ML23116A189

Industry Observations of NRC Licensing Program (NEI Slides May 2023)

ML23116A189
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/31/2023
From:	Schlueter J Nuclear Energy Institute
To:	Office of Nuclear Material Safety and Safeguards
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ML23116A188	List: ML23116A189 ML23116A190
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Download: ML23116A189 (1)

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Industry Observations of NRCs Licensing Program Janet Schlueter Senior Advisor, NEI Industry Representatives NRC Fuel Cycle Facility Stakeholders Meeting - Rockville, MD May 2023

Background

• 2019-2020: Smarter Licensing Program Initiative Launched

• Result: 42 Recommendations Based on Significant Industry Input

• 2021-2022: NRC Implemented Recommendations & Continues Dialogue During Public Meetings

• e.g., October 2022, industry presented actual versus estimated time & cost data for 10 licensing actions

• May 2023: Industry to Share its Experiences & Observations with Recent Licensing Actions & License Renewal

• Goal: identify generic issues & respective areas for improvement and mutually commit to ongoing engagement

Four Licensing Program Themes Emerged

1. Need for Increased Process Clarity & Predictability

2. Need for Increased Transparency & Predictability

3. Need for Increased Management Communication

4. Need for Routine Reviews of Major Licensing Actions

Theme 1. Increased Clarity & Predictability

• Better Define Expectations for Initial Submittal

• 2007-WEC receives 20-year license; 2014-WEC submits same application requesting 40-year license; NRC rejects it in absence of rule change

• Pre-application meetings extremely valuable to applicant and NRC

• NRCs acceptance review decision does not represent safety determination; therefore, it should not be unduly delayed

• Requests for Supplemental Information (RSI) & Requests for Additional Information (RAI) - Opportunity to apply VLSSIR concept?

• Need for purpose, timing & scope of each RSI or RAI

• Need for clear, documented regulatory basis for each request

• Need for early engagement on draft requests to ensure mutual understanding, clear expectations & timeline

1. Increased Clarity & Predictability (cont)

• NRCs Review of Triennial Decommissioning Funding Plan Submittals Continue to Vary Even In Cases Where Site Information & Practices Have Essentially not Changed Since Last NRC Approval(s) - VLSSIR?

• e.g., persistent NRC question on inventory management with same answer

• Increased Clarity on Construction at Risk & Site Preparation Work

• Flexibility on Timing of Application or Amendment & Relevant Environmental Report Submittals - VLSSIR?

• Timing of safety evaluation and environmental reports are not safety or risk significant, not interdependent, and can be reviewed sequentially

• Exemptions available but costly and unnecessary from safety perspective

Theme 2. Increased Transparency/Predictability

• Early Engagement of Stakeholders During Environmental Impact Statement process

• Section 106 & NEPA intersection needs to be clarified & more transparent

• New/Different NRC information requests in absence of new rule or guidance

• Increased Transparency and Predictability of NRC Licensing Action Cost/Time Data

• Industry licensing case examples presented Oct 2022 demonstrate need for increased accuracy of NRC cost/time estimates versus actual expenditures

• Tracking, transparency of case data on NRC webpage would increase predictability of licensing timelines & resource expenditures/needs for both NRC and industry

• Inform NRC budget assumptions & qualitative factors, e.g., effort factor for annual fees

• Inform applicant/licensee resource planning & execution

• Help meet NRCs goal of increased transparency for stakeholders

Theme 3. Increased Communication

• Routine Calls & Meetings Between NRC Management and Applicant or Licensee to Discuss Action Item Status, Projected Timeline, New Challenges, Related Case Work that Informs NRC Review, etc.

• Sites/Applicants benefit from pre-scheduled routine management calls

• Particularly useful prior to issuance of or responding to RSIs/RAIs

• Early Site Visits by Both NRC Management, Technical Reviewers and Project Managers to Inform NRC Reviews of Licensing Submittals

• Additional site visits during the application or licensing process may also be beneficial depending on complexity of action or timeline

Theme 4. Review of Major Licensing Actions

• New or Less Experienced NRC Reviewers Should Benefit From Licensing Lessons-Learned & Similar Completed Casework

• Perform Lessons-Learned Reviews Following Major Licensing Actions to Further Refine Processes/Practices & Define Best Practices

• Routine practice for industry to perform self-assessment with goal of continuous improvement

• Industry could provide valuable, timely input to NRCs respective effort

• Possibly incorporate topic as routine agenda item for future s/a FCF Stakeholders Meeting

Discussion Topics

• NRC Observations?

• Mutual Generic Observations, Best Practices or Concerns?

• Possible Next Steps to Enhance Licensing Program:

• NRC licensing cost/time data routinely posted and trackable on NRCs website

• Routine scheduled management calls (e.g., biweekly/monthly) between applicant/licensee to discuss status, IOUs, etc. on specific licensing actions

• Periodic NRC-industry meetings to track progress with goal of continued improvement THANK YOU!