|
|
| (One intermediate revision by the same user not shown) |
| Line 3: |
Line 3: |
| | issue date = 01/27/2017 | | | issue date = 01/27/2017 |
| | title = Part 52 Licensing Lessons Learned | | | title = Part 52 Licensing Lessons Learned |
| | author name = Cowan P B | | | author name = Cowan P |
| | author affiliation = Nuclear Energy Institute (NEI) | | | author affiliation = Nuclear Energy Institute (NEI) |
| | addressee name = Ordaz V L | | | addressee name = Ordaz V |
| | addressee affiliation = NRC/Document Control Desk, NRC/NRO | | | addressee affiliation = NRC/Document Control Desk, NRC/NRO |
| | docket = PROJ0689 | | | docket = PROJ0689 |
| Line 16: |
Line 16: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:January 27, 2017 Ms. Vonna L. Ordaz Acting Director Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 | | {{#Wiki_filter:PAMELA B. COWAN Vice President, Nuclear Generation 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8093 pbc@nei.org nei.org January 27, 2017 Ms. Vonna L. Ordaz Acting Director Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 |
|
| |
|
| ==Subject:== | | ==Subject:== |
| Part 52 Licensing Lessons Learned Project Number: 689 | | Part 52 Licensing Lessons Learned Project Number: 689 |
|
| |
|
| ==Dear Ms. Ordaz:== | | ==Dear Ms. Ordaz:== |
| It is vitally important to the future of our industry that the licensing process for new nuclear plants be as efficient, effective, timely and predictable as possible to encourage future applicants to bring forward innovative designs, while continuing to assure pubStrategy document for non-light water reactors, we appreciate that the NRC shares the goal of efficient, effective new reactor licensing. With that objective in mind, the purpose of this letter is to provide the results of a recent industry workshop on lessons learned from new plant licensing experience, and to request NRC support for actions to improve new reactor licensing efficiency and reduce regulatory impact on the time-to-market for future new plant applicants. We recognize that the NRC has performed its own lessons-learned evaluations and implemented improvements to both the licensing process and post-licensing implementation. The results of these NRC efforts were considered as inputs to the industry workshop discussions. the NRC and the industry to take action to address new plant licensing lessons learned, while recent and ongoing licensing experience is fresh, and key industry and NRC staff are available for the task. Near term NRC reviewers, and will complement other forward-looking activities the NRC has underway, including development of guidance for staged licensing and non-LWRs. PAMELA B. COWAN Vice President, Nuclear Generation 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8093 pbc@nei.org nei.org Ms. Vonna L. Ordaz January 27, 2017 Page 2 NRC senior management and Commission support will be needed to improve licensing efficiency, effectiveness, timeliness and predictability. Most of the improvements targeted can be accomplished through new or revised NRC guidance, i.e., without rulemaking, and ongoing activities can be leveraged to achieve desired outcomes in key areas. The needed improvements most frequently cited by attendees at the industry licensing lessons learned workshop were: 1. Stemming the growth in application scope and level of detail and clarifying the threshold for information necessary to support required NRC safety findings; 2. review process, application docketing criteria, and the integration of pre-application interactions with NRC staff safety reviews; 3. Simplifying the Part 52 change process by eliminating Tier 2*; 4. Establishing Tier 1/ITAAC First Principles and developing standardized ITAAC; and 5. Avoiding undue combined license delays when the need for changes in a completed design certification is identified Addressing these issues will enable demonstrable improvements in licensing efficiency, effectiveness and predictability, and position the industry and NRC for the future. The industry looks forward to working with the NRC staff and stakeholders to achieve these improvements. The attachment to this letter provides additional discussion of these key lessons learned, and associated recommendations for improving licensing efficiency and predictability going forward. We will follow up with you and your staff concerning implementation of licensing lessons learned activities. Please contact me or Russ Bell (202.739.8087; rjb@nei.org) if you have any questions. Sincerely, Pamela B. Cowan Attachment c: Mr. Michael E. Mayfield , NRO/DEIA, NRC Mr. Michael C. Cheok, NRO/DCIP, NRC Mr. Frank M. Akstulewicz, NRO/DNRL, NRC NRC Document Control Desk}} | | |
