ML25248A231
| ML25248A231 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, Ginna  |
| Issue date: | 09/11/2025 |
| From: | Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML25248A231 (1) | |
Text
Nine Mile Point Nuclear Power Station, Unit 1 Subsequent License Renewal Application Pre-Submittal Meeting September 11, 2025
Speakers Chris Wilson - License Renewal Director Sarah Brochu - License Renewal Engineering Manager Participants Ryan Carey - LR Site Lead Lydia S. Dworakowski - Licensing Lead Dennis Flores - Project Manager
Introductions
1 l NMP1 SLR Pre-Submittal Meeting
Introductions
General Plant Information 10 CFR Part 54 Safety Application Approach Scoping and Screening Aging Management Review Aging Management Programs TLAA and Exemption Identification Operating Experience AMP Summary and Notable Exceptions AMP Tiering Lessons Learned Project Management Schedule and Closing Remarks Questions and Answers Agenda 2
l NMP1 SLR Pre-Submittal Meeting
Nine Mile Point, Unit 1 SLR Project Team 3
l NMP1 SLR Pre-Submittal Meeting License Renewal Director (Chris Wilson)
Senior LR Manager (Sarah Swienton)
Power Uprate & LR Manager (Sara Dennis)
Licensing Lead (Lydia S. Dworakowski)
Environmental Lead (Kristin Meek)
Senior LR Manager (Scott Kauffman)
LR Engineering Manager (Sarah Brochu)
Site Lead (Ryan Carey)
Electrical Staff Mechanical Staff Structural Staff LR Engineering Manager (Casey Muggleston)
AMP specialists TLAA Staff Project Manager (Dennis Flores)
Administrative Coordinator (Crystal Reynolds)
Nine Mile Point Nuclear Power Station, Unit 1 (NMP1)
Dual unit BWR site with different designs Unit 1 is a General Electric Type 2 Reactor with a Mark I Containment (Wet)
Provisional Operating License No. DPR-17 issued on August 22, 1969 Full-Term Operating License No. DPR-63 issued on December 26, 1974 Rated core thermal power of 1850 MWt Ultimate Heat Sink: Lake Ontario The site is approximately 846 acres, located along the shore of Lake Ontario in Oswego County, New York General Plant Information 4
l NMP1 SLR Pre-Submittal Meeting
Overview of Initial License Renewal Initial License Renewal Application submitted on May 27, 2004; Renewed Operating License issued on October 31, 2006 NMP1 entered PEO on August 22, 2009 IP 71003 Phase IV completed on December 20, 2019 (ML20044D074)
Renewed Operating License expires on August 22, 2029 General Plant Information 5
l NMP1 SLR Pre-Submittal Meeting
General Plant Information 6
Major Plant Structures
- 1. Reactor Building
- 2. Turbine Building
- 3. Waste Disposal Building
- 4. Screen and Pump House
- 5. Diesel Generator Building
- 6. Administrative and Administrative Extension Buildings
- 7. Radwaste Solidification and Storage Building
- 8. Lake Ontario (UHS)
- 9. Stack
- 10. ISFSI Pad (shared)
- 11. Offgas Building
- 12. Switchyard 1
2 3
6 4
5 7
8 9
10 11 l NMP1 SLR Pre-Submittal Meeting 12
Regulatory Guidance The Subsequent License Renewal Application (SLRA) format and content is based on:
NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, Revision 1 NUREG-2191, Generic Aging Lessons Learned For Subsequent License Renewal (GALL-SLR) Report, Revision 1 Regulatory Guide 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, Revision 2 10 CFR Part 54 Safety Application Approach 7
l NMP1 SLR Pre-Submittal Meeting
10 CFR Part 54 Safety Application Approach 8
l NMP1 SLR Pre-Submittal Meeting
Utilized NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal Rule, Revision 0
Comprehensive Scoping & Screening was performed
Aging Management Reviews (AMRs)
Identification of Potential Aging Effects
Identification of Aging Effects Requiring Management
