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| number = ML19086A039
| number = ML19086A039
| issue date = 03/28/2019
| issue date = 03/28/2019
| title = NRC Staff Slides for the March 28, 2019 Public Meeting on Slr Lessons Learned
| title = NRC Staff Slides for the March 28, 2019 Public Meeting on SLR Lessons Learned
| author name = Burton W
| author name = Burton W
| author affiliation = NRC/NRR/DMLR/MRPB
| author affiliation = NRC/NRR/DMLR/MRPB
Line 15: Line 15:


=Text=
=Text=
{{#Wiki_filter:Subsequent License Renewal (SLR)Lessons LearnedPublic MeetingMarch 28, 2019 AGENDA*Welcome and Introductions
{{#Wiki_filter:Subsequent License Renewal (SLR)
*Background
Lessons Learned Public Meeting March 28, 2019
*Review Process Changes
 
*Strengths*Areas for Improvement
AGENDA
*Discussions on NRC presentation  
* Welcome and Introductions
*Industry/Applicant presentations
* Background
*Discussions on Industry/Applicant presentations
* Review Process Changes
*Summary*Closeout and Adjourn 2
* Strengths
* Areas for Improvement
* Discussions on NRC presentation
* Industry/Applicant presentations
* Discussions on Industry/Applicant presentations
* Summary
* Closeout and Adjourn 2
 
BACKGROUND
BACKGROUND
*NRC established an optimized 18
* NRC established an optimized 18-month review schedule for SLR applications
-month review schedule for SLR applications
* Piloted on the River Bend license renewal application -
*Piloted on the River Bend license renewal application  
completed in 16 months
-completed in 16 months
* NRC has received 3 SLR applications for review since January 2018
*NRC has received 3 SLR applications for review since January 2018
- Turkey Point in January 2018 (accepted 5/2/18)
-Turkey Point in January 2018 (accepted 5/2/18)
- Peach Bottom in July 2018 (accepted 9/6/18)
-Peach Bottom in July 2018 (accepted 9/6/18)
- Surry in October 2018 (accepted 12/3/18)
-Surry in October 2018 (accepted 12/3/18)*No initial license renewals currently under review 3
* No initial license renewals currently under review 3
BACKGROUND (Con't)*SLR applicants have each gone through or are going through several phases of the review process
 
-Pre-submittal-Acceptance Review
BACKGROUND (Cont)
-Audits-RAIs*Lessons learned from NRC perspective
* SLR applicants have each gone through or are going through several phases of the review process
*Lessons learned from Applicant perspectives including the piloted River Bend license renewal application 4  
- Pre-submittal
*SLR Application (SLRA) review optimization effort identified several changes
- Acceptance Review
*Piloted on River Bend license renewal review
- Audits
*Pre-submittal meetings
- RAIs
*SLRA acceptance review performed by technical staff assigned to review v. tiger team approach*18 month schedule begins upon SLRA acceptance for docketing Review Process Changes 5  
* Lessons learned from NRC perspective
*Applicant provides access to electronic portal (no later than acceptance of the SLRA in order to support the review schedule)  
* Lessons learned from Applicant perspectives including the piloted River Bend license renewal application 4
*Aging Management Audits (Safety) oOffsite Aging Management Program Operating Experience Audit o In-Office Aging Management Audit via telecom/webinar breakout sessions o On-Site Aging Management Audit with regional participation to walk down specific material conditions and plant configurationsReview Process Changes (Con't)6 Review Process Changes (Con't)*Documents and meetings oDraft SEIS public meeting if necessary (environmental) oStreamlined SER process oAdvisory Committee on Reactor Safeguards (ACRS) meetings on safety review  
* SLR Application (SLRA) review optimization effort identified several changes
-only one ACRS Subcommittee meeting oACRS Full Committee meeting scheduled within two months following SC meeting 7  
* Piloted on River Bend license renewal review
*NRC staff provided lessons learned from initial license renewal reviews to industry/applicant in December 2017 (ML17353A035)
* Pre-submittal meetings
*Re-iterated these lessons learned during pre
* SLRA acceptance review performed by technical staff assigned to review v. tiger team approach
-submittal meetings and provided additional plant specific topics  
* 18 month schedule begins upon SLRA acceptance for docketing Review Process Changes 5
-Peach Bottom (ML19084A098)
* Applicant provides access to electronic portal (no later than acceptance of the SLRA in order to support the review schedule)
-Surry (ML18121A034)
* Aging Management Audits (Safety) o Offsite Aging Management Program Operating Experience Audit o In-Office Aging Management Audit via telecom/webinar breakout sessions o On-Site Aging Management Audit with regional participation to walk down specific material conditions and plant configurations Review Process Changes (Cont) 6
*Info on lessons learned and preparing for NRC review also provided at ANS Utility Working Conference in August 2018 (ML18198A273)Previous Lessons Learned 8  
 
