ML22124A254
| ML22124A254 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 05/12/2022 |
| From: | Ekaterina Lenning NRC/NRR/DORL/LPMB |
| To: | Richard Chang NRC/NRR/DORL/LPMB |
| Lenning E, NRR/DORL/LPMB | |
| Shared Package | |
| ML22116A073 | List: |
| References | |
| EPID L-2019-TOP-0044 | |
| Download: ML22124A254 (8) | |
Text
May 12, 2022 MEMORANDUM TO:
Richard Chang, Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Ekaterina Lenning, Project Manager
/RA/
Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF APRIL 18, 2022, MEETING WITH NUCLEAR ENERGY INSTITUTE REGULATORY ISSUES TASK FORCE (EPID L-2019-TOP-0044)
On April 18, 2022, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of the Nuclear Energy Institute (NEI) Regulatory Issues Task Force. The meeting was held in a hybrid format (i.e., attendance in-person, virtual, and teleconference) and all in-person attendees followed the guidance for visitors to NRC facilities on NRC-sponsored events located on the NRC COVID-19 Update public website:
https://www.nrc.gov/about-nrc/covid-19/index.html. The purpose of the meeting was to discuss regulatory issues associated with licensing and oversight. The meeting notice is available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML22104A047, and the presentation slides are located in ADAMS under Accession No. ML22103A083. A list of attendees is provided as an enclosure to this memorandum.
The NRC staff began the public meeting with an introduction and explanation of logistical information. Mike King, Deputy Director of the Office of Nuclear Reactor Regulation for Reactor Safety Programs and Mission Support, NRC, and Brett Titus, Technical Advisor, NEI, provided opening remarks. The topics discussed during the meeting are summarized below. At the end of the presentation, the public had an opportunity to ask questions of the NRC staff. No regulatory decisions were made during this meeting.
Innovation/EMBARK: Update on Web-based licensing requests and update on MAP-X The NRC staff provided an update on Innovation/EMBARK activities including updates on web-based relief requests (WRRs) and MAP-X that was created to empower stakeholders with a secure, flexible, and personalized self-service gateway to retrieve, submit, and interact with regulatory related information and assessment tools through a standard web browser.
The NRC staff stated that WRRs were launched on April 5, 2021, and 13 WRRs were submitted so far (Arizona Public Service Company (1), Tennessee Valley Authority (1), Xcel Energy (11))
and two are already completed/authorized. The NRC staff indicated that less than 50 total project hours and less than 10 project manager hours were billed for each project.
The NRC staff discussed the benefits for the WRRs, explaining that web-based submittals are more flexible than the electronic information exchange, text automatically transferers to the NRC electronic safety evaluation, and the subsequent submittals become easier. The NRC staff highlighted the following WRR improvements suggested by industry stakeholders: availability of the NRC review status, more detailed instructions and tips, formatting and appearance of the submittals, a standard submission template, previews in the Word file, and a faster user credentials process.
While providing the update on MAP-X, the NRC staff mentioned its benefits for the NRC (it allows for the streamlining of incoming data, and increases processing efficiency and automation) and for the licensees (access is enabled anywhere, it is centralized, flexible, secure, personalized, has a built-in ability to clone previous submittals, provides data validation and auto-populated fields, and allows users to create, edit, preview, submit, and receive confirmation).
The NRC staff stated that the goals are to deploy the licensee event report module in 2022, to identify and prioritize future modules, and for continuous Improvement.
The NRC staff encouraged industry to provide feedback and mentioned that the NRC is planning to have a public meeting on WRRs in the near future.
The NEI representatives provided feedback stating that such new tools that relieve administrative burden are very beneficial for industrys future licensing submittals. They highlighted good communication between the NRC staff and licensees and more efficient reviews.
Update on Risk-informed Process for Evaluations (RIPE) and Discussion on Exclusions using RIPE in Support of the Technical Specifications Changes The NRC provided an update on RIPE indicating that RIPE Revision 2 to the Safety Impact Characterization (SIC) Guidance includes changes to the guidelines for characterizing the safety impact of issues.