Review of Operating and Maintenance History
Identification of Aging Management Programs
Aging Management Programs (AMPs)
Goal is to maximize consistency with GALL-SLR, Revision 1
Time Limited Aging Analyses (TLAAs)
Keyword search of licensing basis documents to identify potential TLAAs
Comparison of the identified NMP1 potential TLAAs to SLR guidance documents and other SLR applicants
Review of applicable BWRVIP documents Operating Experience
Initial review period: January 2016 through May 2024; a gap review will be performed prior to submittal
Used Artificial Intelligence to search Corrective Action Program and identify issues with potential aging effects, previously used for Dresden SLRA
No new aging effects identified to date 10 CFR Part 54 Safety Application Approach 9
l NMP1 SLR Pre-Submittal Meeting
NMP1 will have 45 AMPs 35 are existing programs 16 existing programs will be enhanced for SLR purposes 10 are new programs No site-specific AMPs 10 CFR Part 54 Safety Application Approach 10 AMPs Consistent with GALL AMPs with Enhancement(s)
Only AMPs with Exception(s)
Only AMPs with Exception(s) and Enhancement(s)
Plant Specific AMPs Existing 35 18 8
1 8
0 New 10 6
0 4
0 0
Total 45 AMPs l NMP1 SLR Pre-Submittal Meeting (1) - Preliminary Information
10 CFR Part 54 Safety Application Approach 11 l NMP1 SLR Pre-Submittal Meeting New AMPs(1)
Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (XI.M12)
Outdoor and Large Atmospheric Metallic Tanks (XI.M29)
One-Time Inspection (XI.M32)
Selective Leaching (XI.M33)
ASME Code Class 1 Small-Bore Piping (XI.M35)
External Surfaces Monitoring of Mechanical Components (XI.M36)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (XI.M38)
Internal Coatings/Linings for in scope Piping, Piping Components, Heat Exchangers, and Tanks (XI.M42)
Electrical Insulation for Inaccessible Instrumentation and Control Cables Not Subject to EQ (XI.E3B)
Electrical Insulation for Inaccessible Low Voltage Power Cables Not Subject to EQ (XI.E3C)
(1) - Preliminary Information
10 CFR Part 54 Safety Application Approach 12 l NMP1 SLR Pre-Submittal Meeting AMPs with Exceptions(1)
Water Chemistry (XI.M2)
Flow Accelerated Corrosion (XI.M17)
Fire Water System (XI.M27)
Outdoor and Large Atmospheric Metallic Tanks (XI.M29)
Fuel Oil Chemistry (XI.M30)
One-Time Inspection (XI.M32)
Selective Leaching (XI.M33)
Buried and Underground Piping and Tanks (XI.M41)
ASME Section XI, Subsection IWE (XI.S1)
Masonry Walls (XI.S5)
Structures Monitoring (XI.S6)
Inspection of Water-Control Structures Associated with Nuclear Power Plants (XI.S7)
Electrical Insulation for Inaccessible Low Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (XI.E3C)
(1) - Preliminary Information
(1) - Preliminary Information 10 CFR Part 54 Safety Application Approach 13 l NMP1 SLR Pre-Submittal Meeting Notable Exceptions(1)
AMP NUREG-2191 Requirement Requested Exception Outdoor and Large Atmospheric Tanks (XI.M29)
For large aluminum tanks on concrete which are subject to loss of material, perform volumetric inspections from the inside surface for each 10-year period starting 10 years before the subsequent period of extended operation.
NMP1 condensate storage and surge tanks (CSSTs) are indoor, aluminum tanks supported by a concrete base to be managed by one-time volumetric inspections of the tank bottom from the inside surface prior to the period of extended operation.
Fuel Oil Chemistry (XI.M30)
Fuel oil tanks are drained and cleaned, the internal surfaces visually inspected (if physically possible) and volumetrically inspected if evidence of degradation is observed during visual inspection, or if visual inspection is not possible.
