ML24204A269

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Summary of Public Meeting to Discuss Possible Efficiencies on the Subsequent License Renewal Review
ML24204A269
Person / Time
Issue date: 07/26/2024
From: Angela Wu
NRC/NRR/DNRL/NLRP
To: Lauren Gibson
NRC/NRR/DNRL/NLRP
References
Download: ML24204A269 (10)


Text

July 26, 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

SUBJECT:

SUMMARY

OF THE JULY 9, 2024, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW On July 9, 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. ML24185A246. 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 April 29, 2024, meeting (ML24142A560), 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 (ML24185A202) highlighted the newly launched License Renewal Roadmap Dashboard, and environmental and safety updates from the License Renewal Roadmap (SECY-24-0026, Achieving Timely Completion of License Renewal Safety and Environmental Reviews (License Renewal Roadmap) (ML24059A131) and SECY-24-0026A (ML24101A364)).

License Renewal Roadmap Dashboard 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

L. Gibson On June 26, 2024, the NRC staff published the License Renewal Roadmap Dashboard to provide updates on the progress of the License Renewal Roadmap, available on the NRC public website here: https://www.nrc.gov/reactors/operating/licensing/renewal/roadmap.html.

In response to NEIs question on how often the dashboard will be updated, the NRC staff stated that the Dashboard will be updated as soon as an initiative is complete, or a change has been made to the status of an ongoing activity. The NRC staff will provide periodic updates on the progress made on the License Renewal Roadmap at its reoccurring efficiency public meetings.

Environmental Review: Updates to Efficiency Efforts On May 16, 2024, the NRC Commission approved SECY-24-0017, Enclosure 2, NUREG-1437, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, (LR GEIS) (ML23202A179) as an update to the 2013 LR GEIS to fully account for SLR (ML24137A164). This revision includes 80 environmental issues for inclusion in the revised Table B-1, "Summary of Findings on NEPA [National Environmental Policy Act] Issues for License Renewal of Nuclear Power Plants," in Appendix B, "Environmental Effect of Renewing the Operating License of a Nuclear Power Plant," to Part 51, Subpart A, "National Environmental Policy Act-Regulations Implementing Section 102(2)."

NEI asked whether the final rule for the LR GEIS would be on track for completion by August 9, 2024. To this, the NRC staff confirmed that the rulemaking was undergoing an expedited review and is on track for August 9, 2024.

On May 30, 2024, the NRC staff submitted SECY-24-0046, Implementation of Fiscal Responsibility Act of 2023 National Environmental Policy Act Amendments, to evaluate the National Environmental Protection Act requirements set forth in section 321 of the Fiscal Responsibility Act. The notation vote paper offers recommendations on options to revise the NRCs implementing regulations to 10 CFR Part 51. At this time, the paper is pending NRC Commission decision.

As the paper includes six high-level policy topics, including streamlining and enhancing efficiency, NEI asked whether the environmental review initiatives cited in SECY-24-0026 will be revisited by the staff. The NRC staff clarified that the process improvement initiatives cited in SECY-24-0026, Appendix E, Table E-1, were implemented but also ongoing for all active and new environmental reviews, as appropriate, in accordance with the timing of each review.

Additionally, for the environmental review, the NRC staff has initiated an effort to leverage historical data to develop resource models to better assist with forecasting and improving efficiency across the Environmental Center of Expertise, starting with initial license renewal (LR) and SLR reviews. Looking ahead, the NRC staff expect to have datasets of different licensing actions to share by summer of 2024, and plan to host a public workshop early fall of 2024.

In response to the staffs efforts, NEI noted that the initiative would be a beneficial activity, as its been proven valuable for the safety review; trends and datasets would be helpful with the prioritization of work.

L. Gibson Safety Review: Updates to Efficiency Efforts For the safety review, the NRC staff provided an update on the piloting of the new License Renewal Roadmaps Tiered Approach to the Dresden Nuclear Power Station, Units 2 and 3, (Dresden) SLR application. In comparison to the NRCs generic tiering, Dresdens tiering broadly skewed lower than the generic tiering, primarily from leveraging fleetwide programs from a previous SLR review. The downgrading of the tiers of the aging management programs results in a more streamlined review. The staff reiterated that the Dresden tiering at the acceptance stage of the review is preliminary; the Tiered Approach is an ongoing methodology that is conducted throughout the review and is subject to change as a result of the staffs technical review.

