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

V I R T U A L P U B L I C M E E T I N G W I T H T H E N U C L E A R R E G U L AT O R Y C O M M I S S I O N A N D T H E B O I L I N G W AT E R R E A C T O R O W N E R S G R O U P ( B W R O G ) E X E C U T I V E O V E R S I G H T C O M M I T T E E ( E O C )

October 26, 2023

AGENDA October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 2

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 1:10 p.m.

BWROG Introduction - Meeting Objectives & Overview Ho Nieh (Southern Nuclear) - EOC At-Large Member 1:20 p.m.

TSTF-576, "Revise Safety/Relief Valve (SRV) Requirements" Update Phil Lashley (Energy Harbor) - BWROG Licensing 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 Inspections, Software Common Cause]

Bob Rishel (Duke Energy) - BWROG IRIR Committee Chair 2:20 p.m.

Power Uprates Denver Atwood (Southern Nuclear) - BWROG Chairman 2:30 p.m.

Break 2:40 p.m.

Small Modular Reactor [NRC Cooperation with Canadian Nuclear Safety Commission (CNSC) on GE Hitachis BWRX-300 SMR]

Michelle Hayes (NRC) - NRR/DNRL 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

OPENING REMARKS October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 3

Mike King Deputy Director for Reactor Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Steve Douglas Executive Chair Boiling Water Reactor Owners Group (BWROG)

Executive Oversight Committee (EOC)

US NUCLEAR REGULATORY COMMISSION NRC Cooperation with Canadian Nuclear Safety Commission (CNSC) on GE Hitachis BWRX-300 Small Modular Reactor Michelle Hayes Office of Nuclear Reactor Regulation October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 4

Agreements between the US NRC and CNSC October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC

• 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.

5 5

Collaborations under Charter October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 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.

6 6

Charter October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 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-Party Coordination NRC, USA, GEH, OPG, and TVA are actively coordinating to support effective and efficient regulatory engagement and ensure timely and beneficial outcomes 7 7

Next Steps and Challenges October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 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 Timing of applications in each country Level of countries experience 8

8

Collaborations under MOC October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC Joint Regulatory 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 Reactors 9

9

IAEAs Nuclear Harmonization and Standardization Initiative (NHSI)

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

• 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.

10 10

Questions October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 11

US NUCLEAR REGULATORY COMMISSION Human Factors Engineering:

Application to Existing Plants / Digital Upgrades Jesse Seymour Office of Nuclear Reactor Regulation October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 12

HFE Application & Digital Upgrades October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC

• 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 13 13

HFE Application & Digital Upgrades October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC

• 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.

14 14

Further Information on MSV October 26, 2023 US NRC - PUBLIC MEETING WITH BWROG

• 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.

15 15

Questions October 26, 2023 US NRC - PUBLIC MEETING WITH BWROG EOC 16

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 17 Subsequent License Renewal License Renewal &

Environmental Reviews Lauren Gibson, Branch Chief, License Renewal Projects, NRR John Moses, Deputy Director of Division of Rulemaking, Environmental, and Financial Support, NMSS US NUCLEAR REGULATORY COMMISSION

Possible Ways to Make Subsequent License Renewals More Efficient October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 18

• Things NRC has already 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

Possible Ways to Make Subsequent License Renewals More Efficient October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 19

• 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

Possible Ways to Make Subsequent License Renewals More Efficient October 26, 2023 US NRC - PUBLIC MEETING WITH BWROG 20 Things Industry could do to help make the NRC review more efficient 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 benefitsfor future applications benefits

Subsequent License Renewal Applications Under Review October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 21 Peach Bottom (PA)

COMPLETED 03/2020 (ML20044D902)

Surry Units (VA)

COMPLETED 05/2021 (ML20052F523)

Turkey Point (FL)

COMPLETED 12/2019 (ML19191A057)

North Anna (VA)

Accepted for review 10/2020 Point Beach (WI)

Accepted for Review 1/2021 Oconee (SC)

Accepted for review 07/2021 St. Lucie Units (FL)

Accepted for review 9/2021

= Site Specific Environmental Report Submitted

= Safety Evaluation Report Completed Monticello (MN)

Accepted for review 4/2023 VC Summer (SC)

Accepted for review 10/2023

Initial License Renewal Application Status Comanche Peak (TX)

Submitted: October 2022 Accepted for Review: November 2022 October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 22 Perry (OH)

Submitted: July 2023 Accepted for Review: September 2023

Environmental Reviews Planned Path Forward Turkey Point The NRC path forward

• 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 staffs analysis North Anna Oconee Monticello October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 23 VC Summer

Environmental Reviews Planned Path Forward (continued)

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 24

• NRC path forward 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

Environmental Reviews Planned Path Forward (continued)

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 25

• NRC path forward 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 staffs recommendation on whether to authorize the licensing action

Estimated Timeline Based on Current Projections October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 26 Milestone Approximate Timing Site-specific environmental license renewal 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 Register notice (FRN) 30 days 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

Estimated Timeline Based on Current Projections (continued)

October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 27 Milestone Approximate 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 - renewed license/record of decision (assuming no EPA comments or per Commission direction) 22 months

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

Questions October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 29

2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 30 Data-driven Licensing Doug Broaddus Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US NUCLEAR REGULATORY COMMISSION October 26, 2023

Managing the Licensing Workload October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 31

• 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.

Licensing Actions Managed FY2018 to FY2023 October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 32 Amendments by Type Amendments by TSTF

Performance Drivers October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 33

• 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

Internal Level of Effort And Schedule Estimator October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 34

Resource Estimate by Type of Licensing Action October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG 35 Source: https://www.nrc.gov/reactors/operating/licensing/resource-estimator.html

Resource Estimate by Type of LARs October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 36 Source: https://www.nrc.gov/reactors/operating/licensing/resource-estimator/estimates-for-types-of-license-amendment-requests.html

Tracking Performance October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 37 Source: https://www.nrc.gov/reactors/operating/nrc-performance-dashboard.html

Using Data to Drive Improvements October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 38

• 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.

QUESTIONS AND/OR COMMENTS

OPPORTUNITY FOR PUBLIC QUESTIONS AND/OR COMMENTS June 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG 40

CLOSING REMARKS October 26, 2023 U.S. NRC - PUBLIC MEETING WITH BWROG EOC 41

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