The diesel driven fire pump fuel oil storage tank will not be internally inspected. This is a double wall fiberglass tank and the interstitial space between the primary and secondary storage tank wall is equipped with a leak detection system that continuously monitors for inner tank leakage and alarms locally if leakage is detected prompting corrective action.
Chemistry sampling ensures that contaminants detrimental to the integrity of the storage tank are maintained within acceptance criteria.
(1) - Preliminary Information 10 CFR Part 54 Safety Application Approach 14 l NMP1 SLR Pre-Submittal Meeting Notable Exceptions(1)
AMP NUREG-2191 Requirement Requested Exception Buried and Underground Piping and Tanks (XI.M41)
For buried polymeric piping, visual inspections of buried polymeric piping in accordance with Table XI.M41-2.
The buried polymeric piping will not be inspected.
Buried portions of this piping are entirely encased inside of a PVC pipe sleeve with the space between the pipe and sleeve filled with sand. Degradation of the pipe is not expected with the protective sleeve and layer of sand in between.
For safety-related buried piping, backfill is to be consistent within industry standards for aggregate size and distance from the component.
For the NMP1 emergency diesel generator system, the aggregate size meets the specified size, however distance of the safety related fill around the components is shorter than the requirement. This difference is not expected to have any impact on damaging the coating on the piping.
(1) - Preliminary Information 10 CFR Part 54 Safety Application Approach 15 l NMP1 SLR Pre-Submittal Meeting Notable Exceptions(1)
AMP NUREG-2191 Requirement Requested Exception ASME Section XI, IWE (XI.S1)
Steel, stainless steel, and dissimilar metal weld pressure-retaining components that are subject to cyclic loading but have no current fatigue analysis, are monitored for cracking and are supplemented with surface examination (or other applicable technique) in addition to visual examination to detect cracking.
NMP1 has performed a fatigue waiver analysis in accordance with the ASME Code to demonstrate that the drywell and associated penetrations do not require a detailed fatigue analysis through the subsequent period of extended operation. This analysis does not include penetrations for high-temperature process lines as those penetrations will require aging management in accordance with the guidance in XI.S1 ASME Section XI, IWE.
Masonry Walls (XI.S5)
Structures Monitoring (XI.S6)
Inspection of Water-Control Structures Associated with Nuclear Power Plants (XI.S7)
In general, all structures are monitored on an interval not to exceed five years.
The inspection frequency for normally inaccessible areas due to high radiation, including primary containment, main steam tunnel, heater bays, and the condenser bays, may exceed five years as they will be inspected every third refueling outage.
(1) - Preliminary Information 10 CFR Part 54 Safety Application Approach 16 l NMP1 SLR Pre-Submittal Meeting AMPs Not Applicable (Does Not Include PWR Specific AMPs)(1)
Concrete Containment Tendon Prestress (X.S1)
Boraflex Monitoring (XI.M22)
BWR Reactor Water Cleanup System (XI.M25)
High Density Polyethylene (HDPE)
Piping and Carbon Fiber Reinforced Polymer (CFRP) Repaired Piping (XI.M43)
Fuse Holders (XI.E5)
High Voltage Insulators (XI.E7)
ASME Section XI, Subsection IWL (XI.S2)
AMP Tiering 17 Generic Tiering NMP1(1)
Confirmation 15 18 Modified 14 19 Standard 16 8
Total 45 45 l NMP1 SLR Pre-Submittal Meeting (1) - Suggested AMP Tiering
AMP Tiering 18 NMP1 AMP Tiering(1)
Standard Modified Confirmation Mechanical XI.M26 XI.M27 XI.M33 XI.M41 Structural XI.S6 XI.S7 Electrical X.E1 XI.E1 Mechanical X.M1 XI.M9*
XI.M18 XI.M20 XI.M23 XI.M24 XI.M29 XI.M35*
XI.M36*
XI.M40 XI.M42*
Structural XI.S3*
XI.S8*
