ML24008A191
| ML24008A191 | |
| Person / Time | |
|---|---|
| Issue date: | 01/11/2024 |
| From: | Lauren Gibson, Angela Wu NRC/NRR/DNRL/NLRP |
| To: | |
| Siwy, A., NRR/DNRL, 301-287-9232 | |
| References | |
| Download: ML24008A191 (14) | |
Text
Public meeting to discuss possible efficiencies on the Subsequent License Renewal review Lauren Gibson, Angela Wu January 11, 2024
NRC Goal for this Fiscal Year At the end of the Fiscal Year, after evaluating the license renewal program, coordinating with stakeholders, and implementing short-term achievable efficiencies, the NRC envisions a license renewal program that has been enhanced and streamlined such that the safety and environmental reviews for LR/SLRs will be completed with substantially less staff hours when compared to recent estimates. However, due to the significant number of applications, the schedules cannot be shortened. These efficiencies may include:
- 1. Using bottom-up estimating based on the particular application rather than a model and implementing a change control process to go above those hours if a safety or environmental concerns warrants it;
- 2. Modernizing the Technical Review Package Tool;
- 3. Standardizing referencing previous reviews, such as the initial license renewal application or a fleet program.
- 4. Providing training to licensing reviewers on the inspection and oversight process so they have an awareness of the holistic license renewal process.
In addition, substantial progress on binning and/or sampling approaches will be made.
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Overall Objective for License Renewal Objective: Maintain timely, predictable, and efficient license renewal reviews, with a focus on safety.
Close engagement + collaboration with industry is imperative to success 3
Staff Requirements Memorandum: License Renewal Roadmap (SRM-M231102 - December 11, 2023)
Within three months, the staff should provide the Commission with a roadmap to restore the license renewal program to a path of timely and predictable reviews and achieve the goal of 18-month reviews.
The roadmap should include action items and deadlines to risk inform renewal reviews, leverage operating programs, leverage previous reviews, and leverage the agencys and industrys operating experience in aging management.
It should also include dates for achieving staffing levels appropriate for the workload and request any resource allocation or reallocation, if necessary, that the Commission would need to provide.
The staff should provide routine updates on roadmap progress. (ML23317A058) 4
The Tiered Approach: Tailoring the Level of Staffs Safety Review Risk-Informing License Renewal Reviews Leveraging Operating Programs Leveraging Previous Reviews Leveraging NRC/Industry Operating Experience with Aging Management Consistency with NRC Guidance Documents / Topical Reports 5
Risk-Informing License Renewal Reviews Currently, applicants voluntarily provide risk information for NRC consideration.
NRC will enhance its current methodology to further leverage risk insights to determine the depth of review.
Will require additional collaboration with the industry, including tailoring the type of risk information provided to the NRC.
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Leveraging Operating Programs As part of the staffs technical review, there will be a consideration to credit NRC reviews and oversight in other capacities:
- NRC inspection programs
- Other regulatory interfaces Training will be provided to technical staff on the inspection and oversight process, for a holistic understanding of the license renewal process.
NRC welcomes information exchanges with industry and applicants to identify applicable programs.
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Leveraging Previous Reviews Leveraging previous reviews can aid the staff in Initial conducting a more efficient review, if there is no Fleetwide License adverse operating experience. Programs / Renewal Sister
- Initial License Renewal Plants
- Fleetwide Programs / Sister Plants No Adverse Rather than the staff spending significant time Operating reviewing past reviews, it would be beneficial for Experience applicants to provide a roadmap of the information at the start of the review.
Leveraging Previous Reviews 8
Leveraging NRC/Industry Operating Experience with Aging Management Process Improvements
+ Lessons Learned Plant-Specific Generic Operating from License Renewal Operating Experience Experience Reviews Consistent communication A significant number of Review of plant-specific and awareness of generic enhancements have been operating experience operating experience and will continue to be remains a very important across plants can implemented to improve aspect of the staffs contribute to a more the review process. technical review.
efficient review process.
Examples:
The operating experience Staff will leverage Reduction to 1 ACRS can aid the staff in international regulatory meeting; RCIs/optimized determining the proper tier best practices and audits to reduce RAIs; of review. operating experience.
updating GALL/SRP.
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Consistency with NRC Guidance Documents / Topical Reports Consistency with NRCs generic guidance or approved topical reports can aid the staff in streamlining their technical review.
The NRC staff is currently updating the GALL and SRP for SLR.
Topical reports continue to be reviewed and approved for use.
- MRP-227, Revision 2, Pressurized Water Reactor Internals Inspection and Evaluations Guideline
- BWRVIP-315, Reactor Internals Aging Management Evaluation for Extended Operations 10
Timeframe for Tiered Approach Jan 2024: Mar 2024:
Develop Begin Framework Implementation Feb 2024: Apr 2024:
Engage with external Full stakeholders; Implementation Update processes/training Note: The tiered approach schedule cited above is a DRAFT and subject to change.
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Tiers of Staff Review Tier 1: Tier 2: Tier 3:
High Level of Review Medium Level of Review Low Level of Review High risk/safety significance Medium risk/safety significance Low risk/safety significance Complex technical issue, 1st of a AMPs that claim consistency, AMPs that claim consistency will kind issues, plant-specific AMPs; but end up not being consistent require a confirmatory check Exceptions (requires additional interactions/work)
No prior reviews Considers previous reviews Leverages previous reviews (initial license reviews or (initial license reviews or fleetwide programs) fleetwide programs)
Recent and/or reoccurring Operating experience shows Operating experience shows operating experience issues average trends positive trends TLAAs (i) and (ii) TLAAs (iii) Significant level of NRC oversight via inspection or other regulatory programs Note: The tiered approach cited above is a DRAFT. The number of tiers and criteria for each tier are subject to change.
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SLR Efficiencies Project Phase 1 Phase 2: Phase 3 Tiered Approach Technical Crediting Review Peer Review Referencing Methodology other Package Tool Guidance Previous For Estimates Regulatory Phase 2 Reviews Processes Increased Implementation Fleet Risk Insights Restructuring Implemented Formality in Training Programs to determine depth of Audits Oversight review In Progress Initial Technical License Hours Review Renewals Beginning Streamlining Package Tool Staff Training Documentation Phase 1 Preliminary RAIs, Audits, Questions Technical Project Review Management Package Practices Phase 3 Public Availability of Breakout Consider Questions Formal Risk Training on Information to Oversight and Reduce Items Inspections for Review 13
Questions?
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