ML052970042
| ML052970042 | |
| Person / Time | |
|---|---|
| Issue date: | 11/08/2005 |
| From: | Brach E NRC/NMSS/SFPO |
| To: | |
| Caverly J NMSS/SFPO/SFLS 301 415-6699 | |
| References | |
| RIS-05-027 | |
| Download: ML052970042 (6) | |
See also: RIS 2005-27
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, DC 20555
November 8, 2005
NRC REGULATORY ISSUE SUMMARY 2005-27
NRC TIMELINESS GOALS, PRIORITIZATION OF INCOMING LICENSE
APPLICATIONS AND VOLUNTARY SUBMITTAL OF SCHEDULE FOR
FUTURE ACTIONS FOR NRC REVIEW
ADDRESSEES
All 10 CFR Parts 71 and 72 licensees and certificate holders.
INTENT
To communicate the benefits of pre-licensing discussions with the Nuclear Regulatory
Commission (NRC) staff, improve the quality and completeness of applications, and aid
planning; and to inform applicants of NRCs scheduling guidelines and timeliness goals for
reviewing and processing licensing requests. No specific action nor written response is
required.
BACKGROUND
On February 8, 2005, the Spent Fuel Project Office (SFPO) held a conference with licensees
and certificate holders to foster improvement of the licensing process for Title 10 Code of
Federal Regulations (10 CFR) Parts 71 and 72. At the conference, SFPO described the "Rules
of Engagement" (NRC RIS-04-020) for licensing actions and sought feedback from SFPO
stakeholders about the efficiencies and effectiveness of NRC licensing and certification
processes of transportation and storage reviews. One theme that emerged at the conference
was the need for more communication between NRC and applicants regarding schedules and
resources required for future licensing and certification actions.
NRCs Strategic Plan (NUREG-1614) sets a goal of improving effectiveness - to ensure that
NRC actions are effective, efficient, realistic, and timely. Consistent with this goal, NRC has
developed timeliness measures for review of Parts 71 and 72 casework. Stakeholders at the
conference remarked that having this information would be helpful for planning and determining
their own schedules and budgets.
Page 2 of 5
SUMMARY OF ISSUE
INFORMING NRC OF FUTURE LICENSING ACTIONS
NRC staff encourages applicants to meet with staff to discuss potential license actions. In this
way, the staff and applicants gain a mutual understanding of the purpose and type of future
actions. Pre-application public meetings are a valuable component of work planning and
minimize unnecessary effort and rewrites. Staffs experience has shown that these types of
meetings reduce the number of requests for additional information (RAI) comments and provide
a good background for reviewers. Information that is typically discussed during these meetings
includes the type of and need for action, proposed schedules, licensing basis, and
methodology. No regulatory decisions are made during these meetings but this opportunity
allows for an exchange of information and can aid in streamlining the review process.
Estimates of future licensing action requests help NRC plan and budget work loads.
Information related to future licensing actions which are considered resource-intensive, such as
requests for new site-specific license applications, site-specific renewals, new spent fuel
storage cask designs, and new transportation package designs, is especially helpful for
developing future budgets and managing resources. Information identifying possible upcoming
licensing actions is particularly useful if received by NRC by November 30th of each future year
and can be submitted to SFPO via e-mail, telephone, or letter.
Information on future licensing actions can be treated, if appropriate, under the procedures
listed in 10 CFR 2.390(b), which discuss the process for withholding documents, or portions of
documents, from public disclosure that contain trade secrets, privileged or confidential
information, or commercial or financial information.
SFPO REVIEW SCHEDULE AND TIMELINESS GOALS
Several participants at the February 2005, conference also indicated the potential usefulness,
to their own budgeting and planning processes, of information about the method used by SFPO
in scheduling its casework.
NRC staff's experience shows that the quality and completeness of an application and the
technical complexity of a case are the key factors affecting time to complete an application
review. Good quality can be achieved by providing sound engineering and scientific methods
as the basis for the requested licensing actions. Similarly, completeness can be demonstrated
by providing supporting information and a well organized application. Any deviations from the
staff standard review plans should be clearly identified and discussed in the sumittal and this
information will aid in reducing the time for review. Scheduling dates are based on these
factors but may be revised based on other scheduling components, such as availability of
project management and technical review staff, or priority of the review based on safety or
operational needs. NRC staff has found that the pre-application meetings mentioned above
and use of the standard format and content for applications (e.g., Regulatory Guide 7.9), are
highly effective tools for developing high quality, complete applications.
Page 3 of 5
Prioritization of SFPO Workload
NRC currently processes approximately 100 Part 71 certification actions (new applications,
amendments, and renewals) and 35 Part 72 certification or licensing actions annually.
Prioritization of incoming work is based on the level of safety significance and need associated
with an action or request. NRC has established a prioritization system for storage and
transportation casework. The details of the system are listed below.
SFPO Casework Prioritization System
Priority 1:
Maintain the operational safety of spent fuel and other radioactive
materials in storage and transport.
Priority 2:
Maintain the operational capability at operating reactor sites (for
example, maintain full core off-load capability by moving spent
fuel to dry storage), meet actual (identified) transportation
requirements, or need to support transport of nuclear material.
