U.S. NRC Review of Application

The major steps in the United States Nuclear Regulatory Commission (US NRC) safety review are:

• Sufficiency Review and Docketing
• Safety Review Process
• Advisory Committee on Reactor Safeguards (ACRS)
• Environmental Review
• US NRC Commissioners Review

US NRC Review Timeline

• Sufficiency Review – 2 months
• US NRC Staff and Regional review – 14 to 16 months
• ACRS review – 1 month
• Commissioners’ decision – 1 month
• Total duration from submittal to issue of new license - 18 to 20 months. This may vary depending on issues with the application both technical and those raised in filed contentions by the public. Contention resolution may add several months, or more, to the timeline.

The following diagram is a visual of how the different parts of the typical US NRC review fit together.

NRC License Renewal Review Process

Sufficiency Review and Docketing

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The Sufficiency Review is a high-level review of the license renewal application (LRA) to confirm that the application includes the correct types of information at a level of detail that the US NRC can review to make a determination to issue a renewed operating license.

The Sufficiency Review is NOT a technical review of the correctness or adequacy of the application.

The US NRC process for determining sufficiency is documented in Section 1.1 of both NUREG-1800 and NUREG-2192; the US NRC Standard Review Plans for initial and subsequent license renewal. This includes an US NRC acceptance review checklist (see Table 1.1-1 in both NUREGs).

Safety Review Process

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1. US NRC Headquarters Audits IMC2516: The focus of the US NRC headquarters’ review is to determine if the information in the LRA satisfies the standards in the US NRC Standard Review Plan (NUREG-1800 for LR and NUREG-2192 for SLR) for issuance of the renewed license. The US NRC will review the information in the application and in the applicant’s supporting documentation for the five areas listed in subsections i. ii. iii. iv., and v. as described below.
   1. Operating Experience

      Review the plant operating experience identified by the plant in preparation of the application to ensure that plant operating experience for the previous 10 years, and any other significant experience, has been considered in identification of relevant aging effects and of aging management programs to provide reasonable assurance that the in-scope systems, structures, and components (SSCs) will meet their intended function during the period of extended operation (PEO).

   2. Scoping, Screening, and Aging Management Reviews (AMR)
      1. Confirm safety-related SSCs are properly included.
      2. Confirm nonsafety-related SSCs that could impact safety-related functions are included. This usually includes plant walkdowns.
      3. Confirm components for regulated events are properly identified. The regulated events are defined in 10 CFR 54.4(a)(3) as Fire Protection (10 CFR 50.48), Environmental Qualification (10 CFR 50.49), Pressurized Thermal Shock (10 CFR 50.61), Anticipated Transients Without Scram (10 CFR 50.62), and Station Blackout (10 CFR 50.63).
      4. Confirm appropriate screening was preformed to screen out active and short-lived SSCs to focus on passive and long-lived SSCs.
      5. Confirm that the correct environments, materials and aging effects are identified for each component.
      6. Confirm that the Aging Management Programs (AMPs) identified are appropriate for managing the aging effects associated with each component, material, and environment combination.
   3. AMPs
      1. Confirm AMPs are consistent with NUREG-1801/NUREG-2191 or the exceptions, if any, are adequately justified.
      2. Confirm enhancements, if any, are appropriate to bring the existing plant program into alignment with the program as described in NUREG-1801/NUREG-2191.
   4. Time Limited Aging Analyses (TLAAs)
      1. Review the plant’s current licensing basis (CLB) to determine if the TLAAs in the LRA have been correctly identified as those that need to be dispositioned for the PEO.
      2. Review the disposition of the TLAAs to determine if it meets the guidance in NUREG-1800/NUREG-2192.
   5. FSAR and Commitments

      Review the proposed description of the AMPs, TLAA dispositions and License Renewal commitments that will be incorporated into the plant’s Final Safety Analysis Report (FSAR) after the renewed license is issued.

   
   As part of the review, the US NRC will issue requests for additional information (RAIs) in areas where the staff cannot conclude from the application that the requirements of 10 CFR 54 have been met. The applicant will then provide responses. This process continues until US NRC has sufficient information to prepare a safety evaluation report (SER).

   During the US NRC review process, the applicant may elect to submit supplemental information to the US NRC, if needed, to finalize the safety review in accordance with the requirements of 10 CFR 54.

2. Regional Inspection IP71002: The focus of the inspection by US NRC inspectors from the regional office in the region where the plant is located is to ensure that the scoping of plant SSCs has been completed properly, the review of plant operating experience was performed, and the aging management programs committed to in the LRA are planned or in place to implement. For new programs, the inspectors confirm that the documentation to implement the new programs is in place prior to issuing the new license. The US NRC will review the information as described in i., ii., and iii. by performing walkdowns of the plant and reviewing the implementation documents for the AMPs.
   1. Scoping
      1. Confirm safety-related SSCs are properly included.
      2. Confirm nonsafety-related SSCs that could impact safety-related functions are included.
      3. Confirm components for regulated events are properly identified.
   2. Operating Experience

      Confirm that plant operating experience has been properly considered in development of the AMPs described in the LRA and that these AMPs can adequately manage the effects of aging during the PEO.

