ML23353A046

October 26, 2023, Virtual Public Meeting with the Nuclear Regulatory Commission and the Boiling Water Reactor Owners Group (BWROG) Executive Oversight Committee - NRC Presentation, Revision 2

ML23353A046
Person / Time
Issue date:	10/26/2023
From:	Ngola Otto Licensing Processes Branch
To:
Shared Package
ML23349A203	List: ML23349A202 ML23353A046
References
Download: ML23353A046 (1)

Text

VIRTUAL PUBLIC MEETING WITH THE NUCLEAR REGULATORY COMMISSION AND THE BOILING WATER REACTOR OWNERS GROUP (BWROG) EXECUTIVE OVERSIGHT COMMITTEE (EOC)

October 26, 2023 Time Topic Speaker 1:00 p.m. Public Meeting Start / Introductions Ngola Otto (NRC), BWROG PM

1:05 p.m. NRC Opening Remarks Mike King (NRC) - Deputy Office Director for Reactor Programs AGENDA 1:10 p.m. BWROG Introduction - Meeting Objectives & Overview Ho Nieh (Southern Nuclear) - E O C At-Large Member

1:20 p.m. TST F-576, "Revise Safety/Relief Valve (SRV) Requirements" Phil Lashley (Energy Harbor) - BWROG Licensing Update Committee Chair 1:35 p.m. Licensing and TSTF-585, Revise LCO 3.0.3. Phil Lashley (Energy Harbor) - BWROG Licensing Committee Chair 1:50 p.m. Risk [Code Case N-752, PRA Configuration Control Bob Rishel (Duke Energy) - BWROG IRIR Committee Inspections, Software Common Cause] Chair

2:20 p.m. Power Uprates Denver Atwood (Southern Nuclear) - BWROG Chairman 2:30 p.m. Bre ak Small Modular Reactor [NRC Cooperation with Canadian 2:40 p.m. Nuclear Safety Commission (CNSC) on GE Hitachis BWRX-Michelle Hayes (NRC) - NRR/DNRL 300 SMR]

3:00 p.m. Human Factors Engineering - Application to existing plants/digital upgrades Jesse Seymour (NRC) - NRR/DRO

3:10 p.m. Subsequent License Renewal Lauren Gibson (NRC) - NRR/DNRL, John Moses (NRC) -

NMSS/REFS 3:30 p.m. Data-driven Licensing Doug Broaddus (NRC) - NRR/DORL 3:50 p.m. NRC Questions/Comments/Wrap-up NRC/BWROG 3:55 p.m. Opportunity Public Questions/Comments Public/NRC 4:00 p.m. Adjourn

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 2 Mike King Deputy Director for Reactor Pro grams Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission OPENING REMARKS Steve Douglas

Executive Chair Boiling Water Reactor Owners Group (BWROG)

Executive Oversight Committee (EOC)

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 3 NRC Cooper ation with Canadian Nuclear Safety US NUCLEAR REGULATORY Commission (CNSC) on COMMISSION GE Hitachis BWRX-300 Small Modular Reactor

Michelle Hayes Of fice of Nuclear Reactor Re gulation

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC4 Ag r eements between the US NRC and CNSC

• Memorandum of Understanding provides for exchange of technical information and nuclear cooperation (last renewed 2023)

• 2019 Memorandum of Cooperation to further expand collaboration on the technical reviews of advanced reactor and small modular reactor technologies

• 2022 Charter established a collaborative information sharing effort on GE Hitachis BWRX-300 small modular reactor design.

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC55 Colla bor ations under Char ter

• Joint Report on GEH BWRX-300 Safety Strategy White Paper, July 2023.

• Joint Report on GEH BWRX-300 Steel-Plate Composite (SC) Containment Vessel (SCCV) and Reactor Building Structural Design White Paper, June 2023.

• Information exchange on fuel verification and validation

• (Pre-charter) Joint Report on Containment Evaluation Method, April 2022.

