ML20094D415

Decentralization of Operating Reactor Licensing Reviews.Nrr Pilot Program

ML20094D415
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Issue date:	07/31/1984
From:	Hannon J Office of Nuclear Reactor Regulation
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References
NUREG-1075, NUDOCS 8408080370
Download: ML20094D415 (26)

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NUREG-1075 Decentralization of Operating Reactor Licensing Reviews NRR Pilot Program U.S. Nuclear Regulatory Csmmission Offi e of Nuclear Reactor Regulation J. N. Hannon I

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NUREG-1075 Decentralization of Operating Reactor Licens,ing Reviews NRR Pilot Program Manuscript Completed: May 1984 Data Published: July 1984 J. N. Hannon 4

1 Divi:lon of Licensing Offire of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission W:shington, D.C. 20555

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j ABSTRACT

This' report, which has incorporated comments received from the Commission and ACRS, describes the program for decentralization of selected operating reactor licensing technical review activities. The 2 year pilot program will be re-viewed to verify that safety is enhanced as anticipated by the incorporation

- of prescribed management techniques and application of resources.

If the pro-gram fails to operate as designed, it will be terminated.

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7r CONTENTS i

P, age Abstracti..................................

iii r

Executive Summary..................................................

vii E

'I.

'Gdneral Description of Program................................

1 n

A.

Objectives...............................................

1

~'

'B.

Implementation Schedule..................................

2 C.

Evaluation Process.......................................

2

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II. iSelecting Licensing Reviews for Transfer to the Regions......

4 A.

List of Candidate Action Types...........................

4 B.'

Proposed Assignments.....................................

4 L

(.

1.

Transfer to Regions.................................

4 2.'

Retain in Headquarters..............................

5 C.

Summary..................................................

5

III.LSelection of Operating Reactors...............................

7 A'.

Methodology..............................................

7 1.

Regions.............................................

7 12.

NSSS Vendors........................................

7 x

B.

Plants Selected..........................................

7

.IV.

Implementation................................................

8 A.

General. Guidance.........................................

8

. 1.

Licensing Action Review Identification..............

8 2.

Regional Review Assignments.........................

8 3.

Scheduling Work Products............................

9 4.

Tracking Work Progress..............................

9

-5.

Coordination with Licensee..........................

9 L

6.

~ Settling Unstable Review Criteria...................

9 7.

Appeal Process...................

10 8.

Required Documentation..............................

10 B;

Execution................................................

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CONTENTS-(Continued) fage

- V..

Program Evaluation............................................

12 d.

.B.

. Qualitative Success Criteria.............................

12 Quantitative Success Criteria.....................

13 C.

Report...................................................

13

. Appendix:

List'C Analysis.........................................

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EXECUTIVE

SUMMARY

f1 Earlylin 1982' NRC. headquarters and regional offices developed planning assump-tions and began to identify regulatory activities that lent themselves to decen-J ~

tralization..Among those activities were technical licensing reviews for operat-ing reactors. Technical reviews for 260 operating reactor activities were transferred to the regions in 1982.

In 1983, 98 more such reviews were trans-

.ferred;to the: regions.

The regions are planning to conduct approximately 280 additional technical reviews during FY 1984.

They had completed approximately

280 technica1' reviews for operating reactor licensing actions by the end of FY;1983.-

EA 2 year pilot. program, limited to two operating power plants in each of three

. regions, will be implemented to (1) test the method of selecting licensing actions for technicalireview in the regions, (2) evaluate predicted improvements in' the effectiveness of licensing and inspection programs, and (3) verify that

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safety is enhanced (as anticipated) by incorporating prescribed management 1 techniques and applying regional resources to this technical review function.

-The' program will be modeled after the National Program Review being conducted by'thel0ffice of Nuclear Materials Safety and Safeguards (NMSS) for the decen-tralization of nuclear. materials licensing activities.

Quantitative and quali-itative criteria will be developed to measure the success of the regional review

effort for selected operating reactor licensing actions.

The method of selecting licensing action reviews to be sent to the regions is

- based on a~ screening evaluation designed to determine if the review could be t;

enhanced by unique plant-specific knowledge possessed by the regional staff, 1 or if the. region's proximity to the site would enhance safety where onsite physical inspections are preferred.

