Efficiency Bulletin: 16-24

Streamline Regulatory Organizations

Issue date:	September 1, 2016
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September 1, 2016 Color Code: Green Efficiency Bulletin: 16–24 Streamline Regulatory Organizations Streamline licensing and compliance groups to accomplish required tasks at a reduced cost. Addressees: Chief nuclear officers, NEI APCs and INPO APCs Issue: RE-9, Streamline Internal Licensing and Regulatory Organizations

Summary of Efficiency Opportunity

• Desired end-state—Licensing and compliance groups accomplish required tasks at a lower overall cost.
• Value proposition (vision of excellence)—Licensing and compliance groups will focus on priority tasks and eliminate low-value activities, resulting in efficiency gains and increased focus on regulatory issues.

Benchmarking associated with this efficiency bulletin revealed that many utilities have the opportunity to potentially realize over 20 percent savings.

• Why it is important?—Licensing and compliance groups have evolved

differently in the industry and are of varying sizes doing essentially the same work. A standard task list with defined man-hours (Attachment 1) has been developed that provides an opportunity for utilities to reduce the number of full time equivalent (FTE) workers devoted to licensing and compliance while still performing required tasks. Attachment 2 provides a companion listing of recurring tasks. Attachment 3 is a sample organization chart for consideration. There is no expectation that companies implement this organization structure as it is shown.

Relevant Standards

• No relevant standards
• No relevant guidance

Recommended Industry Actions

• This efficiency bulletin will implement phase 1 of streamlining licensing and compliance groups. A subsequent efficiency bulletin will be developed based on the results of this efficiency bulletin.
• Sites are encouraged to implement Phase 1 activities by Dec. 31, 2016.
• Phase 1

• Each company should perform an assessment of their licensing and compliance tasks and man-hours against Attachments 1 and 2, “nominal” drivers, and man-hour

estimates

• If a company performs fewer tasks, the site should evaluate why and report best practices to NEI. If a company performs more tasks, it should report to NEI if it believes something should be added to the “nominal” list.
• If a company’s man-hours for a task are greater than the “nominal,” sites should investigate and determine why. It may be appropriate to revise the current approach for performing that task. If a company’s man-hours for a task are much less than the “nominal,” sites should describe how it is achieved and document that best practice on the Attachment 4 form.
• Transmit best practices forms to NEI’s Chris Earls (cee@nei.org) by the end of 2016.

• Phase 2

• The efficiency bulletin development team will revise the driver/man-hour list based on best practices and will issue a new efficiency bulletin in the first quarter of 2017. Companies will be encouraged to move their regulatory/compliance resource loading toward the revised man-hour estimates in that efficiency bulletin.

Change Management Considerations

Industry Activities

• Industry webinar to provide background for initiative and provide an open forum to clarify expectations and ask questions. Webinar information can be found at https://web.inpo.org/Pages/Nuclear-Promise-Issues.aspx.
• Discuss at the NEI Regulatory Issues Working Group, regional meetings and industry conference calls.

Company Actions

• A comprehensive change management plan should be developed and implemented for any changes resulting from the Phase 1 review. The change management should include training and monitoring.
• The attached task list does not dictate a particular organizational structure. Tasks may be performed on-site or in corporate offices depending on company preference. Two possible organization structures are offered for company consideration.

Guiderails

• Continue to fully comply with all regulatory requirements.
• There is risk that if an organization is “streamlined” without full understanding of the scope, some required tasks may be inadvertently missed.

Report Your Site’s Results

Please report your company’s implementation of this improvement opportunity, including the date of completion. Send this information, along with your company point of contact, to EfficiencyBulletin@NEI.org.

Industry Contacts

• Industry champion for this issue: Steve Bethay, 423-751-8728, sjbethay@tva.gov
• NEI contact: Chris Earls, 202-739-8078, cee@nei.org
• On the web: www.nei.org/bulletin1624

Industry Approval:

Mano Nazar, CNO Lead Anthony R. Pietrangelo, Nuclear Energy Institute

Attachment 1 RE-009 Streamline Internal Licensing/Regulatory Organization

Assumptions:

1. The plant is not a troubled plant, generally operating in Column 1 of the ROP and at least an INPO 2. 2. Major licensing initiatives/projects are not included (e.g., License Renewal, ITS conversion, NFPA-805, Power Uprates, FLEX, Fukushima, etc.) 3. Individuals performing the tasks are assumed to be fully qualified and experienced performers. 4. Resource estimates assume limited effort on governance and oversight and relatively non-aggressive industry involvement. 5. Resource estimates exclude the most senior regulatory affairs manager and administrative assistants. 6. Manhours/FTE are for a Typical 2 Unit Site. Task Scope Working Team Notes Est. Hours (Contract or Full-Time, Site or Corporate Function, etc.) 1 NRC - Region interface 1 hr/wk interaction with Branch Chief 50 Not counting inspections; routine communication 2 NRC Resident Support Coordinating resident activities 2050 3 NRC inspections and assessments preparation and management Routine Inspections: ISI, RP - (10/yr/site) 450 45 hours for inspections x 10/yr. Large Inspections: Graded EP, FOF, CDBI, PI&R, Triennial FP - (2/yr/site) 420 4 Inspection Issue Support Resolving potential greater than green issues - (2/site/yr) 200 Work to prevent greater than green findings, does not include Regulatory conferences Attachment 11 5 Task Scope Working Team Notes Est. Hours (Contract or Full-Time, Site or Corporate Function, etc.) 5 Generic Communications (Information Notices, Bulletins, RIS, GL, etc.) 160 8 generic communications requiring significant response @ 20 hours each. 6 Allegations Investigation performed outside licensing, licensing provides oversight/processing 150 5 allegations @ 30 hours each 7 NRC-NRR Interface 50 Routine communication; not specific license amendment request 8 Rule Implementation Assumes Reg Affairs role is facilitation 50 Nominal items, excludes issues such as Fukushima 9 ROP Oversight / Performance Indicators 200 e.g., MSPI data entry, NRC KPIs. Not ROP Task Force participation 10 Self-Assessments Assumes process improvement to the SA/BM; BM embedded in other line items 40 One self-assessment per year, reduction from current practice 11 FSAR Maintenance Assumes majority of work is performed by Engineering 190 Reviewing FSAR changes, generating changes occasionally 12 TRM/TS Bases Changes (LDCR) Assumes 3 are by other orgs and 2 are by Licensing 140 3 changes per year @ 10 hours/change; 2/yr @40 hrs 13 Security, QA, EP Plan Changes Assumes most work performed by Core Groups 40 14 Manage company posture on regulatory issues - drop-ins, regions and NRR 3/yr/site 330 Attachment 11 6 Task Scope Working Team Notes Est. Hours (Contract or Full-Time, Site or Corporate Function, etc.) 15 Procedure and Policy management 4 Licensing Procedures per year at 40 hours each - 3 Licensing Guidelines @ 10 hours each - Review procedure from other departments 190 16 Routine reports and correspondence 240 See routine report attachment. The routine correspondence list assumes Licensing is not responsible for submitting Special Nuclear Material (SNM) reports and Licensed Operator Training and Medical. 17 Commitment management This is commitment database management 48 4 hours/month, no INPO tracking 18 LERs and non-routine conditionbased/special reports 280 5 per year @ 40 hours each; one significant @ 80 19 Part 21 40 Varies by utility where this is performed, assumes majority of work is performed by Engineering 20 License amendments and associated RAIs (includes Security, EP, QA) Hours assume that industry is successful in making process improvements under RE-010; 4/yr/site 1200 Includes smaller changes (e.g., TSTFs) and larger plant-specific submittals (e.g., many risk-informed submittals), but excludes major project submittals such as power uprates, license renewal, NFPA805 21 Document validation process and packages for NRC submittals Peer checks and validation package development primarily for LARs submittals 600 Attachment 11 7 Task Scope Working Team Notes Est. Hours (Contract or Full-Time, Site or Corporate Function, etc.) 22 Code Relief and Alternative requests 270 3 per year @ 90 hours per 23 Exemption Requests 60 1 per year 24 NOED 0.5 actual, 2 close calls; can be largely eliminated through risk informed regulations (TSTF 505, initiative 4B) 60 1 per year 25 Operability/Reportability consultations and regulatory analysis Does not include CAP reviews 360 15 hours per occurrence, twice per month 26 Support site safety committee and other boards Includes: NSRB, Plant Review Board, CARB, SARB, NSCMP; this may be impacted by RE-012 - Redundant Oversight 400 Off/On-site boards, corrective action boards; HU boards; review meetings; Maintenance Rule Expert Panel, Oversight Committees, Many EC reviews (at 30%/70%/100%), Config management Review Board (CMMRB), Mod Review and Prioritization Team (MRPT), Etc. 27 Licensing basis interpretations 500 Assume 2 hours per day providing various information to customers 28 Monitor potential regulatory changes and OE Review regulatory subscription services, etc. identify potential impacts : Not influencing change, influencing change captured in item 31 255 29 Maintain NRC postings 10 30 Licensing Performance Indications (internal/utility/fleet) 100 Licensing indicators Attachment 11 8 Task Scope Working Team Notes Est. Hours (Contract or Full-Time, Site or Corporate Function, etc.) 31 BWR and PWR Owner’s Group Support 150 4 meetings per year for licensing subcommittees 32 NEI Support This does include influencing regulatory; RIWG, RITF, ROPTF, other NEI sponsored activities 480 Input into rulemaking or other regulatory proposals, participation in working groups; 30 hours/meeting 16 times per year 33 RUG Support 140 Includes offsite RUG meetings and conference calls 34 Compliance with non-NRC regulations such as NERC/NEIL/ANI, Etc. 40 Responsibilities vary considerably among utilities 35 NOS audit and CAP support Includes CAP review and screening meetings, does not include management meeting 520 2 hr/day 36 Manage Budget and NRC fees 32 Four hours per quarter 37 Contract management Contract management for licensing support services 20 2 hours per month 38 Outage Support Outage support included in adder assumptions; this is non-licensing outage support 580 1 outage/year. 3 people/4 wks 39 ISFSI Support Includes routine submittals; manhours are for user group/industry meetings and specific inspections 80 Would be a major project upon initiation, becomes routine once installed 40 10 CFR50.59 / 72.48 Program Maintenance This item includes process ownership and training only 120 For ownership, oversight and execution of the program, estimates would be much higher Attachment 11 9 Task Scope Working Team Notes Est. Hours (Contract or Full-Time, Site or Corporate Function, etc.) 41 RCE/ACE team support 160 2/yr, 80 hrs each Sub Total Man-Hours 11455 Benefits and Training Calculation=(subtotal/2080)*628 3459 628 hrs/worker: Holidays - 88 hrs, PTO - 300 hrs, Training - 40 hrs, Miscellaneous Activities (ERO, CAP execution, etc.) - 200 Total Man-Hours 14914 Calculation=(total/2080) 7.2 FTE