Priority 3:
Support dry storage and/or transportation needs of
decommissioning facilities.
Priority 4:
Other spent fuel storage and transportation efforts, provided these
are budgeted.
Priority 5:
Other spent fuel storage and transportation efforts, which are not
budgeted and no effort or resources are scheduled or planned.
Scheduling Guidelines
In addition to the prioritization system, NRC Project Managers estimate schedules for licensing
actions under both Parts 71 and 72 based on the type and complexity of the action. Scheduling
guidelines set a general schedule for new casework. Scheduling guidelines are listed below.
Transportation certificate renewals, or transportation or storage amendments that do not
require detailed technical review are typically scheduled for a 2 to 5 month completion
time.
Storage or transportation amendments that need technical review by one to three
disciplines, for example, a structural, thermal, containment, materials, or criticality
reviewer, are typically scheduled for approximately a 7 month completion time.
Non-spent fuel transportation package designs, or complex amendments for storage or
transportation that need technical review by more than three technical disciplines are
typically scheduled for approximately a 9 month completion time.
Page 4 of 5
New spent fuel transportation package designs, and new storage casework or storage
amendments that need technical review by more than five technical disciplines, are
typically scheduled for approximately an 11 month completion time.
With respect to the level of effort, there is a wide variation based on the nature of the request
and the quality of the application. Transportation certificate renewals and simple amendments
typically take tens of hours to process, whereas the most complex reviews typically take 1 to 2
staff years.
Timeliness Goals
SFPOs goal is completing 100 percent of storage and transport licensing actions in 2 years or
less. To this end, separate timeliness goals have been set for subsets of the overall workload.
A timeliness goal for Part 71 is completion of 80% of all cases in less than 7.7 months; and
80% of all Part 72 cases in less than 13.3 months. These goals include actions of all types and
complexities. Less complex actions are generally completed in a shorter amount of time and
the timeliness goals are balanced by the more complex actions requiring longer time for
completion. The timeliness measure does not include the time interval when the licensee is
preparing a response to RAIs.
Ongoing SFPO Initiatives
To extend the effort of continuous improvement, SFPO has set a separate goal of improving
timeliness efficiency by 5% per year for each year after the 2005 baseline of 8 months (Part 71)
and 14 months (Part 72). SFPO has set this goal for continuous improvement to achieve
overall improved efficiencies in the licensing and certification process.
Another initiative that resulted from the February 2005 conference is the formation of an
industry working group dealing with spent fuel storage and transportation issues. NRC has
appointed a staff member as point of contact. The staff person will interact with the working
group as it identifies issues concerning Part 71 and 72 stakeholders.
PAPERWORK REDUCTION ACT STATEMENT
This regulatory information summary contains voluntary information collection that is subject to
the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections
were approved by the Office of Management and Budget, approval number 3150-0011, which
expires February 28, 2007.
The burden to the public for these voluntary information collections is estimated to average
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per response, including the time for reviewing instructions, searching existing data
sources, gathering and maintaining the data needed, and completing and reviewing the
information collection. Send comments regarding this burden estimate or any other aspect of
these information collections, including suggestions for reducing the burden, to the Records
and FOIA/Privacy Services Branch (T-5 F53), U.S. Nuclear Regulatory Commission,
Washington, DC 20555-0001, or by Internet electronic mail to INFOCOLLECTS@NRC.GOV;
and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202,
(3150-0011), Office of Management and Budget, Washington, DC 20503.
Page 5 of 5
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid OMB control number. Licensees and Certificate Holders will not be held to
schedules provided in response to this communication nor penalized if actions are submitted
later than estimated, or altogether eliminated.
CONTACT
Please direct any questions about this matter to the technical contact listed below.
/RA/
E. William Brach, Director
Spent Fuel Project Office
Office of Nuclear Material Safety
and Safeguards
Technical Contact: Jill Caverly, NMSS
(301) 415-6699
Email: jsc1@nrc.gov
Note: NRC generic communications may be found on the NRC public website,
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Page 5 of 5
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid OMB control number. Licensees and Certificate Holders will not be held to
schedules provided in response to this communication nor penalized if actions are submitted
later than estimated, or altogether eliminated.
CONTACT
Please direct any questions about this matter to the technical contact listed below.
/RA/
E. William Brach, Director
Spent Fuel Project Office
Office of Nuclear Material Safety
and Safeguards
Technical Contact: Jill Caverly, NMSS
(301) 415-6699
Email: jsc1@nrc.gov
Note: NRC generic communications may be found on the NRC public website,
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Distribution:
NMSS r/f
SBaggett
NJensen, OGC
EEaston
OFC
SFPO
SFPO
Tech Ed
SFPO
IMNS
IS/IRSD
SFPO
NAME
JCaverly
RLewis
EKraus
WRuland
FCardile
BStMary
EWBrach
DATE
08/17/05
09/ 7 /05
fax 8/8/05
09/26 /05
09/27 /05
09/28 /05
11/8/05
OFFICIAL RECORD COPY