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 6
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.
Leveraging Operating Programs 7
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.
Leveraging Previous Reviews 8
Leveraging Previous Reviews No Adverse Operating Experience Fleetwide Programs /
Sister Plants Initial License Renewal Leveraging previous reviews can aid the staff in conducting a more efficient review, if there is no adverse operating experience.
- Initial License Renewal
- Fleetwide Programs / Sister Plants Rather than the staff spending significant time reviewing past reviews, it would be beneficial for applicants to provide a roadmap of the information at the start of the review.
Leveraging NRC/Industry Operating Experience with Aging Management 9
Process Improvements
+ Lessons Learned from License Renewal Reviews A significant number of enhancements have been and will continue to be implemented to improve the review process.
Examples:
Reduction to 1 ACRS meeting; RCIs/optimized audits to reduce RAIs; updating GALL/SRP.
Plant-Specific Operating Experience Review of plant-specific operating experience remains a very important aspect of the staffs technical review.
The operating experience can aid the staff in determining the proper tier of review.
Generic Operating Experience Consistent communication and awareness of generic operating experience across plants can contribute to a more efficient review process.
Staff will leverage international regulatory best practices and operating experience.
Consistency with NRC Guidance Documents / Topical Reports 10 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
Timeframe for Tiered Approach 11 Jan 2024:
Develop Framework Feb 2024:
Engage with external stakeholders; Update processes/training Mar 2024:
Begin Implementation Apr 2024:
Full Implementation Note: The tiered approach schedule cited above is a DRAFT and subject to change.
Tiers of Staff Review 12 Tier 1:
High Level of Review Tier 2:
Medium Level of Review Tier 3:
Low Level of Review High risk/safety significance Medium risk/safety significance Low risk/safety significance Complex technical issue, 1st of a kind issues, plant-specific AMPs; Exceptions AMPs that claim consistency, but end up not being consistent (requires additional interactions/work)
AMPs that claim consistency will require a confirmatory check No prior reviews Considers previous reviews (initial license reviews or fleetwide programs)
Leverages previous reviews (initial license reviews or fleetwide programs)
Recent and/or reoccurring operating experience issues Operating experience shows average trends Operating experience shows 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.
SLR Efficiencies Project 13 Phase 1 Phase 2:
Tiered Approach Phase 3 Methodology For Estimates Increased Formality in Oversight Hours
- RAIs, Audits, Questions Peer Review Guidance Implementation Training Technical Review Package Tool Phase 1 Project Management Practices Referencing Previous Reviews Fleet Programs Training on Oversight and Inspections Technical Review Package Tool Phase 2 Staff Training Technical Review Package Phase 3 Crediting other Regulatory Processes Public Availability of Breakout Questions Streamlining Documentation Risk Insights to determine depth of review Consider Formal Risk Information to Reduce Items for Review Restructuring Audits Initial License Renewals Implemented In Progress Beginning Preliminary
Questions?
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