ML24260A002
| ML24260A002 | |
| Person / Time | |
|---|---|
| Issue date: | 09/24/2024 |
| From: | Angela Wu NRC/NRR/DNRL/NLRP |
| To: | Lauren Gibson NRC/NRR/DNRL/NLRP |
| References | |
| Download: ML24260A002 (10) | |
Text
September 24, 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 SEPTEMBER 5, 2024, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW On September 5, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff held an information meeting with the Nuclear Energy Institute (NEI) on possible efficiencies for the Subsequent License Renewal (SLR) review. The public meeting notice is located at Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML24249A107. 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 July 9, 2024 meeting (ML24204A269), 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 (ML24247A004) highlighted the following topics: issuance of newly renewed licenses, Staff Requirements Memorandum (SRM) COMCTH-24-0003, License Renewal and Subsequent License Renewal Review Expectations, dated August 8, 2024 (ML24221A320), feedback regarding the staggering of future applications, and updates to the efficiency efforts related to the safety and environmental reviews.
CONTACT:
Angela Wu, NRR/DNRL 301-415-2995
Issuance of Newly Renewed Licenses On July 30, 2024, the staff issued the renewed licenses for Comanche Peak Nuclear Station, Units 1 and 2. The review was completed two months ahead of the original 22-month schedule, and 5,932 hours0.0108 days <br />0.259 hours <br />0.00154 weeks <br />3.54626e-4 months <br /> under the original estimate of 23,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. This is mainly attributed to staffs implementation of efficiency efforts and a high-quality application and a proactive, responsive applicant.
On August 28, 2024, the staff issued the subsequent renewed licenses for North Anna Power Station, Units 1 and 2. The review was completed ~5,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> under the original estimate of 23,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. Overall, the application was high-quality, as the application carried lessons learned from the review of its sister plant, Surry Power Station, Units 1 and 2, whose subsequent renewed licenses were issued on May 4, 2021.
SRM-COMCTH-24-0003, License Renewal and Subsequent License Renewal Review Expectations On August 8, 2024, the Commission issued SRM-COMCTH-24-0003, describing the new expectations related to LR/SLR reviews. The staff will begin completing LR/SLR reviews in no more than 14,000 staff hours and no more than 18 months, assuming a high-quality application submittal, and timely responses from the applicant to requests for additional or confirmatory information, for new applications received after the date of the SRM. New applications will also target a 30-day acceptance review. For active reviews, the staff will re-evaluate, and to the extent possible, adjust schedules to meet the new metrics.
Additionally, the staff will continue applying process improvements and lessons learned, engagement with the industry regarding the timing of applications, and affording credit for operational programs. The staff will also conduct a business process improvement exercise to identify and implement additional efficiencies. On a monthly basis, the staff will report the progress and metrics of LR/SLR reviews, via Commissioner Assistant Notes, including any exceedance of 10 percent of its metrics.
Requesting Feedback on NRCs Recommendation: Staggering Future Submittals In SECY-24-0026, Achieving Timely Completion of License Renewal Safety and Environmental Reviews (License Renewal Roadmap) (ML24059A131), the staff proposed a recommendation to stagger applications at one application every 3 months. Its analysis showed that it was the optimal conditions to maximize the efficiency of reviews.
At this meeting, the staff sought feedback from NEI, industry, and members of the public regarding this recommendation. In consideration of the staffs recommendation, NEI conducted a survey and received a total of 27 responses; a number of applications have flexibility to modify the timing of their submittal. The industry noted that there are business considerations related to the timing of a submittal. Additionally, the industry raised a concern regarding having adequate time for program implementation following the issuance of the renewed licenses. While the NRCs analysis was in accordance with the expected applications, there was a consensus that the modification in the timing of application should be left on a case-by-case basis for the NRC staff to coordinate with each applicant, with no one-size-fits-all approach that can be applied generically to all plants.
