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 Review Angela Wu, John Wise April 29, 2024
2 A. SECY-24-0026: License Renewal Roadmap (Commission Paper + Supplement)
B. The Tiered Approach C. Piloting the Tiered Approach D. Standardization of Applications Meeting Agenda
SECY-24-0026, Achieving Timely Completion of License Renewal Safety and Environmental Reviews (License Renewal Roadmap) (ML24059A131, March 28, 2024) 3 License Renewal Roadmap: Goal of timely and predictable 18-month reviews, while reducing staff resources Safety Review Process Improvements Tiered Approach Updates to NUREG-2191 +
NUREG-2192 Environmental Review Process Improvements Awaiting Commission decision - Feb 2024 update to LR GEIS Ongoing work to evaluate new NEPA requirements from the FRA An optimized, efficient review depends on a high-quality, uncontested application, and timely and sufficient responses to requests for information Enhanced review approaches, many adapted from new and advanced reactor application reviews, have already led to efficiency gains 18-month schedules
- Feasible starting FY 2026
- Staff recommendation to stagger applications Public dashboard on Roadmap Progress (August 2024)
Safety Review: 3-Phase Approach Mar 2024 Apr 2024 Dec 2024 For more information, see SECY-24-0026, Appendix D.
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Environmental Review For more information, see SECY-24-0026, Appendix E.
Process Improvement Initiatives 1 Streamline EIS Development 2 Agile Methodology for Workload Planning 3 Realignment of the ECOE 4 Use of Technology Tools to Improve Audits 5 Requests for Confirmatory Information (RCIs) 6 Improvements in Comment Processing 7 Streamlining Administrative Prepublication Reviews 8 Assessment of Public Meetings 9 Increased Use of Contractor Support for Reviews More to come, following:
Commission decision on Feb 21, 2024 update to LR GEIS (ML23202A179)
Staffs Notation Vote Paper (May 2024):
Options + recommendations for addressing new NEPA requirements set forth by the FRA 5
Ongoing based on lessons learned
Staff Recommendation: Staggering Future Submittals Proven successful approach (NFPA 805/
Initial License Renewal)
Minimizes staffing constraints Front loading staff expertise Facilitates 18-month reviews No significant impact on continued safe operation of reactor fleet One application every 3 months Industry thoughts?
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SECY-24-0026A: Supplement to SECY-24-0026 (ML24101A364, April 15, 2024) 7 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 implemented Roadmap initiatives Notable Safety + Environmental Review Experiences Note: As these reviews are still ongoing, the data cited is preliminary and does not portray the total expenditures for the reviews.
Comanche Peak LRA 8
Estimated @
Acceptance Expended (As of 3/23/24)
Hours Cost Staff Cost Contractor Costs*
Total Costs 23,000
$6.9M
$4.1M
$0.5M
$4.6M Approximately 67% of original expected resources has been expended Safety: Issued SE (3/18/24, 16 months); ACRS FC Meeting (4/30/24)
Environmental: Issued DSEIS (10/31/23); FSEIS (Target: 4/2024)
Process Improvements Implemented (SECY-24-0026, Appendices D and E)
Safety Environmental Early Process Improvements (Table D-1)
Phase 1 (Table D-2)
Process Improvements (Table E-1) 88%
57%
78%
Complete, well-developed LRA Applicant provided prompt, proactive responses to staffs questions Safety: 70% fewer RAIs and 70% fewer RCIs than previous SLR review; No significant challenging technical issues Env: Leverages 2013 LR GEIS, limited RAIs and RCIs (12 RAIs, 25 RCIs), successfully applied contractor support
- Contractor costs are estimated and a lagging indicator of actual expended costs.