The NRC staff stated that TSG-DORL-2021-01 was being revised to remove limitations on technical specification (TS) changes, added the TS Branch as lead for the TS change in license amendment requests (LARs) submitted under RIPE, and included clarification that a TS LAR submitted under RIPE must demonstrate that the Probabilistic Risk Assessment considerations described in the TSG-DORL-2021-01 justify that the requested change is not significant to public health and safety. The NRC plans to complete and issue SIC guidance in June 2022.
The NRC emphasized the importance of pre-application activities for RIPE submittals that would support efficiency of the NRCs reviews.
The NEI representatives asked the NRC staff to indicate if industrys support on RIPE is needed. The NRC staff stated that there is a need to address any lessons learned and to engage broader stakeholder groups to highlight the potential benefit of using RIPE when TS changes are involved.
The NEI representatives provided feedback highlighting the value of pre-submittal meetings, audits, and requests for confirmation of information.
Discussion on Best Practices in Communications for the Review of Licensing Actions As a continuation to the previous topic, the NRC emphasized the importance of open communication and applicants early engagement with the NRC when planning for future submittals.
The NEI representatives stated that early communications with the NRC on future licensing submittals are very beneficial.
Updated on Standard Review Plan Modernization Effort The NRC staff provided an update on the status of Standard Review Plan Modernization (SRPMod) effort that included the background, detailed overview of the benefits for modernizing the SRP, assessment of the SRPMod effort, outcome from the assessment with the outline of what is changing, specifics on the revised SRP project plan, and next steps that includes plans for obtaining industry feedback and scheduling a public meeting in summer 2022. The NRC staff mentioned plans for submitting batches of modernized SRP sections to the Office of Management and Budget for review, with the first batch submittal planned for summer 2022.
The NRC staff reiterated that the SRPMod effort focuses on what is important to safety and to provide guidance that is focused on the requirements. The SRPMod effort goals are the development of clear and concise guidance for completing reviews and the improved quality of the NRC review products including requests for additional information (RAIs) and safety evaluations (SEs).
The NEI representatives indicated that they would continue to monitor the progress of this effort and will offer their support as needed. The NEI representatives asked the NRC staff to let NEI know if the need for support is identified.
Industry Notice of the Enforcement Discretion/Emergency License Amendment Request Desk Guide Development NEI opened the discussion to provide an update on the status of the notice of enforcement discretion (NOED)/emergency license amendment request desk guide being developed by industry. The NRC staff emphasized the need for early and clear communications during the NOED/potential emergency amendment situations. The NRC staff indicated that a checklist with standard questions might be developed to assist in assessing such situations.
The NEI representatives also stated that there is constant communication between the sites and their corporate offices.
Overview of Changes to LIC-500, Revision 9, Topical Report Process The NRC staff presented an overview of the changes to the LIC-500, Revision 9, Topical Report Process. The NRC staff indicated that three new review pathways for the topical reports (TRs), which were added to increase the efficiency and timeliness of the reviews: compressed, uncomplicated, and SE confirmation reviews, noting that the traditional standard review remains
available also. The NRC staff described added review process efficiencies that include e-mail transmittals of RAIs, draft and final SEs, audits, and four new NRC forms (895-898).
The NRC staff provided a detailed overview of the TRs review pathways criteria for each type of review that are reflected in the picture below:
The NRC staff explained in detail the process for standard, compressed, and uncomplicated and SE confirmation reviews.
The NRC staff also described the current TR review prioritization that is based on the business line or agency priority, the TRs relation to the direct response to a safety significant event, the level of safety significance, the schedule priority, and if the TR is accident tolerant fuel related.
The NRC is currently reviewing these priorities and is considering including additional ones, such as: complexity of the submittal, requested timeline, if the submittal is related to a future licensing action, resource availability for the review, and exigent requests.
The NEI representatives thanked the staff for the update and asked the NRC staff to let NEI know if the need for support is identified.
Proprietary Reviews The NRC led a discussion on a limited number of submittals that contain proprietary information to highlight recent occurrences that have made NRC reviews of proprietary withholding requests more complicated.
Additionally, the NRC reminded the stakeholders to refer to the 10 CFR 2.390(b)(4)(ii) and 10 CFR 2.390(b)4(iv) when identifying proprietary information, so no publicly available information is marked as proprietary.
