ML17179B058
| ML17179B058 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 08/27/1993 |
| From: | Siegal B Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9309010286 | |
| Download: ML17179B058 (21) | |
Text
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August 27, 1993 Docket Nos. STN 50-~. STN 50-457,
~
STN 50-454~~ 50-455, 50-297, 50-249, 50-373, 50-374, 50-254, 50-265, an& 50-295, 50-304 LICENSEE:
Commonwealth Edison Company FACILITIES:
Braidwood, Units 1 and 2 Byron, Units 1 and 2 Dresden, Units 2 and 3 LaSalle, Units 1 and 2 Quad Cities, Units 1 and 2 Zion, Units 1 and 2
SUBJECT:
SUMMARY
OF MEETING ON REGULATORY BURDEN REDUCTION INITIATIVES A meeting was held between the NRC staff and Commonwealth Edison Company (CECo) at One White Flint North in Rockville, Maryland, on August 18, 1993.
The purpose of the meeting was for CECo to present the preliminary results of its Regulatory Burden Reduction Initiatives (RBRI).
The staffs efforts related to Cost Beneficial Licensing Actions (CBLA) was also presented. is a list of meeting attendees. contains a copy of the CECo handout which presents the details of their RBRI.
Mr. Steve Stimac (CECo) described the process overview and inputs, screening criteria and prioritization, process outputs, and examples of identified issues that are candidates for reduction of burden.
A general discussion of the process CECo will utilize in implementing this initiative was also presented.
Following the CECo presentation Mr. Tad Marsh, NRC Group Leader of CBLA Task Force, described the purpose of the task force, summarized the staff efforts to date related to cost-reduction, and presented pot~ntial solutions/enhancements that the Task Force will be proposing to NRC management to address this issue. contains a copy of the staffs handout related to CBLA.
During the meeting there was a beneficial exchange of information between the staff and the licensee. This exchange should have given CECo a better under-standing of the type and quality of the initiatives that, if submitted, would be reviewed by the staff - considering its limited resources.
original signed by Byron L. Siegel, Project Manager Project Directorate III-2
~g~9010286-930827 p
ADOCK 05000237 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation
Enclosures:
. PDR As stated OFC D:PDIII-2 NAME JOVER~
DATE d '(j 93_
93 93 COPY YES/NO YES/NO I I 1
,/
DISTRIBUTION Docket File NRC & Local PDRs POI 11-2 r/f TMurley/FMiraglia JPartlow JRoe JZwol inski JDyer CMoore BSiegel RAssa JHickman CPatel CShiraki JStang JKennedy OGC EJordan BHughes, CBLA JDonohew, CBLA TMarsh, CBLA ACRS(lO)
AGodyJr, EDO BClayton, Rill
I
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DISTRIBUTION Docket File NRC & Local PDRs PDIII-2 r/f TMurley/FMiraglia JPartlow JRoe JZwol inski JDyer CMoore BSiegel RAssa JHickman CPatel CShiraki JStang JKennedy OGC EJordan BHughes, CBLA JDonohew, CBLA TMarsh, CBLA ACRS(lO)
AGodyJr, EDO BClayton, RIII
l OFC NAME DATE COPY Docket Nos. STN 50-4ji, STN 50-457, STN 50-454~N 50-455, 50-237, 50-249, 50-373, 50-374, 50-254, 50-265, and 50-295, 50-304 J\\.lgust 27, 1993 LICENSEE:
Commonwealth Edison Company FACILITIES:
Braidwood, Units 1 and 2 Byron, Units 1 and 2 Dresden, Units 2 and 3 LaSalle, Units 1 and 2 Quad Cities, Units 1 and 2 Zion, Units 1 and 2
SUBJECT:
SUMMARY
OF MEETING ON REGULATORY BURDEN REDUCTION INITIATIVES A meeting was held between the NRC staff and Commonwealth Edison Company (CECo}
at One White Flint North in Rockville, Maryland, on August 18, 1993.
