ML25064A633
| ML25064A633 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/2025 |
| From: | Angela Wu NRC/NRR/DNRL/NLRP |
| To: | Bill Rogers NRC/NRR/DNRL/NLRP |
| References | |
| Download: ML25064A633 (11) | |
Text
March 13, 2025 MEMORANDUM TO:
Bill H. Rogers, Acting Chief Licensing Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM:
Angela Wu, Senior Project Manager /RA Mark Yoo for/
Licensing Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE FEBRUARY 13, 2025, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW On February 13, 2025, 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. ML25042A134. 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 December 3, 2024, meeting (ML24361A083), 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 (ML25042A688) highlighted the following topics: NRCs revised mission statement, issuance of the Monticello Nuclear Generating Plant, Unit 1 (Monticello) subsequent renewed license, Staff Requirements Memorandum (SRM) COMCTH-24-0003, License Renewal and Subsequent License Renewal Review Expectations, dated August 8, 2024 (ML24221A320), efficiency efforts related to the safety and environmental reviews, the Tiered Approach, lessons learned on the proper use of industry documents, and industry perspectives on the scoping and screening review.
CONTACT:
Angela Wu, NRR/DNRL 301-415-2995
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NRC Mission Statement In January 2025, the NRC revised its mission statement to align with the 2024 Accelerating Deployment of Versatile Advanced Nuclear for Clean Energy (ADVANCE) Act. The NRCs mission statement reads the following: The NRC protects public health and safety and advances the nations common defense and security by enabling the safe and secure use and deployment of civilian nuclear energy technologies and radioactive materials through efficient and reliable licensing, oversight, and regulation for the benefit of society and the environment.
Issuance of Monticello Subsequent Renewed License On December 30, 2024, the NRC staff issued subsequent renewed license for Monticello. At the time of acceptance on February 23, 2023, the staff estimated the review would require 24,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> and 22 months. The review was completed on time at 22 months and underbudget of approximately 8,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. Monticello was one of the ongoing reviews that benefited from SECY-24-0026, Achieving Timely Completion of License Renewal Safety and Environmental Reviews (License Renewal Roadmap) (ML24059A131), with the safety review seeing a reduction in hours.
As evidenced with the Monticello review, the License Renewal Roadmap is showing gains to reduce the hours required for a review. As the staff continues to proactively implement the License Renewal Roadmap and other initiatives to license renewal (LR) and SLR reviews, the staff expects to continue to reduce review hours and timeframe.
SRM-COMCTH-24-0003, License Renewal and Subsequent License Renewal Review Expectations The staff provided an update on its activities related to meeting SRM-COMCTH-24-0003.
Starting with new applications received after August 2024, the staff will begin completing initial LR and 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. New applications will also target a 30-day acceptance review.
The staff is currently implementing the License Renewal Roadmap, as well as new initiatives, to meet the new metrics. Additionally, the staff is exploring opportunities to shorten the acceptance review from the current target of 45 days to the new 30-day target.
The H.B. Robinson Steam Electric Plant, Unit 2 (Robinson) SLR, expected April 2025, will be the first application received after August 2024, and will be subject to the new metrics.
For current applications, the staff will re-evaluate, and to the greatest efforts, adjust schedules to meet the new metrics. The staff has reduced hours for two reviews to account for the realized efficiencies as well as the new update to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (LR GEIS) (ML24137A164).
The staff will continue applying process improvements and lessons learned through the ongoing implementation of the License Renewal Roadmap.
Through bi-monthly public meetings, the staff continues to engage the industry regarding
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the timing of applications, which was a topic of discussion at the last public meeting on December 3, 2024.
The staff will also afford credit of operational programs for the safety review with the implementation of the Tiered Approach, currently being piloted on the Clinton Power Station, Unit 1 (Clinton) LR and Dresden SLR.
The staff is conducting a business process improvement exercise to identify and implement additional efficiencies.
The staff continues to report to the Commission on the progress and metrics related to LR and SLR reviews.
