ML23100A105
| ML23100A105 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 04/12/2023 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML23100A105 (1) | |
Text
©2023 Nuclear Energy Institute April 12, 2023 Potential LAR Process Improvements
©2023 Nuclear Energy Institute 2 The purpose and the team.
Background
Observations/Opportunities Other Ideas Conclusion Next Steps Industry data observations and the opportunities they present.
Leveraging technology and other processes.
The key message.
A course of action.
Outline
©2023 Nuclear Energy Institute 3 Things are good NRC metrics are being met Industry-requested completion dates are largely met Vast majority of LARs processed within 12 mos.
Almost all reviews (~96%) do not exceed resource estimates Drivers for continuous improvement Workforce/staffing challenges Knowledge Management/Knowledge Transfer
Why do we do it this way?
How can we do it better?
Longstanding tenet of the nuclear industry - Strive for excellence License Amendment Requests (LARs)
©2023 Nuclear Energy Institute 4 A strategic review of Technical Specifications (TS) and TS-related processes identified improvements and streamlining that could reduce NRC and licensee resources for LAR reviews Industry-wide effort with Core Team members representing the BWROG, PWROG, and NEI Core Team reviewed data and procedures for trends and opportunities to be discussed with NRC
Background
Illustrative Example of Hours Expenditure 0
10 20 30 40 50 60 70 80 90 Cumulative hours PM hours 22%
PM hours 65%
Submitted December 2021 Est. Completion by January 2023 Estimated hours: 230 Actual hours: 85 Acceptance Review January 2022 Actual Completion in
©2023 Nuclear Energy Institute 6 Selected milestones drive LAR issuance 12-month template for project milestones is being used independent of scope/resource estimates (i.e., 100-hour LAR or 1000-hour LAR follow the same general timetable)
Observation #1 - Template-driven schedule
©2023 Nuclear Energy Institute 7 Develop graded schedule and milestone templates based on estimated review hours Benefits Reduces start/stop refamiliarization inefficiencies Allows earlier implementation of changes Reduces LAR inventory Opportunity #1 - Resource-driven schedule
©2023 Nuclear Energy Institute 8 Data review identified several examples of actual hours being < 50%
of estimates (minimum was ~13%)
Unintended consequences of overly conservative estimates Unnecessary allocation of additional resources - negating the pursuit of other work Inaccurate tracking of progress completion Observation #2 - Estimates very conservative
©2023 Nuclear Energy Institute 9 Use data-driven tracking and feedback to monitor and refine future estimates Establish accuracy goal for estimates/actuals (not just exceedances)
Benefits Potential for additional plant improvements Improved tracking of progress to project completion Synergy with Opportunity #1: Resource-driven schedules Opportunity #2 - More realism in estimates
©2023 Nuclear Energy Institute 10 The NRC Project Manager is often the single largest contributor to review hours on LARs Their essential role should be examined for cross-cutting process and technology improvements applicable to all LAR reviews Observation #3 - PM Contributions
©2023 Nuclear Energy Institute 11 Feedback on industry best practices to reduce the burden on PMs Process improvements Improve/revise the standard LAR format Maximize the use of streamlined regulatory processes (i.e., LIC-206)
Optimize tools and technology Electronic submittal enhancements Leverage internal file sharing (further)
Opportunity #3 - Reduce burden on PM
©2023 Nuclear Energy Institute 12 Relocating implementation period to the cover letter could alleviate additional, administrative amendments For practicality (not compliance), all LARs include an implementation period Implementation period is currently part of the amendment - thus, changes to it require another (usually exigent) amendment Licensees could inform NRC of implementation date changes via letter Data review identified at least 10 examples in the last 5 years Other Ideas - TS Implementation Flexibility
©2023 Nuclear Energy Institute 13 Establishing a permanent exchange area for each licensee could facilitate streamlined information sharing The NRC and industry have seen benefits from using the audit process to review files and calculations Currently, an exchange area is established for specific LARs on a case-by-case basis Other Ideas - Permanent Audit File Exchange Site
©2023 Nuclear Energy Institute 14 Expanding the interactive Request for Additional Information (RAI) process to complex LARs could streamline reviews This process has been successfully used for specific LAR reviews (e.g., Improved TS Conversions)
Workflow processes incorporated to ensure appropriate NRC and licensee internal review of questions and responses Maintains transparency to the public Other Ideas - Interactive RAI Process
©2023 Nuclear Energy Institute 15 Using data, technology, and targeted process improvements will mitigate workforce and resource challenges by maximizing efficiency while maintaining the quality and openness of the LAR review process.
Conclusion
©2023 Nuclear Energy Institute 16 NRC reviews and considers information provided Future engagement and continued dialogue Dedicated public meeting Workshop to table-top the LAR process and identify additional opportunities Follow-up during fall RITF public meeting Proposed Next Steps