The purpose of the meeting was for CECo to present the preliminary results of its Regulatory Burden Reduction Initiatives (RBRI}.
The staffs efforts related to Cost Beneficial Licensing Actions (CBLA} was also presented. Enclosure 1 is a list of meeting attendees. contains a copy of the CECo handout which presents the details of their RBRI.
Mr. Steve Stimac (CECo} described the process overview and inputs, screening criteria and prioritization, process outputs, and examples of identified issues that are candidates for reduction of burden.
A general discussion of the process CECo will utilize in implementing this initiative was also presented.
Following the CECo presentation Mr. Tad Marsh, NRC Group Leader of CBLA Task Force, described the purpose of the task force, summarized the staff efforts to date related to cost-reduction, and presented potential solutions/enhancements that the Task Force will be proposing to NRC management to address this issue. contains a copy of the staffs handout related to CBLA.
During the meeting there was a beneficial exchange of information between the staff and the licensee. This exchange should have given CECo a better under-standing of the type and quality of the initiatives that, if submitted, would be reviewed by the staff - considering its limited resources.
Enclosures:
As stated cc w/enclosures:
See next a e
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-~~ 93
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original signed by Byron L. Siegel, Project Manager Project Directorate 111-2 Division of Reactor Projects 111/IV/V Office of Nuclear Reactor Regulation D: POii 1-2 JOVER~
93 93 YES/~oJ YES/NO YES/NO
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~l UNITED STATES NUCLEAR REGULATORY COMMISSION
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,f WASHINGTON. D.C. 20555-0001
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Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-237, 50-249, 50-373, 50-374, 50-254, 50-265, and 50-295, 50-304 August 27, 1993 LICENSEE:
Commonwealth Edison Company FACILITIES:
Braidwood, Units 1 and 2 Byron, Units 1 and 2 Dresden, Units 2 and 3 LaSalle, Units 1 and 2 Quad Cities, Units 1 and 2 Zion, Units 1 and 2
SUBJECT:
SUMMARY
OF MEETING ON REGULATORY BURDEN REDUCTION INITIATIVES A meeting was held between the NRC staff and Commonwealth Edison Company (CECo}
at One White Flint North in Rockville, Maryland, on August 18, 1993.
The purpose of the meeting was for CECo to present the preliminary results of its Regulatory Burden Reduction Initiatives (RBRI}.
The staffs efforts related to Cost Beneficial Licensing Actions (CBLA} was also presented. is a list of meeting attendees. contains a copy of the CECo handout which presents the details of their RBRI.
Mr. Steve Stimac (CECo} described the process overview and inputs, screening criteria and prioritization, process outputs, and examples of identified issues that are candidates for reduction of burden.
A general discussion of the process CECo will utilize in implementing this initiative was also presented.
Following the CECo presentation Mr. Tad Marsh, NRC Group Leader of CBLA Task Force, described the purpose of the task force, summarized the staff efforts to date related to cost-reduction, and presented potential solutions/enhancements that the Task Force will be proposing to NRC management to address this issue. contains a copy of the staffs handout related to CBLA.
During the meeting there was a beneficial exchange of information between the staff and the licensee. This exchange should have given CECo a better under-standing of the type and quality of the initiatives that, if submitted, would be reviewed by the staff - considering its l~e~~ources.
/luMA Si~~
Manager
~~~~~*Directorate III-2
Enclosures:
As stated cc w/enclosures:
See next page Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation
e
- commonwealth Edison Company cc:
Mr. William P. Poirier Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355, Bay 236 West Pittsburgh, Pennsylvania 15230 Joseph Gallo, Esquire Hopkins and Sutter 888 16th Street, N.W., Suite 700 Washington, D.C.