On Slide 10 of the presentation, the staff showed three pie charts comparing NEIs graded approach, NRCs generic tiering, and Dresdens preliminary tiering. As noted previously, NEIs graded approach and NRCs generic tiering are similar in distribution of Low, Medium, and High level of review. In comparison, Dresens tiering is lower, indicating an even more streamlined review.

NEI noted that it will be valuable to continue the dialogue as the NRC staff conducts its technical review, with interest in the vision of the Tiered Approach. In addition, NEI questioned what applicants can prepare in its applications to aid the NRC staff in its application-specific tiering process. In response, the NRC staff stated that overall, the application speaks for itself. The NRC staff recognizes that applicants voluntarily provide risk information at the start of the review, and such information will continue to be useful in the application of the Tiered Approach.

Aside from the risk information, the NRC staff advises applicants to clearly cite the plants operating experience in the application.

Constellation Energy Generation, LLC (Constellation) expressed its appreciation on the work for the Tiered Approach, while S&P Global requested the data related to Slide 10 of the presentation. The NRC staff shared additional files from previous public meetings to S&P Global that included the data requested.

Standardization of Applications As described in the License Renewal Roadmaps safety reviews three-phased approach, the NRC staffs internal tool, the Technical Review Package (TRP) Tool is being modernized to automatically read PDF applications. Standardizing tables, application changes, and nomenclature allows for automatic processing of the submittal to reduce manual efforts and staff hours, while improving accuracy and efficiency.

While standardization of the applications is not a requirement, it contributes to a more efficient staff review. Applications that do not meet the standardization recommendations will be processed manually.

As the NRC staff walked through the Standardization Recommendations for License Renewal Applications - DRAFT (ML24184C131), numerous questions regarding standardization arose, noted in Table 1, Standardization of the Application - Questions & Answers. Another public meeting will be scheduled to solicit feedback on the staffs standardization recommendations.

L. Gibson Table 1: Standardization of the Application - Questions & Answers From Questions Answers (NRC) 1 NEI Can applicants implement the recommendations piecemeal, or must all recommendations be implemented?

It is acceptable to implement recommendations piecemeal; the more recommendations that are implemented to an application, the greater the efficiency in its processing.

It is important to be consistent with the recommendations that are chosen to be implemented. For example, if an application adopts the Table 1 recommendations, it is advisable that it is consistent for all Table 1s throughout the application.

2 Constellation Adding the AMR ID squishes the rest of the table, making it less legible. Could we use invisible text?

The NRC staff discussed this question with its developers following the meeting and determined that invisible text cannot be utilized.

3 Exelon Can we submit Excel Spreadsheets?

No, ADAMS only accepts PDF files.

4 NEI Can we use MAP-X?

No, MAP-Xs General Submission only accepts PDF.

5 TVA AMR ID will be useful, especially for breakout sessions.

Are we standardizing the usage of certain words in the tables?

The NRC staff will consider this recommendation in the future. A limited degree of word standardization may appear in the GALL-SLR update, but a more concerted effort will be considered in a future revision.

6 Constellation There is a fair amount of administrative work involved.

Applicants may provide a clean copy of the end result of the changes (not show the strikethroughs/highlights/etc).

7 Duke Energy How much savings would there be for standardization?

The NRC staff will provide estimated savings at the next public meeting.

8 Exelon Why is the changed line needed? Why do changes need to be put into the TRP Tool?

If the purpose of the TRP tool is to make work assignments, why do changes need to be incorporated?

The change line is to indicate where changes have been made as a result of RAI responses and/or supplements.

9 GE Nuclear Energy What if we make changes that are outside of the tables?

Changes made elsewhere in the application (outside of the tables) will not be processed automatically.

L. Gibson 10 Southern Nuclear Why are the commitments called FSAR Commitments?

It is best to have alignment with other commitments.

The NRC staff will continue exploring this question later date.

The NRC staff plans to hold its next public meeting on SLR efficiencies in September 2024.