| | It is vitally important to the future of our industry that the licensing process for new nuclear plants be as efficient, effective, timely and predictable as possible to encourage future applicants to bring forward innovative designs, while continuing to assure public health and safety. As indicated in the NRCs Vision and Strategy document for non-light water reactors, we appreciate that the NRC shares the goal of efficient, effective new reactor licensing. With that objective in mind, the purpose of this letter is to provide the results of a recent industry workshop on lessons learned from new plant licensing experience, and to request NRC support for actions to improve new reactor licensing efficiency and reduce regulatory impact on the time-to-market for future new plant applicants. We recognize that the NRC has performed its own lessons-learned evaluations and implemented improvements to both the licensing process and post-licensing implementation. |
| | The results of these NRC efforts were considered as inputs to the industry workshop discussions. |
| | We support the NRCs efforts to develop and implement regulatory changes in this area. The time is right for the NRC and the industry to take action to address new plant licensing lessons learned, while recent and ongoing licensing experience is fresh, and key industry and NRC staff are available for the task. Near term improvements to NRCs licensing process and guidance would clearly benefit the next wave of applicants and NRC reviewers, and will complement other forward-looking activities the NRC has underway, including development of guidance for staged licensing and non-LWRs. |
| | |
| | Ms. Vonna L. Ordaz January 27, 2017 Page 2 NRC senior management and Commission support will be needed to improve licensing efficiency, effectiveness, timeliness and predictability. Most of the improvements targeted can be accomplished through new or revised NRC guidance, i.e., without rulemaking, and ongoing activities can be leveraged to achieve desired outcomes in key areas. The needed improvements most frequently cited by attendees at the industry licensing lessons learned workshop were: |
| | : 1. Stemming the growth in application scope and level of detail and clarifying the threshold for information necessary to support required NRC safety findings; |
| | : 2. Clarifying of NRCs application acceptance review process, application docketing criteria, and the integration of pre-application interactions with NRC staff safety reviews; |
| | : 3. Simplifying the Part 52 change process by eliminating Tier 2*; |
| | : 4. Establishing Tier 1/ITAAC First Principles and developing standardized ITAAC; and |
| | : 5. Avoiding undue combined license delays when the need for changes in a completed design certification is identified Addressing these issues will enable demonstrable improvements in licensing efficiency, effectiveness and predictability, and position the industry and NRC for the future. The industry looks forward to working with the NRC staff and stakeholders to achieve these improvements. The attachment to this letter provides additional discussion of these key lessons learned, and associated recommendations for improving licensing efficiency and predictability going forward. |
| | We will follow up with you and your staff concerning implementation of licensing lessons learned activities. |
| | Please contact me or Russ Bell (202.739.8087; rjb@nei.org) if you have any questions. |
| | Sincerely, Pamela B. Cowan Attachment c: Mr. Michael E. Mayfield , NRO/DEIA, NRC Mr. Michael C. Cheok, NRO/DCIP, NRC Mr. Frank M. Akstulewicz, NRO/DNRL, NRC NRC Document Control Desk}} |
|
|---|
Category:Letter
MONTHYEARML24023A0392024-01-22022 January 2024
NEI Comments on the Information Collection Renewal for Domestic Licensing of Special Nuclear Material, Docket Id NRC-2023-0118
ML23355A1972023-12-14014 December 2023
NEI, Comments on NRC Draft Resolution of SFAQ 2022-02, SAE Program Requirements
ML23219A1672023-10-25025 October 2023
Response Letter to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07
ML23270B9002023-09-27027 September 2023
NEI Letter Request for an Extension of Comment Period on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses, Docket Id NRC 2023 0079
ML23268A0102023-09-22022 September 2023
NEI, Fee Exemption Request for Endorsement, Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors
ML23241A8612023-08-25025 August 2023
Consolidated Industry Comments to NRC Regulatory Issue Summary 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels
ML23236A4992023-08-24024 August 2023
Industry Feedback on Region II Fuel Cycle Facility Construction Oversight Workshop Held August 15, 2023, and Suggested Topics for Additional Public Meetings in Fall 2023
ML23256A1622023-08-0101 August 2023
Incoming NEI Letter Dated August 1, 2023 Regarding Increase in Fees 2023-2025
ML23206A0292023-07-24024 July 2023