License Renewal Roadmap - Safety and Environmental Review 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 (ML24059A131). The License Renewal Roadmap Dashboard is available on the NRC public website here:
https://www.nrc.gov/reactors/operating/licensing/renewal/roadmap.html.
Safety Updates:
For the safety review, the staff is finalizing Phase 3, Additional Process Improvements of the safety reviews 3-phase efficiency approach. This entails restructuring the aging management audit and streamlining documentation, both of which will be applied to the Robinson SLR application upon its receipt in April 2025. In preparation for the review, the staff will hold a separate public meeting late March 2025 to discuss the changes for the aging management audit.
For Item 3 of the Commitment Table, the staff has been working to update 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. While the final issuance of the GALL-SLR Report has been impacted by the Office of Management and Budgets pause on the Congressional Review Act reviews per Executive Order, Regulatory Freeze, the NRC staff plans to issue a draft of the GALL-SLR Report, Revision 1, to aid the industrys continued development of high-quality applications in March 2025.
Environmental Updates:
For the environmental review, the staff issued a report to Congress on its efforts to facilitate efficient, timely, and predictable environmental reviews for nuclear reactor applications for a license under Atomic Energy Act Section 103 on January 6, 2025.
Additionally, the staff has begun realizing the efficiencies from the implementation of the LR GEIS by reducing the hours required for the V.C. Summer SLR and Browns Ferry SLR environmental reviews and continues its application of the LR GEIS to the Dresden SLR review.
To date, the staff is awaiting NRC Commission decision on SECY-24-0046, Implementation of Fiscal Responsibility Act of 2023 National Environmental Policy Act Amendments, May 2024 (ML24078A013).
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For the V.C. Summer SLR review, the staff eliminated Appendix F from the draft supplemental environmental impact statement (SEIS) by leveraging the LR GEIS generic findings for severe accident mitigation alternatives, reducing the size of the final product.
The staff is working with applicants in pre-application meetings to consider the opportunity to designate applicants as non-Federal representatives for Endangered Species Act (ESA) Section 7 consultations. The ESA implementing regulations allow Federal agencies to designate a non-Federal representative to conduct consultation on behalf of the Federal agency. If implemented, the staff project a reduction of hours by approximately 50 percent per ESA consultation.
The Tiered Approach The staff continues to pilot the Tiered Approach to the Dresden SLR and Clinton LR reviews, with continuous training throughout the technical review. Each month, the staff receives feedback from the technical staff on the experience of applying the new Tiered Approach. The feedback will aid the NRC in refining the Tiered Approach to apply best practices and lessons learned to future reviews. In terms of next steps, the staff are working the expand the Tiered Approach to the review of time limited aging analyses (TLAAs).
NEI noted that at their next License Renewal Task Force meeting, the industry will discuss lessons learned and best practices related to the Tiered Approach and will plan to provide feedback back to the NRC.
Lessons Learned Series: Proper Use of Industry Documents Kicking off the Lessons Learned Series, the staff shared lessons learned related to the use of newly issued industry documents and how providing the relevant information on plant-specific applicability upfront in the application will contribute to a more efficient safety review.
In response to NEIs question on whether this was a documentation, administrative, or technical issue, the staff replied that it could be considered a combination of all three. As a best practice, the staff advised that explicitly offering the appropriate information will prevent misunderstanding and eliminate unnecessary, iterative interactions.
Industry Perspectives: Scoping & Screening Regarding the scoping and screening review, the industry spoke to the recommendation to incorporate by reference the review from initial license renewal application to subsequent license renewal application. According to Constellation, by maximizing the incorporation by reference approach, there is an elimination of regurgitation in the subsequent license renewal application with a focus on the changes since the initial license renewal, including in the boundary drawings.
The staff is working towards an update to NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, that will incorporate the opportunity to improve the efficiency of the scoping and screening review. The staff is prepared to have additional dialogue on the change to the scoping and screening portion of the application, recommending pre-submittal engagement and focused public meetings to discuss the details of such a submittal.
Open Dialogue:
NEI asked whether 5,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> for the environmental review will be the new ceiling
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moving forward for all LR and SLR reviews. The NRC staff replied that 5,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> takes into consideration the LR GEIS and also depends on a number of variables, including a high-quality application and any emergent operational events that may have environmental impacts. If there is low public interest on the draft SEIS, then the finalization of the final SEIS may require fewer hours for completion.
The staff is in the process of developing reports and dashboards to track the metrics of environmental reviews to improve timeliness and predictability. The model will be used to reduce hours for reviews over time. NEI expressed interest in the level of granularity of information that such models could show.
The industry continues to be interested in understanding the process related to an environmental assessment, as opposed to an environmental impact statement, for the environmental review. The staff noted that it is not a matter of choice of one over the other, but rather, whether there are significant environmental impacts. If there are significant environmental impacts, then an environmental assessment is not appropriate.
The staff will hold a separate public meeting in the future to further discuss the framework, process, and expectations related to an environmental assessment.
With respect to the new metrics cited in SRM-COMCTH-24-0003, NEI asked whether the targets for active reviews have been reduced. In response, the staff responded that the License Renewal Roadmap initiatives have shown progress in reducing the hours required for the reviews and will continue to be applied to future reviews. However, since the schedules for active reviews were already in motion at the time SRM-COMCTH 0003 was issued and significant review milestones had already been planned or in progress, it is challenging to modify the schedules while the reviews are ongoing.
NEI requested an update of the graph of the expenditures for LR and SLR reviews, by safety and environmental reviews, that was originally shared in the October 31, 2024 public meeting. The staff will provide an update of the graph in the next SLR efficiencies public meeting.
Constellation offered three recommendations related to format of the tables in Chapter 3 of the license renewal application (LRA). Specifically, the industry recommended a condensation in the structural Table 2, removing duplication and taking on a commodity-based approach. The recommendations also included presenting the aging management review (AMR) items to better match the NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, and combining AMR tables, where appropriate. The staff and industry agreed that a public workshop would be an appropriate forum to discuss such detailed recommendations.
Southern Nuclear recommended re-classifying the term commitments, in future (LRAs) to be another term, such as implementation actions. The industry also suggested that the staffs final safety evaluation could forgo Appendix A, License Renewal Commitments, to simply reference the original submission provided by the applicant.
The staff clarified that while applicants submit a table of their commitments at the time of submission, the commitments continue to evolve as the review progresses.
Supplements to the application and responses to requests for additional information or requests for confirmatory information may modify the commitments over the life of the
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review. If the applicant preferred to share its final version of the table of commitments at the conclusion of the review, the staff would leverage such submission in its finalization of the safety evaluation. The staff will continue to explore the possibility to redefine the term commitments for future applications.
Regulatory Information Conference (RIC):
This years Regulatory Information Conference (RIC) is scheduled for Tuesday, March 11 to Thursday, March 13, 2025. On Wednesday, March 12th, the staff will host two sessions related to the continued advancement of the safety and environmental license renewal reviews:
Session W-11, Re-Energizing License Renewal, and Session W-12, Implementing the Blueprint for Modernizing Environmental Reviews and the ADVANCE Act.