   3. AMPs
      1. Verify that the AMPs as implemented will produce results consistent with the LRA.
      2. Review the implementation documents.
      3. Review results of implementation of existing programs.

   
   At the satisfactory conclusion of the Regional Inspection, the US NRC Regional Administrator will issue a letter recommending the approval of the application and issuance of the renewed license.

3. Issuance of Safety Evaluation Report (SER): With input from Headquarters and the Regional Inspection, the US NRC will then issue a SER documenting the results of their review and recommendation that the US NRC Commissioners approve issuance of the renewed license.

Advisory Committee on Reactor Safeguards (ACRS)

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The ACRS is an advisory committee independent of the NRC Staff consisting of varied technical experts who provide independent advise that is factored into the Commission's decision-making process.

After the US NRC staff has issued the SER, the ACRS will review the licensee's application, the SER, relevant inspections and audits. The goal of this review is to assure that the established programs and commitments made by the applicants to manage age-related degradation provide confidence the reactors can be operated safely.

The ACRS will hold a meeting with the applicant and the US NRC staff to solicit information they deem necessary to issue a recommendation to the US NRC Commissioners regarding issuance of the renewed license.

1. This process may involve ACRS issuing written requests for specific information they want discussed during the meeting with the NRC staff and the applicant.
2. There may also be written requests for additional information the ACRS deems necessary to reach a conclusion.
3. This process may result in a revision to the SER to address ACRS concerns.

When the ACRS is satisfied that the renewed license should be issued, they issue a recommendation letter to the US NRC Commissioners.

Environmental Review

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The US NRC review of the Environmental application results in a supplement to the US NRC Generic Environmental Impact Study (GEIS) that is needed for the US NRC commissioners to issue the renewed license. See NUREG-1437 for reference.

The supplement to the GEIS documents the environmental review that is as detailed and as extensive as the safety review, but further discussion on the GEIS supplement is not included in this Wiki.

US NRC Commissioners Review

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This is primarily a review by the US NRC Commissioners’ staff resulting in the US NRC Commissioners approving the renewed license at a regular Commissioners meeting.

The US NRC Commissioners may ask some questions of the US NRC Staff, but these questions are typically very high level or may be about a specific concern for that plant. The US NRC staff will address any questions and, if needed, include any changes to the SER.

International Review of LTO-Assessment

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The regulatory review of the LTO Assessment on the international level is based on the LTO approach that the country follows, in general it can be the LR process, periodic safety review (PSR) process, or a combination of the two.

The following scheme provides an overview of the international approaches to LTO. These approaches are based on the authorization term length of the operation of the NPP. Depending on the approach followed in each country, the national regulatory body reviews either tasks related to aging management (LR approach), selected safety aspects in addition to aging management tasks (PSR approach), or a combination of the two.

Independent of the methodology followed, the regulatory body is responsible for regulating, monitoring, and evaluating the operator’s safety assessment for LTO; in line with the safety requirements specified in advance (e.g., authorization term length, aging of SSCs, obsolescence of SSCs, or environmental impact).

An essential part of the LTO regulatory body review are tasks related to aging management of SSCs. Each regulator verifies that the applicant has sufficiently addressed the following aspects of aging management:

• Aging management scope
• Aging management review
• Aging management program implementation
• Identification and re-validation of TLAAs
• Consideration of operating experience (OE) in the development of AMPs

During their review, the regulatory body considers relevant OE of aging phenomena for similar combinations of materials and environments of the SSCs of the reviewed NPP. The regulator considers both plant-specific OE and OE from NPPs with a similar design. In some cases, the national regulator may require modifications to the plant design in order to meet pre-established safety objectives for LTO.

The regulatory body in many countries ensures that the NPP operator has procedures in place for addressing any issues that may arise during the LTO. Typically it involves, but it is not limited to, a methodology for systematically assessing new OE and R&D findings relevant for the NPP.

The IAEA’s Safety Report SRS-109 “Regulatory Oversight of Ageing Management and LTO Programme of NPPs” is a document that provides a comprehensive review of the existing international regulatory approaches.

1. International regulatory review of the LR approach

   If the LR approach is applicable according to valid national nuclear regulation, the applicant submits an LRA to the regulatory body that assesses the technical information that demonstrates that safety functions of in-scope SSCs will be maintained during the LTO. The main objective of the regulatory body is to verify that the licensee has ensured that the ongoing safe operation of the NPP will be ensured by maintaining the CLB. A typical example of a regulatory review of the LR approach is described above.