*Communicate with NRC  
Review Process Changes (Cont)
-frequently / timely
* Documents and meetings o Draft SEIS public meeting if necessary (environmental) o Streamlined SER process o Advisory Committee on Reactor Safeguards (ACRS) meetings on safety review - only one ACRS Subcommittee meeting o ACRS Full Committee meeting scheduled within two months following SC meeting 7
*Communicate w/other applicants / prospective
* NRC staff provided lessons learned from initial license renewal reviews to industry/applicant in December 2017 (ML17353A035)
*Peer reviews
* Re-iterated these lessons learned during pre-submittal meetings and provided additional plant specific topics  
*Review most recent NRC RAIs
- Peach Bottom (ML19084A098)
*Ensure internal application consistency
- Surry (ML18121A034)
*Ensure CLB issues are addressed prior to SLRA
* Info on lessons learned and preparing for NRC review also provided at ANS Utility Working Conference in August 2018 (ML18198A273)
*Address NRC concerns from previous reviews (ML17353A035)
Previous Lessons Learned 8
*Facilitate the NRC's reviewPreparing for NRC Review 9  
* Communicate with NRC - frequently / timely
*Pre-Submittal Meetings
* Communicate w/other applicants / prospective
*Environmental at least 12 months prior to submittal*Safety at least 6 months prior to submittal
* Peer reviews
*Referencing unapproved Topical Reports or unapproved methodologies
* Review most recent NRC RAIs
*Proprietary information  
* Ensure internal application consistency
-must be reviewed before application can be made public
* Ensure CLB issues are addressed prior to SLRA
*Portal for documentation
* Address NRC concerns from previous reviews (ML17353A035)
*Update program for consistency with GALL
* Facilitate the NRCs review Preparing for NRC Review 9
-SLR and SRP-SLR Preparing for NRC Review 10 SLR Reviews  
* Pre-Submittal Meetings
-STRENGTHS*Excellent communication during all phases of the review
* Environmental at least 12 months prior to submittal
*Excellent responsiveness to NRC requests for info on portal, clarifications on draft RAIs, and responses to final RAIs*Portal demonstrations were very helpful
* Safety at least 6 months prior to submittal
*Good RAI quality
* Referencing unapproved Topical Reports or unapproved methodologies
-More detailed
* Proprietary information - must be reviewed before application can be made public
-Higher-quality dialogue/clarification calls
* Portal for documentation
-Allowed for better informed RAI response
* Update program for consistency with GALL-SLR and SRP-SLR Preparing for NRC Review 10
-Fewer 2 nd-round RAIs 11  
 
*Excellent support during audits
SLR Reviews - STRENGTHS
*Optimized effectiveness of in
* Excellent communication during all phases of the review
-house audits through use of Skype
* Excellent responsiveness to NRC requests for info on portal, clarifications on draft RAIs, and responses to final RAIs
*Staff provided questions and talking points to better focus the audit discussions
* Portal demonstrations were very helpful
*On-site audit needs better assessed and limited to only those that are actually needed
* Good RAI quality
*Application quality is on an improving trendSLR Reviews  
- More detailed
-STRENGTHS 12 13*Pre-Submittal-Submit SLRAs about 6 months apart
- Higher-quality dialogue/clarification calls
-Begin PM outreach activities 6 months before SLRA submittal-Highlight new, challenging, plant
- Allowed for better informed RAI response
-specific, and or unique technical and process issues
- Fewer 2nd-round RAIs 11
*Allows time to align people and resources early
* Excellent support during audits
*Allows time to consider impacts on the review scheduleSLR -AREAS FOR IMPROVEMENT  
* Optimized effectiveness of in-house audits through use of Skype
*Pre-Submittal-Minimize proprietary information in the SLRA  
* Staff provided questions and talking points to better focus the audit discussions
-must be reviewed before application can be made public
* On-site audit needs better assessed and limited to only those that are actually needed
-Prepare OpEdatabase as soon as possible
* Application quality is on an improving trend SLR Reviews - STRENGTHS 12
-Clarify level and type of access requirements to the CAP database early
 