Enclosures:

1. Meeting Agenda
2. List of Attendees

ML24204A269

  • 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 07/22/2024 07/23/2024 07/26/2024 07/26/2024

U.S. NUCLEAR REGUALTORY COMMISSION (NRC)

SUMMARY

OF THE JULY 9, 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 Nuclear Energy Institute 2:15 pm - 2:30 pm Opportunity for public comments NRC and Public 2:30 pm Adjourn All

U.S. NUCLEAR REGUALTORY COMMISSION

SUMMARY

OF THE JULY 9, 2024, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW List of Attendees Name Affiliation Alysia Bone U.S. Nuclear Regulatory Commission (NRC)

Andrew Siwy NRC Andy Patz NRC Angela Sabet NRC Angela Wu NRC Austin Im NRC Billy Gleaves NRC Billy Rogers NRC Brian Allik NRC Brian Correll NRC Brian Harris NRR NRC Brian Smith NRC Carol Moyer NRC Carolyn Fairbanks NRC Charles Moulton NRC Christopher Tyree NRC David Dijamco NRC David Rudland NRC David Roth OGC NRC Derek Scully NRC Devendra Ray NRC Eric Bowman NRC Eric Palmer NRC Isaac Morton NRC James Gavula NRC Jason Paige NRC Jay Collins NRC Joel Jenkins NRC John Tsao NRC John Moses NRC John Wise NRC Karen Bratcher NRC Kevin Bernstein NRC Kevin Folk NRC Kim Conway NRC Lance Rakovan NRC Lauren Gibson NRC Leah Parks NRC

2 Marieliz Johnson NRC Mark Yoo NRC Matt Burton NRC Matthew Mitchell NRC Michael Benson NRC Michelle Kichline NRC Miranda Ross NRC Nathan Denney NRC Naeem Iqbal NRC Omar Khan NRC Reena Boruk NRC River Rohrman NRC Robert Davis NRC Robert Hoffman NRC Scott Burnell NRC Steve Koenick NRC Todd Keene NRC Tony Nakanishi NRC Varoujan Kalikian NRC Andrew Mauer Nuclear Energy Institute (NEI)

Brett Titus NEI Tony Brown NEI Bob Kalinowski American Electric Power Allison C. Stalker Constellation Nuclear Brandon M. De Graaf Constellation Nuclear Casey Muggleston Constellation Nuclear Ida Ello Fletcher Constellation Nuclear Kristin C. Meek Constellation Nuclear Robert Froom Constellation Nuclear Jonathan Zeitz Department of Environmental Protection Veena Gubbi Department of Environmental Protection Keith J. Miller Dominion Energy Pratt Cherry Dominion Energy Luke Obenauf Duke-Energy Paul F Guill Duke-Energy Andrew Mantey Electric Power Research Institute (EPRI)

Garry Young EPRI Monica Hurley EPRI Jeff Gromatzky ENERCON Terry Herrmann Entergy Michael Gallagher Exelon Helen Levendosky Indiana Michigan Power Company Steve Franzone Florida Power and Light Russ L. Wenzl Nebraska Public Power District Gulshan K. Pahwa PSEG Nuclear LLC Shawn Madden PSEG Nuclear LLC Steven Dolley S&P Global Amy G. Aughtman Southern Nuclear Glenn A. Waterworth Southern Nuclear

3 Robert Jeffrey Lane STP Nuclear Operating Company Jonathan DeLaune Tennessee Valley Authority (TVA)

Peter John Donahue TVA Suzanna Irby Stevens TVA Heather Galloway Texas State University Jason Tribe Xcel Energy Marc E. Anderson Xcel Energy Steven Sollom Xcel Energy Justin Truxall Vistra Corporation Vicken Khatchadourian VK Engineers, Inc.

Richard Rogalski Volt Andrew Bowman Westinghouse Electric Company Matthew Golliet Westinghouse Electric Company Annessa Lippincott Alyssa Reynolds Brian Frew Charles Chapski David Morris Eric Ashley Michael Ilya Golberg Jana Bergman Jerry Humphreys Kenneth Mack Lindsey Renee Grissom Matthew B. Walker Michael Macfarlane Phil Couture Richard Browder Thomas Earl Braudt Todd Evans W.M. Smith