These factors are weighed with other

. considerations to produce a preferred resource assignment.

lBy. offering closer coordination between inspection and licensing activities,

" :as well as closer communication between the staff and the licensee on matters relating.to the review, selected regional review activities should produce more effective licensing and inspection programs.

It is also expected that

'the conduct of selected reactor licensing reviews by regional staff will

improve safety effectiveness for the agency, by enabling headquarters per-

.sonnel to focus on generic problems while the regions handle some of the more t

plant-specific issues.

The ACRS and Commission will review the results of the pilot program at the end of.2 years.

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. ! DECENTRALIZATION OF OPERATING REACTOR LICENSING REVIEWS:

NRR PILOT PROGRAM I. LGENERAL DESCRIPTION OF PROGRAM'

'The'0fficeio'f: Nuclear' Reactor Regulation (NRR) has examined various approaches i

for' decentralizing operating-reactor licensing activities to meet the goals of i

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the Commission's Policy Statement on Regionalization. A pilot approach involv-ing the performance of safety reviews by regional' staff rather than by head-

quarters' staff has been recommended.

This report describes the details of that Pilot program.

. A.

l0b.iectives

Theobjectiveof'theCommission'sdecentralizationeffortistoimprovethe

= quality of nuclear regulation and thus provide better service to the public and the industry.. The pilot program will transfer selected technical reviews that care.assocjated with specific license amendment actions to three regional offices; the head,uarters office will retain the licensing authority.

The technical re-l l views,?sQ ected will be associated with two plants in each of three regions, and

+

willl.,e. subject to evaluation under the pilot program.

The review activities

-included in the pilot program will be a subset of the present limited licensing review activities being conducted by all regions to assist in reducing the

-inventory of outstanding licensing actions.

Although the six nuclear stations that will' participate in the pilot program are

/ considered representative for purposes of evaluating the success of the regional

' effort, the program'will retain sufficient flexibility to permit reviewing addi-tional reactors.

Such expansion might be necessary if, for example, too few cactions;were processed on a pilot reactor to provide an adequate sample.

10btaining safety evaluation inputs from regional offices for selected operating licensing reviews-is expected to result in closer coordination between inspec-tion and licensing activities and to facilitate communication between the staff H

and the licensee on matters relating to these reviews, consequently, producing more effective licensing and inspection programs.

.The~ region can handle ~ safety reviews of-certain licensing actions more effec-tivley than headquarters can.

Plants selected for review in the pilot program l

are those sites the regional staff knows well or for which the proximity of the regional staff to the site enables a more effective safety review.

Regional personnel'can directly observe a plant's relevant physical configurations or can interact with the licensee's onsite staff in a more direct manner, giving prompter response.

Previous a gionalization of selected reactor licensing reviews increased inter-

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action between headquarters and regional personnel.

The improvement in communi-cations has, in some cases, resulted in joint licensing decisions and contrib-utes to the agency's effectiveness insolar as safety assurance is concerned.

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An example is the licensing review conducted for modifications to plant shield-ing, in accordance with TMI Action Plan Item II.B.2 (NUREG-0737).

Moving safety reviews of certain licensing actions to the regions should relieve some of the demands on the licensing staff at the home office.

Resources at headquarters may be more efficiently spent on timely resolution of more complex issues or generic matters such as ECCS analyses, pipe crack issues, or steam generator problems.

B.

Implementation Schedule The staff plans to begin the pilot program during the first quarter of FY 1984.

Once the general topic areas are approved for transfer to the regions, anJ the

-selected plants are confirmed, the licensing review process can be initiated by the project manager following the procedures set forth for implementation.

Review schedules will be established as items are transferred to the region for review. A mechanism will be established for revising the schedules when delays occur.

The flow chart for processing regional licensing action reviews is shown in Figure 1.

It should be noted that an item indicated for regional review dur-ing the initial screening by the project manager on the basis of the guidelines developed for the pilot program, may ultimately not get reviewed in the region.

This may happen for a number of reasons, including an unplanned diversion of technical resources, or scheduled revisions by the licensee.

Statistics on these issues will be factured into the post-implementation evaluation process.

Technical staffing in the regions will be allocated for the conduct of the pilot program as required.

C.

Evaluation Process The pilot program will be evaluated over a 2 year trial period to determine its effectiveness in meeting the stated objectives.

An independent evaluation will include recommendations to management about the future of the program.