20006 Regional Administrator U. S. NRC, Region III 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex, Illinois 60935 Mr. Edward R. Crass Nuclear Safeguards and Licensing Division Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1, Box 79 Braceville, Illinois 60407 Mr. Ron Stephens, Director Illinois Emergency Services and Disaster Agency 110 East Adams Street Springfield, Illinois 62706 Robert Neumann Office of Public Counsel State of Illinois Center 100 W. Randolph, Suite 11-300 Chicago, Illinois 60601 EIS Review Coordinator Environmental Protection Agency Region V 230 S. Dearborn Street Chicago, Illinois 60604 Attorney General 500 South 2nd Street Springfield, Illinois 62701 U. S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 North German Church Road Byron, Illinois 61010-9750 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 Douglass Cassel, Esquire 17 East Monroe Street, Suite 212 Chicago, Illinois 60603 U. S. Nuclear Regulatory Commission Resident Inspectors Office 105 Shiloh Blvd.
Zion, Illinois 60099 George L. Edgar Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, D.C.
20036 Commonwealth Edison Company Byron Station Manager 4450 North German Church Road Byron, Illinois 61010 Illinois Dept. of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Commonwealth Edison Company Braidwood Station Manager Rt. 1, Box 84 Braceville, Illinois 60407 Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434 Mayor of Zion Zion, Illinois 60099
Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. G. Spedl Plant Manager Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 U. S. Nuclear Regulatory Commission Resident Inspectors Office Dresden Station 6500 North Dresden Road Morris, Illinois 60450-9766 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 West Randolph Street Suite 12 Chicago, Illinois 60601 Resident Inspector/LaSalle, NPS U. S. Nuclear Regulatory Commission Rural Route No. 1 P. 0. Box 224 Marseilles, Illinois 61341 Chairman LaSalle County Board of Supervisors LaSalle County Courthouse Ottawa, Illinois 61350 Dr. Cecil Lue-Hing Director of Research and Development Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 West Randolph Street Chicago, Illinois 60601 Mr. G. Diederich LaSalle Station Manager LaSalle County Station Rural Route 1 P. 0. Box 220 Marseilles, Illinois 61341 Chairman Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. 0. Box 4350 Davenport, Iowa 52808 Mr. Richard Bax Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 Resident Inspector U. S. Nuclear Regulatory Commission 22712 206th Avenue North Cordova, Illinois 61242 Chairman Rock Island County Board
.of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.
Rock Island, Illinois 61201 Mr. D. L. Farrar Manager, Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West Ill, Suite 500 1400 OPUS Place Downers Grove, Illinois 60515
