ML24142A560

Summary of the April 29, 2024, Public Meeting to Discuss Possible Efficiencies on the Subsequent License Renewal Review

ML24142A560
Person / Time
Issue date:	05/28/2024
From:	Angela Wu NRC/NRR/DNRL/NLRP
To:	Lauren Gibson NRC/NRR/DNRL/NLRP
References
Download: ML24142A560 (10)

Text

May 28, 2024

MEMORANDUM TO: Lauren K. Gibson, Chief Licensing Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation

FROM: Angela Wu, Senior Project Manager /RA/

Licensing Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation

SUMMARY

OF THE APRIL 29, 2024, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW

On April 29, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff held an information meeting with the Nuclear Energy Institute (NEI) on possible efficiencies on the Subsequent License Renewal (SLR) review. The public meeting notice is located at Agencywide Documents Access and Management Systems (ADAMS ) Accession No. ML24117A272. The agenda and list of meeting attendees are included as in Enclosures 1 and 2 of this meeting summary respectively.

SUMMARY

As a follow-up from the February 13, 2024, meeting (ML24057A028), the purpose of this meeting was for the NRC staff to further discuss efficiency opportunities for the SLR review process with NEI, industry, and members of the public. The NRC staffs presentation (ML24116A216) highlighted SECY-24-0026, Achieving Ti mely Completion of License Renewal Safety and Environmental Reviews (License Renewal Roadmap) dated March 28, 2024 (ML24059A131), the supplement to SECY-24-0026 dated April 15, 2024 (ML24101A364), the Tiered Approach, piloting the Tiered Approach, and the standardization of applications.

SECY-24-0026, Achieving Timely Completion of License Renewal Safety and Environmental Reviews (License Renewal Roadmap)

The License Renewal Roadmap, as detailed in SECY-24-0026, describes the staffs goal to achieve timely and predictable 18-month license renewal reviews while reducing resources and providing reasonable assurance of adequate protection of public health and safety.

CONTACT: Angela Wu, NRR/DNRL 301-415-2995

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The agency strives to meet the regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Part 54 and 51, including related National Environmental Policy Act (NEPA) requirements.

The License Renewal Roadmap entails initiatives for both the safety and environmental review.

Of the 3-phase approach for the safety review, the staff implemented Phase 1, Process Improvements, on March 29, 2024, and launched Phase 2, Tiered Approach in April 2024.

The staff plans to complete Phase 3, Additional Process Improvements, by December 2024.

Additionally, the staff is updating NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, and NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, with an upcoming public meeting scheduled for May 23, 2024.

Similar to the safety review, the environmental review has undertaken nine initiatives that have been implemented in active reviews and will continue to do so for future reviews. While not formally a part of the Roadmap, the staff is also awaiting the Commission decision on an update to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS), dated February 21, 2024 (ML23202A179), that will fully support one-term of SLR, if approved. Furthermore, the staff continues to evaluate the new NEPA requirements set forth in section 321 of the Fiscal Responsibility Act (FRA) and how they affect the NRCs environmental review regulations in 10 CFR Part 51 and related guidance, processes, and policy. The staff plans to provide a notation vote paper to the Commission in May 2024 that will include options and recommendations for addressing the new requirements.

To track and report License Renewal Roadmap progress, a public dashboard will be available starting August 2024.

To make 18-month reviews more feasible, the staff recommends that the industry stagger applications (one application every 3 months), noting its success in the Alternate Fire Protection Rule (NFPA) 805 reviews and initial license renewal. Such frequency would minimize staffing constraints, allowing for staff experts to focus on the key technical parts of each review before efficiently transitioning to the next review. The staffs analysis took into consideration the expiration dates of the current fleet and determined that staggering would not have impact on the expiration or safety of the plants.

Per SECY-24-0026, the staff estimated that 18-month reviews will be feasible starting fiscal year 2026, at 15,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per review. However, the staff emphasized that with the implementation of the License Renewal Roadmap and continuous lessons learned, work processes and estimated costs/schedules will continue to be re fined as the NRC reviews more license renewal applications (LRA).