If ex-pansion or continuation is justified, the regions will continue to review selected licensing activities for essentially all operating reactors, with the provision that special coordination between the regional licensing reviewers and Integrated Safety Assessment Program (ISAP) reviewers will be required for those plants undergoing ISAP review.

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A Evaluate licensing action reviews I Review criteria adequate 8 Assign licensing action reviews to

.J Return to Division.of Licensing regions

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Project manager modifies TAC C Project manager assigns TAC 1/ develop 1 L NFA develops-criteria list M Return to Division of Licensing D Division of Licensing / technical N Fegion conducts review division 0 Retain in headquarters E Project manager assembles correspondecca P TAC to Technical Division F AD forwards to region Q Prepere SER G Region evaluates schedule R Forward to Division-of Licensing H Technical resources adequate S Procass license amendment 1 Technical Assignment Control (TAC) Syston is used by NRR for resource account-1 ability and tracking.

Figure 1.

Flow chart for processing regicnal licensing action reviews 3

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1 II.

SELECTING LICENSING REVIEWS FOR TRANSFER TO THE REGIONS

To be' proposed for transfer to the regions, a licensing action review must meet one of two general-criteria:

(1) quality of review would be enhanced by unique regional knowledge of specific plants, or (2) quality of review would benefit

- greatly from.the regional staff / resident inspector's proximity to the site.

?These transferred technical reviews would thus be conducted by regional review-ers with the. expectation that more_ effective reviews would result.

The approach to the : selection of technical issues to be transferred is described below.

When one looks'at historical data it is possible to characterize into roughly 50 categories the kinds of_ licensing actions that take place.

Then, using ex-

per.ience gained over the past several months working with the regions on other

' licensing actions, and applying some widely held criteria as to the need for HQ review (e.g., gene ~ '3pplicability, significant safety hazard), it is possible

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to tentatively assi n about half of these issues to either the regions or HQ t

for review. +If an tem has been or should be assigned to a contractor, it will not be-transferred to the region. 'Such an item is typically considered to be of a complex; technical nature requiring special expertise and close coordina-Ltion by the headquarters staff.

For the other half, it is necessary to develop the selection criteria a little further in order to estimate where the most

~ fficient resource for the particular issue resides region or headquarters.

l eIf it.is~not possible to discriminate, the licensing review will remain in HQ.

-Appendix 1 analyzes selected issues, using a well-recognized decision aid l

'esthodology.to help with the discrimination process.

2.

A. : List of-Candidate Action Types E<

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Before' ref=pring to the appendix, tit is useful to examine the candidate actions

.that emerge to need this. discrimination tool. On Vable 1, List A shows the types of actions which seem suitable, without further analysis, for regional review.'

List B identifies those actions which clearly should be retained in M).... List C, then, identifies those remaining actions for which assignment is in doubt; thus the decision process is indicated.

8.-

Proposed Assignments A summary of proposed regional assignments by issue type is provided below.

t 1.-

Transfer to Regions i

s List'A(byInspectionJ (1).Aeninistrative TS changes (9) Reoroganization of plant management (2) Design verification (10) Training in place (3) 'In-service inspection (11) Quality assuraace topics (4) ~ Plant maintenance (12) Health physics topics (13) Operator licensing (topical issues)

(5). Plant operations-

.(14) Procedure reviews (6). Plant-specific security issues

-(7) Surveillance testing (15) Emergency preparedness (8). TS_ verification (16) Environmental TS l

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List C (by Prediction)

(1) Control room design *

(5) Radwaste treatment management

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(2) Control room habitability *

(6) Radioactive effluent control

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l4 (3) Fire protection *

(7) Structural hardware

• 9 (4) Instrumentation setpoint (8) In-service testing programs F.C.

modifications

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• Plant-specific features / issues.

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Retain in Headquarters IM

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The discrimination for the following issues was weak as shown in the appendix.

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. Therefore, these issues will be retained in HQ unless the attribute profile for A.V M

a particular plant can be shown to support regional review.

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(1) Spent fuel pool modifications s;

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(3) Radiation protection programs f'.

1 (4) Developmental training programs yf

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The' result is a list of 24 licensing issues that can be transferred to the

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regions with a high expectation that the review can be more effectively done by 7.T region-based personnel.