-Clarify usage of terms "not applicable" vs. "not used"
13
-Communicate more clearly staff process regarding vetting of acceptance issues and decisionsSLR -AREAS FOR IMPROVEMENT 14  
* Pre-Submittal Submit SLRAs about 6 months apart Begin PM outreach activities 6 months before SLRA submittal Highlight new, challenging, plant-specific, and or unique technical and process issues
*Pre-Submittal-Compare refueling outage plans to the anticipated application review schedule. If conflicts exist, the application submission should be advanced or delayed to minimize the conflicts.
* Allows time to align people and resources early
-Understand criteria on sufficiency for environmental review -The NRC staff will need to see (not review) the SAMA new and significant basis document to support the application acceptance determination.SLR -AREAS FOR IMPROVEMENT 15 SLR -AREAS FOR IMPROVEMENT
* Allows time to consider impacts on the review schedule SLR - AREAS FOR IMPROVEMENT
*Acceptance Review
 
-Portal operable, as needed, during acceptance review
Pre-Submittal
-Portal fully functional at the conclusion of the acceptance review
- Minimize proprietary information in the SLRA - must be reviewed before application can be made public
-Provide index of the folders on the portal to make it more user friendly 16 SLR -AREAS FOR IMPROVEMENT
- Prepare OpE database as soon as possible
*Audits-Optimize effectiveness of in
- Clarify level and type of access requirements to the CAP database early
-house audits through use of Skype by NRC  
- Clarify usage of terms not applicable vs. not used
-Staff assess and minimize number of on
- Communicate more clearly staff process regarding vetting of acceptance issues and decisions SLR - AREAS FOR IMPROVEMENT 14
-site audits to those essential
* Pre-Submittal
-Staff provide questions and talking points in advance of in-office audit to focus discussion
- Compare refueling outage plans to the anticipated application review schedule. If conflicts exist, the application submission should be advanced or delayed to minimize the conflicts.
-Challenging areas should be scheduled later for the in
- Understand criteria on sufficiency for environmental review  
-office audit
- The NRC staff will need to see (not review) the SAMA new and significant basis document to support the application acceptance determination.
-If applicant commits to a voluntary SLRA supplement during breakout session, public meeting, or teleconference, clarify submittal date 17  
SLR - AREAS FOR IMPROVEMENT 15
*Audits (Con't)-Don't provide voluntary supplements if supplement was not proposed and agreed upon as the appropriate course of action
 
-Schedule 3 days at most for the environmental site visit-Include in the OpEdatabase a master sheet of the Excel search term tabsSLR -AREAS FOR IMPROVEMENT 18  
SLR - AREAS FOR IMPROVEMENT
*Requests for Additional Information (RAIs)
* Acceptance Review
*Qualitative evaluations and conclusions should be supported by quantitative evaluations for staff review
- Portal operable, as needed, during acceptance review
-Example: applications should include enough information for the staff to verify calculations have been performed in accordance with RG 1.190*Technical analysis based on unapproved Topical Reports or unapproved methodologies require sufficient staff resources and appropriate documentation for staff reviewSLR -AREAS FOR IMPROVEMENT 19 SLR -AREAS FOR IMPROVEMENT
- Portal fully functional at the conclusion of the acceptance review
*Application information
- Provide index of the folders on the portal to make it more user friendly 16
-Don't include a reference if unsure if it supports a consistency determination in GALL
 
-SLR. References should clearly support the consistency determination.
SLR - AREAS FOR IMPROVEMENT
-Provide clarity in language for commitments in SLRA Appendix A and for enhancements or exceptions (actions to be taken, when, and how action relates to the enhancement or exception)
* Audits
-Each program element should be addressed in the program basis documents, not generally repeat the same information for several program elements without discernment between the elements.
- Optimize effectiveness of in-house audits through use of Skype by NRC  
20 SLR -New Issues
- Staff assess and minimize number of on-site audits to those essential
*New issues have been identified during the reviews of the first 3 SLRA's that could result in Interim Staff Guidance (ISG) documents:
- Staff provide questions and talking points in advance of in-office audit to focus discussion
-Impact on material properties and intended function due to irradiation of structural steel
- Challenging areas should be scheduled later for the in-office audit
-Management of aluminum or stainless steel support members, welds, bolted connections, or support anchorage to building structure components for loss of material due to pitting and crevice corrosion, and cracking due to stress corrosion cracking (SCC) 21 DISCUSSION}}
- If applicant commits to a voluntary SLRA supplement during breakout session, public meeting, or teleconference, clarify submittal date 17
* Audits (Cont)
- Dont provide voluntary supplements if supplement was not proposed and agreed upon as the appropriate course of action
- Schedule 3 days at most for the environmental site visit
- Include in the OpE database a master sheet of the Excel search term tabs SLR - AREAS FOR IMPROVEMENT 18
* Requests for Additional Information (RAIs)
* Qualitative evaluations and conclusions should be supported by quantitative evaluations for staff review
- Example: applications should include enough information for the staff to verify calculations have been performed in accordance with RG 1.190
* Technical analysis based on unapproved Topical Reports or unapproved methodologies require sufficient staff resources and appropriate documentation for staff review SLR - AREAS FOR IMPROVEMENT 19
 