The NRC also reminded the industry to refer to the publicly available LIC-204, Revision 4, Handling Requests to Withhold Proprietary Information from Public Disclosure (ADAMS Accession No. ML20049A139), and that the applicants need to work with the NRC project managers to resolve any issues with the submittals.
Accident Tolerant Fuel Next Steps and Coordination The NRC led discussion on the ATF next steps and coordination. The NRC emphasized the importance of open discussions, early engagements, and pre-application activities for future ATF submittals that will support NRCs resource planning and streamlined reviews.
NEIs Feedback on the Virtual 2022 Regulatory Information Conference The 2022 Regulatory Information Conference (RIC) was held March 8 through March 10 in a hybrid format (the in-person component followed all applicable safety guidelines), which consisted of several plenary sessions and 30 technical sessions.
The NEI representatives provided feedback stating that they appreciated the 2022 RIC focus on the new reactors, but they also would like to see topics such as the use of diverse and flexible coping strategies in licensing submittals on the agenda.
The NRC action item regarding a follow-up with NEI on the ways and timeframes for the stakeholders to submit future RIC topics of interest to the NRC was resolved.
No comments or questions were received at the meeting from members of the public.
Please direct any inquiries to Ekaterina Lenning at Ekaterina.Lenning@nrc.gov.
Docket No. 99902028
Enclosure:
List of attendees
Enclosure List of Attendees Nuclear Energy Institute Regulatory Issues Task Force Public Meeting April 18, 2022 1:00 pm - 4:00 pm Name Organization Brett Titus Nuclear Energy Institute (NEI)
Aladar Csontos NEI Tony Brown NEI Melody Rodriguez NEI Mike King U.S. Nuclear Regulatory Commission (NRC)
Bo Pham NRC Caroline Carusone NRC Gregory Suber NRC Richard Chang NRC Jackie Harvey NRC Tim Mossman NRC Justin Fuller NRC Audrey Klett NRC Richard Bright NRC Brian Wittick NRC Dana James NRC Michael Markley NRC Meena Khanna NRC Antonios Zoulis NRC Kristy Bucholtz NRC Jason Paige NRC Ekaterina Lenning NRC Daniel King NRC Ngola Otto NRC Ed Miller NRC Carol Moyer NRC Julie Ezell NRC Dennis Galvin NRC Siva Lingam NRC Brian Benney NRC Jay Robinson NRC John Hughey NRC Undine Shoop NRC Gayathri Sastry NRC Derek Scully NRC Tony Nakanishi NRC Kerby Scales NRC Andrew Zach U. S. Senate Environment and Public Work Mathew Cox Arizona Public Service (APS)
Katherine Gill APS Name Organization Sarah Kane APS Archie Manoharan BWX Technologies, Inc.
Larry Nicholson Certrec Deann Raleigh Curtiss-Wright Jana Bergman Curtiss-Wright Sophie Gutner Dominion Energy Phil Lashley Energy Harbor Stephenie Pyle Entergy Phillip Couture Entergy Ron Gaston Entergy Brian Mann Excel Services Dave Gullott Constellation Nuclear Roy Linthicum Constellation Nuclear Christian Ramos Constellation Nuclear Steve Catron NextEra Harry Ballian PSEG Nuclear LLC (PSEG)
Mike Wiwel PSEG Hossein Hamzehee Strategic Teaming and Resource Sharing Group Cheryl Gayheart Southern Nuclear Company Wendy Brost South Texas Project Nuclear Operating Company Ricardo Medina Tennessee Valley Authority (TVA)
Christopher Riedl TVA Stuart Rymer TVA Sarah Scott Xcel Energy Richard Stadtlander Xcel Energy Michelle Byman Unknown George Wilson Unknown James Cirilli Unknown Michael Bradbury Unknown John Pfabe Unknown Ian Gifford Unknown
ML22116A073 (Package)
ML22104A047 (Meeting Notice)
ML22103A083 (Presentation Slides)
ML22124A254 (Meeting Summary)
OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DORL/LLPB/BC NRR/DORL/LLPB/PM NAME ELenning DHarrison RChang ELenning DATE 05/05/2022 05/09/2022 05/12/2022 05/12/2022