Licensing reviews on these issues being conducted in HQ will be transferred to the regions for the selected plants upon commencement

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of the pilot program, if in the judgment of the project manager, sufficient Ry review activity remains to make the transfer worth while.

Any new licensing iM

- action reviews identified during the demonstration period which fit the cri-

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• 7 teria will also be transferred.

Any multi plant actions (MPAs) that are

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6 transferred under this program will be individually analyzed and shown to be D?

appropriate.

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I Table 1 Candidate action types a

List C.

Decision Process

• Was Used List A.

Transfer to the Regions g

To Determine Assignment

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1.

Administrative TS changes 1.

Ct m al room design **

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Design verification 2.

Ce trol room habitability **

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In-service inspection 3.

Equipment operability.

.HQ 4.

Plant maintenance 4.

Exemption requests.

.HQ 5.

Plant operations 5.

Fire protectiont.

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Security issuest 6.

Fuel limit modifications **

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Surveillance testing 7.

Instrumentation setpoint 8.

TS verification modifications.

.R 9.

Reorganization of plant 8.

Meteorological data.

.HQ j~ p-management 9.

Offsite dose consequences.

.HQ lji;p" 10.

Training in place 10.

Process control procedures.

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Quality assurance topics 11.

Radwaste treatment 12.

Health physics topics management **

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Operator licensing 12.

Radioactive effluent control.

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(topical issues) 13.

Reloads (routine).

.HQ 14.

Procedure reviews 14.

Spent fuel pool expansions /

15.

Emergency preparedness modifications.

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Environmental TS 15.

Steam generator repair /

replacement.

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16.

Seismic qualification **

.HQ List B.

Retain in Headquarters 17.

Piping system designt

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18.

Equipment qualification.

.HQ E

19.

Structural hardwaret.

.R 1.

Accident analysis 20.

In-service testing programs.

.R 2.

Code review 21.

Radiation protection programs.

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ECCS analysis 22.

Improved maintenance programs..HQ 1

4.

Methodology reviews 23.

Upgraded olant management.

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5.

Thermal-hydraulic analysis 24.

Training programs to be

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6.

Topical report reviews developed.

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7.

Multi plant equipmeat design 25.

Other iscuc3 (not included F

reviews in List A or List B).

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PRA reviews 9.

Reviews of equipment important

• Described in appendix.

iF to safety

• • Plant-specific features.

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Complex core reloads h

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Exemptions from regulations NOTE:

HQ = headquarters; R = region; 12.

linreviewea safety questions TBD = to be determined.

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Hearing requests L

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Safeguards reviews 1

E-tPlant-specific issues E

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i III.

SELECTION OF OPERATING REACTORS A.

Methodology The pilot program will be composed of twc nuclear stations in each of three regions.

The plants have been selected to include a cross-section of NMSS vendors, as well as utilities, to provide an adequate demonstration of Ge concept.

1.

Regions Plants are selected from Regions I, III, and V.

2.

MSSS Vendors To select a proportionate share by vendor 2 GE, 2 W, 1 CE, and 1 B&W plants are selected.

B.

Plants Selected Applying the above considerations, the following plan *s will be included in the pilot program Rayton Plant NSSS Licensee I

Vermont Yankee 1 GE VY Nuclear Power Corp.

I Millstone 2 CE Northeast Nuclear Energy Co.

III Monticello GE Northern States Power Co.

III Kewaunee W

Wisconsin Public Service Corp.

V Trojan W

Portlant General Electric V

Rancho Seco B&W Sacramento Municipal Utility District i

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IV.

IMPLEMENTATION Now that the types,i licensing actions to be transferred have been identified and the demonstratioi, nlants have been selected, the following guidance is necessary for implementing the program:

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Identification of p' ant-specific. licensing action reviews to be transferred n;

(2) Assignment of licensing actica reviews to the region

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(3) Scheduling work products (deliverables) a ?". p 3

i (4) Tracking of work (TAC / RAM /0RLAS)

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(5) Coordination with licensee

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(6) Settling unstable review criteria 3

(7) Handling appeals j?..,

(8) Required documentation

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Q4 A.