During the conversation, a member of the public inquired on how the recommendation of one application every 3 months was developed. In response, the NRC staff explained that considering the letters of intents of the future submittals, an analysis determined the frequency that would minimize staffing constraints. This frequency allows for experts to focus on the key technical parts of each review before efficiently transitioning to the next review, as the start of the review is the most intensive period of the review.
Safety Review License Renewal Roadmap - Safety Updates 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 at: https://www.nrc.gov/reactors/operating/licensing/renewal/roadmap.html.
For the safety review, the staff continues to implement the Tiered Approach to the technical review. In addition to the Dresden Nuclear Power Station, Units 2 and 3 (Dresden) SLR, the staff now is adopting the new, innovative approach to the Clinton Power Station, Unit No. 1 (Clinton) LR as well. The staff continues to make strides in their process improvement initiatives.
In particular, the staff completed Phase 3 of the Technical Review Package (TRP) Tool Modernization Effort on July 19, 2024. The TRP Tool, an internal tool used to make safety work assignments, was revamped to leverage automatic processing of the application and improve other workflow processes. The staff continues to explore other opportunities to leverage the tool in other aspects of the staffs internal processes.
Additionally, the staff is on track to issue the next updates to NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR), and NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, (SRP-SLR) in February 2025. In response to a question from Southern Nuclear regarding the availability of the latest GALL-SLR Report to aid with the development of applications, the staff responded that it would issue a draft final in approximately 5 weeks.
The Tiered Approach The staff provided an update on its progress applying the Tiered Approach to the Dresden SLR review, and more recently, the Clinton LR review. For the Dresden SLR review, its plant-specific tiering was a reduction from the Generic Tiering due to leveraging of fleetwide programs. As the staff continues its technical review, reviewers will continue to receive training and clarifications on review expectations to support successful implementation.
For the Clinton LR review, the plant-specific tiering generally matched the Generic Tiering.
Similar to the Dresden SLR review, the staff will continue its effort to pilot the approach into its technical review, while maintaining open communication with the staff to ensure proper feedback and refinement is made to the new Tiered Approach in accordance with lessons learned.
Requesting Feedback: Restructuring the Aging Management Audit As part of the staffs License Renewal Roadmap, the staff is restructuring the aging management audit to improve its efficiency, taking into consideration the overall process, timing and length of the audit, interactions between the NRC and applicant, technology, best practices
and lessons learned. Upon requesting external input, NEI shared a series of recommendations that was discussed at their semi-annual meeting the week prior. First, the industry supported the implementation of the Tiered Approach and noted its role in aiding with resource planning.
Additionally, NEI stated that the NRC should prioritize the more labor-intensive work at the start of the review. Regarding documents added to the electronic portal, NEI noted that, at times, several of the requested documents are not opened, begging the question if the requested documents were required for the staffs review.
NEI emphasized the importance of establishing clear expectations to the audit, as well as the expected supplements, requests for additional information, and requests for confirmatory information. Another suggestion made by the industry was the development of an NRC desk guide on project manager best practices to carry forth lessons learned from one review to the next.
Additionally, NEI noted the interest in understanding the issue escalation process: How can issues efficiently move along in the process? How do issues get raised to management?
The NRC posed a question regarding any preference between in-person and virtual audits. In response, NEI stated that there is a lot of value in human connection. According to NEI, structure is important, such as having touchpoints throughout the day and end of day close-out meetings to improve accountability. Constellation agreed that in-person interactions offered structure to audits, with the added benefit of having eyes on the site. Tennessee Valley Authority noted the on-site audits forced issues to be resolved in real time, rather than a back-and-forth over the course of a longer timeframe.
Environmental Review NRC Commission Approval of License Renewal Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS) Rule On August 6, 2024, the Commission approved the LR GEIS rule, updating the Commissions 2013 findings on the environmental effect of renewing the operating license. The rule redefines the number and scope of environmental issues addressed during the review of each application.
On May 16, 2024, the NRC Commission had approved SECY-24-0017, Enclosure 2, NUREG-1437, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, (LR GEIS) (Package 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)."