Electrical XI.E2*
XI.E3A*
XI.E3B*
XI.E3C*
XI.E4 XI.E6*
Mechanical X.M2*
XI.M1*
XI.M2*
XI.M3 XI.M4*
XI.M7*
XI.M8*
XI.M12*
XI.M17*
XI.M21A*
XI.M30*
XI.M31*
XI.M32*
XI.M38*
XI.M39 Structural XI.S1*
XI.S4 XI.S5 l NMP1 SLR Pre-Submittal Meeting (1) - Suggested AMP Tiering
(*) - Fleet-wide Program
Lessons learned from previous Constellation and industry license renewal projects are being utilized in the NMP1 SLR Project In particular, lessons learned from the recent Clinton and Dresden license renewal projects will be leveraged, such as:
Managing resources given concurrent projects Standardizing reviews from project to project to avoid variances Reviewing recent Breakout Questions, Supplements, and RAIs for generic applicability Utilizing the Tiered Approach for categorizing AMP reviews Successful utilization of Constellation SharePoint as the ePortal for sharing documents Populating the ePortal consistent with that required for the Tiered Approach Assigning unique tracking numbers for Document Requests vs Breakout Questions Submitting timely Supplements to minimize the number of RAIs Portal letter clarity on the portal open duration Constellation is a strong advocate of working with the NRC staff to enable an efficient review using tools such as: Audits, Tiering, and the use of an electronic portal Constellation is open to NRC feedback on a collaborated review process to support efficiency efforts Lessons Learned 19 l NMP1 SLR Pre-Submittal Meeting
Constellation has extensive aging management experience
20 of 21 units have renewed operating licenses
15 units are operating in the period of extended operation
Fleet level AMPs previously evaluated in SERs Constellation participates in NEI and EPRI initiatives related to License Renewal and Long-Term Operations
Using Best Practices to number AMR data tables to facilitate the review process
The Constellation NMP1 SLR Project Team consists of experienced technical personnel Current NRC Expectations and SRP Guidance Constellation reviews Breakout Questions, RAIs/RCIs, and Supplements associated with recent license renewal applications to ensure consistency with current NRC expectations and SRP guidance An External Review of the SLRA will be performed Lessons Learned 20 l NMP1 SLR Pre-Submittal Meeting
The SLRA, including the Environmental Report (ER), will be submitted via the NRC Electronic Information Exchange (EIE)
The Constellation SharePoint will be utilized as the ePortal to support NRC review Documentation uploaded to the ePortal will be consistent with the Tiered Approach Constellation Licensing Lead will coordinate with the NRC PM Audit Support Constellation will work with the NRC PM to establish and manage the schedules Constellation will track NRC audit questions, requests, and the responses in a database Site Lead will coordinate plant walkdowns and other on-site activities Supplements Constellation will submit timely Supplements, as needed, to optimize efficiency and reduce the number of RAIs RAI Responses Constellation will submit timely responses to NRC requests for additional information Project Management 21 l NMP1 SLR Pre-Submittal Meeting
The NMP1 SLRA will be consistent with GALL-SLR, Revision 1 to the greatest extent possible The NMP1 SLRA will be consistent with industry practices and lessons learned from recent LRs/SLRs to meet NRC requirements Constellation will submit a high-quality application that can support an efficient staff review The NMP1 SLRA is on track to be submitted on the target date of March 25, 2026 Schedule and Closing Remarks 22 l NMP1 SLR Pre-Submittal Meeting
Questions 23 l NMP1 SLR Pre-Submittal Meeting
R.E. Ginna Nuclear Power Plant Subsequent License Renewal Application Pre-Submittal Meeting September 11, 2025
Speakers Chris Wilson-License Renewal Director Julian Laverde-License Renewal Engineering Manager Participants George Wrobel-LR Site Lead Iba Ello-Fletcher - Licensing Lead Dennis Flores-Project Manager
