associated " Guide for Technical and Process Lessons Leamed for License Renewal."
2.0 Renewal Licensing itema Process The Renewal Licensir g items Process is administered and controlled by NRR, Division of I
Reactor Program Management under the License Renewal Project Directorate (PDLR).
Participating offices, divisions, and Regions involved in license renewal review and inspection activities are responsible for participating in this process.
Lis-LR must be documented as completed in an inspection report, or added to the license or j
FSAR supplement prior to final approval of a renewed license. Verification that the licensee meets its license conditions and its commitments will be integrated into operating reactor i
programs and controls in place for licensed facilities. The Renewal Licensing items Process includes the following:
identifying LI-LR tracking LI-LR documenting Lis-LR in the renewed license or FSAR supplement, or the resolution of Lis-LR in inspection reports 2.1 Identifying LI-LR As part of an LRA review, reviewers are to identify the key elements of the programs and activities required to manage the effects of aging and to evaluate TLAAs, licensee commitments, and staff identified open items that are substantively relied upon by the staff in making its finding under 10 CFR 54.29. This information is to be documented on an LI-LR Form (Attachment A to this guide) and forwarded to PDLR with each completed individual safety evaluation (SE) or safety evaluation report (SER). The PM-LR, with assistance from PDLR, Engineering Section, is required to review each SE or SER and its LI-LR forms to ensure that all key elements, commitments, and open items are documented on forms. Concerns identified during this review will be discussed with the reviewers. Concems that are not resolved will be brought to the license renewal PD for resolution. The PM-LR can initiate an Ll-LR form for items not included by the reviewer upon license renewal PD approval. To remove an item submitted by the l
reviewer will require the signature of the license renewal PD and the originator's branch chief or the action item will remain.
Lis-LR include the following:
For the aging management programs and activities, and TLAA evaluations, a description of the key elements of each program, activity, or evaluation that the staff relied upon to make its findings under 10 CFR 54.29, that must be contained in the FSAR supplement as required under 10 CFR 54.21(d).
Any commitment made by the applicant during the LRA process that the staff substantively relied upon in making its findings under 10 CFR 54.29 that must be contained in the FSAR supplement as required under 10 CFR 54.21(d), in the TS as a j
TS requirement, or in the renewed license as a license condition.
Any open item identified during the review and inspection of license renewal programs and activities substantively relied upon by the staff in making its findings under 10 CFR 54.29 that must be contained in the FSAR supplement as required under 10 CFR 54.21(d), in the TS, or in the renewed license. Safety items applicable to the current licensing term that are identified during a license renewal inspection will immediately be brought to the attention of the resident inspector. Other current term I
items will be documented and forwarded to the region for resolution.
Any open item or action item substantively relied upon by the staff in making its findings under'10 CFR 54.29 that requires verification prior to issuing a renewed license must be documented in an inspection report.
2.2
. Tracking LI-LR During a safety evaluation of an LRA, each reviewer is required to document alllicensing items on an LI-LR Tracking Form. The PMs-LR will input the Li-LR into the RLID and retain the hard copy throughout the licensing process. Upon verifying that the renewal Lis-LR have been documented in the renewed license, TS, FSAR supplement, or inspection report, the PMs-LR will complete the form and update the RLID, completing tracking activities associated with the Li-LR process.
2.3 Processing LI-LR Prior to issuing a renewed license, Lis-LR need to be evaluated by the staff and documented in an SE. The PM-LR will verify that each Ll-LR is documented in the renewed license, FSAR supplement, TSs, or an inspection report. For each item, the PMs-LR will add the specific reference and a brief description of the action taken to the form and in the RLID. Lis-LR not specifically addressed in the proposed renewed license or an inspection report, must be added to the renewed license or inspected before a license can be issued. A computer printout of an applicant's renewal Lis-LR will be attached to the license approval package for the review' process. Upon final approval of a renewed license, the completed LI-LR forms will be sent to file, and an updated copy of the database will be forwarded to the RxPM and the Region. Upon - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ - - -
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I completion of these actions, the renewal action item process will be completed and any remaining actions will be taken under the operating reactor programs and activities.
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LICENSING ITEM - LICENSE RENEWAL FORM
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TECHNICAL REVIEWER:
APPLICANT:
REPORT / APPLICATION:
REVIEWER:
REFERENCE:
TYPE OF ACTION: PROGRAM ELEMENTS LICENSEE COMMITMENT OPENITEM ACTIONITEM VERIFICATION c,ca a.a DESCRIPTION OF ACTION:
CANCELED - PDLR:
TECHNICAL BRANCH CHIEF:
LICENSE RENEWAL PROJECT MANAGER:
PM-LR:
ITEM DESIGNATOR:
PLANTINITIALS. ITEM $$QVENCE NUMBER DATE ENTERED RLID:
ADDRESSED:FSAR SUPPLEMENT - LIC. COND. - TS REQUIREMENT - FSAR COMMITMENT - INSPECTION REPORT caea a,a RESOLUTION
REFERENCE:
ACTION (S) TAKEN:
VERIFIER:
DATE VERIFIED:
Attachment A
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