ML25083A125
| ML25083A125 | |
| Person / Time | |
|---|---|
| Issue date: | 03/26/2025 |
| From: | Angela Wu NRC/NRR/DNRL/NLRP |
| To: | |
| References | |
| Download: ML25083A125 (1) | |
Text
NRC Public Workshop:
LR/SLR Efficiencies for the Safety Review NRR/DNRL March 26, 2025
2 A. Technical Review Package (TRP) Tool B. Changes to the Aging Management Audit C. Another Look at the License Renewal Framework Meeting Agenda
3 Technical Review Package (TRP) Tool The Technical Review Package (TRP) Tool bundles items into safety work assignments (also known as TRPs).
Application Processed in TRP Tool TRP 1 TRP 2 TRP 3 Etc.
Safety Work Assignments TRP: a work assignment for particular technical area TRP Tool:
Internal platform utilized to ensure completeness of review of a very large submittal and aid with workflow management Not a guidance document for reviewers to conduct the safety review New ability to automatically process PDF files led to NRCs engagement with industry to standardize the way the application is formatted
4 Restructuring the Audit Modifications to Aging Management Audit Management Direction Industry Feedback Focus Groups License Renewal Roadmap Dashboard
Current Aging Management Audit 5
Portions of the Audit Duration 1
In-Office Technical Review 2 weeks Buffer 1 week 2
On-Site Audit 1 week 3
Preparation for Breakout Sessions 3 weeks 4
Breakout Sessions 4 weeks Total Length of Audit 11 weeks The 18-month schedule, including the audit dates, are unique to each review.
Purpose:
Gain understanding, verify, and identify information that will require docketing to support the basis of the licensing decision.
Change #1: Applicant Presentations 6
Lessons Learned: Proper Use of Industry Documents Applicant to make presentations to the staff on complex, technical areas within 2 weeks of the audit Advances the technical dialogue between the staff/applicant by 5 weeks Step #1:
During the Acceptance Review, PM communicates the technical areas of interest to the applicant.
Step #2:
During the In-Office Audit, applicant makes meaningful presentations to the staff.
Step 3:
Staff share initial reactions, type of information needed, ask questions, and ePortal requests.
Examples:
TLAAs, Standard Review AMPs Important documents, technical bases, historical insights (initial LR, fleetwide programs, etc)
Early identification + resolution of any complex, technical issues to prevent review delays
Change #2: Audit Metrics 7
Lessons Learned: Proper Use of Industry Documents Metrics on Length of the Audit: (Per 18-Month Schedule)
Any deviations will require justification + NRC management approval o +2 weeks: Branch Chief Approval o +4 weeks: Division Management Approval Definitions:
o Start: Kick-off meeting, with clear expectations for the staff/applicant o End: Close-out meeting, defining next steps ePortal:
Information to be posted no later than 1 week after requested, unless communicated with the PM Ensure ePortal is user friendly and contains the adequate user interface and tools (e.g., search capability) to support an efficient audit
Change #3: Supplement Schedules 8
Supplement Schedules:
Optimal, recommended timeframes of when supplements can be leveraged by the staff for the safety finding to support 18-month schedule Unique schedules to be provided to applicant at time of acceptance Supplements outside of the Supplement Schedule:
Depending on the timing of the submission and active review schedule, it may/may not be considered in time for the safety finding.
Applicants to work with the PM to coordinate the submission of supplements General Targets:
Supplement #1: 4 weeks post-audit Supplement #2: 6 weeks post-audit Subsequent Supplements: Requires close coordination with PM
License Renewal Framework - Another Look 9
10 1986 Policy development - solicitation of public comments 1991 10 CFR Part 54 rulemaking With the exception of age-related degradation unique to license renewal, the regulatory process is adequate 1995 10 CFR Part 54 rulemaking Aging management of in-scope passive, long-lived structures and components Evaluation of time-limited aging analyses History Different in character or magnitude Only occurs in period of extended operation (PEO)
Not explicitly evaluated for PEO
Meeting 10 CFR Part 54 10 CFR 54.29, Standards for Issuance of a Renewed License
...if the Commission finds that:
(a) actions have been identified and have been or will be taken such that there is reasonable assurance...