ENCLOSURE 1 LIST OF MEETING ATTENDEES DISCUSSION OF REDUCTION IN REGULATORY BURDEN INITIATIVES AUGUST 18. 1993 Brian Hughes Jack Donohew Tad Marsh Byron Siegel John Zwolinski James Dyer Dennis Farrar Steve Stimac AFFILIATION NRC, CBLA NRC, CBLA NRC, Group Leader, CBLA NRC, Project Manager NRC, Asst. Director for Region III Reactors, DRPW NRC, Project Director, PDIII-2 CECo, Manager, Nuclear Regulatory Services CECo, Special Asst. to Manager, Nuclear Regulatory Services
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ENCLOSURE 2 PRELIMINARY INFORMATION COMMONWEAL TH EDISON COMPANY NUCLEAR OPERATIONS DIVISION REGULA TORY BURDEN REDUCTION IN/TIA TIVES PROCESS OVERVIEW PROCESS INPUTS SCREENING CRITERIA AND PRIORITIZATION PROCESS OUTPUTS EXAMPLES OF IDENTIFIED CANDIDATES GENERAL DISCUSSION TOPICS
PROCESS OVERVIEW IDENTIFY, PRIORITIZE AND IMPLEMENT CHANGES TO REGULATORY REQUIREMENTS AND/OR COMMITMENTS TO RECAPTURE RESOURCES CURRENTLY APPLIED TO ACTIVITIES WHICH HAVE MARGINAL IMPACT ON SAFETY PARTICULAR ATTENTION PAID TO:
REVIEW OF CANDIDATES FOR CECo ABILITY TO MODIFY WITHOUT NEED FOR NRC ACTION SENIOR MANAGEMENT CONCURRENCE WITH PRIORITY LIST FOR THOSE REQUIRING NRC ACTION CECo PROCESS HAS BEEN DEVELOPED TO IDENTIFY AND ACT ON OPPORTUNITIES IN A TIMELY AND EFFICIENT MANNER WHILE MAINTAINING STATION FOCUS ON CORE MISSION FOCUS NOT ONLY ON HIGH COST ITEMS, BUT ALSO ON LOW AND MODERATE COST ITEMS WITH HIGH ATTAINABILITY/LOW RESOURCE APPLICATIONS
PROCESS INPUTS CANDIDATE ISSUES FOR REGULATORY BURDEN REDUCTION ARE BEING IDENTIFIED FROM VARIOUS SOURCES EXTERNALLY DEVELOPED CANDIDATES INDUSTRY PEER INITIATIVES NUMARC INITIATIVE NRC REGULATORY REVIEW GROUP ACTIVITIES REVIEWED AS THEY ARE REPORTED FOCUS OF REVIEW ON SPECIFIC/SPECIAL IMPACT ON CECo INTERNALLY DEVELOPED CANDIDATES ALL LEVELS OF PERSONNEL INVOLVED IN CANDIDATE IDENTIFICATION FUNCTIONAL AREA MANAGERS FOCUS ON AREA SPECIFIC BURDENS WORKER/FIRST-LINE SUPERVISOR INPUT ACTIVELY SOUGHT/DEVELOPED PLANT INTERVIEWS CONDUCTED IN STRUCTURED ONE-ON-ONE FORMAT TO ENCOURAGE BROAD REVIEWS INTERVIEWS COMPLETED AT FOUR SITES..* QUAD CITIES TO BE DEFERRED WORKSHOP PLANNED TO PRIORITIZE CANDIDATES EXPECT MANY INTERNALLY DEVELOPED CANDIDATES TO BE ABLE TO BE RESOLVED WITHOUT NRC ACTION
SCREENING CRITERIA AND PRIORITIZATION SCREENING CRITERIA SAFETY REDUCTION MINIMAL ACCURATELY DETERMINED BY EXPERIENCED REVIEWERS SUBSTANTIAL COST SAVINGS AT LEAST $100K PER YEAR ACCURATELY EVALUATED ALTERNATIVES READILY JUSTIFIABLE CANDIDATE TRANSPARENTLY ACCEPTABLE BASED ON TECHNICALLY SOUND ALTERNATIVES PRIORITIZATION PHILOSOPHY REVIEW ALL CANDIDATES CAREFULLY TO MAXIMIZE USE OF 50.59 AND MINIMIZE APPLICATION OF NRC RESOURCES CANDIDATES REQUIRING NRC ACTION MUST PASS SCREENING CRITERIA TO WARRANT HIGHEST PRIORITY SENIOR MANAGEMENT WILL REVIEW/APPROVE PRIORITIZATION FOR NRC SUBMITTAL