Attachment 2 – Recurring Task List

© 2016 Nuclear Energy Institute 10 Section Title Type of Report Source of Requirement Applicability Timing Reporting Method Primary Recipient Licensee guarantees of payment of deferred premiums Guarantee of payment of deferred premium §140.21 Licensee required to have financial protection for each nuclear reactor Annually In writing DCD, NRR, NRO, FSMEM, or NMSS, as appropriate Fitness-for-duty program performance data FFD program performance data (for January through December) §26.717(e) Subpart N – Recordkeeping and Reporting Requirements Before March 1 of the following year In writing DCD, RO, RI Emergency Planning and Preparedness for Production and Utilization Facilities Emergency Drill Exercise Scenario §50, App. E(F)(b) Each Licensee at each site shall conduct a subsequent exercise of its onsite emergency plan every 2 years. Submit exercise scenarios at least 60 days before use in an exercise In writing DCD Technical specifications on effluents from nuclear power reactors Annual report that specifies the quantity of each of the principal radionuclides released to unrestricted areas in liquid and in gaseous effluents during the previous 12 months §50.36a(a)(2) Operating licensee, and each holder of a combined license after the Commission has made the finding under § 52.103(g) Annually not to exceed 12 months In writing DCD Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors Report the nature of the change or error and its estimated effect on limiting ECCS analysis discovered in an acceptable emergency core cooling system evaluation model, or application of such model, that affect the temperature calculation §50.46(a)(3)(ii) Licensee of boiling or pressurized water-cooled nuclear power reactor fueled with uranium oxide pellets within cylindrical zircaloy or ZIRLO cladding Annually/Within 30 days if significant in writing DCD QATR Changes to the quality assurance program description in the Safety Analysis Report that do not reduce commitments must be submitted to the NRC in accordance with the requirements of § 50.71(e). §50.54(a)(3) Operating licensee or combined licensee subject to quality assurance criteria in Appendix B Annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months In writing DCD, RO, RI Conditions of licenses Report current levels of insurance or financial security and the sources of this insurance or financial security §50.54(w)(3) Power reactor licensee On April 1 each year In writing DCD Codes and standards/Examination of metal containments and the liners of concrete containments For each inaccessible area identified, provide description of the type and estimated extent of degradation, and the conditions that led to the degradation; An evaluation of each area, and the result of the evaluation, and; A description of necessary corrective actions §50.55a(b)(2) Licensees applying Subsection IWE, 1998 Edition through the latest edition and addenda (Farley and Vogtle only) Within 90 days of the completion of each refueling outage ISI Summary Report required by IWA–6000 DCD, RO, RI Owner's Activity Report (form OAR-1) - ASME permits the use of the Summary Report of by a Code Case, the new OAR-1. §50.55a(b)(2) As committed Within 90 days of the completion of each refueling outage In writing DCD Attachment 2 – Recurring Task List © 2016 Nuclear Energy Institute 11 Section Title Type of Report Source of Requirement Applicability Timing Reporting Method Primary Recipient FSAR FSAR revisions containing updated information on a replacement-page basis that is accompanied by a list which identifies the current pages of the FSAR following page replacement. The revisions must reflect all changes up to a maximum of 6 months prior to the date of filling. §50.71(e)(4) Licensee or applicant Annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months (Hatch - 6 months after each outage; Farley - 6 months after Unit 1 outages; Vogtle - 6 months after U2 outages) 50.71(e) DCD Revised Regulatory Commitment Summaries Revised Regulatory Commitment Summaries NEI 99-04, Section 5.1 10 CFR 50.71 (e) Annually in writing DCD Changes, tests, and experiments Report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation §50.59(d)(2) Combined licenses during period from application to §52.103(g)/Licensee under parts 50 or part 52 Intervals not to exceed 6 months/Intervals not to exceed 24 months In writing DCD Reporting and recordkeeping for decommissioning planning Status report of decommissioning funding on a calendar year basis §50.75(f)(1) Licensee By March 31 every two years/after §52.103(g) finding for COL licensees Report NRC Financial assurance and recordkeeping for decommissioning Decommissioning funding plan §72.30(b) Each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan At the time of license renewal and at intervals not to exceed 3 years In writing DCD License conditions Annual report specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during the previous 12 months of operation §72.44(d)(3) License authorizing the receipt, handling, and storage of spent fuel, high-level radioactive waste, and/ or reactor-related GTCC waste Annually within 60 days after the end of the 12-month monitoring period In writing SFT, NMSS Changes, tests, and experiments Brief description of any changes, tests, and experiments, including a summary of the evaluation of each §72.48(d) Licensee and certificate holder Intervals not to exceed 24 months In writing SFT, NMSS Changes to security practices and procedures NRC facility clearance update (Standard Practice Procedures Plan or certification that the existing plan is fully current) §95.19( c) Licensee, certificate holder or other person having the need to use, process, store, reproduce, transmit, transport, or handle NRC classified information Every 5 years In writing DCD, DNS Requirements for Mitigation Strategies for Beyond - Design Basis External Events Status Report EA-12-049 Licensee Every 6 Months Following Submittal of the ISG In writing DCD Annual Non-Radiological Environmental Operating Reports Annual Non-Radiological Environmental Operating Reports Environment Protection Plan Section 5.4.1 Fleet Annually In writing DCD Attachment 2 – Recurring Task List © 2016 Nuclear Energy Institute 12 Section Title Type of Report Source of Requirement Applicability Timing Reporting Method Primary Recipient Annual Radioactive Environmental Operating Reports Annual Radioactive Environmental Operating Reports 5.6.2 Fleet Annually In writing DCD COLR The COLR, including any mid-cycle revisions or supplements, shall be provided upon issuance for each reload cycled to the NRC TS 5.6.5.d Fleet About one month after each refueling outage In writing DCD Steam Generator Tube Inspection Report (PWR) Steam Generator Tube Inspection Report (PWR) PWR TS 5.6.10 PWR 180 days after entry into Mode 4 (if there is a SG tube inspection performed) In writing DCD FOCI Five-Year Resubmittal FOCI Five-Year Resubmittal NISPOM Fleet Every 5 years In writing DCD