Incoming Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07
ML23143A1232023-06-22022 June 2023
NRC Fee Waiver Request for Draft NEI 23-01
ML23200A1662023-05-30030 May 2023
NEI Proposed Metrics for a Performance-Based Emergency Preparedness Program
ML23116A0732023-05-25025 May 2023
Letter to Hillary Lane in Response to a Request for a Fee Exemption for NEI 23-03
ML23135A7332023-05-0909 May 2023
NEI Comments on NRC Safety Culture Program Effectiveness Review
ML23110A6752023-04-18018 April 2023
04-18-23_NRC_Fee Waiver for NEI 23-03
ML23110A6782023-04-18018 April 2023
Request for Review and Endorsement of NEI 23-03, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications at Non-Power Production or Utilization Facilities
ML23110A6762023-04-18018 April 2023
04-18-23_NRC_NEI 23-03 Review + Endorse
ML23107A2302023-03-31031 March 2023
NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking
ML23138A1662023-03-24024 March 2023
Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07
ML23083B4622023-03-24024 March 2023
Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07
ML23060A3272023-03-0101 March 2023
NEI, Wireless Cyber Security Guidance
ML23060A2142023-03-0101 March 2023
NEI, Request for NRC Endorsement of NEI White Paper, Enabling a Remote Response by Members of an Emergency Response Organization, Revision 0
ML23023A2752023-01-23023 January 2023
Request for Extension of Comment Period from the Nuclear Energy Institute on PRM-50-124 - Licensing Safety Analysis for Loss-of-Coolant Accidents
ML22348A1122023-01-17017 January 2023
Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7
ML22353A6082023-01-11011 January 2023
U.S. Nuclear Regulatory Commission Report of the Regulatory Audit of the NEI-Proposed Aging Management Program Revision to Selective Leaching Program (XI.M33)
ML22349A1012022-12-12012 December 2022
LTR-22-0343 Ellen Ginsberg, Sr. Vice President, General Counsel and Secretary, Nuclear Energy Institute, Expresses Concerns Related to Issuance of Regulatory Issue Summary 2022-02; Operational Leakage
ML22336A0372022-11-16016 November 2022
Fee Exemption Request for NEI 08-09 Revision 7 - Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors
ML22321A3152022-11-16016 November 2022
NEI Letter with Comments on Significance Determination Process Timeliness Review
ML22298A2262022-10-25025 October 2022
Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated October 2022
ML22298A2302022-10-17017 October 2022
Submittal of NEI 22-03, Draft Revision 0, Nuclear Generation Quality Assurance Program Description
ML22207B6512022-07-26026 July 2022
NEI, Full Fee Exemption Request for Industry Guidance Proposal - Weather Related Administrative Controls During Transient Outdoor Dry Cask Operations
ML22195A1662022-07-14014 July 2022
NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7
ML22195A0202022-07-13013 July 2022
07-13-22 NRC Fee Exemption Request for NEI 21-05 Review
ML22195A0672022-07-13013 July 2022
Fee Exemption Request for Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 21-05, Reporting Guidance for Licensees with Risk-Informed Licensing Bases
ML22159A2772022-06-28028 June 2022
Response Letter to Richard Mogavero for Fee Exemption for the Nuclear Regulatory Commission Review Ad Endorsement of NEI 15-09, Revision 1
ML22153A2782022-06-0202 June 2022
Nie, Fee Exemption Request for Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated May 2022
ML22154A2962022-06-0202 June 2022
LTR from R. Mogavero to M. Sampson Dated Jun 2 2022 Endorsement of NEI 15-09 Cyber Security Event Notifications Rev 1 Dated May 2022
ML22152A2712022-06-0101 June 2022
Digital Instrumentation and Control Common Cause Failure Policy Considerations, Revision 1
ML22143A9362022-05-20020 May 2022
May 13, 2022, Public Meeting on Draft Regulatory Issue Summary Operational Leakage, 87 Fed. Reg. 2361 (Jan. 14, 2022) (Docket Id NRC-2021-0173)
ML22110A1752022-05-0303 May 2022
NRC Response to the Nuclear Energy Institute April 1, 2022, Letter, Regarding the Nrc'S CUI Implementation Plan
ML22109A2082022-04-0808 April 2022
April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0
ML22110A1782022-04-0101 April 2022
April 1, 2022, Letter from NEI Regarding Nrc'S Controlled Unclassified Information Program Implementation
ML22048A5812022-02-16016 February 2022
NEI 22-02: Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations
ML22019A2922022-01-12012 January 2022
NEI, Submittal of Proposed Revisions to Aging Management Programs XI.M33, Selective Leaching and XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements
ML21343A2922021-12-0808 December 2021
NEI, Transmittal of NEI 21-07 Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactor Safety Analysis Report: for Applicants Utilizing NEI 18-04 Methodology
ML21337A3802021-12-0303 December 2021
