ML24116A216
| ML24116A216 | |
| Person / Time | |
|---|---|
| Issue date: | 04/25/2024 |
| From: | John Wise, Angela Wu NRC/NRR/DNRL/NLRP |
| To: | |
| References | |
| Download: ML24116A216 (1) | |
Text
Public Meeting to Discuss Possible Efficiencies on the Subsequent License Renewal Application Rev iew
Angela Wu, John Wise April 29, 2024 Meeting Agenda
A. S EC Y-24-0026: License Renewal Roadmap (Commission Paper + Supplement)
B. The Tiered Approach
C. Piloting the Tiered Approach
D. Standardization of Applications
2 SEC Y-24-0026, Achieving Timely Completion of License Renewal Safety and Environmental Reviews (License Renewal Roadmap) (ML24059A131, March 28, 2024)
License Renewal Roadmap: Goal of timely and predictable 18-month reviews, while reducing staff resources
Safety Environmental An optimized, efficient review depends on a high-quality, Review Review uncontested application, and timely and sufficient responses to requests for information
Process Process Enhanced review approaches, many adapted from new and Improvements Improvements advanced reactor application reviews, have already led to efficiency gains Awaiting Tiered Approach Commission decision - Feb 2024 18-month schedules update to LR GEIS
- Feasible starting FY 2026
Updates to Ongoing work to
- Staff recommendation to sta g ge r applications NUREG-2191 + evaluate new NEPA NUREG-2192 requirements from the FRA Public dashboard on Roadmap Progress (August 2024) 3 Safety Rev i ew : 3-Phase Approach
For more information, see S EC Y 0026, Appendix D.
Mar 2024 Apr 2024 Dec 2024 4
Environmental Review
Process Improvement Initiatives 1 Streamline EIS Development More to come, following:
2 Agile Methodology for Workload Planning 3 Realignment of the ECOE Commission decision on Feb 21, 2024 4 Use of Technology Tools to Improve Audits update to LR GEIS ( ML23202A179)
5 Requests for Confirmatory Information (RCIs) Staff s Notation Vote Paper (May 2024):
6 Improvements in Comment Processing
- Options + recommendations for 7 Streamlining Administrative Prepublication Reviews addressing new NEPA requirements 8 Assessment of Public Meetings set forth by the FRA
9 Increased Use of Contractor Support for Reviews For more information, see Ongoing based on lessons learned S EC Y 0026, Appendix E.
5 Staff Recommendation: Stag gering Future Submittals
Proven successful Minimizes staffing approach constraints
(NFPA 805/ Front loading One Initial License staff expertise application Renewal) every 3 months No significant Facilitates 18-impact on Industry thoughts?
month reviews continued safe operation of reactor fleet
6 S EC Y 0026A: Supplement to SECY-24- 0026 (ML24101A364, April 15, 2024)
Supplement: Detailed analysis of resource usage for Comanche Peak LRA and Monticello SLRA reviews to illustrate the efficiency gains already achieved
Underbudget + On Schedule Efficiency gained from already Notable Safety + Environmental implemented Roadmap initiatives Review Experiences
N o te: As these reviews are still ongoing, the data cited is preliminary and does not portray the total expenditures for the reviews.
7 Comanche Peak LRA
- Environmental: Issued DSEIS (10/31/23); FSEIS (Target: 4/2024)
Estimated @ Expended (As of 3/23/24) Process Improvements Implemented Acceptance (S EC Y 0026, Appendices D and E)
H o urs Cost Staff Cost Contractor Costs* Total Costs S a fe t y Environmental 23,000 $6.9M $4.1M $0.5M $4.6MEarly Process Improvements Phase 1Process Improvements Approximately 67% of original expected resources has been expended (Table D-1) (Table D-2) (Table E-1) 88% 57% 78%
- Safety: 70% fewer RAIs and 70% fewer RCIs than previous SLR review; No significant challenging technical issues Complete, well-developed LRA
- Env: Leverages 2013 LR GEIS, limited RAIs and RCIs (12 RAIs, Applicant provided prompt, proactive responses to 25 RCIs), successfully applied contractor support staff s questions
Comanche Peak LRA Costs
8.0M
7.0M
6.0M
5.0M
4.0M
3.0M
2.0M
1.0M
.0M 0 3 6 9 12 15 18 21 24
Number of months from receiving the application
Estimated Total Total unofficial data Safety
Safety unofficial Environmental Environmental unofficial Estimated completion 9
Monticello SLRA
- Environmental: Issued DSEIS (4/12/24); FSEIS (Target: 10/2024)
Estimated @ Expended (As of 3/23/24) Process Improvements Implemented Acceptance (S EC Y 0026, Appendices D and E)
H o urs Cost Staff Cost Contractor Costs* Total Costs S a fe t y Environmental 24,000 $7.2M $3.2M $0.4M $3.6MEarly Process Improvements Phase 1Process Improvements Approximately 50% of original expected resources has been expended (Table D-1) (Table D-2) (Table E-1) 100% 57% 89%
- Safety: 75% fewer RAIs and 90% fewer RCIs than previous SLR review; Leveraged 3 audits to successfully resolve Productive interactions with applicant technical issues Aligns with NRC recommendation to
- E nv : S i te-specific EIS; while DSEIS timeline was extended stagger future submittals due to need for information, FSEIS and licensing decision on schedule 10
- Contractor costs are estimated and a lagging indicator of actual expended costs.