Introductions
1 l Ginna SLR Pre-Submittal Meeting
Introductions
General Plant Information 10 CFR Part 54 Safety Application Approach Scoping and Screening Aging Management Review Aging Management Programs TLAA and Exemption Identification Operating Experience AMP Summary and Notable Exceptions AMP Tiering Lessons Learned Project Management Schedule and Closing Remarks Questions and Answers Agenda l Ginna SLR Pre-Submittal Meeting 2
License Renewal Director (Chris Wilson)
Senior LR Manager (Sarah Swienton)
Power Uprate & LR Manager (Sara Dennis)
Licensing Lead (Iba Ello-Fletcher)
Environmental Lead (Rebecca Craddick)
LR Engineering Manager (Julian Laverde)
Site Lead (George Wrobel)
Electrical Staff Mechanical Staff Structural Staff Senior LR Manager (Scott Kauffman)
LR Engineering Manager (Casey Muggleston)
AMP specialists TLAA Staff Project Manager (Dennis Flores)
Administrative Coordinator (Crystal Reynolds) l Ginna SLR Pre-Submittal Meeting 3
R.E. Ginna Nuclear Power Plant SLR Project Team
R.E. Ginna Nuclear Power Plant (Ginna)
A single unit Westinghouse two-loop Pressurized Water Reactor with Large Dry Containment Full-Term Operating License No. DPR-18 issued on December 10, 1984, superseded Provisional Operating License No. DPR-18 issued on September 19, 1969 Ultimate Heat Sink: Lake Ontario The site is approximately 426 acres, located on the south shore of Lake Ontario in Wayne County, near Rochester, New York General Plant Information l Ginna SLR Pre-Submittal Meeting 4
Core Power History Current rated core thermal power of 1775 MWt 1969: 1300 MWt initial 1972: 1520 MWt Power Uprate 2006: 1775 MWt Power Uprate Overview of Initial License Renewal Initial License Renewal Application was submitted on August 1, 2002; Renewed Operating License issued on May 19, 2004 Ginna entered PEO on September 19, 2009 IP 71003 Phase IV completed on March 22, 2019 (ML19126A012)
Renewed Operating License expires on September 18, 2029 General Plant Information l Ginna SLR Pre-Submittal Meeting 5
General Plant Information Major Plant Structures
- 1. Containment Building
- 2. Turbine Building
- 3. Auxiliary Building
- 4. Administrative Building
- 5. Diesel Generator Building
- 6. Screenhouse Building
- 7. Main Access Facility
- 8. Switchyard
- 9. Lake Ontario (UHS)
- 10. Training Center
- 11. Meteorological Tower
- 12. Canister Preparation Building
- 13. ISFSI Pad l Ginna SLR Pre-Submittal Meeting 6
Regulatory Guidance The Subsequent License Renewal Application (SLRA) format and content is based on:
NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, Revision 1 NUREG-2191, Generic Aging Lessons Learned For Subsequent License Renewal (GALL-SLR) Report, Revision 1 Regulatory Guide 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, Revision 2 10 CFR Part 54 Safety Application Approach l Ginna SLR Pre-Submittal Meeting 7
10 CFR Part 54 Safety Application Approach l Ginna SLR Pre-Submittal Meeting 8
, PTS
Utilized NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal Rule, Revision 0
Comprehensive Scoping & Screening was performed
Aging Management Reviews (AMRs)
Identification of Potential Aging Effects
Identification of Aging Effects Requiring Management
Review of Operating and Maintenance History
Identification of Aging Management Programs
Aging Management Programs (AMPs)
Goal is to maximize consistency with GALL-SLR, Revision 1
Time Limited Aging Analyses (TLAAs)
Keyword search of licensing basis documents to identify potential TLAAs
Comparison of the identified Ginna potential TLAAs to SLR guidance documents and other SLR applicants
Review of applicable Material Reliability Program (MRP) reports Operating Experience
Initial review period: 01/01/2016 through 05/15/2024; will perform gap review prior to submittal
Used Artificial Intelligence to search Corrective Action Program and identify issues with potential aging effects, previously used for Dresden SLRA
No new aging effects identified to date 10 CFR Part 54 Safety Application Approach l Ginna SLR Pre-Submittal Meeting 9
AMPs applicable to Ginna(1)
Ginna will have 48 AMPs 45 are existing programs 24 existing programs will be enhanced for SLR purposes 3 are new programs No site-specific AMPs 10 CFR Part 54 Safety Application Approach l Ginna SLR Pre-Submittal Meeting 10 AMPs Consistent with GALL-SLR AMPs with Enhancement(s)
Only AMPs with Exception(s)
Only AMPs with Exception(s) and Enhancement(s)
Plant Specific AMPs Existing 45 20 16 1
8 0
New 3 3
0 0
0 0
Total 48 AMPs (1) - Preliminary Information
10 CFR Part 54 Safety Application Approach l Ginna SLR Pre-Submittal Meeting 11 (1) - Preliminary Information New AMPs(1)
One-Time Inspection (XI.M32)
ASME Code Class 1 Small-Bore Piping (XI.M35)
Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (XI.E6)
AMPs with Exceptions(1)
Boric Acid Corrosion (XI.M10)
Flow-Accelerated Corrosion (XI.M17)
Closed Treated Water System (XI.M21A)
Fire Water System (XI.M27)
Fuel Oil Chemistry (XI.M30)
Selective Leaching (XI.M33)
Flux Thimble Tube Inspection (XI.M37)
Buried and Underground Piping and Tanks (XI.M41)
Concrete Containment Unbonded Tendon Prestress (X.S1)
10 CFR Part 54 Safety Application Approach l Ginna SLR Pre-Submittal Meeting 12 Notable Exceptions(1)
AMP NUREG-2191 Requirement Requested Exception Closed Treated Water Systems (XI.M21A)
Chemistry parameters are monitored and testing frequency is in accordance with EPRI guidance Some sampling parameters and frequency differ from EPRI guidance based on vendor recommendations, operating experience, and long-term chemistry trends showing no excursions Fuel Oil Chemistry (XI.M30)
Biocide or corrosion inhibitors may be added as a preventive measure Corrosion inhibitors, oil stabilizers, or biocides are not added to fuel oil. The program evaluates the need for addition of biocide or corrosion inhibitors if periodic testing indicates biological activity or evidence of corrosion. If biocide addition is required, increased fuel oil filter monitoring will occur Buried and Underground Piping and Tanks (XI.M41)
Cathodic protection is supplied for reinforced concrete pipe, prestressed concrete cylinder pipe, and carbon steel pipe Cathodic protection systems are not utilized on all in-scope buried piping and tanks Concrete Containment Unbounded Tendon Prestress (X.S1)
The program periodically measures and evaluated tendon forces Ginna has requested a relief request for the third Containment Inservice Inspection (CISI) Interval examination of containment post-tensioning components The measured prestress forces on common (control) tendons and tendons selected by random sampling of each tendon group using the lift-off or equivalent method Ginna has not designated any common (control) tendon The estimated and measured prestress forces up to the current examination to be plotted against time for each tendon group The estimated and measured prestress forces from the last re-tensioning up to the current surveillance are plotted against time for the vertical tendons (1) - Preliminary Information
(1) - Preliminary Information 10 CFR Part 54 Safety Application Approach 13 l Ginna SLR Pre-Submittal Meeting AMPs Not Applicable (Does Not Include BWR Specific AMPs)(1)
Boraflex Monitoring (XI.M22)
High Density Polyethylene (HDPE) Piping and Carbon Fiber Reinforced Polymer (CFRP) Repaired Piping (XI.M43)
Fuse Holders (XI.E5)
High Voltage Insulators (XI.E7)
AMP Tiering 14 Generic Tiering Ginna(1)
Confirmation 16 20 Modified 16 22 Standard 16 6
Total 48 48 l Ginna SLR Pre-Submittal Meeting (1) - Suggested AMP Tiering
AMP Tiering 15 Ginna AMP Tiering(1)
Standard Modified Confirmation Mechanical XI.M27 XI.M33 XI.M41 Structural XI.S6 Electrical X.E1 XI.E1 Mechanical XI.M18 XI.M20 XI.M21A*
XI.M24 XI.M26 XI.M29 XI.M30*
XI.M35*
XI.M36*
XI.M37 XI.M38*
XI.M40 XI.M42*
Structural X.S1*
XI.S3*
XI.S7 Electrical XI.E2*
XI.E3A*
XI.E3B*
XI.E3C*
XI.E4 XI.E6*
Mechanical X.M1 X.M2*
XI.M1*
XI.M2*
XI.M3 XI.M10*
XI.M11B*
XI.M12*
XI.M16A*
with MRP-227, R2-A XI.M17*
XI.M19*
XI.M23 XI.M31*
XI.M32*
XI.M39 Structural XI.S1*
XI.S2*
XI.S4 XI.S5 XI.S8*
l Ginna SLR Pre-Submittal Meeting (1) - Suggested AMP Tiering
(*) - Fleet-wide Program
Lessons learned from previous Constellation and industry license renewal projects are being utilized in the Ginna SLR Project In particular, lessons learned from the recent Clinton and Dresden license renewal projects will be leveraged, such as:
Managing resources given concurrent projects Standardizing reviews from project to project to avoid variances Reviewing recent Breakout Questions, Supplements, and RAIs for generic applicability Utilizing the Tiered Approach for categorizing AMP reviews Successful utilization of the Constellation SharePoint as the ePortal for sharing documents Populating the ePortal consistent with that required for the Tiered Approach Assigning unique tracking numbers for Document Requests vs Breakout Questions Submitting timely Supplements to minimize the number of RAIs Portal letter clarity on the portal open duration Constellation is a strong advocate of working with the NRC staff to enable an efficient review using tools such as: Audits, Tiering, and the use of an electronic portal Constellation is open to NRC feedback on a collaborated review process to support efficiency efforts Lessons Learned 16 l Ginna SLR Pre-Submittal Meeting
Constellation has extensive aging management experience
20 of 21 units have renewed operating licenses
15 units are operating in the period of extended operation
Fleet level AMPs previously evaluated in SERs Constellation participates in NEI and EPRI initiatives related to License Renewal and Long-Term Operations
Using Best Practices to number AMR data tables to facilitate the review process The Constellation Ginna SLR Project Team consists of experienced technical personnel Current NRC Expectations and SRP Guidance Constellation reviews Breakout Questions, RAIs/RCIs, and Supplements associated with recent license renewal applications to ensure consistency with current NRC expectations and SRP guidance An External Review of the SLRA will be performed Lessons Learned l Ginna SLR Pre-Submittal Meeting 17
The SLRA, including the Environmental Report (ER), will be submitted via the NRC Electronic Information Exchange (EIE)
The Constellation SharePoint will be utilized as the ePortal to support NRC review Documentation uploaded to the ePortal will be consistent with the Tiered Approach Constellation Licensing Lead will coordinate with the NRC PM Audit Support Constellation will work with the NRC PM to establish and manage the schedules Constellation will track NRC audit questions, requests, and the responses in a database Site Lead will coordinate plant walkdowns and other on-site activities Supplements Constellation will submit timely Supplements, as needed, to optimize efficiency and reduce the number of RAIs RAI Responses Constellation will submit timely responses to NRC requests for additional information Project Management l Ginna SLR Pre-Submittal Meeting 18
The Ginna SLR application will be consistent with GALL-SLR, Revision 1 to the greatest extent possible The Ginna SLRA will be consistent with industry practices and lessons learned from recent LRs/SLRs to meet NRC requirements Constellation will submit a high-quality application that can support an efficient staff review The Ginna SLRA is on track to be submitted on the target date of June 17, 2026 Schedule and Closing Remarks l Ginna SLR Pre-Submittal Meeting 19
Questions l Ginna SLR Pre-Submittal Meeting 20