During the discussion portion, productive dialogue was held on multiple topics:

• In response to the NRCs recommendation to stagger applications, NEI stated that the industry will be taking this recommendation into consideration. The NEI questioned whether increasing the timeframe between applicat ions would result in a review that was less than 18 months. The staff noted that the 18-month review schedule considers audits, as well as requirements outside of NRC regulation (ie, NEPA requirements) that contribute to the 18-month timeframe. Therefore, increasing the time between applications would not translate into a review shorter than 18 months.

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• NEI recognized that staggering applications would contribute to more predictable reviews but noted that there are other business considerations that have a date tied to them, as well as other license amendments such as power uprates. Such activities may introduce challenges to the staggering of applications, but NEI will continue to explore the topic with the industry.

• Regarding the cost of the review, NEI noted the breakdown of the review costs have historically been: two-thirds for the safe ty review, and one-third for the environmental review. NEI questioned whether it would be correct to assume this trend to continue in the future. In response, the NRC confirmed the distribution of the costs is not expected to change.

• ENERCON questioned whether the NRCs staggering recommendation would offer adequate time for program implementation fo llowing the issuance of renewed licenses.

In response, the NRC stated that the analysis was conducted in accordance with the expected applications. With that information, the staggering of one application every 3 months would allow each applicant 3.5 years to implement programs from the date of the renewed license(s).

SECY-24-0026A: Supplement to SECY-24-0026

The supplement to SECY-24-0026A focuses on two active reviews, Comanche Peak Nuclear Power Plant, Units 1 and 2 (Comanche Peak) LRA and Monticello Nuclear Generating Plant, Unit 1 (Monticello) subsequent license renewal application (SLRA), expenditures, and efficiencies gained from process improvement initiatives.

As both the Comanche Peak LRA and Monticello SLRA review are still ongoing, the data presented was preliminary and did not portray the total expenditures for the reviews.

Additionally, as both reviews are simply just two data points, the data did not represent a trend for all reviews that follow. However, the NRC staff found the data to be optimistic for increased efficiency for plants to follow, as it has shown in Comanche Peak and Monticello.

Both the Comanche Peak LRA and Monticello SLRA are expected to be completed underbudget and on schedule; the efficiencies can be attributed to the initiatives that have been implemented and the reviews itself (see Slides 8 to 11 of ML24116A216 for additional detail). Of special note, the timing of the Monticello SLRA submittal supported the staffs recommendation of staggering applications at one application ever y 3 months. Monticellos submittal arrived 3 months after a previous review, and the next application followed 3 months after. The staff observed that with such distribution of applications, the staff constraints were minimized, and the staff experts were effectively focused on t he key activities for Monticello before moving along to the next review.

The Tiered Approach and Piloting the Tiered Approach

The Tiered Approach tailors the level of staff review of aging management programs and time-limited aging analyses by incorporating risk insi ghts, leveraging operating programs, leveraging previous reviews, leveraging the NRC and industrys operating experience with aging management, and considering consistency with NRC guidance documents.

As part of the staffs presentation, the staff presented its generic tiering aging management programs (AMP) breakdown, which was comparable to NEIs graded approach of three plants L. Gibson 4

from the January 11, 2024, public meeting (ML24024A227). Slide No. 15 of the presentation is the staffs generic tiering findings for AMPs, as classified into the three different tiers of review -

standard, modified, and confirmation. The standard tier would entail a comprehensive review, while the confirmation tier would entail a confirmation check. The staff emphasized that the Tiered Approach does not necessarily mean there will be a greater depth of review overall; there will be scenarios where a lesser degree of review is required. All in all, the goal is for all areas of application to be allocated the proper level of review.

To determine the tiering for a specific application, the staff will begin with the generic tiering as its starting point. With the questions listed on Slide No. 16, the plant-specific tiering for each application will be developed.