General Guidance. i 1. 'icensing Actio.e Review Identification 47' ' k s.~. (j, The Technical Assignment Contro! (TAC) Form is used to enter all new, non-casework assignments which do not have permanent tracking nunbers into the g',1 Regulatory Activities Manpower System (RAMS). g'? [ N; The project manager for each plant selechd will be asked to identify the cur-rent licensing actions that fall in the categories on the list for regional Qil assignment. A listing will be generated showing t.he TAC numbec, current review .;k.[@ branch, dates for incoming correspondence, dates for outgoing correspondence, w the status of the review, including tht existence of a draft SER/TER, and ex-AY pected completion date. 8:x-In general, a review that is being contracted autside the agency by MRR will ? f$ S/ not be transferred to the region, since the intent of the pilot program is to demonstrate the use of regional technical resources in conducting licensing l0.i reviews. The init'al list will be reviewed with the lead technical divisions Y' s : by DL managemeni. (Branch Chief or above) and approved for issuance to the region. Subsequent issues that come in will be treated similarly, after a TAC ?- is assigned by the project manager.

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.$am,f 2. Regional Review Assignments W :; After the initial list has been approved, the project manager will assemble the pertinent documentation for each TAC, including appropriate review criteria m-.it i

7 y (either a suitable Document Control System (DCS) reference or hard copy), and forward the package to the AD Technical Assistant for issuance to the appre-priate region. The Assistant Director (AD) will forward the package to the region, through the Director, DL. requesting that the work be accepted for regional technical review. 3. Scheduling Work Products The region will evaluate the work package schedules, technical resource require-ments, and review criteria for acceptability within one month of receipt. Once a TAC has been accepted for regional review, the region will based on overali completion schedule needs specified by NRR, schedule those of the following milestones that the regional considers appropriate, consistent with the over-all completion schedule, and inform the project manager: (1) issue RAI, (2) receive response, (3) conduct plant inspections, (4) prepare revised TS, (5) prepare SER, (6) prepare cover muo documenting time spent and mitii-SALP input, and (7) forward TS/SER to the project manager. If a TAC is rejected by the region, it will be returned to the project manager with an explanation pro-viding the basis for the rejection. A review requiring more than one RAI will result in a revised schedule if the need for that request was not anticipated. 4. Tracking Work Progress The region will provide the project manager with a quarterly status report set-ting forth the initial schedule of milestones for each TAC under review and the progress status, including revised schedules if appropriate. For program re-view purposes, the project manager will retain the original schedule, including milestone dates, established by the region at the beginning of the review. The region will record time spent by TAC so that it may be retrieved when the final SER is issued. The project manager will forward the initial TAC schedule to the E@ AD Technical Assistant so it can be included in the monthly Operating Reactor 3. Licensing Action Summary (ORLAS). The project manager will close the TAC upon y(] issuance of the license amendment or similar document, as appropriate.

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5. Coordination with Licensee yd:_- y. The regions will establish their own contacts with the licensee for technical 'l review purposes; however, the regicn must keep the NRR project manager informed 71' 5 of such contacts and document the discussions with the licensee. The project i.p g.;, manager will be advised in advance about conference c1: Is and meetings on con-CA" troversial issues to permit the project manager to participate, if participation is aopropriate. The regions may contact NRR review groups directly or through the project manager, as appropriate. L.; 4 i Any request for additional information A^ will be processed through the OL project manager. 6. Settling Unstable Review Criteria If the region decide.s to return a TAC for lack of clear review guidance or acceptance criteria, the project manager may elect to resolve the review cri-teria question and then return the TAC to the region for review. Alternatively, the TAC may be forwarded to an NRR technical review branch for completion. In the event only the criteria question is to be addressed by NRR, the TAC will be _W revised to indicata this before forwarding the TAC to the review branch. g g M

I h; $U m jf The project manager will maintain records adequate to show the disposition of ??gj any TACs returned by the region. 7. Appeal Process 22, 1983 -An appeal process similar to that provided for in the Commission's June memorandum on backfitting guidance will be established. A licensee desiring to discuss any areas of disagreement regarding a regional licensing review will initiate the same appeal process used for all other licensing actions. Specf 71cally, licensees may appeal any licensing action by letter to the Director, Division of Licensing, NRR. 8. Required Documentation The following documents / records are considered necessary to help the demonstration work and permit an adequate postimplementation audit (new items are introouced by asterisks): (1) List of approved-for-transfer Licensing Action Reviews by TAC / dates (2) Review criterie for each TAC ^ (3) Incoming correspondence for each TAC (4) Out;oing correspondence for each TAC (5) DL-to-region work package transmittal (6) Region milestone schedule for each TAC accepted (7)

