ML19199A477
| ML19199A477 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/2019 |
| From: | James Downs Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| To: | |
| Marcano J | |
| Shared Package | |
| ML19199A476 | List: |
| References | |
| Download: ML19199A477 (5) | |
Text
Building a Smarter Fuel Cycle Licensing Program -
Comment Resolution Table
- Comment NRC Response Resolution/Path Forward/Action Item A recommendation will be made to Solicit input from each licensee regarding incorporate the establishment of milestones that should be established, The comment primarily aligns with the reliability licensee coordinated milestones 1 these may vary based on the complexity of principle from the NRCs Principles of Good into publicly available procedures the licensing action and estimated Regulation.
governing the fuel cycle licensing timeline.
program.
A recommendation will be made to continue sharing standard metrics The comment primarily aligns with the clarity principle Consider sharing standard metrics from and hours estimates with from the NRCs Principles of Good Regulation. This 2 Web Based Licensing along with the hours licensees. Future revisions of the process was recently implemented by FCSE project estimated in the acceptance letter. procedures governing the fuel managers and should continue.
cycle licensing program should ensure this practice is maintained.
The comment primarily aligns with the openness Consider updating the status of the review principle from the NRCs Principles of Good During the public meeting on as it progresses. Licensees are planning Regulation. Clarity is needed on when these updates August 8, 2019, discuss the 3 capital projects, so the status of the should occur and what method is appropriate (e.g.,
additional information needed to reviews will allow them to keep their telephone, email, or letter). Would it be sufficient to clarify this comment.
management informed. update the status at each of the licensee coordinated milestones discussed in Comment #1?
Consider a meeting with the applicant The comment primarily aligns with the efficiency during the acceptance review to better principle from the NRCs Principles of Good understand the unique aspects of the Regulation. However, this process (either during pre- During the public meeting on licensees request and provide for early application or the acceptance phase) could increase August 8, 2019, discuss the 4
identification of complexities or unique the initial cost to the licensee, but efficiencies may be additional information needed to aspects of the review and provide for early realized over the course of the review. Should this clarify this comment.
identification of complexities or unique meeting become a standard practice or only utilized if aspects of the review. requested by either the applicant or the NRC?
- Comment NRC Response Resolution/Path Forward/Action Item A recommendation will be made to continue evaluating each review for potential time savings. Future The comment primarily aligns with the efficiency revisions of the procedures Consider if multiple steps of the licensing principle from the NRCs Principles of Good governing the fuel cycle licensing 5 process can be combined for simple Regulation. This process was recently implemented by program should ensure that reviews.
FCSE project managers and should continue. project managers continue to be aware of this option and that metrics do not obstruct this efficiency.
The comment primarily aligns with the openness Clarify when NRCs Office of General principle from the NRCs Principles of Good Counsel (OGC) is involved with the review 6 Regulation. A representative from OGC will discuss To be determined of a licensing action and share milestones this comment during the public meeting on August 8, for OGC reviews.
2019.
A recommendation will be made to continue optimizing the timing of The comment primarily aligns with the efficiency Site visits are valuable, and the timing of site visits and to leverage virtual principle from the NRCs Principles of Good the visits should optimize the effort of audits/visits using available 7 Regulation. This process has been implemented by NRCs review and with respect to requests technology. Future revisions of the some FCSE project managers but should be more for additional information (RAIs). procedures governing the fuel uniformly applied.
cycle licensing program should ensure this practice is maintained.
A recommendation will be made to develop a template for RAIs to The comment primarily aligns with the clarity principle further ensure that regulatory from the NRCs Principles of Good Regulation. The bases for RAIs are consistently RAIs should have clear regulatory bases, 8 importance of providing regulatory bases for RAIs has provided. The recommendation perhaps a uniform template is needed.
been communicated to the staff but should be more will suggest inclusion of the uniformly applied. template in future revisions of the procedures governing the fuel cycle licensing program.
- Comment NRC Response Resolution/Path Forward/Action Item A recommendation will be made for NRC project managers to The comment primarily aligns with the efficiency arrange discussions of draft RAIs principle from the NRCs Principles of Good with the licensee at an established Consider if RAIs should be discussed with Regulation. This process has been implemented by milestone and for larger 9 the licensee in draft form to confirm some FCSE project managers but should be more applications to consider scheduling understanding of the request. uniformly applied. This is also related to Comment # 7 a site visit (per Comment # 7) at in that a site visit could be coordinated at the draft RAI this stage. Future revisions of the stage for larger applications. procedures governing the fuel cycle licensing program should ensure this practice is maintained.
