ML051360026
| ML051360026 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/25/2005 |
| From: | Robert Kuntz NRC/NRR/DLPM/LPD3 |
| To: | Nuclear Energy Institute |
| Kuntz, Robert , NRR/PMAS/POEB, 415-3733 | |
| References | |
| Download: ML051360026 (10) | |
Text
May 25, 2005 ORGANIZATION:
NUCLEAR ENERGY INSTITUTE LICENSING ACTION TASK FORCE SUB-GROUP
SUBJECT:
SUMMARY
OF APRIL 26, 2005, MEETING WITH NUCLEAR ENERGY INSTITUTE LICENSING ACTION TASK FORCE SUB-GROUP ON EVALUATION OF TRENDS OF REQUESTS FOR ADDITIONAL INFORMATION On April 26, 2005, a Category 2 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of the Nuclear Energy Institute (NEI) Licensing Action Task Force (LATF) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss evaluation of trends of requests for additional information (RAI). A list of attendees is provided as Attachment 1 and a copy of the updated agenda is provided as Attachment 2.
The NRC staff and NEI/LATF sub-group re-affirmed the definition of RAIs for data trending purpose to be the number of supplements for each licensing action. RAI data trends will be developed using NEI supplied information for completed 10 CFR Part 50 licensing actions on a per plant basis and on a fleet-wide basis for each of the past three calendar years. Data trending is scheduled for completion by June 2005, with additional trending on a subject matter basis to be considered. For case studies, the actual number of RAI questions would also be determined. Draft RAI categories were discussed and are outlined as part of Attachment 2.
The NEI/LATF sub-group will obtain industry review and comments on the draft listing.
The participants discussed the scope and conduct of case studies to evaluate the quality and completeness of licensee submittals and RAI responses and the appropriateness of RAI questions. Completion of four pilot cases and the identification of approximately 20 case studies are scheduled for June 2005, with completion of the remaining case studies by October 2005. The cases studies will not involve de novo reviews of the licensing actions, but will largely depend on the RAI questions that were asked to assess the quality and completeness of the licensee's submittals and whether precedents were appropriately used.
NRC staff requested that NEI/LATF members consider a discussion of licensee processes, constraints and limitations, and licensee performance metrics for licensing actions at a future RAI project sub-group meeting. NRC staff also asked NEI/LATF members to consider industry interim actions in advance of RAI project completion to support effective and efficient processing of RAI responses. NRC staff also discussed current staff efforts to develop criteria fo non-acceptance, rejection, and denial of licensee submittals that are not of adequate quality and completeness.
The participants agreed that data trending and case study results, draft rules of use for precedents, and draft guidance on selected topics in the area of quality and completeness of licensee submittals and RAI responses, and associated draft changes in NRC office instructions, should be considered for presentation at the planned NEI Licensing Forum, scheduled currently for early November 2005.
Public feedback forms were distributed. No comments were received from members of the public during the meeting.
Please direct any inquiries to Robert Kuntz at 301-415-3733, or rfk@nrc.gov.
/RA/
Robert Kuntz, Project Engineer, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Project No. 689
Enclosures:
- 1. List of Attendees
- 2. Revised Agenda cc w/atts: See next page CONTACT:
Robert Kuntz 301-415-3733 NRR/DLPM The participants agreed that data trending and case study results, draft rules of use for precedents, and draft guidance on selected topics in the area of quality and completeness of licensee submittals and RAI responses, and associated draft changes in NRC office instructions, should be considered for presentation at the planned NEI Licensing Forum, scheduled currently for early November 2005.
Public feedback forms were distributed. No comments were received from members of the public during the meeting.
Please direct any inquiries to Robert Kuntz at 301-415-3733, or rfk@nrc.gov.
/RA/
Robert Kuntz, Project Engineer, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Project No. 689
Enclosures:
- 1. List of Attendees
- 2. Revised Agenda cc w/atts: See next page CONTACT:
Robert Kuntz 301-415-3733 NRR/DLPM DISTRIBUTION:
PUBLIC RidsNrrDlpmLpdiii2 (GSuh)
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PDIII-2 R/F RidsOgcRp RidsNrrDlpmLpdiii (AMohseni)
RKuntz RidsAcrsAcnwMail RidsNrrLAPCoates TMensah RidsRgn3MailCenter DWeaver WRuland CHolden EHackett HBerkow Package: ML052020374 Notice: ML051030227 ADAMS Accession Number: ML051360026 OFFICE PE:PDIII-2 LA:PDIII-2 SC:PDIII-2 NAME RKuntz PCoates GSuh DATE 05/25/05 05/24/05 05/25/05 OFFICIAL RECORD COPY LIST OF ATTENDEES REQUESTS FOR ADDITIONAL INFORMATION (RAI) TREND EVALUATION NRC/INDUSTRY LICENSING ACTION TASK FORCE SUB-GROUP MEETING APRIL 26, 2005 NEI/Licensing Action Task Force J. Fisicaro M. Schoppman D. Woodlan D. Gullott C. Brinkman NRC A. Mohseni G. Suh B. Reckley L. Lois R. Taylor R. Kuntz AGENDA (revised)
REQUESTS FOR ADDITIONAL INFORMATION (RAI) TREND EVALUATION NRC/INDUSTRY LICENSING ACTION TASK FORCE SUB-GROUP MEETING APRIL 26, 2005 1.
Introductions & agenda (5 minutes) 2.
Data trends and case studies (30 minutes)
RAI draft categories RAI trend data presented at October 2004 NEI Licensing Forum Data trends (RAI data trends on a per plant/subject basis for actions completed during the last 3 years)
Case studies (discuss case study candidates, scope, approach, resource needs, pilot effort, updates to NEI data file to support case studies, and schedule) 3.
Discussion items (30 minutes)
Discuss licensee and NRC processes for licensing actions (NRC RAI documentation process; licensee licensing action processes; licensee process for development, review, and issuance of RAI responses; constraints and limitations; licensee performance metrics)
Criteria for non-acceptance, rejection, and denial of licensee submittals (discuss preliminary issues and approach)
Precedents - clear rules for use (future meeting item)
Topical reports - common understanding on applicability and submittal descriptions (future meeting item)
Quality and completeness - need for additional guidance (future meeting item) 4.
Project deliverables, resources, and schedules (30 minutes)
- 5.
Questions and discussion, including members of the public in attendance (15-30 minutes)
RAI CATEGORIES (Draft)
- 1.
Information (related to needed depth and scope) not contained in initial submittal, is not contained in any other docketed correspondence, or can not be reasonably be inferred from information available to the staff. Includes information needed to address statutory requirements.
- 2.
Information needed due to:
- a. complexity of the request
- b. first-of-a-kind nature of the request
- c. changes to previous methodology, or
- d. proposed reductions in safety margins.
- 3.
Information needed due to change in regulatory significance or focus
- 4.
Follow-up RAIs sent in response to incomplete RAI responses
- 5.
Revised submittal to provide clarifications or to correct typographical, administrative, or other minor errors
- 6.
RAI response where licensees submit information on the docket because resolution of an item under discussion during the staff review relies on information not submitted to the NRC
- 7.
Background information (shouldnt be part of RAI questions normally)
- 8.
Inappropriate of unnecessary RAI question because it meets one of the criteria below
- 9.
Other causes CRITERIA FOR INAPPROPRIATE OR UNNECESSARY RAI QUESTION
- 1.
Not directly related to the applicable requirements (e.g., general information requests or commitments being encouraged from licensees)
- 2.
Not consistent with applicable codes, standards, RGs, or SRP sections
- 3.
Information already available in original submittal or contained in other docketed correspondence or can be reasonably inferred from information available to the staff provided that the information is (1) stated in the original submittal, (2) explicitly referenced in the submittal, or (3) known to engineers who work in the general technical area related to the licensing action
- 4.