Attachment 3 – Sample Organization Chart

© 2016 Nuclear Energy Institute 13 The following examples illustrate the use of the task description and target staffing level attachment. A review of the task descriptions should be made to remove any tasks that are not performed by your organization, and the total hours revised down accordingly. The same should be done to add for any tasks that are not listed that you are required to support. Assume the target staffing level remains the same as shown, at 7.2 FTEs per number of Sites. Assume a fleet with a total of 5 sites (regardless of Units per Site). Therefore, target staffing level = 7.2 x 5 Sites = 36 FTEs for the Licensing/Regulatory Affairs Organization. Example 1: Larger Presence at the Sites

Total at the Corporate Office = 6 Total at each Site = 6 (x 5 Sites) = 30 Example 2: Larger Presence at the Corporate Office

Total at the Corporate Office = 16 Total at each Site = 4 (x 5 Sites) = 20 Director Regulatory Affairs Not Included in Total Fleet Licensing Manager 1 Position Licensing 2 Positions Fleet Compliance Manager 1 Position Compliance 2 Positions Admin As Needed Site Manager 1 Position Licensing 2 Positions Compliance 3 Positions Admin As Needed Director Regulatory Affairs Not Included in Total Fleet Licensing Manager 1 Position Licensing 10 Positions Fleet Compliance Manager 1 Position Compliance 4 Positions Admin As Needed Site Manager 1 Position Licensing All at Corporate Compliance 3 Positions Admin As Needed Attachment 4 – Best Practice Feedback Form © 2016 Nuclear Energy Institute 14 Task Name: Revised Task Man-hour Estimate (Hours): Best Practice Description (Should describe how the revised man-hour estimate can be achieved for the given task): Submitting Utility/Site: Contact Name: Contact Phone Number/E-Mail Address: