ML25149A236
| ML25149A236 | |
| Person / Time | |
|---|---|
| Issue date: | 06/03/2025 |
| From: | Angela Wu NRC/NRR/DNRL/NLRP |
| To: | |
| References | |
| Download: ML25149A236 (1) | |
Text
NRC Public Meeting: Possible Efficiencies on the Subsequent License Renewal Application Review NRR/DNRL and NMSS/REFS June 3, 2025
2 A. LR/SLR Licensing Activity i.
Big Picture ii.
Issuance of Oconee SLR iii. Acceptance of Robinson SLR B. Environmental Review C. Safety Review i.
License Renewal Roadmap - Status Update ii.
Lessons Learned Series: Tiered Approach iii. NUREG-2191 and NUREG-2192 iv. License Renewal Framework: Open Discussion Meeting Agenda
3 Big Picture 0
5000 10000 15000 20000 25000 30000 35000 Initial License Renewal (LR) and Subsequent License Renewal (SLR) Reviews Safety Hours Environmental Hours Total Hours
- Review Ongoing
- Impacted by February 2022 Commission Orders LR/SLR Reviews (Since 2018)
Hours Legend:
- The hours represent staff hours processed through April 2025 and contractor hours received since March 2025.
- While this data captures both the NRC staff and contractor hours as one lump sum, the NRC staff and contractors have differing billing rates.
4 Oconee 1, 2, and 3 - Subsequent License Renewal Oconee Nuclear Station, Units 1, 2, and 3 subsequent renewed licenses were issued March 31, 2025.
The review was completed 2,575 hours0.00666 days <br />0.16 hours <br />9.507275e-4 weeks <br />2.187875e-4 months <br /> underbudget.
Oconee SLR Acceptance Est: 23,000 hrs, 18 months July 2021 Environmental Review Pauses (Commission Orders)
Feb 2022 Environmental Review Resumes (Site-Specific Supplement)
Nov 2022 Staff License Renewal Roadmap Mar/Apr 2024 Commission SRM 14,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, 18 months (for new applications)
Aug 2024 Oconee SLR Issuance 20,425 hrs, 44 months Mar 2025
5 H.B. Robinson, Unit 2 - Subsequent License Renewal Robinson SLR:
Accepted for Review: April 28, 2025 Estimated to be completed within 12,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> and 18 months Consistent with:
Staff Requirements Memorandum, SRM-COMCTH-24-0003, LR and SLR Review Expectations ML24221A320 - August 8, 2024
Environmental Review 6
Safety Review 7
License Renewal Roadmap 8
License Renewal Roadmap Dashboard
Lessons Learned Series: Tiered Approach - NRC Approach 9
A) Initial Steps:
Pre-application communications Assign tier designations for all aging management programs B) Implementation:
NRC reviews each AMP consistent with Tiered Approach expectations Dresden matched the level of documentation in the ePortal based upon the tier (NOT REQUIRED)
NRC tracks the document requests and breakout questions for each AMP
Tiered Approach: NRC Approach 10 C) Data Gathering
- Analyze document requests and breakout questions
- Analyze resource and time needed to conduct the review
- Solicit feedback from NRC staff and applicant
Tiered Approach: Applicant Feedback 11 1.
For Confirmation AMPs, ensure that document requests have a reasonable justification 2.
Better clarification is needed regarding the expected review for a Modified AMP NRC Response: There are aspects of the AMP that may include more complex activities that require more resources to determine consistency or evaluate associated enhancements/exceptions 3.
AMP tiers were beneficial to applicant resource loading 4.
There can be variance in the staffs review from project-to-project 5.
Full documentation provided in the ePortal may reduce document requests and the effort expended to accommodate the request 6.
Will other aspects of the review be incorporated into the Tiered Approach?
Tiered Approach: Initial Lessons Learned 12
- Clinton LR and Dresden SLR safety reviews are currently being completed within the estimated resources and schedule
- Identified potential refinements:
o AMP generic tier designation o Pre-application preparations
Tiered Approach: Open Discussion / Industry Feedback 13
14 SLR Guidance (Safety Review)
NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR)
Revision 1 to GALL-SLR and SPR-SLR: To be determined
15 March 26, 2025 SLR Efficiencies Workshop (Safety Review):
NRC Presentation: ML25083A125 License Renewal Framework - Another look GALL Report referenced like a topical report Delta Review (Gap: LR vs. SLR)
Methodology Review (Sampling-Based)
Graded/Tiered Approach (Risk, Margin, Prior Approvals)
Delta review (Gap: LR vs. SLR)
Renewal Term Fundamental Framework Aging Management Review Time-Limited Aging Analyses 10 CFR Part 54
16 License Renewal Framework - Open Discussion Discussion Topics:
- 1) GALL Report referenced like a topical report Options for greater implementation flexibility than traditional TRs?
(level of detail / scope of detail)
- 2) Application structure / streamlining Support focused staff review of GALL deviations vs. aspects that are consistent
License Renewal Framework - Current Approach 17 Aging management program (AMP) possibly with GALL Report exceptions Initial LR Review AMP evolution over time GALL R0 GALL R1 GALL R2 ISGs GALL-SLR ISGs GALL-SLR R1 SLR Review 2001 2005 2010 2017
Questions?
18