ML24039A097
| ML24039A097 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/2024 |
| From: | Lauren Gibson, John Wise NRC/NRR/DNRL/NLRP |
| To: | NRC/NRR/DNRL/NLRP |
| Wu, A., NRR/DNRL/NLRP, 301-415-2995 | |
| References | |
| Download: ML24039A097 (13) | |
Text
Public meeting to discuss possible efficiencies on the Subsequent License Renewal review Lauren Gibson, John Wise February 13, 2024
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 2
The Tiered Approach: Tailoring the Level of Staffs Safety Review Incorporating Risk Insights Leveraging Operating Programs Leveraging Previous Reviews Leveraging NRC/Industry Operating Experience with Aging Management Consistency with NRC Guidance Documents 3
Staff Requirements Memorandum (SRM-M231102): License Renewal Roadmap (ML23345A214)
Tiers of Review 4
Standard (High)
Modified (Medium)
Confirmation (Low)
Application Operating experience AMP and TLAA basis documents Engineering analyses Implementing procedures Inspection and test results Corrective actions Application Operating experience AMP and TLAA basis documents
[Discretion to review key details in other plant documents]
Application Operating experience
[Discretion to confirm key details in basis documents]
- For previously approved AMPs, a focus on gaps and new information AMP or TLAA weighing factors High risk/safety significant SSCs Medium risk/safety significant SSCs Low risk/safety significant SSCs Limited or no reference to widely accepted standards GALL-SLR recommends significant augmentation of industry standards Mature plant programs with high degree of standardization No or minimal NRC oversight/visibility Moderate NRC oversight/visibility Robust NRC oversight/visibility No prior reviews Relies on some aspects of previous reviews Fully leverages previous reviews (initial license reviews or fleetwide programs)
Plant-specific AMPs or a high number/significance of exceptions to GALL-SLR Limited GALL-SLR inconsistencies Full GALL-SLR consistency Recent, novel, or reoccurring operating experience of degradation Operating experience shows average trends Absence of unexpected operating experience of degradation; or shows positive trends TLAAs dispositioned with calculations:
10 CFR 54.21(c)(1)(i or ii)
TLAAs that are dispositioned with an AMP:
10 CFR 54.21(c)(1)(iii)
Tiering Process 5
Generic Risk Characterization
- Compilation of plant PRAs Operating Program Characteristics
- Codes, standards, topical reports
- NRC oversight Integrated Panel Review Generic Review Tiers Standard Confirmation Modified Plant-Specific Adjustments PRA Operating Experience GALL Consistency Prior Reviews (Initial LR or Fleet)
Plant-Specific Review Tiers Standard Confirmation Modified Feedback to General Tiering Process
Incorporating Risk Insights 6
PRA Information Traditional Engineering Factors Incorporating Risk Insights Follows general framework of LIC-206, Integrated Risk-Informed Decision-Making for Licensing Reviews NRC to enhance its current review process to develop a clear, comprehensive, and predictable methodology to determine the depth of review.
NRC will continue to invite applicants to voluntarily make PRA information available - supplementing NRCs own information i
Leveraging Operating Programs 7
NRC to enhance its current review process to more fully leverage operating programs to determine the appropriate level of review:
Operating programs cited by GALL-SLR Mature, existing plant programs/activities that are captured by NRC oversight Additional training will be provided to technical staff on the inspection and oversight process, for a holistic understanding of how existing NRC processes complement the license renewal application review.
NRC welcomes information exchanges with industry and applicants to discuss controls and oversight of applicable programs.
i
Leveraging Previous Reviews 8
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 Allows for greater focus:
Operating Experience Unique Site-Specific Considerations Changes to aging management approaches since prior review Efficiency will be aided by providing NRC with a roadmap between the prior and current proposal (e.g., mark-ups to prior AMP documentation)
Initial Renewal of Same Reactor Site Utility Reactor Fleet Prior Reviews i
Leveraging NRC/Industry Operating Experience with Aging Management 9
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.
Burn-in Maturity Wear-out Chance of Failure Figure: Bathtub curve Ensure applications are promptly updated to reflect new information (NRC RIS 2014-06, Rev 1) i
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 The functions and format of the electronic audit portal can impact the staffs efficiency of confirmation of consistency i
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 Ongoing:
Re-evaluation of Tiered Approach/Lessons Learned Note: The Tiered Approach schedule cited above is a DRAFT and subject to change.
SLR Efficiencies Project
Questions?
13