Comanche Peak LRA - Costs Expended 9
.0M 1.0M 2.0M 3.0M 4.0M 5.0M 6.0M 7.0M 8.0M 0
3 6
9 12 15 18 21 24 Cost Billed Number of months from receiving the application Comanche Peak LRA Costs Estimated Total Total unofficial data Safety Safety unofficial Environmental Environmental unofficial Estimated completion
Monticello SLRA 10 Estimated @
Acceptance Expended (As of 3/23/24)
Hours Cost Staff Cost Contractor Costs*
Total Costs 24,000
$7.2M
$3.2M
$0.4M
$3.6M Approximately 50% of original expected resources has been expended Safety: Issued SE (3/18/24, 13 months); ACRS FC Meeting (4/30/24)
Environmental: Issued DSEIS (4/12/24); FSEIS (Target: 10/2024)
Process Improvements Implemented (SECY-24-0026, Appendices D and E)
Safety Environmental Early Process Improvements (Table D-1)
Phase 1 (Table D-2)
Process Improvements (Table E-1) 100%
57%
89%
Productive interactions with applicant Aligns with NRC recommendation to stagger future submittals Safety: 75% fewer RAIs and 90% fewer RCIs than previous SLR review; Leveraged 3 audits to successfully resolve technical issues Env: Site-specific EIS; while DSEIS timeline was extended due to need for information, FSEIS and licensing decision on schedule
- Contractor costs are estimated and a lagging indicator of actual expended costs.
Monticello SLRA - Costs Expended 11
.0M 1.0M 2.0M 3.0M 4.0M 5.0M 6.0M 7.0M 8.0M 0
3 6
9 12 15 18 21 24 Cost Billed Number of months from receiving the application Monticello SLRA Costs Estimated Total Total unofficial data Safety Safety unofficial Environmental Environmental unofficial Estimated completion
Future Reviews 12 Considerations:
- Dependent on Commission decision on LR GEIS
- Staggering of applications (1 application every 3 months)
- Quality of application, timely and sufficient responses, and proper issue resolution 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*.
- Estimate will continue to be refined as data is available.
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 13
The Tiered Approach: Generic Tiering 14 High (Cat 3)
Medium (Cat 2)
Low (Cat 1)
NEI Graded Approach Average of 3 Plants
- NEI: Jan 11, 2024 public meeting High (Standard)
Medium (Modified)
Low (Confirmation)
NRC Generic Tiering AMP Breakdown
The Tiered Approach: Generic Tiering 15 Standard Modified Confirmation Mechanical XI.M20 XI.M22 XI.M26 XI.M27 XI.M33 XI.M35 XI.M36 XI.M41 XI.M42 Structural XI.S6 Electrical X.E1 XI.E1 XI.E2 XI.E3A XI.E3B XI.E3C XI.E6 Mechanical XI.M9 XI.M12 XI.M16A*
with MRP-227, R2-A XI.M17 XI.M21A XI.M23 XI.M24 XI.M29 XI.M30 XI.M32 XI.M37 XI.M38 XI.M40 Structural X.S1 XI.S3 XI.S8 Electrical XI.E4 XI.E5 XI.E7 Mechanical X.M1 X.M2 XI.M1 XI.M2 XI.M3 XI.M4 XI.M7 XI.M8 XI.M10 XI.M11B XI.M18 XI.M19 XI.M25 XI.M31 XI.M39 Structural XI.S1 XI.S2 XI.S4 XI.S5 XI.S7 Comprehensive Review Operating experience Basis documents As needed:
procedures, analyses, inspection results, health reports Confirmation Check Operating experience Verify essential details in basis documents
Tiering Process 16 Is it a standardized, proven program?
Are SSCs typically of lower risk?
Can later oversight provide assurance of implementation?
Insights from recent reviews & operating experience?
Generic Tier Do plant-specific considerations change the generic answers?
Does the application reference prior AMP reviews?
Is the proposal consistent with NRC guidance?
Plant-Specific Tier
Pilot Plant: Dresden Nuclear Power Station, Units 2 and 3, SLRA 17 Input Requested of Applicant
- 1) Plant-specific operating experience, e.g., significant or frequent aging degradation
- 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)
Staff begins with Generic Tiering Staff considers application +
input from applicant NRC tailors Generic Tiering into Dresden Tiering
Standardization of Applications: Safety Review 18
- Standardize tables, sections nomenclature, any application changes Applications
- Simple, automatic processing of submittal reduces manual efforts and staff hours Technical Review Package (TRP) Tool
- Improved accuracy and efficiency in review assignments Safety Work Assignments
Example #1: Changes to Table 2s as a Result of RAI Responses/Supplements 19 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.
Automatically read the changes throughout the life of the review and notify reviewers of impacted TRP assignments
Example #2: Appendix A - New Summary Table for AMPs/TLAAs 20
- New table to summarize the AMPs/TLAAs requires low effort from applicants
- Consistent nomenclature allows TRP Tool to assign AMPs/TLAAs automatically
Questions?
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