- PROCESS OUTPUTS IDENTIFICATION AND EVALUATION OF CANDIDATES ACTIVELY ONGOING FINAL LIST OF HIGHEST PRIORITY ITEMS REQUIRING NRC ACTION AWAITING CONCLUSION OF ONGOING EVALUATIONS PRELIMINARY PRIORITIZATION SUGGESTS THE FOLLOWING ISSUES DESERVE HIGH PRIORITY CECo SPECIFIC ISSUES SECURITY PLAN CHANGES ALTERNATIVE APPROACH FOR IPEEE USE OF ALTERNATIVES TO FIREWATCH BWR ILRT FREQUENCY EXERCISE FREQUENCY FOR MAZON EOF COMMERCIAL GRADE PROCUREMENT PROCESS ISSUES FRAMEWORK FOR CHANGES TO DISCRETIONARY COMMITMENTS INDUSTRY ISSUES MOV PROGRAM APPENDIX J RULE CHANGES (NUMARC)
COMMERCIAL GRADE PROCUREMENT (NUMARC)
FREQUENCY OF EP EXERCISES
EXAMPLES OF IDENTIFIED CANDIDA TES DESCRIPTION MISCELLANEOUS CHANGES TO SECURITY PLANS ALLOW USE OF ALTERNATIVES TO FIREWATCH PROPOSED MODIFICATIONS TO 10CFR50, APPENDIX J LEAKRATE TESTING REQUIREMENTS PROPOSED CHANGES TO MOV PROGRAM TO PRIORITIZE DIFFERENTIAL PRESSURE TESTS BASED ON RISK PERFORM IPEEE USING ALTERNATIVE APPROACH CHANGE EMERGENCY PLANNING EXERCISE FREQUENCY FROM ANNUAL TO BIENNIAL EXTEND THE FREQUENCY OF FIRE DETECTOR SURVEILLANCES TECH SPEC CHANGE TO REDUCE SURVEILLANCE FREQUENCIES ELIMINATE THE EQUIPMENT STATUS DISPLAY SYSTEM ELIMINATE MANDATORY TWO-YEAR PROCEDURE REVIEWS RE-EVALUATE EQ DRIVEN PARTS REPLACEMENTS ELIMINATE UNNECESSARY REPLACEMENT OF EMERGENCY LIGHTING BATTERIES OPTIMIZE COMMITMENTS RELATED TO GL 89-13 SERVICE WATER PROGRAMS ESTIMATED SAYINGS
$1. 2M/YR/SITE
$1M/YR/SITE
$SM/YR (CECO-TOTAL)
$17M (CECo-TOTAL)
$200K/EXERCISE (VEPCO ESTIMATE)
$300K/YR/SITE
$100K/YR/SITE
$200K/UNIT (B/B ONLY)
$SOK/YR/SITE
$50K/YR/SITE
$26K/YR/SITE TBD
GENERAL DISCUSSION TOPICS PRIORITIZATION OF WORK CECo RECOGNIZES STAFF RESOURCE LIMITATIONS FINAL SELECTION OF PRIORITIES WILL BE AT SENIOR LEVEL ADDITIONAL CONSIDERATION REQUIRED TO DEVELOP A FINAL PRIORITIZED LIST OF CANDIDATE ISSUES REQUIRING NRC ACTION IMPLEMENTATION OF CHANGES 10CFR50.59 WILL BE USED EXTENSIVELY TREATMENT OF DISCRETIONARY COMMITMENTS COMMUNICATION TOOLS RESOLUTION OF TECHNICAL ISSUES RESOLVE ISSUES WITH TECHNICAL BRANCH PRIOR TO SUBMITTAL IPEEE, MOV AND SECURITY MEETINGS ARE EXAMPLES "LEAD PLANT" INITIATIVES CECo WILL CONTINUE TO MONITOR INITIATIVES OF INDUSTRY PEERS, NUMARC AND REGULATORY REVIEW GROUP HOW TO FOLLOW UP ON SUCCESSES FROM THESE AREAS
Cost Beneficial Licensing Actions.. -
BACKGROUND
- Continued rise in Industry O&M costs
- Licensees have expressed concern that some regulatory commitments or requirements provide little or no safety,
payoff, but require significant resource expenditure.
- Amendment requests to provide relief would normally receive low priority (Priority 3 or 4), and may take a LONG TIME to process.
- Pilot program (Task Force) to give special consideration to amendment or exemption requests with high cost but low safety benefits.
- Focus on VEPCO, FPC and NEU programs
- Significant discussion I description of the Task Force at the R.l.C. (Chm. Selin, Dr. Murley, and F. Gillespie)
L. B. Marsh, Project Director, NRC
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Cost Beneficial Licensing Actions.-
- PREMISES
- Fixed NRC Resources for addressing CBLAs
- Relaxations/ Reliefs granted by NRC will result in more efficient resource expenditure by industry, and SAFER nuclear plants.
