ML24010A020
| 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
©2024 Nuclear Energy Institute Brett Titus Licensing Director Regulatory Affairs January 11, 2024 Public Meeting on SLR Efficiencies
©2024 Nuclear Energy Institute 2 Overview of the complete approach.
Recap of Initiative Graded Approach Examples and Verification Environmental Discussion/Next Steps Industry focus area and near-term opportunity.
Practical application of the Graded Approach.
This is an essential piece of the effort.
Continue moving forward.
Agenda
©2024 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
©2024 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
©2024 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
©2024 Nuclear Energy Institute 6 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 7 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 General Verification Process
©2024 Nuclear Energy Institute 8 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 Environmental Reviews
Feedback and Discussion
Backup Slides
- Eliminate or reduce the scoping process
- 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-NEPA)
- Expedite a lessons learned review of NRC SLR-related consultations with other federal and state agencies Environmental Review Efficiencies