The pilot plant of the Tiered Approach will be Dresden Nuclear Power Station, Units 2 and 3 (Dresden) SLRA. For Dresden, as explained above, the staff first begins with the generic tiering.

Then, considering the application and input from the applicant (questions listed on Slide No. 17),

the staff will develop the Dresden Tiering.

During the discussion portion, productive dialogue was held on multiple topics:

• NEI noted its appreciation for the staffs work on the Tiered Approach and recognized that the NRC and NEI were in the same ballpark. However, NEI noticed that there were four instances where NEI/NRC were in two degr ees of separation for the level of review.

NEI requested that NRC and NEI have a meeting in the future to discuss the technical details in greater detail.

In response, the NRC agreed that this public meeting may not be the right forum to go into the technical detail of the disposition of each AMP in the generic tiering but would be happy to discuss in a future meeting.

The NRC further explained that to determine the generic tiering, the staff reviewed the previous applications and also considered the level of oversight each AMP had in the inspection process that followed the issuance of a renewed license. The staff had recently received training from a senior inspector on the oversight of AMPs.

NEI appreciated the insight on how the generic tiering was developed and noted that it was interested in places where NRC/NEI were further apart in the disposition of the level of review for a particular technical area. NEI noted the importance of this was to be able to share with applicants the right information that would be helpful to the NRC in its plant-specific tiering.

While it was noted that there are four AMPs that conflicted in level of review, the staffs later clarified that it was a total of five:

1. X.E1, Environmental Qualification of Electric Equipment

2. XI.M22, Boraflex Monitoring

3. XI.M26, Fire Protection

4. XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements

5. XI. E2, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumental Circuits L. Gibson 5

• Constellation Energy Generation, LLC (Constellation) noted that the number of enhancements is a big factor in the generic tiering. Since it is normally a commitment for the applicant, Constellation asked why it was used as a factor to determine the generic tiering.

In response, the staff explained that while certain AMPs are binned into a higher tier, it does not necessarily equate into a deeper review; simply, its the opportunity to explore additional details if necessary. For example, in its evaluation of the adequacy of an enhancement, the staff may seek to better understand the gap between the current program and the GALL Report guidance.

Standardization of Applications: Safety Review

To improve the staffs process of making work assignments for the safety review, the staff introduced the standardization of future applications. As part of Phases 1 and 3 of the safety reviews 3-phase approach, the modernization of the Technical Review Package (TRP) Tool leverages automation processing of the application. In addition to reducing staffs manual efforts and hours, the automation feature is expected to contribute to improved efficiency, accuracy and timeliness of making work assignments for both initial and subsequent license renewal reviews.

Because the TRP Tool will begin to utilize automation, standardizing the format of an application will be instrumental in the effectiveness of the Tool. Particularly, consistency in the tables, nomenclature, and the process for capturing application changes across applications will enable greater efficiency.

During the discussion portion, productive dialogue was held on multiple topics:

• NEI questioned whether the communication of the standardized application format will be one on one as each applicant prepares for submission of their application to the NRC, or if it would be an industry rollout. In response, the NRC stated it will be more of the latter, and reminded the industry that applicants have the opportunity to have pre-application engagements with their respective project managers for questions or guidance on submission.

• Constellation questioned if the NRC will be issuing formal guidance to capture the proposed standard approach to an application. It stated that while the application is compiled using a database, it will take time to update the database to be consistent with the standardized approach. The NRC replied that t he staff is still deliberating the best approach to document the recommended standard format of the application and will be providing an update at the next public meeting.

The NRC staff plans to hold its next public meeting on SLR efficiencies on July 9, 2024.

