ML23303A192
| ML23303A192 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/30/2023 |
| From: | Brett Titus Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML23303A192 (1) | |
Text
©2023 Nuclear Energy Institute Brett Titus Licensing Director Regulatory Affairs October 31, 2023 Right-sizing SLR Reviews
©2023 Nuclear Energy Institute 2 Look holistically at the process.
Right-sizing Elements A Graded Approach Categories & AMPs Environmental Discussion/Next Steps Give credit where credit is due.
Focus on what has changed and what is unique.
Pursue opportunities for efficiency.
Prioritize and execute the plan.
Agenda
©2023 Nuclear Energy Institute 3 Reexamine what is needed for reasonable assurance Strong leadership and staff discipline are essential Adopt a more graded approach for reviews Schedule and resource metrics must strive for excellence and predictability Right-sizing SLR Reviews
©2023 Nuclear Energy Institute 4 Risk and safety significance should be a driver for depth of review Maximize credit for adherence to guidance and standardization Focus on what has changed since the ILR review AMPs that are unchanged over GALL revisions AMPs with minimal changes over GALL revisions Fleetwide programs already reviewed for another ILR/SLR Licensee commitments that continue from ILR through SLR Routinely inspected programs subject to other regulatory requirements ISI, IWE, IWL, FAC, Fire Protection, App. J, Boric Acid Control Graded Approach
©2023 Nuclear Energy Institute 5 Graded Approach Least Most Review Resource Model Category 1 Category 2 Category 3 Licensee Program Adheres to GALL Criteria Unchanged New w/o Exception Covered by Reg Program Supplemented or Modified More detailed Further Evaluation Plant-specific Exceptions Significant OE Substantial Further Evaluation Review Scope Sampling of population OE/Effectiveness Consistency Confirmatory gap analysis Enhancement review Detailed confirmatory evaluation Detailed OE review Category 4 Category 5 Category 6 Licensee Program Contains Plant-specific Considerations Criteria Unchanged Supplemented or Modified More detailed Further Evaluation Plant-specific Exceptions Significant OE Substantial Further Evaluation Review Scope Sampling of population OE/Effectiveness Consistency Confirmatory gap analysis Enhancement review Plant-specific considerations Unique program attributes Detailed confirmatory evaluation Detailed OE review
©2023 Nuclear Energy Institute 6 SLR Aging Management Program Reviews ELECTRICAL Category 1 Category 2 Category 3 Licensee Program Adheres to GALL X.E1 XI.E1 XI.E2 XI.E4 AMR items with notes A or C XI.E3A XI.E3B XI.E3C XI.E5 XI.E6 AMR items with notes B or D XI.E7 Exceptions AMR items with notes E or above
©2023 Nuclear Energy Institute 7 SLR Aging Management Program Reviews STRUCTURAL Category 1 Category 2 Category 3 Licensee Program Adheres to GALL XI.S1*
XI.S2 XI.S4 XI.S5 XI.S7 XI.S8 XI.S1*
XI.S3 Licensee Program Contains Plant-specific Considerations Category 4 Category 5 Category 6 X.S1 XI.S6
©2023 Nuclear Energy Institute 8 SLR Aging Management Program Reviews MECHANICAL Category 1 Category 2 Category 3 Licensee Program Adheres to GALL X.M1, X.M2 XI.M1 - XI.M17 XI.M19*
XI.M22 - XI.M26 XI.M31 XI.M37 XI.M39 XI.M40 XI.M18 XI.M33 XI.M36 XI.M38 XI.M42 XI.M19*
Category 4 Category 5 Category 6 Licensee Program Contains Plant-specific Considerations XI.M30 XI.M42 XI.M41
©2023 Nuclear Energy Institute 9 Multiple AMPs have regulatory oversight outside of license renewal In addition to LR inspections (IP 71003), the NRC routinely inspects and observes:
Flow Accelerated Corrosion Boric Acid Corrosion In-Service Inspections Focused Engineering Inspections
Fire Protection/Fire Water
Age-related Degradation Significant overlap in compliance requirements outside of LR (e.g., 10 CFR 50.55a)
Leveraging Oversight
©2023 Nuclear Energy Institute 10 XI.M1 XI.M3 XI.M4 XI.M7 XI.M8 XI.M9 XI.M16A XI.M22 XI.M31 XI.M37 XI.M40 XI.M41 Leveraging Oversight The following list of Mechanical AMPs was identified as an example of programs that have overlap with other regulatory requirements or oversight that should be credited in LR reviews:
©2023 Nuclear Energy Institute 11
- Eliminate or reduce the scoping process
- Use exemptions and develop a process for preparing an Environmental Assessment/Finding of No Significant Hazards vice a SEIS
- Utilize the applicants ER as the DSEIS (or DEA)
- Ensure strict adherence to time and page limits of NEPA as revised by the Fiscal Responsibility Act
- Allow hearings on environmental contentions after the DSEIS is issued Environmental Review Efficiencies
©2023 Nuclear Energy Institute 12
- Bound the discussion of climate change-related impacts by rule of reason and proportionality
- Take lessons learned and process improvements from new reactor licensing proceedings
e.g.; enhanced audits, earlier and better-defined onsite evaluations, increased use of RCIs
- Fully utilize online and digital technologies identified by Congress in Section 110 (E-NEPA)
- Expedite a lessons learned review of NRC SLR-related consultations with other federal and state agencies Environmental Review Efficiencies
Feedback and Discussion
©2023 Nuclear Energy Institute 14 Evaluate exchanged information Examine updates or supplements to industry guidance Mid-December Public Meeting to focus on prioritization and actionable items Continue investigating innovative ideas (e.g., leveraging industry peer reviews, organizational enhancements)
Next Steps