License Renewal Roadmap - Environmental Updates Following the Commissions approval of the LR GEIS, the staff is in the process of implementing the LR GEIS. This entails streamlining inflight LR/SLR reviews, implementing streamlining efforts, leveraging Category 1 issues for inflight reviews, and restarting paused SLR reviews that were affected by Commission Orders CLI-22-02 and CLI-22-03.
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. At this time, the paper is still pending NRC Commission decision. In June 2024, the staff developed the framework to consider environmental assessments, which is a consideration that was piloted with the Dresden SLR in July 2024.
ADVANCE Act - Report on Environmental Reviews As part of the new Accelerating Deployment of Versatile Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024, the NRC staff is developing a paper to report to Congress the efforts to facilitate efficient, timely, and predictable environmental reviews for nuclear reactor applications for a license under Atomic Energy Act Section 103. The paper will be issued in January 2025, with a public meeting scheduled for September 25, 2024.
The NRC staff plans to hold its next public meeting on SLR efficiencies in November 2024.
Enclosures:
- 1. Meeting Agenda
- 2. List of Attendees
- 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 9/13/2024 9/23/2024 9/23/2024 9/24/2024
U.S. NUCLEAR REGUALTORY COMMISSION (NRC)
SUMMARY
OF THE SEPTEMBER 5, 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 SEPTEMBER 5, 2024, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW List of Attendees Name Affiliation Ali Rezai U.S. Nuclear Regulatory Commission (NRC)
Alysia Bone NRC Andy Patz NRC Angela Sabet NRC Angela Wu NRC Bart Fu NRC Brian Allik NRC Brian Correll NRC Brian Harris NRR NRC Carol Moyer NRC Carolyn Fairbanks NRC Christopher Regan NRC Cory Parker NRC David Dijamco NRC Derek Scully NRC Eric Bowman NRC Eric Reichelt NRC Evan Davidson NRC James Gavula NRC Jay Collins NRC Jessica Hammock NRC Jessie Quintero NRC Joel Jenkins NRC John Tsao NRC John Moses NRC John Wise NRC Karen Bratcher NRC Kenn Miller NRC Kevin Folk NRC Lance Rakovan NRC Lauren Gibson NRC Liliana Ramadan NRC
2 Manny Sayoc NRC Mark Yoo NRC Melissa Ralph NRC Melissa Walker NRC Michael Benson NRC Michele Sampson NRC Michelle Kichline NRC Omar Khan NRC On Yee NRC Reena Boruk NRC River Rohrman NRC Robert Hoffman NRC Samuel Lee NRC Sarah Lopas NRC Sean Gallagher NRC Seung Min NRC Steve Koenick NRC Steven Levitus NRC Ted Smith NRC Varoujan Kalikian NRC Andrew Mauer Nuclear Energy Institute (NEI)
Brett Titus NEI Tony Brown NEI Casey Muggleston Constellation Nuclear Iba Ello Fletcher Constellation Nuclear Ketan Patel Constellation Nuclear Kristin C. Meek Constellation Nuclear Jonathan Zeitz Department of Environmental Protection Veena Gubbi Department of Environmental Protection Keith J. Miller Dominion Energy Rounette Nader Duke Energy Andrew Mantey Electric Power Research Institute (EPRI)
Garry Young EPRI Jeff Gromatzky ENERCON Michael Gallagher Exelon Stephan Franzone Florida Power and Light Russ L. Wenzl Nebraska Public Power District Amy G. Aughtman Southern Nuclear Eric Ashley Michael Tennessee Valley Authority (TVA)
Peter John Donahue TVA Suzanna Irby Stevens TVA Richard Rogalski Volt Aaron Halstrom Robert Booher Sofia Bouhrizi Thomas Earl Braudt Rob Burg Andrew Burgess Scott Christman
3 Bradley Creek Rigel Davis Bradford D. Deen Leo S Fifield Rob Gibson Ian Miller Jeffrey Head John Robinson Levi Jones Brandon Kenneth Marlow David Morris Rachel Turney Deann Raleigh Chris Saville W.M. Smith Stephen Sollom Spencer Toohill Michael Todd Adam Wilcher