Key Influencing Factors in Review Resources and Timeline for Operating Reactor Licensing Reviews

Many factors may impact the NRC resources or schedule required to review a particular licensing action.  The staff has provided a list of some key influencing factors that drive impacts to licensing action review resources or schedule.  While it’s not possible to identify all possible influencing factors, this list is some of the more common factors encountered by the staff.

Other potential factors include, for example, prioritization, fleet vs single submittal, and licensee need date.  Examples of positive influencing factors not shown here include the conduct of pre-submittal meetings for planned licensing actions, as well as submissions of license amendments under streamlined processes such as the Consolidated Line Item Improvement Program (CLIIP).

Key Influencing Factors in Review Resources and Timeline for Operating Reactor Licensing Reviews

Key

PRA: Probabilistic Risk Assessment

TR: Topical Report

First-of-its-Kind Submittal:  A licensing action where the requested change is one that the NRC staff have not previously reviewed, for example, a new program, a new (novel) component, a new methodology.  While this distinction may be unavoidable when introducing a new technology or analysis, the effects may be mitigated by extensive preapplication engagement with the NRC staff and a high-quality application.

Application Quality:  The quality of a requested licensing action has a significant impact on the amount of NRC staff’s resources expended in the review process. Requested licensing actions that include information of a sufficient scope and depth allow the NRC staff to focus its efforts on reviewing the safety, technical, and regulatory merits of the arguments put forth by the licensee. When an application lacks critical information necessary (e.g., analyses/calculations, unjustified use of unapproved methodologies, etc.) for the NRC staff to complete its review, an excessive amount of NRC staff time is spent gathering this information.

PRA Quality:  If a requested licensing action justifies any portion of its application through risk-informed analysis, the plant PRA must be of sufficient quality to support probabilistic analysis with the right level of scope and detail. 

Application Complexity:  The specific change that is being requested will determine what engineering, risk, scientific, security, or financial technical review it will require from the NRC staff.  When a requested licensing action crosses many technical disciplines, it is important that the application contain the technical information required to complete the review for each technical discipline.

Plant Specific Deviations:  When a licensing action requests to adopt a Technical Specification Task Force (TSTF) Traveler or to reference an approved Topical Report (TR), it is essential to point out any plant-specific deviations from the TSTF Traveler or the assumptions or analysis in the referenced TR.  For example, if the TSTF Traveler or Topical Report assumes that a plant has a certain type of main feed pump, but the actual plant that is the subject of the requested licensing action has a different type of main feed pump, then that difference, and its potential impact on the analysis that underpins the original TSTF Traveler or Topical Report, needs to be clearly stated in the application.

Referencing Unapproved Topical Reports:  Licensees may not reference a topical report in a license amendment request until the topical report is fully completed and the approved ("-A") version of the topical report is verified by the NRC staff. Using an –A version provides a report that has all the documentation related to the review in one place. It includes the technical report, revised to incorporate answers to NRC staff Requests for Additional Information (RAIs); the NRC staff RAIs and answers; and the NRC staff safety evaluation. Exceptions to using a version other than the –A version may be allowed on a case-by-case basis if the NRC staff determines that an exception is in the public interest.

Page Last Reviewed/Updated Tuesday, April 05, 2022