Enclosures:
- 1. Meeting Agenda
- 2. List of Attendees
ML25064A633 *via email NRR-106 OFFICE NRR/DNLR/NLRP:
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U.S. NUCLEAR REGUALTORY COMMISSION (NRC)
SUMMARY
OF THE FEBRUARY 13, 2025, PUBLIC MEETING TO DISCUSS POSSIBLE EFFICIENCIES ON THE SUBSEQUENT LICENSE RENEWAL REVIEW Meeting Agenda Time Topic Organization 2:30 pm
Introductions
All 2:45 pm Discussion U.S. Nuclear Regulatory Commission (NRC) and Nuclear Energy Institute 3:45 pm Opportunity for public comments NRC and Public 4:00 pm Adjourn All U.S. NUCLEAR REGUALTORY COMMISSION
SUMMARY
OF THE FEBRUARY 13, 2025 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 Johnson NRC Andy Patz NRC Angela Sabet NRC Angela Wu NRC Angie Buford NRC Ashley Waldron NRC Ava Falgie NRC Bill Rogers NRC Billy Gleaves NRC Brian Harris NRR NRC Brian Taylor NRC Carol Moyer NRC Carolyn Fairbanks NRC Charles Kreuzberger NRC Chris Tyree NRC Cory Parker NRC David Dijamco NRC David Rudland NRC Derek Scully NRC Emma Haywood NRC Eric Palmer NRC Eric Reichelt NRC Getachew Tesfaye NRC Greg Makar NRC Hanry Wagage NRC James Gavula NRC Jason Paige NRC Jay Collins NRC Jessica Hammock NRC Jessie Quintero NRC Joel Jenkins NRC John Tsao NRC Jordan Glisan NRC Karen Loomis NRC Karen Sida NRC Kenn Miller NRC Kevin Folk NRC Kim Conway NRC Lance Rakovan NRC Lauren Gibson NRC
2 Leah Parks NRC Liliana Ramadan NRC Lydiana Alvarado NRC Manny Sayoc NRC Marieliz Johnson NRC Mark Yoo NRC Matthew Mitchell NRC Michael Benson NRC Michele Sampson NRC Michelle Kichline NRC Miranda Ross NRC Naeem Iqbal NRC Omar Khan NRC On Yee NRC Paul Klein NRC Peter Lom NRC Reena Boruk NRC Reinaldo Rodriguez NRC River Rohrman NRC Robert Davis NRC Samuel Lee 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 Andrew J. Burgess Ameren Rigel Davis Ameren Andrew Smolensky American Electric Power Service Corporation (AEPSC)
Dave Sudhoff AEPSC Randy Keppeler AEPSC Ryan Wasielewski AEPSC Allison C. Stalker Constellation Nuclear Casey Muggleston Constellation Nuclear Christopher D. Wilson Constellation Nuclear Hannah E. Pell Constellation Nuclear Iba Ello Fletcher Constellation Nuclear John Hilditch Constellation Nuclear Ketan Patel Constellation Nuclear Kristin C. Meek Constellation Nuclear Kurt R. Lindeman Constellation Nuclear Scott L. Kauffman Constellation Nuclear William H. Ford, Jr.
Constellation Nuclear Keith J. Miller Dominion Energy Pratt Cherry Dominion Energy Chris Saville Duke Energy
3 Heather Galloway Duke Energy Paul F. Guill Duke Energy Sofia Bouhrizi Electricite de France (EDF)
Aaron Halstrom ENERCON Gary Adkins ENERCON Jeff Gromatzky ENERCON Jeffrey Head ENERCON Latoya Bennett ENERCON Min Noh ENERCON Russell Day ENERCON Tristen Hunnewell ENERCON Richard J. Rogalski Energy Northwest Tina Morton Entergy Michael Gallagher Exelon Annessa Lippincott GSE Solutions Todd Evans Luminant Robert C. Gibson Nebraska Public Power District Russ L. Wenzl Nebraska Public Power District Gulshan K. Pahwa PSEG Nuclear LLC Andrew Zach Senate Environment and Public Works (EPW)
DeLisa S. Pournaras Southern Company Lindsey Renee Grissom Southern Company Stephen Franzone Southern Company Eric Ashley Michael Tennessee Valley Authority (TVA)
Jonathan Delaune TVA Peter John Donahue TVA Suzanna Irby Stevens TVA Thomas Earl Braudt TVA Caleb Fisler Westinghouse Electric Company Matthew Golliet Westinghouse Electric Company Kristy Gillespie Vistra Corp Mark Bensi Vistra Corp Marc E. Anderson Xcel Energy Jason L. Tribe Xcel Energy Matthew T. Sears Xcel Energy Steven Sollom Xcel Energy Toutseng Hawj Xcel Energy W. M. Smith Xcel Energy Anne Leidich Jana Bergman Jim Andersen K. Hernandez Kevin Wong Richard Paese Ryan K. Lighty Shane Jurek