- CBLAs should not involve any significant SAFETY issue
- LOW cost or HIGH SAFETY items shouldn't be handled via CBLA
- Solution will involve PROCESS improvements by both NRC and INDUSTRY.
- This is a WINDOW of OPPORTUNITY for licensees and may not last forever.
- Cost savings considerations will be considered for work PRIORITIZATION purposes, not as the BASES for the ultimate disposition on the issue.
- Embarking on a CBLA PROGRAM should be carefully considered within the overall NRC/Licensee agenda L. B. Marsh, Project Director, NRC 7/93
Cost Beneficial Licensing Actions--
QUESTIONS FOR NRC and INDUSTRY
- Define a CBLA?
- How many CBLAs in NRC system now?
- Is there a problem (Are we late? Is there a large number in the queue? Are we working lower cost items faster than higher cost items?)
- How do licensees determine if an item is a CBLA?
- What's their criteria? Compatable with NRC's system?
- Are licensees NOT SUBMITTING CBLAs? Why?
- Are the CBLAs in house now due to OVERCOMMITMENTS?
- Can licensees change these OVERCOMMITMENTS themselves?
- Will there be a flood of NEW SUBMITTALS?
- How complicated will they be?
- Could the "Integrated Living Schedule" solve the CBLA issue?
- Are licensees CLEARLY identifying CBLAs to the NRC?
L. 8. Marsh, Project Director, NRC 7/93
Cost Beneficial Licensing Actions--
OBSERVATIONS
- Many task forces within NRC and industry. Need for coordination / communication to avoid problems.
- VEPCO program began large - now FOCUS LIST
- VEPCO items being worked well by staff. On schedule.
- Initial VEPCO items not difficult I controversial.
- FPC items aren't really a CBLA program, per se, yet
- ENTERGY program - new, significant, major $ implications
- When a licensee can change a commitment w/o NRC approval varies among licensees and issues
- Not clear Integrated Living Schedule would help CBLAs get processed. Licensees are reluctant.
- Licensees sometimes request UNNECESSARY or CONTINGENCY type 9 NRC reviews L. B. Marsh, Project Director, NRC 7/93
Actions*.-
NRC TASK FORCES I GROUPS (related to CBLAs)
- Regulatory Review Group (Gillespie - NRR)
- Marginal to Safety (Dey - RES)
- Licensee Commitments I CLB (Leeds - NRR)
- Tech Spec Improvement Program (Grimes - NRR)
- NRR Priority I Ranking system (Slosson - NRR)
- Amendment Screening Panel (Peterson - NRR)
- Computer Support Development (Wiggington - NRR/IRM)
REGULATORY REVIEW GROUP
- Draft report issued 5/28
- Comment period ends 7 /28 L. 8. Marsh, Project Director, NRC 7/93
Cost Beneficial Licensing Actions*,"
1 POTENTIAL SOLUTIONS I ENHANCEMENTS
- Modify NRA Priority System to include costs - sliding scale
- Formally PRIORITIZE all jobs being sent to Tech Staff
- Industry perform generic assessments / submittals
- Licensees NUMERICALLY PRIORITIZE all incoming work
- Utilize "Integrated Living Schedule"
- Look for GENERIC RELIEFS that can be undertaken by NRC
- NRC articulate characteristics of HIGH QUALITY submittals
- Enhance current AMENDMENT SCREENING process
- Enhance electronic tracking / sorting of past SERs
- Clearly articulate what licensees can and can't do on their own w/o NRC review
- Better control (rejections) of licensee's request for UNNECESSARY or CONTINGENCY reviews
- Public list of CBLAs - update periodically
- Issue GUIDANCE to Licensees and Staff
- Licensees provide SUPPORT / PRODDING to submittals
- No trivial CBLAs L. 8. Marsh, Project Director, NRC 7/93*