NEI Technical Report NEI 17-06 - Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1
ML21319A3522021-11-10010 November 2021
NRC NEI Fee Waiver Request Changes to NEI 10-04 and NEI 13-10, Dated November 10, 2021
ML21306A3652021-10-29029 October 2021
NEI Letter from D. Young to NRC S. Atack to Cease Work on Draft D of NEI 20-05, Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Eligibility Criteria of 10 CFR 73.55(a)(7)
ML21342A1682021-10-29029 October 2021
Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 3, Dated October 29, 2021
ML21342A2032021-10-29029 October 2021
Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 13-10, Cyber Security Control Assessments, Revision 7, Dated October 29, 2021
ML22081A2002021-10-29029 October 2021
NEI Backfitting Concerns with NRCs Developing Position on Protection of Dry Storage Systems from Natural Phenomena During Short Term Operations
2024-01-22
[Table view] |
Text
PAMELA B. COWAN Vice President, Nuclear Generation 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8093 pbc@nei.org nei.org January 27, 2017 Ms. Vonna L. Ordaz Acting Director Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Part 52 Licensing Lessons Learned Project Number: 689
Dear Ms. Ordaz:
It is vitally important to the future of our industry that the licensing process for new nuclear plants be as efficient, effective, timely and predictable as possible to encourage future applicants to bring forward innovative designs, while continuing to assure public health and safety. As indicated in the NRCs Vision and Strategy document for non-light water reactors, we appreciate that the NRC shares the goal of efficient, effective new reactor licensing. With that objective in mind, the purpose of this letter is to provide the results of a recent industry workshop on lessons learned from new plant licensing experience, and to request NRC support for actions to improve new reactor licensing efficiency and reduce regulatory impact on the time-to-market for future new plant applicants. We recognize that the NRC has performed its own lessons-learned evaluations and implemented improvements to both the licensing process and post-licensing implementation.
The results of these NRC efforts were considered as inputs to the industry workshop discussions.
We support the NRCs efforts to develop and implement regulatory changes in this area. The time is right for the NRC and the industry to take action to address new plant licensing lessons learned, while recent and ongoing licensing experience is fresh, and key industry and NRC staff are available for the task. Near term improvements to NRCs licensing process and guidance would clearly benefit the next wave of applicants and NRC reviewers, and will complement other forward-looking activities the NRC has underway, including development of guidance for staged licensing and non-LWRs.
Ms. Vonna L. Ordaz January 27, 2017 Page 2 NRC senior management and Commission support will be needed to improve licensing efficiency, effectiveness, timeliness and predictability. Most of the improvements targeted can be accomplished through new or revised NRC guidance, i.e., without rulemaking, and ongoing activities can be leveraged to achieve desired outcomes in key areas. The needed improvements most frequently cited by attendees at the industry licensing lessons learned workshop were:
- 1. Stemming the growth in application scope and level of detail and clarifying the threshold for information necessary to support required NRC safety findings;
- 2. Clarifying of NRCs application acceptance review process, application docketing criteria, and the integration of pre-application interactions with NRC staff safety reviews;
- 3. Simplifying the Part 52 change process by eliminating Tier 2*;
- 4. Establishing Tier 1/ITAAC First Principles and developing standardized ITAAC; and
- 5. Avoiding undue combined license delays when the need for changes in a completed design certification is identified Addressing these issues will enable demonstrable improvements in licensing efficiency, effectiveness and predictability, and position the industry and NRC for the future. The industry looks forward to working with the NRC staff and stakeholders to achieve these improvements. The attachment to this letter provides additional discussion of these key lessons learned, and associated recommendations for improving licensing efficiency and predictability going forward.
We will follow up with you and your staff concerning implementation of licensing lessons learned activities.
Please contact me or Russ Bell (202.739.8087; rjb@nei.org) if you have any questions.
Sincerely, Pamela B. Cowan Attachment c: Mr. Michael E. Mayfield , NRO/DEIA, NRC Mr. Michael C. Cheok, NRO/DCIP, NRC Mr. Frank M. Akstulewicz, NRO/DNRL, NRC NRC Document Control Desk