Enclosures:

1. Meeting Agenda

2. List of Attendees

ML24142A560 *via email NRR-106 OFFICE NRR/DNLR/NLRP: PM NRR/DNRL/NLIB: LA NRR/DNRL/NLRP: BC NRR/DNLR/NLRP: PM NAME AWu* KBratcher* LGibson* AWu*

DATE 05/21/2024 05/22/2024 05/28/2024 05/28/2024 7

U.S. NUCLEAR REGUALTORY COMMISSION

SUMMARY

OF THE APRIL 29, 2024, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW

Meeting Agenda

Time Topic Organization

1:00 pm-1:15 pm Introductions All

1:15 pm-2:15 pm Discussion NRC and NEI

2:15 pm-2:30 pm Opportunity for public comments NRC and Public

2:30 pm Adjourn All

Enclosure 1 U.S. NUCLEAR REGUALTORY COMMISSION

SUMMARY

OF THE APRIL 29, 2024, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW

List of Attendees

Name Affiliation Andrew Siwy U.S. Nuclear Regulatory Commission (NRC)

Angela Wu NRC Angela Sabet NRC Angie Buford NRC Aus ti n Im NRC Bart Fu NRC Billy Gleaves NRC Billy Rogers NRC Brandon Marlow NRC Brian Allik NRC Brian Correll NRC Bri an Harri s NRR NRC Brian Smith NRC Boyce Travis NRC Carol Moyer NRC Carolyn Fairbanks NRC Charles Kreuzberger NRC Christopher Regan NRC David Dijamco NRC David Rudland NRC Eric Bowman NRC Eric Palmer NRC Eric Reichelt NRC Garry Armstrong NRC Garry Young NRC Gerry Stirewalt NRC Greg Makar NRC James Medoff NRC Jason Paige NRC Jay Collins NRC Joel Jenkins NRC John Moses NRC John Tsao NRC John Wise NRC Karen Bratcher NRC Karen Loomis NRC Kenneth Fossum NRC Kevin Folk NRC Kim Conway NRC Lance Rakovan NRC Lauren Gibson NRC Leslie Terry NRC

Enclosure 2 2

Lloyd Desotell NRC Marieliz Johnson NRC Mark Yoo NRC Matt Burton NRC Matthew Yoder NRC Michael Benson NRC Michelle Kichline NRC Miranda Ross NRC Michelle Kichline NRC Naeem Iqbal NRC Omar Khan NRC Reena Boruk NRC Ricky Vivanco NRC Robert Gibson NRC Robert Davis NRC Robert Hoffman NRC Robert Taylor NRC Samuel Lee NRC Scott Burnell NRC Seung Min NRC Shakur Walker NRC Stephen Koenick NRC Steven Bloom NRC Steven Levitus NRC Tanya Smith NRC Ted Smith NRC Todd Keene NRC Varoujan Kalikian NRC Andrew Mauer Nuclear Energy Institute (NEI)

Brett Titus NEI Tony Brown NEI Andrew J Burgess Ameren Rigel Davis Ameren Casey Muggleston Constellation Nuclear Hannah Pell Constellation Nuclear Ida Ello Fletcher Constellation Nuclear Kurt Lindeman Constellation Nuclear Robert Froom Constellation Nuclear William Ford Jr. Constellation Nuclear Deann Raleigh Curtiss-Wright Jonathan Zeitz Department of Environmental Protection Veena Gubbi Department of Environmental Protection Pratt Cherry Dominion Energy Paul F Guill Duke-Energy Chris Saville Duke-Energy Keith J Miller Dominion Andrew Mantey Electric Power Research Institute (EPRI)

Monica Hurley EPRI Jeff Gromatzky ENERCON 3

Jeffrey Head ENERCON Richard Grumbir Entergy James Andersen Excel Services Michael Gallagher Exelon Helen Levendosky Indiana Michigan Power Company Steve Franzone Florida Power and Light Annessa Lippincott GSE Solutions Hunter Young Jensen Hughes Jerry Humphreys Nuclear Engineering Section Andrew Zach Senate Committee on Environment and Public Works Andrew Charles Taylor Tennessee Valley Authority (TVA)

Jonathan DeLaune TVA Adam Reinholz Xcel Energy Jason Tribe Xcel Energy Justin Truxall Vistra Corporation Richard Rogalski Volt Charles Chapski Cotasha Wilson Blackburn Ilya Golberg Lindsey Renee Grissom Michael Macfarlane