2. International regulatory review of the PSR approach

   If the national nuclear regulation mandates the PSR assessment as a prerequisite for LTO, the regulatory body will periodically perform the review of the PSR assessment submitted by the applicant. Depending on the initial authorization term length of the NPP, the PSR assessment for LTO can correspond to the first, third or even to the fourth PSR assessment. Once the NPP enters into a period of extended operation (LTO), the regulator gives a permission/license/authorization for the continuous operation of the NPP until the next PSR review (normally 10 years). The regulatory body will confirm that the plant complies with its licensing basis. The regulator will also review the assessment of the current plant safety level relative to the modern safety standards and best international practices.

   In some countries, the scope of the PSR assessment for LTO can differ from the previous ones. That is why it is vital that the scope of the PSR assessment for LTO is defined in advance, as it is usually of a larger extent in comparison with the previous PSR assessments. Typically, the regulatory body systematically evaluates each of 14 safety factors against the valid national and international safety standards. The safety factors 1, 2, 3 and 4 are the most relevant to aging management of SSCs.

   Additionally, the regulatory body ensures that the overall plant safety has been enhanced since the last PSR assessment and will continue to demonstrate enhancement during the further authorized operation.

   • When reviewing safety factor 1 (Plant design), the regulatory body considers the operator’s evaluation based on the cumulative effect, or alternatively on new proposals emerging from diverse sources (e.g., modern standards, or OE).
   • In the case of safety factor 2 (Actual condition of SSCs important to safety), the regulatory body ensures that the aging effects and degradation mechanisms of in-scope SSCs are exhaustively identified and will be managed during LTO.
   • When reviewing safety factors 3 (Equipment qualification) and 4 (Aging), the regulatory body examines that the operator has established a methodology for assessing the effectiveness of AMPs, and that the AMPs meet the generic attributes of an effective AMP.
3. International Peer Review: IAEA SALTO Missions

   The main objective of the SALTO (Safety Aspects of Long Term Operation) missions organized by the IAEA, is a comprehensive peer safety review ensuring safe LTO of NPPs performed by an international team of experts from IAEA Member States. The team of experts follow the recommendations of IAEA’s SVS-26, “SALTO Peer Review Guidelines” to accomplish these missions. They do so by reviewing the NPP’s documents and databases, by interviewing the NPP’s personnel, and by direct observation of performance. The experts, who do not need to be affiliated with the IAEA, voluntarily contribute their expertise to SALTO missions. These peer reviews enhance the exchange of experience and practices aimed at strengthening the procedures and programs for LTO. The participation in SALTO missions is voluntary; they are executed on a request of each power plant from IAEA Member States.

   The SALTO missions are usually organized in four phases: 1. Workshop on IAEA safety standards and [SALTO review method, 2. Pre-SALTO mission, 3. SALTO mission, and 4. Follow-up SALTO missions, as illustrated in the following figure.

   

   SALTO Phases

   The peer review of the NPP is organized by the following areas:

   • Area A: Organization of aging management and LTO activities
   • Area B: Scope setting, plant programs and corrective action program
   • Area C: Aging management of mechanical SSCs
   • Area D: Aging management of electrical and I&C SSCs
   • Area E: Aging management of civil SSCs
   • Area F: Human resources, competence and knowledge management for continued operation

   Once the mission is concluded, a comprehensive report based on the working notes developed during the mission is submitted to the operator of the reviewed NPP.

   The team members of the SALTO mission follow the IAEA guidelines and recommendations from these documents:

   • IAEA, Services Series 26 “Guidelines for Peer Review of Safety Aspects of Long Term Operation of Nuclear Power Plants and Research Reactors”, Rev. 1, 2021
   • IAEA, SSG-48 “Ageing Management and Development of a Programme for Long Term Operation of Nuclear Power Plants”, 2018
   • IAEA, SRS-82 “Ageing Management for NPPs: International Generic Ageing Lessons Learned (IGALL)”, Rev. 1, 2020

   Record of Revisions

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   Number	Date	Description of Changes
   0	6/11/2024	Initial version

United States of America

Nuclear Regulatory Commission - The US federal government agency that regulates nuclear power plants

Advisory Committee on Reactor Safeguards - A US Nuclear Regulatory Commission statutory committee that reviews applications for nuclear facility licenses, both original and renewal licenses

License Renewal Application - The document submitted by the plant licensee under 10 CFR 54 to extend the operating license of the plant from 40 to 60 years.

License Renewal

Subsequent License Renewal - The extension of the original license from 40 years to 60 years is known as License Renewal. Extensions of the license beyond 60 years are known as Subsequent License Renewal.

Period of Extended Operation - The Period of Extended Operation is the time period between the end of the original plant operating license and the end of the plant renewed license. In US plants, this will typically be 20 years.

Aging Management Review

Current Licensing Basis - 10 CFR 54.3 under references

Final Safety Analysis Report

Safety Evaluation Report

Generic Environmental Impact Statement - NUREG-1437. The US NRC generic assessment of the environmental impact of operation of nuclear power plants during the license renewal term. Each applicant prepares a supplement to the GEIS for the plant.

Long Term Operation

Periodic Safety Review

Nuclear Power Plant

International Atomic Energy Agency

Operating Experience

Instrumentation and Control