• Region rejection basis for each TAC rejected (8) Regional RAIs as necessary (9) Regional inspection reports

~ (10) Minutes of meetings / conference calls (11) Revised TS (12) Regional SER 1 - (13) RAMS data-recording hours expended (14) ORLAS tracking by fiscal year '(15) Region mini-SALP input with cover memo (16) Project manager TAC inputs (17) Appeal letters with disposition correspondence (18) Final license amendment / documentation 10

Two of these items are new; they were created to serve the pilot program. The other items are in routine use in the current programs and can be readily adopted for use with the pilot program. B. Execution Actual review responsibility for the selected actions is to be shifted from NRR to the regions in early FY 1984. The project managee will generate the TAC list within 2 weeks of program approval. If necessary, a meeting will be scheduled with each region within a week of approval of the initial TAC list. The meeting will discuss the PM's role, identify regional contacts, and cover general information flow responsi-bility. Detafis of the documentation format will be worked out, including pro-vision for management oversight. 11

k [ = c V. PROGRAM EVALUATION E = The 2 year pilot program will be evaluated to test the method of selecting 7,,, E licensing actions for technical review in the regions, and tc measure the $43 success of the reg hnal review effort in meeting the objectives of imp oved T T!J safety at operating power reactors. .ff.} = 7% [sr jfily% The technical reviews transferred to the regions under the 2 year pilot program will comprise only a portion of the total number of technical reviews that will P be done in all five regions. However, the six nuclear stations that are MQ2 selected for the pilot program are considered representative for parposes of M '. SQ[ 5 evaluating the success of the regional licensing action review effort. Since lL no operating power reactors are excluded from having selected licensing actions

..g i, reviewed in the region, it will not be feasible to establish a concrol group of A.[

y *C plants unaffected by the program, as some have suggested. The purpose of such l Q$.,l a control group would have been to provide a baseline against which the effec-tiveness of the regional effort involving technical review of licensing actions (eg could be measured. The same purpose can be achieved by evaluating technical [SA - I reviews performed by a region against similar technical reviews conducted in rd; 5 ;. j,; headquarters. F 4 .s. - The evaluation will include both quantifiable and qualitative criteria. The A I J.% [ criteria will include indicators designea to assess any safety implications of %'?.;[ p the regional licensing action review effort. It will be conducted in a manner = similar to the National Program Review being conducted by NHSS for the regional-4,e[# y E-ization of materials licensing reviews. Although the details have not been f solidified, the following criteria are being considered to measure the success Q;.) L of the program. L p.. Y 1.M d' [ A. Qualitative Success Criteria ? 4r.- y

c. V.. ;

P E (1) Was the action taken technically correct? %v',( (2) Is it consistent with guidance (both among regions and between regions and N; e headquarters)? W+ g <e h (3) Was appropriate management of regional technical resources applied? 9 4.. g - r ,.[ MN[ g (4) Was the incident-response capability in the region enhanced by the technical licensing action reviews? k ill,; E (5) Was the quality of sork products commensurate with similar oroducts pro-2l (M L vided by headquarters? p.,j! Ji h ,i : (6) Were interoffice communications and coordination improved betwnen head-Sih.y { quarters and the regions? QpJ =.E (7) Were communications improved between the staff and the licensee? W e 12 wU inE

(8) Was the application of HQ technical resources to more complex issues or t generic matters enhanced as a result of the regional technical reviews? (9) Were selection criteria adequate? (10) Does the licensee feel that the overall safe operation of its nuclear i station has been e'hanced by having selected licensing action technical reviews conducted in the region? (11) Were contacts with state and local governments improved? (12) Was regional staffing adequate for the assigned reviews? B. Quantitative Success Criteria How many reviewer hours were expended in producing a deliverable product? (1) E Compa.ae with headquarters expenditure. (2) Compare the rate of plant-specific inventory reduction before and after regional review was applied to the plant. K (3) Compare the number of licensee appeals before and after regional review. (4) How many issues were rejected by regions and returned to headquarters? i (5) How many resources did the licensee commit to licensing reviews before and i after regional review? (6) How much total time was required to complete the review? Compare with I headquarters expenditure of time. [ F C. Report L The staff will report to the Commission on the results of the pilot piogram within one month of completing the program review. The report will be expected to make recommendations regarding continuation / expansion / termination of the k program. The program review will be conducted in accordance with NRC Manual Chapter 0128 " Organization and Functions of Regional Offices," Section 6 of " Accountability." ACRS will review the results of the evaluation and provide comments to the Commission. p ( E h p L p F 13 y P