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC6 6 Char ter

Context

• Ontario Power Generation (OPG) and Tennessee Valley Authority (TVA) considering constructing BWRX-300 small modular reactor in Canda and the US, respectively

• CNSC and NRC will adhere to their own national laws and regulations Objectives

• Share expertise and experience

• Reduce duplication of licensing review efforts

• Jointly utilize third party verification 5-Par ty Coor dination

• NRC, USA, GEH, OPG, and TVA are actively coordinating to support effective and efficient regulatory engagement and ensure timely and beneficial outcomes

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC7 7 Next Steps and Challenges

Next Steps

• The five parties are considering lessons learned on the completed activities and are exploring the next topics for collaboration.

Challenges

• Variation in laws and regulations between countries

• T iming of applications in each country

• L evel of countries experience

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC8 8 Colla bor ations under MOC

Joint Re gulator y Reviews

• Comparison of NRCs Licensing Modernization Project and Canadian practice for technology-inclusive, risk -informed, and performance-based reviews of advanced reactors

• Similarities and differences in the safety classification process

• Common regulatory position on Tristructural Isotropic (TRISO) fuel qualification

Joint Vendor Reviews

• X-energys Xe-100 white paper on the reactor vessel construction code

• Terrestrial Energys white paper on Postulated Initiating Events Integral Molten Salt Reactor s

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC9 9 IAEAs Nuclear Har monization and Standar dization Initiative (NHSI)

• NHSI includes a Regulatory Track and an Industry Track.

• The NRC is participating in all three regulatory working groups under IAEAs Nuclear Harmonization & Standardization Initiative o WG1: Develop an international framework for pre-licensing/licensing information sharing to facilitate collaborative reviews and multinational reviews.

o WG2: Develop a process and reference framework for multinational pre-licensing regulatory reviews.

o WG3: Develop a process to leverage the reviews of other regulators and for regulators to work together during ongoing regulatory reviews.

• NHSI working groups will issue draft technical reports in 2024.

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC10 10 Questions

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 11 Human Factor s Engineering:

US NUCLEAR REGULATORY A pplication to Existing COMMISSION Plants / Digital Upg r ades

Jesse Seymour Of fice of Nuclear Reactor Re gulation

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC12 HFE A pplication & Digital Upg r ades

• Human Factors Engineering (HFE) supports operator performance and is a key design consideration o Digital upgrades can reduce operator workload and reliance upon manual actions

• Plants vary in their HFE-related regulatory bases and commitments o Both the NRC staff and the facility licensee need to understand the licensee's HFE commitments and licensing basis

• Timing of integrated system validation (ISV) completion can present challenges (e.g., ISV results not being available in time to support a submittal) o Tools such as early pre-application engagement and methods such as multi -stage validation (MSV) can help to navigate this

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC13 13 HFE A pplication & Digital Upg r ades

• Licensees are increasing the scope of digital upgrades to main control room

• It is important to engage the NRC staff early to establish a common understanding of regulatory bases, project scope, and timelines for HFE-related design and validation activities

• NRC staff note that awareness of MSV (including how it can be used as an effective component of broader HFE design and validation processes) can be improved.

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC14 14 Fur ther Infor mation on MSV

• Nuclear Energy Agency (NEA) Report No. 7466, Multi-Stage Validation of Nuclear Power Plant Control Room Designs and Modifications.

• Institute of Electrical and Electronics Engineers. (IEEE) Std. 2411-2021, IEEE Guide for Human Factors Engineering for the Validation of System Designs and Integrated Systems Operations at Nuclear Facilities.