SLR - AREAS FOR IMPROVEMENT
* Application information
- Dont include a reference if unsure if it supports a consistency determination in GALL-SLR. References should clearly support the consistency determination.
- Provide clarity in language for commitments in SLRA Appendix A and for enhancements or exceptions (actions to be taken, when, and how action relates to the enhancement or exception)
- Each program element should be addressed in the program basis documents, not generally repeat the same information for several program elements without discernment between the elements.
20
 
SLR - New Issues
* New issues have been identified during the reviews of the first 3 SLRAs that could result in Interim Staff Guidance (ISG) documents:
- Impact on material properties and intended function due to irradiation of structural steel
- Management of aluminum or stainless steel support members, welds, bolted connections, or support anchorage to building structure components for loss of material due to pitting and crevice corrosion, and cracking due to stress corrosion cracking (SCC) 21
 
DISCUSSION}}

Latest revision as of 04:03, 5 January 2025

NRC Staff Slides for the March 28, 2019 Public Meeting on SLR Lessons Learned
ML19086A039
Person / Time
Issue date: 03/28/2019
From: William Burton
NRC/NRR/DMLR/MRPB
To:
Burton W, NRR-DMLR 415-6332
References
Download: ML19086A039 (22)
v • d • e


Text

Subsequent License Renewal (SLR)

Lessons Learned Public Meeting March 28, 2019

AGENDA

  • Welcome and Introductions
  • Background
  • Review Process Changes
  • Strengths
  • Areas for Improvement
  • Discussions on NRC presentation
  • Industry/Applicant presentations
  • Discussions on Industry/Applicant presentations
  • Summary
  • Closeout and Adjourn 2

BACKGROUND

  • NRC established an optimized 18-month review schedule for SLR applications

completed in 16 months

  • NRC has received 3 SLR applications for review since January 2018

- Turkey Point in January 2018 (accepted 5/2/18)

- Peach Bottom in July 2018 (accepted 9/6/18)

- Surry in October 2018 (accepted 12/3/18)

BACKGROUND (Cont)

  • SLR applicants have each gone through or are going through several phases of the review process

- Pre-submittal

- Acceptance Review

- Audits

- RAIs

  • Lessons learned from NRC perspective
  • SLR Application (SLRA) review optimization effort identified several changes
  • 18 month schedule begins upon SLRA acceptance for docketing Review Process Changes 5
  • Applicant provides access to electronic portal (no later than acceptance of the SLRA in order to support the review schedule)
  • Aging Management Audits (Safety) o Offsite Aging Management Program Operating Experience Audit o In-Office Aging Management Audit via telecom/webinar breakout sessions o On-Site Aging Management Audit with regional participation to walk down specific material conditions and plant configurations Review Process Changes (Cont) 6

Review Process Changes (Cont)

  • Documents and meetings o Draft SEIS public meeting if necessary (environmental) o Streamlined SER process o Advisory Committee on Reactor Safeguards (ACRS) meetings on safety review - only one ACRS Subcommittee meeting o ACRS Full Committee meeting scheduled within two months following SC meeting 7
  • Re-iterated these lessons learned during pre-submittal meetings and provided additional plant specific topics

- Peach Bottom (ML19084A098)

- Surry (ML18121A034)

  • Info on lessons learned and preparing for NRC review also provided at ANS Utility Working Conference in August 2018 (ML18198A273)