Late 1990s NRC / industry discussions on what is required to meet the standard of issuance
- with respect to managing the effects of aging and time-limited aging analyses 11
SECY-99-148, Credit for Existing Programs for License Renewal Did the Commission conclude that existing programs that adequately manage aging effects during the current term to ensure compliance with the current licensing basis will continue to be adequate in the renewal term because of the ongoing regulatory oversight?
Did they conclude that existing programs may or may not be adequate and direct the Staff to formally conclude how that adequacy is demonstrated as part of the basis for granting a renewed license?
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SRM-SECY-99-148 (Approved Option 3)
- Develop the Generic Aging Lessons Learned (GALL) Report to document the adequacy of existing plant programs and where they need augmentation
- Applicant can reference its programs against GALL and address areas for augmentation Staff to verify that applicants have identified appropriate existing programs
- Reviews to focus on areas where existing programs should be augmented Staff could verify that the GALL is applicable to an applicants plant 13
Revisiting the Approach Considering:
- Maturity of the renewal process & guidance
- Experience with most plants having already applied and approved for one renewal
- 2/3rds of the operating units are in PEO, implementing aging management programs
- Practices have been refined (e.g., NRC aging oversight, plant corrective actions, industry collaboration) 14 March 2025
Open Discussion: Areas of Consideration Potential streamlining GALL Report referenced like a topical report Delta review (aging gap LR vs. SLR)
Methodology review (sampling-based)
Aging Management Review Potential supporting measures Final Safety Analysis Report detail Optimized NRC oversight Enhanced AMP self-assessment (e.g., NEI 14-03 tollgates, operating experience database)
Artificial intelligence assist 15
Open Discussion: Areas of Consideration Potential streamlining Graded/tiered approach (risk, margin, prior approvals)
Explicit delta review vs. initial LR Potential supporting measures Application detail Analysis maintenance & oversight (QA - design control, corrective actions) 16 10 CFR Part 54 Term Framework?
Time-Limited Aging Analyses
References - How we got here Solicitation of public comments on LR policy, Federal Register, Vol 51, No. 215, pg. 40334, 1986 SECY-87-179 (Activities to develop LR policy) ML21309A435, 1987 NUREG-CR-5332 (Summary and analysis of public comments; reg. options for LR), ML20246D588, 1989 NUREG-1412 (Foundation for the Adequacy of the Licensing Basis) ML080310668, 1991 10 CFR Part 54 (1991), Federal Register, Vol 56, No. 240, pg. 64943, 1991 SECY-93-331 (LR workshop results and staff proposals to revise rule), ML19346D622, 1993 Staff briefing to Commission (on SECY-93-331), ML15121A532, 1993 Commission direction re: SECY-93-331, ML003759367, 1994 10 CFR Part 54 (1995), Federal Register, Vol 60, No. 88, pg. 22461, 1995 SECY-99-148 (Credit for existing programs for license renewal) ML12339A671, 1999 SRM-SECY-99-148, ML003751930, 1999 NUREG-1850 (FAQ on license renewal), ML061110022, 2006 SECY-14-0016 (Regulatory considerations for SLR) ML14050A306, 2014 NEI letter (Comments on SECY-14-0016), ML14093A321 April 1, 2014 SRM-SECY-14-0016, ML14241A578, 2014 Closure of activity to consider 40 years of PEO, ML21117A007, June 22, 2021 SRM M231102 (Strategic program overview) ML23345A214, 2023 SECY-24-0026 (LR roadmap) ML24059A131, 2024 SRM-COMCTH-24-0003 (LR and SLR expectations) ML24221A319, 2024 17
Questions?
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