October 26, 2023 US NRC - PUBLIC MEETING WITH BWROG15 15 Questions

October 26, 2023 US NRC - PUBLIC MEETING WITH BWROG EOC 16 US NUCLEAR REGULATORY COMMISSION

Subsequent License Renewal License Renewal &

Envir onmental Reviews

Laur en Gibson, Br anch Chief, License Renewal Pr ojects, NRR John Moses, Deputy Dir ector of Division of Rulemaking, Envir onmental, and Financial Suppor t, NMSS

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 17 Possible Ways to Make Subsequent License Renewals Mor e Ef ficient

• T hings NRC has alr eady implemented o Tiger team for acceptance review rather than all reviewers o Eliminating the keyword list and report for Operating Experience Reviews o Smaller scoping and screening audit o One Advisory Committee on Reactor Safeguards (ACRS) meeting o Inspections not part of licensing decision

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 18 Possible Ways to Make Subsequent License Renewals Mor e Ef ficient

• Things we are currently working on o Streamlining Safety Evaluation o Streamlining audit report o Modernizing the internal Technical Review Package (TRP) tool o Revising generic documents (SRP -SLR, GALL-SLR, GEIS)

• Things we are discussing to improve efficiencies o Reconsidering Peer reviews o Reconsidering audit execution and time available

• Open to suggestions

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 19 Possible Ways to Make Subsequent License Renewals Mor e Ef ficient

• T hings Industr y could do to help make the NRC r eview mor e ef ficient o Keep the GALL numbering in your application o Review previous Audit Reports and Breakout questions o Proactively communicate Late Breaking Operating Experiences o Early communication of complex issues o Early communication on Annual updates, especially if changes are expected o Maintain a master copy of the application with all the changes What would be the implications of submitting this to NRC? (e.g., cost from applicants, NRC efforts to confirm the information, etc.)

Could NEI maintain the clean copies for future applications benefitsfo r future applications benefits

October 26, 2023 US NRC - PUBLIC MEETING WITH BWROG 20 Subsequent License Renewal A pplications Under Review

= Site Specific Environmental Report Submitted = Safety Evaluation Report Completed

Turkey Point (FL) Peach Bottom (PA) Surry Units (VA)

COMPLETED 12/2019 COMPLETED 03/2020 COMPLETED 05/2021 North Anna (VA)

(ML19191A057) (ML20044D902) (ML20052F523) Accepted for review 10/2020

Point Beach (WI) Oconee (SC) St. Lucie Units (FL) Monticello (MN) VC Summer (SC)

Accepted for Review 1/2021 Accepted for review 07/2021 Accepted for review 9/2021 Accepted for review 4/2023 Accepted for review 10/2023

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 21 Initial License Renewal A pplication Status

Comanche Peak (TX) Per r y (OH)

Submitted: October 2022 Submitted: July 2023 Accepted for Review: November 2022 Accepted for Review: September 2023

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 22 Envir onmental Reviews Planned Path Forwar d

Tur key Point Nor th Anna Oconee MonticelloVC Summer

T he NRC path forwar d

• Review all applicable Category 1 (generic) issues listed in the applicable SEIS Table 4-1 for site-specific findings (e.g., SMALL, MODERATE, LARGE) using the methodology in the LR GEIS and document NRC staff s analysis

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 23 Envir onmental Reviews Planned Path Forwar d (continued)

• NRC path forwar d o Review applicable Category 2 (site-specific) issues listed in the applicable SEIS Table 4-2 for new information since the issuance of the site-specific draft or final SEIS and update site-specific analyses o Issue a notice of availability that begins a limited scoping period (comments invited; no public meeting) o Complete an (virtual) environmental audit, including issuing RAIs and RCIs, as appropriate

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 24 Envir onmental Reviews Planned Path Forwar d (continued)

• NRC path forwar d o Issue a site-specific draft SEIS or draft SEIS supplement for public comment, and a notice of opportunity for hearing o Issue a site-specific final SEIS or final SEIS supplement to provide NRC staff s recommendation on whether to authorize the licensing action

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 25 Estimated Timeline Based on Cur r ent Pr ojections

Milestone A ppr oximate Timing Site-specific environmental license renew al application supplement received by NRC -60 days Acceptance Review Complete day 0 NRC publishes availability of supplement and intent to prepare an EIS supplement starting the 30- day scoping period, as appropriate, Federal 30 days Register notice (FRN)

