ML24010A020

Public Meeting on SLR Efficiencies - NEI Presentation

ML24010A020
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/11/2024
From:	Brett Titus Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
References
Download: ML24010A020 (1)

Text

Public Meeting on SLR Efficiencies

Brett Titus Licensing Director Regulatory Affairs

January 11, 2024

©2024 Nuclear Energy Institute Agenda

Recap of Initiative Overview of the complete approach.

Graded Approach Industry focus area and near-term opportunity.

Examples and Verification Practical application of the Graded Approach.

Environmental This is an essential piece of the effort.

Discussion/Next Steps Continue moving forward.

©2024 Nuclear Energy Institute 2 Right-sizing SLR Reviews

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

©2024 Nuclear Energy Institute 3 Graded Approach

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

©2024 Nuclear Energy Institute 4 Graded Approach Most

Least Review Resource Model

Category 1 Category 2 Category 3

• Unchanged

• Supplemented or Modified

• Plant-specific Exceptions

• New w/o Exception

• More detailed Further Evaluation

• Significant OE

• Covered by Reg Program

• Substantial Further Evaluation Licensee Program Adheres to GALL

• Sampling of population

• Confirmatory gap analysis

• Detailed confirmatory

• OE/Effectiveness

• Enhancement review evaluation

• Consistency

• Detailed OE review

Category 4 Category 5 Category 6

• Unchanged

• Supplemented or Modified* Plant-specific Exceptions

• More detailed Further Evaluation

• Significant OE Licensee Program

• Substantial Further Contains Plant-Evaluation specific

• Sampling of population

• Confirmatory gap analysis

• Detailed confirmatory Considerations

• OE/Effectiveness

• Enhancement review evaluation

• Consistency

• Plant-specific considerations

• Detailed OE review

• Unique program attributes ©2024 Nuclear Energy Institute 5 Graded Approach - Example Plants

Plant Total AMPs Cat. 1 Cat. 2 Cat. 3 Plant X 48 22 46 15 31 11 23

Plant Y 49 21 43 17 35 11 22

Plant Z 48 12 25 21 44 15 31

Average 48 18 38 18 38 12 25

Key Takeaway: ~75% of AMPs are Cat. 1 and Cat. 2

©2024 Nuclear Energy Institute 6 General Verification Process Review Commitment for AMP

• Confirm consistency with GALL-SLR (new - Cat. 1)

• Confirm continuation of FLR AMP and inclusion of GALL-SLR enhancements (existing -Cat. 1)

• Verify enhancements address the gaps to GALL-SLR or plant -specific OE (Cat. 2

& Cat. 3)

Review Appendix A and B write-ups

• Compare descriptions for consistency and required elements per SRP-SLR

• Verify consistency within the applications write-ups, commitment table, and Appendix B tables

• Review OE write-up in Appendix B

• Check Further Evaluations where applicable

• Search 9-column Tables for AMP and check for inconsistencies

©2024 Nuclear Energy Institute 7 Environmental Reviews

Environmental reviews are an important component of SLR applications and efficiency is essential to meeting overall SLR review goals

Seek understanding of environmental review plans and schedule that supports the NRC's FY2024 goals

NEI introduced recommendations at public meeting on October 31, 2023

Interested in staff feedback and perspectives

©2024 Nuclear Energy Institute 8 Feedback and Discussion Backup Slides Environmental Review Efficiencies

• Eliminate or reduce the scoping process

• Fully leverage the LR GEIS and initial LR SEISs

• Use exemptions and develop a process for preparing an Environmental Assessment/Finding of No Significant Impact 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

• 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 -

N E PA )

• Expedite a lessons learned review of NRC SLR-related consultations with other federal and state agencies