Previous Lessons Learned 8

  • Communicate with NRC - frequently / timely
  • Communicate w/other applicants / prospective
  • Peer reviews
  • Review most recent NRC RAIs
  • Ensure internal application consistency
  • Ensure CLB issues are addressed prior to SLRA
  • Address NRC concerns from previous reviews (ML17353A035)
  • Facilitate the NRCs review Preparing for NRC Review 9
  • Environmental at least 12 months prior to submittal
  • Safety at least 6 months prior to submittal
  • Referencing unapproved Topical Reports or unapproved methodologies
  • Proprietary information - must be reviewed before application can be made public
  • Portal for documentation
  • Update program for consistency with GALL-SLR and SRP-SLR Preparing for NRC Review 10

SLR Reviews - STRENGTHS

  • Excellent communication during all phases of the review
  • Excellent responsiveness to NRC requests for info on portal, clarifications on draft RAIs, and responses to final RAIs
  • Portal demonstrations were very helpful
  • Good RAI quality

- More detailed

- Higher-quality dialogue/clarification calls

- Allowed for better informed RAI response

- Fewer 2nd-round RAIs 11

  • Excellent support during audits
  • Optimized effectiveness of in-house audits through use of Skype
  • Staff provided questions and talking points to better focus the audit discussions
  • On-site audit needs better assessed and limited to only those that are actually needed
  • Application quality is on an improving trend SLR Reviews - STRENGTHS 12

13

  • Pre-Submittal Submit SLRAs about 6 months apart Begin PM outreach activities 6 months before SLRA submittal Highlight new, challenging, plant-specific, and or unique technical and process issues
  • Allows time to align people and resources early
  • Allows time to consider impacts on the review schedule SLR - AREAS FOR IMPROVEMENT

Pre-Submittal

- Minimize proprietary information in the SLRA - must be reviewed before application can be made public

- Prepare OpE database as soon as possible

- Clarify level and type of access requirements to the CAP database early

- Clarify usage of terms not applicable vs. not used

- Communicate more clearly staff process regarding vetting of acceptance issues and decisions SLR - AREAS FOR IMPROVEMENT 14

- Compare refueling outage plans to the anticipated application review schedule. If conflicts exist, the application submission should be advanced or delayed to minimize the conflicts.

- Understand criteria on sufficiency for environmental review

- The NRC staff will need to see (not review) the SAMA new and significant basis document to support the application acceptance determination.

SLR - AREAS FOR IMPROVEMENT 15

SLR - AREAS FOR IMPROVEMENT

- Portal operable, as needed, during acceptance review

- Portal fully functional at the conclusion of the acceptance review

- Provide index of the folders on the portal to make it more user friendly 16

SLR - AREAS FOR IMPROVEMENT

  • Audits

- Optimize effectiveness of in-house audits through use of Skype by NRC

- Staff assess and minimize number of on-site audits to those essential

- Staff provide questions and talking points in advance of in-office audit to focus discussion

- Challenging areas should be scheduled later for the in-office audit

- If applicant commits to a voluntary SLRA supplement during breakout session, public meeting, or teleconference, clarify submittal date 17

  • Audits (Cont)

- Dont provide voluntary supplements if supplement was not proposed and agreed upon as the appropriate course of action

- Schedule 3 days at most for the environmental site visit

- Include in the OpE database a master sheet of the Excel search term tabs SLR - AREAS FOR IMPROVEMENT 18

  • Requests for Additional Information (RAIs)
  • Qualitative evaluations and conclusions should be supported by quantitative evaluations for staff review

- Example: applications should include enough information for the staff to verify calculations have been performed in accordance with RG 1.190

  • Technical analysis based on unapproved Topical Reports or unapproved methodologies require sufficient staff resources and appropriate documentation for staff review SLR - AREAS FOR IMPROVEMENT 19

SLR - AREAS FOR IMPROVEMENT

  • Application information

- Dont include a reference if unsure if it supports a consistency determination in GALL-SLR. References should clearly support the consistency determination.

- Provide clarity in language for commitments in SLRA Appendix A and for enhancements or exceptions (actions to be taken, when, and how action relates to the enhancement or exception)

- Each program element should be addressed in the program basis documents, not generally repeat the same information for several program elements without discernment between the elements.

20

SLR - New Issues

  • New issues have been identified during the reviews of the first 3 SLRAs that could result in Interim Staff Guidance (ISG) documents:

- Impact on material properties and intended function due to irradiation of structural steel

- Management of aluminum or stainless steel support members, welds, bolted connections, or support anchorage to building structure components for loss of material due to pitting and crevice corrosion, and cracking due to stress corrosion cracking (SCC) 21

DISCUSSION

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