Consider when the clock should start on 10 To be determined To be determined NRCs metrics surrounding RAIs.
Consider if the requirement to notice a 11 public meeting 10-days in advance limits To be determined To be determined the benefit of discussing draft RAIs.
The comment primarily aligns with the efficiency principle from the NRCs Principles of Good Regulation. This goal is already captured in review A recommendation will be made to guidance and is routinely communicated to FCSE staff continue emphasizing the tools and the messaging should continue. Current guidance that are available to facilitate Limit the quantity and number of rounds of states that RAIs should not be submitted if the achieving the goal of a single round 12 RAIs. information is available elsewhere or can be inferred of RAIs. Future revisions of the from other information. Clarifying calls should also procedures governing the fuel address or confirm such information. Current review cycle licensing program should guidance also indicates that RAIs should be developed ensure this practice is maintained.
from gaps in a draft SER. Addressing Comments # 7 and 9 would also support achieving this goal.
- Comment NRC Response Resolution/Path Forward/Action Item The comment primarily aligns with the reliability Development of draft inputs early principle from the NRCs Principles of Good in reviews will continue to be Regulation. The importance of providing for emphasized. A recommendation continuity of reviews has been communicated to the will be made for NRC project staff and guidance on this topic has recently been The continuity of licensing process quality managers to request draft incorporated into the FCSE Licensing Review 13 and efficiency must be maintained despite deliverables at specific interim Handbook. The staff agrees that continuity should be staff and/or management turnover. milestones to better ensure staff more uniformly achieved. In addition, current effort is captured. Future revisions guidance recommends development of draft SER of the procedures governing the inputs early in the review process which ensures more fuel cycle licensing program should efficient development of RAIs (supporting Comment #s ensure this practice is maintained.
7, 9, and 12) and provides more effective turnover.
The comment primarily aligns with the efficiency Seeking clarity on the following License renewals should focus only on principle from the NRCs Principles of Good questions: What defines safety 14 safety significant areas of change. Lessons Regulation. The Working Group will seek clarity on significant? Are there examples of can be learned from recent renewals. this comment during the public meeting on August 8, focusing on non-safety significant 2019. areas? Is only the right word?
The comment primarily aligns with the efficiency principle from the NRCs Principles of Good Consider incorporating concepts from the Regulation. A key concept, that is directly During the public meeting on recently issued NRR LIC-206, Integrated implementable by FCSE for larger team reviews, is the August 8, 2019, discuss concepts 15 Risk-Informed Decision-Making for use of integrated teams throughout the review and from LIC-206 and how they could Licensing Reviews, into the fuel cycle the use of relative risk insights in planning and be applied to the fuel cycle licensing program. conducting the review. LIC-206 is available at: licensing program.
https://www.nrc.gov/docs/ML1903/ML19031C861.pdf
- Comment NRC Response Resolution/Path Forward/Action Item Consider developing an instruction for the Fuel Facility Business Line on license amendments like NRRs LIC-101, License A recommendation will be made to The comment primarily aligns with the openness Amendment Review Procedures. This develop publicly available principle from the NRCs Principles of Good would take the relevant information out of procedures governing the fuel 16 Regulation. The NRC staff views this as the preferred the internal desk guide (FCSE Licensing cycle licensing program and have path forward and would be more useful instead of Review Handbook) and place it into a stakeholder feedback incorporated redacting the FCSE License Review Handbook.
publicly available document that is into the development process.
applicable to all NRC staff performing work under the Fuel Facility Business Line.
Develop a tool to track licensing actions in accordance with the new metrics 17 To be determined To be determined associated with the Nuclear Energy Innovation and Modernization Act.
A recommendation will be made to Ensure internal NRC work requests identify continue developing and utilizing the appropriate technical staff and that The comment primarily aligns with the reliability accurate internal work requests.
principle from the NRCs Principles of Good 18 resource estimates are consistent with the Future revisions of the procedures Regulation. This process was recently implemented by projected scope and focus of each review governing the fuel cycle licensing FCSE project managers and should continue.
area. program should ensure this practice is maintained.
Training on the licensing program, that highlights recent changes and longstanding 19 fundamentals, should be provided for fuel To be determined To be determined cycle project managers and technical reviewers A standard review plan is needed for 20 reviews of greater than critical mass To be determined To be determined licensees.