Scoping period ends (if one is conducted) 60 days Conduct environmental audit 5-7 months NRC issues environmental RAIs/RCIs (if needed) 6-8 months NRC receives RAI/RCI responses 7-9 months

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 26 Estimated Timeline Based on Cur r ent Pr ojections (continued)

Milestone A ppr oximate Timing

NRC publishes draft SEIS supplement or draft SEIS and FRNs to start 45-day comment period and 60- day period to request a hearing 13 months Draft SEIS supplement or draft SEIS comment period ends 15 months Develop Comment Responses/Prepare final SEIS 16 months Publish final SEIS supplement or final SEIS and FRN 21 months EPA Issues FRN - final SEIS supplement, or final SEIS, notice of availability and beginning of 30-day cooling off period 21 months NRC issues FRN - renew ed license/record of decision (assuming no EPA comments or per Commission direction) 22 months

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 27 Outlook

• Based on available information, we are expecting up to nine supplements/applications by the end of 2024.

• Resources are projected to be tight.

• Please continue to send in Notices of Intent so we can plan.

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 28 Questions

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 29 US NUCLEAR REGULATORY COMMISSION

D at a-driven Licensing

Doug Br oaddus Division of Oper ating Reactor Licensing Of fice of Nuclear Reactor Re gulation

October 26, 20232023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 30 Mana ging the Licensing Wor kload

• Historically, managing and tracking the status of ~1000 licensing reviews each year has been a time-consuming manual process that was more reactive than proactive.

• NRC has increased access to licensing data, and using modern data visualization tools has established a more effective and consistent processes for managing our licensing work.

• NRC is using an integrated workload management process to inform changes to our licensing processes and performance goals.

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 31 Licensing Actions Mana ged FY2018 to FY2023

Amendments by Type

Amendments by TSTF

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 32 Perfor mance Driver s

• Historically, NRRs performance metric has been to complete 90% of the reviews within 1-year.

• NRR has shifted its focus to developing resource and schedule estimates that reflect the historical performance of the various types of completed reviews.

• NRR is utilizing its licensing data to :

o inform the development of estimates communicated to applicants o track in real-time our performance against those estimates, and o complete our reviews within 75% - 115% of the estimated schedule and less than 125% of the estimated resources

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 33 Inter nal Level of Ef fo r t And Schedule Estimator

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 34 Resour ce Estimate by Type of Licensing Action

Source: https://w w w.nrc.gov/reactors/operating/licensing/resource-estimator.html

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG 35 Resour ce Estimate by Type of LARs

Source: https://w w w.nrc.gov/reactors/operating/licensing/resource-estimator/estimates-for-types-of-license-amendment-requests.html

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 36 Tr acking Perfor mance

Source: https://w w w.nrc.gov/reactors/operating/nrc-performance-dashboard.html

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 37 Using Data to Drive Impr ovements

• The NRC staff is using historical performance data to inform the schedule and resource estimates for licensing reviews and identifying specific types of reviews that have taken significantly more or less than 1 year.

• NRRs is using real time data to gauge performance against its estimated completion schedules (ECS) to drive schedule accuracy to 75% < ECS < 115% and identify areas for improvement.

• NRR is utilizing its data to identify and proactively mitigate potential future challenges.

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 38 QUESTIONS AND/OR COMMENTS OPPORTUNITY FOR PUBLIC QUESTIONS AND/OR COMMENTS

June 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG40 CLOSING REMARKS

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 41 Acr onyms

GALL Generic Aging Lessons Learned

GALL-SLR Generic Aging Lessons Learned for Subsequent License Renewal

GEH GE Hitachi Nuclear Energy

GEIS Generic Environmental Impact Statement

IAEA International Atomic Energy Agency

LR License Renewal

MOC Memorandum of Cooperation

NEI Nuclear Energy Institute

RAI Request for Additional Information

RCI Request for Confirmation of Information

SEIS Supplemental Environmental Impact Statement

SLR Subsequent License Renewal

SRP-SLR Standard Review Plan for Subsequent License Renewal

October 26, 2023October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 42