ML111101551

Enclosure 3 - 4/14/11 NFPA NRC Public Mtg

ML111101551
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/14/2011
From:	Nuclear Energy Institute
To:	Division of Operating Reactor Licensing, NRC/NRR/DRA, NRC/RES/DRA, Nuclear Energy Institute
Pickett D, NRR/DORL/LPL1-1, 415-1364
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ml111101501	List: ML111101551
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Download: ML111101551 (12)

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Transition of Non-Pilot Licensees to NFPA 805 NRC Public MeetingApril 14, 2011 PurposeDiscuss sequenced approach to LAR submittalsProvide industry considerations that factoredintosequencing factored into sequencingProvide projected results and need for implementing sequenced approachProvide suggestions on LAR review approach and adjustment to monthly

status meetings to support reviews Sequenced NFPA 805 ApplicationCurrent non-pilot plant submittals

-23 LARs (33 units) by June 29, 2011

-LIC 109 reviews extended to 60 days

-Pilot reviews took over 2 years when originally estimatedforonly6months estimated for only 6 months-Review and SE issuance for 23 submittals will require multiple review teams to support a 2 year review timeframe

-"-the staff and the industry have underestimated the complexity and resources necessary to address the technical issues associated with review and approval of LARs for use of NFPA

805."

Sequenced NFPA 805 ApplicationImpact of current submittal approach

-Opportunity lost to apply lessons learned or improvements in FPRA methodologyMultiplereviewteamswillresultin

-Multiple review teams will result in inconsistent reviews

-Review period beyond 2 years places undue burden on licensees

• Risk of losing knowledgeable support

• Additional significant financial cost Sequenced NFPA 805 ApplicationIntroduction of staggered approach

-NEI letters to NRC recommending staggered approach to LAR submittals

• February22007

• February 2 , 2007*March 7, 2008

• November 15, 2010

-ACRS Letter issued February 17, 2011

-SECY 11-0033 issued March 4, 2011 Sequenced NFPA 805 ApplicationBenefits of sequenced submittals

-Allow application of any improvements developed in the FPRA methodology

-Incorporate lessons learned Piltifti*Pil o t i n f orma ti on*Fleet information

• RAIs from early submittals

-More consistent reviews by limiting the number of required review teams

-Stable, predictable and efficient transition Industry Considerations for Sequencing Management of fleet stations

-Internal resource utilization

-Incorporation of lessons learned

-Program consistencyStation designsFire PRA-Status-Approach-Peer Review Industry Considerations for Sequencing Fire PRA methodology improvementsOther significant licensee applications

-License Renewal

-Riskinformedapplications Risk informed applications

-EPUOutage and modification schedulesIndustry and vendor resourcesLicense CommitmentsFAQ closure Projected Industry Submittals under Sequenced ApproachFiscal Year 2011 -7 to 9 Fiscal Year 2012 -10 to 12Fiscal Year 2013 -9 to 11 Enforcement Policy RevisionSECY-11-0033 recommends staggered submittals and reviews of LARsStaff to submit policy paper recommendingchangestoEnforcement recommending changes to Enforcement PolicyEnforcement policy revision required now to preclude expending industry and staff

resources on applications LAR Review ApproachProcess reviewed and approved (NEI 04-02, FAQs, SE and LAR templates)Suggest NRC review teams organized by subject matter experts/LAR sectionsMiifltidititM ax i m i ze use o f e l ec t ron i c au dit s it eSample review of items where licensee state compliance with NFPA 805 without

conditionsIndustry will provide a matrix of sections requesting specific approval Monthly Status MeetingsAdjust monthly FAQ public meeting

-High level status of LAR reviews

-RAIs with generic applicationsNeedfornewFAQs

-Need for new FAQsBenefits-Timely recognition and response to generic issues

-Maintain consistency in reviews and responses