Technical complexity of the question is not merited in view of the safety significance of the issue in question CASE STUDY CANDIDATES (Draft)
Case Study Candidates - RAI Trend Evaluation Project Case studies are planned for completed 10 CFR Part 50 licensing actions. The case studies, to be conducted jointly by the NRC team and NEI/LATF team, will evaluate the quality and completeness of the licensee's submittal and RAI responses and the appropriateness of RAI questions. Candidate for case studies will involve licensing actions completed in the last 1-2 years that involved one or more of the following:
poor or incomplete submittals inappropriate or unnecessary RAI questions use of precedents that do not apply use of topical reports and not demonstrating applicability or not meeting limitations and restrictions of the staff's topical report approval first-of-a-kind requests change in methodology or reductions in margin licensees looking to NRC to lead them through the analysis and evaluation additional information needed due to change in regulatory significance or focus other aspects The RAI teams are looking for significant examples that may lead to insights to support process improvements. The decision to pursue process improvements is largely dependent on the significance of evaluation results and industry and staff's commitment to improve effectiveness and efficiency. The number of case studies is expected to be on the order of 10 - 20 examples.
(NRC and LATF teams to both identify half of the case studies.)
Schedule for identification of case study candidates? (06/05)
Schedule for completion of case studies? (06/05 for pilots) (09/05 for remainder)
CASE STUDIES (Draft)
RAI Trend Evaluation Project - Case Studies (Draft)
Case studies are planned for licensing actions that appeared to involve (a) incomplete or poor quality submittals or (b) RAIs not needed for the regulatory finding or RAI questions that asked for information already available to the staff.
The objectives of the case studies are to (a) gain insights on the apparent causes for the recent RAI trends, (b) obtain insights on needed process improvements and on needed guidance and clarifications of current process steps, ©) provide bases and justification for process changes that the RAI project teams may recommend, (d) provide input to RAI project deliverables such as project summary reports, improved guidance documents, or generic communications.
Resource estimates are as follows:
Estimated time NRC/RAI assignee LATF/RAI assignee 2-4 hrs review request & NRC action review request & NRC action 1-2 hrs RAI review RAI review 2-4 hrs discuss with reviewer*
discuss with licensee staff*
2 hrs discuss with LATF assignee discuss with NRC assignee 2-3 hrs document case study document case study 9-15 hrs for NRC/RAI assignee & 9-15 hrs for LATF/RAI assignee 2-4 hrs reviewer & 2-4 hrs licensee staff
- Estimated time includes discussion of completed case study results Scope Case studies would include the following activities:
(1) review the licensing action request and NRC actions (2) review and characterize all RAI questions (3) identify inappropriate RAI questions, if any, and their disqualification criteria (4) assess completeness of the submittal (5) assess the quality of the submittal (6) determine whether precedents were appropriately used (7) discuss with reviewer (NRC assignee) and licensee staff (LATF assignee)
(8) evaluate licensee and staff interactions and communications (9) develop list of strengths and areas for improvement and (10) document case study results.
Notes:
- 1. NRC/RAI assignee makes 4 copies of original request, RAIs, RAI responses, and NRC issued action for case studies that appeared to involve incomplete or poor quality submittals.
LATF/RAI assignee makes 4 copies for case studies that appeared to involve RAIs that were not needed. One copy each goes to each assignee, and one copy to Mike Schoppman and one copy to Gene Suh.
- 2. Consider discussions with the NRC technical reviewer's and licensee staff's supervisors for additional insights.
- 3. Exclude case studies where issues appear primarily related to NRC technical reviewer or licensee staff performance problems.
February 2000 Nuclear Energy Institute Project No. 689 cc:
Mr. Ralph Beedle Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Alex Marion, Director Programs Nuclear Energy Institute 1776 I Street, Suite 400 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. H. A. Sepp, Manager Regulatory and Licensing Engineering Westinghouse Electric Company P.O. Box 355 Pittsburgh, PA 15230-0355 Mr. Jim Davis, Director Operations Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Ms. Lynnette Hendricks, Director Plant Support Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Charles B. Brinkman, Director Washington Operations ABB-Combustion Engineering, Inc.
12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852