ML19112A206

March 28, 2019, Summary of Category 2 Public Meeting on Lessons Learned from the Review of the First Subsequent License Renewal Applications

ML19112A206
Person / Time
Issue date:	04/26/2019
From:	Angela Wu NRC/NRR/DMLR/MRPB
To:	Eric Oesterle NRC/NRR/DMLR/MRPB
Wu A, NRR-DMLR 415-2995
References
Download: ML19112A206 (9)

Text

April 26, 2019 MEMORANDUM TO: Eric R. Oesterle, Chief License Renewal Projects Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation FROM: Angela Wu, Project Manager /RA/

License Renewal Projects Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation

SUMMARY

OF MARCH 28, 2019, CATEGORY 2 PUBLIC MEETING ON LESSONS LEARNED FROM THE REVIEW OF THE FIRST SUBSEQUENT LICENSE RENEWAL APPLICATIONS On March 28, 2019, the U.S. Nuclear Regulatory Commission (NRC) held a public meeting to discuss the NRC staff and industry experience in the review of the first three subsequent license renewal (SLR) applications: Turkey Point Nuclear Generating Station, Units 3 and 4 (Turkey Point); Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom); and Surry Power Station, Units 1 and 2 (Surry).

The public meeting agenda (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19086A120) included presentations by the NRC (ADAMS Accession No. ML19086A039) and the industry (ADAMS Accession No. ML19086A036).

In 2017, the NRC established an optimized, 18-month review schedule for SLR applications, which was piloted with the River Bend Station, Unit 1 license renewal application (LRA) review.

The River Bend LRA review was completed in 16 months, ahead of the 18-month goal.

Since then, the NRC has received three SLR applications - Turkey Point in January 2018, Peach Bottom in July 2018, and Surry in October 2018. With all three SLR application reviews underway, the NRC staff and industry, represented by the SLR applicant organizations, reflected on the strengths and areas for improvement of the optimized SLR review process, with a consensus that the streamlined process was working and communication has been excellent.

As a Category 2 meeting, the public was invited to participate in the meeting by discussing regulatory issues with the NRC staff at designed points identified on the agenda.

Enclosures:

1. Summary of Discussions

2. List of Meeting Attendees CONTACT: Angela Wu, NRR/DMLR/MRPB 301-415-2995

ML19112A206 OFFICE PM:DMLR:MRPB LA:DMLR:MRPB BC:DMLR:MRPB PM:DMLR:MRPB NAME AWu YEdmonds EOesterle AWu DATE 4/22/19 4/25/2019 4/26/2019 4/26/2019

Lessons Learned Public Meeting: Summary of Discussions March 28, 2019 Main Messages:

• The optimized subsequent license renewal application (SLRA) review process is working, however, there are still process improvement opportunities.

• Early and frequent communication between the U.S. Nuclear Regulatory Commission (NRC) staff and industry has been effective in the new SLRA review process.

• The new SLRA review process has led to fewer and higher quality requests for additional information (RAIs).

• Although there have been some task scheduling and priority challenges that have impacted interim milestone schedules, the NRC and applicants have maintained flexibility to address these challenges while remaining focused on meeting the 18-month review schedules.

• To maintain the dialogue initiated at the March 28, 2019 lessons learned meeting, the NRC staff and industry have committed to engage approximately quarterly to discuss lessons learned and to align and prioritize steps to be taken to prepare for the next SLR applications.

Summary of Discussions:

The following lessons learned discussions during the meeting were focused on different project phases: pre-submittal activities; acceptance review; operating experience audit; in-office audit; requests for additional information (RAIs); and environmental review. In addition, there was discussion on technical issues that arose during the reviews for which new or additional guidance should be considered.

Pre-Submittal Activities:

License renewal applications - both initial license renewal and SLR - can optimally be submitted to the NRC about 6 months apart to allow for adequate resource allocation and scheduling of activities. The NRC staff and industry agreed that early assignment of NRC project managers, and technical staff, if possible, is beneficial. This supports adequate preparation by the staff in advance for receipt of the application, helps with technical reviewer continuity during the acceptance review and technical review, and allows time to consider impacts on the review schedule.

The 18-month optimized review process is highly dependent on a quality application and pre-submittal meetings are held 6-12 months prior to the submission of a SLR application. Such meetings have been valuable in developing a common understanding between the NRC staff and industry on the aspects of a quality SLRA. During safety and environmental pre-application meetings, the NRC staff has discussed lessons learned and expectations for SLRAs from initial license renewal reviews and SLRA reviews to date. Applicants, in turn, should be prepared to highlight during pre-submittal meetings and pre-application interactions with staff any new, challenging, plant-specific, and/or unique technical and process issues for their specific application.

Enclosure 1

Acceptance Review:

The staff indicated that the acceptance reviews benefited at times by having the applicants portal (electronic reading room) available, in full or in limited form, to help determine whether identified issues needed to be raised as sufficiency items or could be resolved using the RAI process. The staff suggested that applicants should make the portal operable, as needed, during the acceptance review to facilitate the dispositioning of issues. Full access is expected following acceptance of the SLRA.

The industry expressed that some sufficiency review issues were perhaps unnecessarily tied to the ability to complete the review in 18 months (e.g. required new analyses or reanalysis could impact the schedule). In addition, the industry expressed that caution should be exercised so that the acceptance review does not become the technical review of the application. It was agreed that discussions during pre-submittal meetings could clarify expectations on the technical and environmental content requirements of the application and appropriate supporting or confirmatory documentation provided on the portal; and further, would support any audit needs that the staff identifies later during its review of the document.

Operating Experience (OpE) Audit:

The NRC indicated the revised format and local venues for the OpE audit provided efficiency in that it is one of several measures that obviates the need for large numbers of staff to travel to conduct review activities. This reduced onsite NRC footprint was viewed as beneficial by the applicants.

The applicants also identified that the OpE audit is an extensive and expensive process considering the need for updated cyber security provisions. As such, the industry offered some suggestions to the NRC to refine the OpE audit process and scope. These suggestions included:

• Standardizing the keyword search list

• Investigating the possibility of optimizing the historical period of operating experience needed for the review

• Investigating the feasibility of holding the OpE audit onsite again but with designated representatives from each NRC technical branch to address all the technical reviewers needs NRC recommended industry also consider alternative innovative means (e.g. use of VPN technology) to more efficiently conduct OpE reviews.

Both parties agreed that the electronic portal and OpE orientation held prior to the OpE audit by the applicant to NRC staff was a useful practice. The NRC and industry committed to hold dialogue on the suggestions in preparation for the next quarterly meeting.

In-Office Audit:

The in-office audit was recognized to be an integral part of the new SLRA review process as an avenue for the applicant to understand and support the information needs of the NRC staff.

• Schedule: The NRC staff and industry agreed that early development and adherence to the schedule is very important during the in-office audit. While the industry was flexible to schedule changes, a larger than expected number of the meetings were rescheduled.

The industry questioned if it would be possible to communicate schedule changes through the electronic portal. For complex technical subjects, the industry recommended the breakout sessions be broken up and spaced out, starting at the beginning of the audit.

• Format of Audit and Availability of Questions:

The in-office audit format included: 1) sharing of technical questions by the NRC staff to the applicant, 2) clarification call/pre-breakout session to provide clarity on the questions, and 3) breakout session to have technical discussion on the questions.

The NRC staff and industry both recognized that the efficiency of the breakout sessions depended on receiving questions in a timely manner (approximately 1 week in advance of the clarification call). Providing questions in advance offered focus for the discussions. In many cases, the technical discussion was accomplished during the clarification call and the breakout session was cancelled. With that, it was clear that the timing of the questions was a central factor in how efficiently the audit proceeded.

The questions from the NRC staff ranged from general topics that improved understanding of the application to questions that would become formal RAIs. As the questions do not need to be as formal as RAIs at this phase of the review, the industry recommended that the NRC staff standardize the scope, format, and detail of the questions to be consistent with those provided for the Fire Water System topic for the Surry SLRA review.

The industry also found the clarification calls to be valuable in understanding the staffs needs. It gave the applicant the opportunity to load additional documents on the electronic portal to support the upcoming breakout session.

Throughout the in-office audit, the applicant volunteered to supplement the application to respond to issues identified by the staff. Voluntary supplements resulting from in-office audit discussions were acknowledged to be efficient and effective. In addition, the Attachment 4D letter, a process by which the applicant could provide confirmatory items via a docketed letter, was identified as another opportunity for the applicant to efficiently confirm information on the docket.

• Technology:

The use of technology, in addition to traditional conference calls, have been vital in improving the communication between the NRC staff and applicant during the review.

For the in-office audit, Skype for Business was utilized to share screens during breakout sessions to allow the applicant and NRC staff to view the same information at the same time. The electronic portal continued to support information sharing, as it had throughout the review. There was discussion on how to organize information on the electronic portal in a more user-friendly fashion, with the potential to standardize the organization style throughout the industry for all SLRA reviews.

Moving forward, the NRC will prioritize training on Skype for Business to support future SLR reviews. Additionally, as a common practice, the industry requested a dedicated conference call number be used throughout the SLRA review to minimize confusion.

The in-office audit process has evolved into an efficient open exchange of information that challenges the applicant to reflect on what theyve submitted in the SLRA in response to the NRC staffs information needs. As a direct result of the new in-office audit process, there are fewer and higher quality RAIs.

RAIs:

While the RAIs have been fewer and higher quality, the industry believed that the NRC could improve on the timeliness of issuing RAIs, although there is variation among applicants as to process efficiencies in this area. For example, some applicants prefer the RAIs in batches while others prefer receiving them as soon as they are finalized, even if individually. Clarification calls on draft RAI between NRC staff and the applicant prior to the issuance of the final RAIs were beneficial and focused. Additionally, public meetings to clarify RAI responses were considered valuable and have resulted in revisions to RAI responses. RAI response revisions provided some process efficiencies versus second round RAIs. Overall, in comparison to the latest initial LRA reviews, the number of RAIs have decreased for SLRA reviews and the quality has increased.

Environmental Review:

For the environmental on-site audit, improvements in communication between NRC and the industry with respect to audit needs and site tour needs and applicant preparations to support these were discussed to improve overall planning and results.

Differing interpretations of the guidance in Nuclear Energy Institute (NEI) 17-04, Model SLR New and Significant Assessment Approach for SAMA was also discussed with a recognition that efforts to realign were already in progress and that moving forward, the industry and NRC staff would continue to engage on resolutions to improve the review process and documentation needs in the SAMA area.

Staff also discussed finalizing its pre-submittal guidance tables, as well as the benefits of additional communications to ensure the availability of supporting technical staff at audits.

Guidance on Technical Issues:

New issues were identified during the review of SLRAs that either required or would benefit from development of new guidance or clarification of existing guidance. Among the issues discussed were the following:

• Impact due to irradiation of reactor pressure vessel structural steel supports

• Aging management of aluminum and stainless steel support members, welds, bolted connections, or support anchorage due to stress corrosion cracking

• Revisions to water chemistry guidelines

The NRC and industry committed to continued engagement on defining the scope and schedule for developing updates to the SLR guidance documents.

Summary of Follow-Up Items for Future Discussion:

The NRC staff and industry will engage approximately quarterly to further discuss the following items:

Process Area Lessons Learned Item Acceptance Review

• Availability of the electronic portal operable, as needed, during the acceptance review OpE Audit

• Standardize the keyword search list

• Investigate possibility of optimizing historical period of operating experience

• Investigate feasibility of holding OpE audit onsite again but with designated representatives from each NRC technical branch to address all the branches needs

• Consider alternative innovative means (e.g. use of VPN technology)

In-Office Audit

• Investigate possibility of communicating schedule changes through the electronic portal

• Investigate feasibility of breakout sessions for complex technical issues being broken up and spaced out over entire audit period

• Improve NRC timing in providing audit questions to applicant.

• Investigate feasibility of standardizing the scope, format, and detail of the audit questions

• Organize information on the electronic portal in a more user-friendly fashion with potential for standardizing format for future SLRAs Environmental

• Continue engagement on NEI 17-04 to improve review process Review and documentation needs in the SAMA area Guidance on

• Continue engagement to define scope and schedule for Technical Issues developing updates for SLR guidance

Lessons Learned Public Meeting: List of Meeting Attendees March 28, 2019 Name Affiliation Gary Adkins Enercon Services Mitchell McFarland Enercon Services Rachel Turney-Work Enercon Services Hope Alexander PSEG David Alley Nuclear Regulatory Commission Bennett Brady NRC Angela Buford NRC William Burton NRC Phyllis Clark NRC Kenneth Erwin NRC Carolyn Fairbanks NRC William Holston NRC Lois James NRC Ray McKinley NRC Eric Oesterle NRC Bill Rogers NRC George Thomas NRC Tam Tran NRC Brian Wittick NRC Angela Wu NRC Mark Yoo NRC Paul Aitken Dominion Energy Mark Sartain Dominion Energy Amy Aughtman Southern Company Paul Bessette Morgan Lewis & Bockius Rick Buckley Entergy David Lach Entergy Herbert Rideout Entergy Mark Spinelli Entergy Garry Young Entergy David Distel Exelon Mike Gallagher Exelon Scott Kauffman Exelon Albert Piha Exelon Donald Warfel Exelon Paul Weyhmuller Exelon Todd Evans Luminant Chris Earls Nuclear Energy Institute Paul Guill Duke Energy Lori Hekking Duke Energy Arun Kapur Duke Energy Tracey LeRoy Duke Energy Rounette Nadar Duke Energy Greg Robinson Duke Energy Steve Hamrick Florida Power & Light Terry Herrmann Structural Integrity Associates William Maher NextEra John Simons MPR Associates Emma Wong Electric Power Research Institute Thomas Zalewski Westinghouse Enclosure 2