Monticello SLRA - Costs Expended
Monticello SLRA Costs
8.0M
7.0M
6.0M
5.0M
4.0M
3.0M
2.0M
1.0M
.0M 0 3 6 9 12 15 18 21 24
Number of months from receiving the application
Estimated Total Total unofficial data Safety
Safety unofficial Environmental Environmental unofficial Estimated completion 11 Future Reviews
With the License Renewal Roadmap and continuous lessons learned, the estimated target starting with applications received in FY 2026 is 15,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br />s*.
Considerations:
- Dependent on Commission decision on LR GEIS
- Stag gering of applications (1 application every 3 months)
- Quality of application, timely and sufficient responses, and proper issue resolution
- Estimate will continue to be refined as data is available.
12 The Tiered Approach: Tailoring the Level of Staff s Safety Review
Incorporating Risk Insights
Leveraging Operating Programs
Leveraging Previous Reviews
Leveraging NRC/Industry Operating Experience with Aging Management
Consistency with NRC Guidance Documents
13 The Tiered Approach: Generic Tiering
NRC Generic Tiering NEI Graded Approach AMP Breakdown Average of 3 Plants
Low High High (Cat 3)
(Confirmation) (Standard) Low (Cat 1)
Medium Medium (Cat 2)
(Modified)
- NEI: Jan 11, 2024 public meeting
14 The Tiered Approach: Generic Tiering
Standard Modified Confirmation Mechanical Mechanical Mechanical XI.M20 XI.M9 X.M1 XI.M22 XI.M12 X.M2 XI.M26 XI.M16A* XI.M1 XI.M27 with MRP-227, R2-AXI.M2 XI.M33 XI.M17 XI.M3 Comprehensive XI.M35 XI.M21A XI.M4 XI.M36 XI.M23 XI.M7 Review XI.M41 XI.M24 XI.M8 Confirmation XI.M42 XI.M29 XI.M10 Operating experience XI.M30 XI.M11B Check Structural XI.M32 XI.M18 Basis documents XI.S6 XI.M37 XI.M19 Operating experience As needed: XI.M38 XI.M25 Electrical XI.M40 XI.M31 Verify essential details procedures, analyses, X.E1 XI.M39 in basis documents inspection results, XI.E1 Structural health reports XI.E2 X.S1 Structural XI.E3A XI.S3 XI.S1 XI.E3B XI.S8 XI.S2 XI.E3C XI.S4 XI.E6 Electrical XI.S5 XI.E4 XI.S7 XI.E5 XI.E7 15 Tiering Process
Is it a standardized, Are SSCs typically Can later oversight Insights from recent Generic proven program? of lower risk? provide assurance of reviews & operating implementation? experience? Tier
Do plant-specific Does the Is the proposal Plant-considerations application consistent with NRC Specific change the generic reference prior guidance? Tier answers? AMP reviews?
16 Pilot Plant: Dresden Nuclear Power Station, Units 2 and 3, SLRA
Staff begins with Staff considers N RC tai l ors Generic Tiering application + Generic Tiering into input from applicant Dresden Tiering
Input Requested 1) Plant-specific operating experience, e.g., significant or frequent aging degradation of Applicant
- 2) Consistency with the GALL-SLR Report, e.g., complexity and number of exceptions and/or enhancements
- 3) The extent to which an AMP is largely a continuation of existing operating (40-60 year) programs, e.g.,
reliance on NRC -approved Codes and Standards, topical reports, or other mature inspection frameworks
- 5) Reliance of fleet -wide programs that have been reviewed during previous LRA or SLRA reviews, with a clear basis for why those programs are also appropriate for the specific site (considering plant configuration, operating experience)
17 Standardization of Applications: Safety Review
Technical Review
- Standardize Package (TRP) Tool tables, sections
- Simple, automatic
- Improved accuracy nomenclature, processing of and efficiency in any application submittal reduces review assignments changes manual efforts and staff hours Safety Work Applications Assignments
18 Example #1: Changes to Table 2s as a Result of RAI Responses/Supplements
- Automatically read the changes throughout the life of the review and notify reviewers of impacted TRP assignments
- Applicants will create a unique identifier to number each AMR item in the application
- When a change is made, additional lines are added to the tables to explicitly describe the change.
19 Example #2: Appendix A - New Summary Table for AMPs/TLAAs
- New table to summarize the AMPs/TLAAs requires low effort from applicants
- Consistent nomenclature allows TRP Tool to assign AMPs/TLAAs automatically
20 Questions?
21