J l, i APPENDIX LIST C ANALYSIS Assumptions are made for each licensing action type which muy or may not be correct in a particular case. Therefore, in order to apply the results of this analysis to a particular licensing action, it is necessary to verify that the assumed attribute profile is appropriate. Where deviaticns exist, it will be necessary to revise the analysis to reflect the correct profile. s A. Resource Assignment Problem 1. Basic Premise After identifying the types of licensing actions that are likely to be encoun-tered in the licensing area, the problem can be simplified to one of assigning the appropriate resources to either the home office (HQ) or the field (regions). It would be heipful to define those characteristics of a licensing action that would contribute to it being more effectively accomplished in the regions. Once the choracteristics are established, a basis for judging wh a a particular licensing action should reside for the optimum results can L! developed. Start with the basic p-emise that for a licensing review to be accomplished more effectively in the region, it must either require specialized knuwledge of the affected plant that would typically exist with the regional staff as opposed to the HQ staf f, or it would greatly benefit from the regional staf f' c / resident inspector's proximity to the site. Such knowledge might include specific details of a plant's design, configura-tion, operational characteristics, management, or procedures. Given the requisite knowledge, regio 7al reviewers should be in a position to conduct a more thorough review more efficiently, resulting in a maximum condition of safety at a minimum cost to the agency. 2. Assumpticns In order to proceed with the develcpment of the decision criteria, it will be necessary to make certain assumptions. First, assume that the resources are uniformly distributed throughout the regions of interest. Assume that it is possible to characterize each type of licensing activity by an " attribute pro-file." Assum? that the attribute profile so constructed is collectively - o exhaustive for corposes of resource assignment determinations. Assume that relative weighting factors can be assigned to each of the attributes that will correctly convey the importance attached to that attribute in the overall determination of where the review should be conducted. Finally, assume that relative probability of success indices for each attribute can be estimated which will describe the collective judgment as to where the best resource for ? each attribute is located. Once these assumptions are adopted, a decision algorithm (or utility function) can be constructed that can be used to compute an expected value for the region and for HQ. The resource with the largest computed expected value is favored for that particular licensing review. 14

s 4 E 3. Subjective Criteria i The principal reason that a pilot program is being adopted involves the set of unknowns that exist in the area of resource allocation. The fact is, a good set of data is not available to formulate objective criteria for transferring 1 licensing reviews to the regions. Therefore, subjective criteria must be con-vertad (thcough use of a utility function) to an objective prediction. It is E recognized that even in the best of worlds (all predictions for r-gional review prove accurate), since the criteria are subjective, issues can be assigned to HQ that would be better accomplished in the regions. Such errors will go undetected since the postimplementation evaluation will be designed to detect only those issues that were misassigned to the regions. However, as a starting point, this approach, which is nothing more than a simplified value-impact [ analysis, has as good a promise as any that are currently being evaluated of identifying an appropriate set of issues for regional review. It should be pointed out that this approach will leave open the question of ~ whether adequate technical capability exists in the regions. It also does not include the development of uniform review criteria in the event an item is indicated for regional review which suffers from such a defect. These issues [ will be confronted by the project manager as shown in the flow chart for pro-cessing regional licensing action reviews (Figure 1), and again by the post-k implementation evaluation team when assessing the merits of the demonstration. 1 8. Methodology - Value-Impact Analysis (VIA) 2 To cnmplete the VIA utility function, it is necessary to identify the set of E all possible characteristics which could have a bearing on a resource assign-ment decision. To do this, recall that the principal characteristic of a licensing review that can be used as an indicator for regional assignment has been identified: namely, the necessity for special; zed knowledge of the particular plant or proximity to the site. There may be other characteristics that would suggest regional review i; appropriate. For example, an amendment requiring a procedure walkthrough or one requiring several trips to the plant. E However, none of these ideas rules out the possibility of HQ review being done as effectively as regional review so much as the requirement for specialized ~_ k plant knowledge or proximity to the site. rk There also are characteristics of licensing actions that would suggest a more E effective review could be done in HQ. Once these characteristics are identi-fied, it is possible to construct a comprehensive attribute prufile, or tem-plate, against which all licensing actions can be examined. 4 1. Establish Attribute Profile 5 Some attributes of an amendment request o' licensing issue that would seem to p favor HQ review are: (1) generic applicati.n, (2) multi-discipline review, F (3) complex technical aspects, (4) exemption-related issues, (5) unstable re-t view criteria, (6) policy issucc, (7) significant safety issue or unreviewed b safety question, and (J) 191al ur hearing-re ated issues. Although there may L be others, presume that this iist of eight characteristics is collectively exhaustive for purposes of resource allocation decisions. i, L 15

yg - - < 1 - 6 A UsingLthe following symbols, generate Boolean expressions to describe the state Lof~ knowledge about a' specific licensing review. .SY20L-ATTRIBUTE L A Specialized plant knowledge / proximity B Generic application C Multi-discipline D.

Complex technical

-E= Exemption related F Unr. table criteria G Policy issue H Unresolved safety question /significant safety hazard I Legal / hearing For example, ~ R = AABACA5AEAFA5AHAT is' a way of expressing.the view that regional review is clearly indicated if ! specialized plant _ knowledge is required and none of the indicators for HQ . review are present. Alternately, HQ = AVAABACADAEAFAGAHAI is the Boolean expression confirming the view that HQ review is clearly lindicated if_all of the indicators for HQ review are present, regardless of the need for specialized plant knowledge. 2. Assion Index Numbers ' Now assign relative weighting factors for the review attributes, and probabil-v

ity.of success estimates for the review resources. These indices will be used in the computation of expected values to aid management in the selection of

. appropriate resources. 1As previously mentioned, the indices ~are purely subjective and represent at best a' ball park estimate of the true situation. To complete the decison aid, 'a template-such as the one shown below is developed using the assigned indices. DECISION TEMPLATE Attribute A B C D E -F G H I TOTAL

p Weight 200 _175 100 125 50 150 25 150 25 1000

~POS* -Region ' .9 .1 .3 .2 .4 .05 .5 .01 .1 HQ. .1 .9 .7' .8 .6 .95 .5 .99 .9

• POS:. Probability of success - the relative likelihood that a given resource will complete the review more effectively

~for each individual attribute. 16

l The relative weighting factors are indicated to represent how important each l-attribute is, relative to the others. The probability of success is similarly intended to represent the relative likelihood that a licensing action with the given attribute will be completed more effectively by the associated resource. 3. Define Utility Function After first describing the state of knowledge about a particular licensing review in terms of the attributes which it possesses that are important for resource allocation, it is then necessary to compute an expected value for each resource using the indices in the decision template. The utility function is derived from the Boolean description and yields the expected value (EV). For example, a licensing action described by AMACMAEAFA5AIIM Yields: Expected value (region) =.9(200) = 180 Expected value (HQ) =.1(200) = 20 This is consistent with the previous determination that such an action was clearly indicated for regional review. Likewise, a licensing action described by AABACADAEAFAGAHAI yields: EV(R) =.9(200) +.1(175) +.3(100) +.2(125) +.4(50) +.05(150) +.5(25) +.01(150) +.1(25) = 180 + 17.5 + 30 + 25 + 20 + 7.5 + 12.5 + 1.5 + 2.5 = 296.5 EV(HQ) =.1(200) +.9(175) +.7(100) +.8(125) +.6(50) +.95(150) +.5(25) +.99(150) +.9(25) = 20 + 157.5 + 70 + 100 + 30 + 142.5 + 12.5 + 148.5 + 22.5 = 703.5 Again, this is consistent with the previous determination of items appropriate for HQ review. Although these are extreme examples, it is now apparent that all one needs to de to determine the appropriate resource for a particular licensing action is to determine its associated attributes, enter the decision template, and compute the expected values. The resource with the largest ex-pected value is estimated to have a better chance of producing the most effi-cient review with the attendant greatest improvement in safety and least cost to the government. 4. Calculate Expected Values Sample calculations have been done for each of the issues appearing in List C. Following is a summary of the worksheet calculations. -17

c f, LIST C ANALYSIS

SUMMARY

~ Issue No. EV EV(R) EV(HQ) Conclusion 1 A+C+D 235 190 Region 2 .A+C+D 235 190 Region 3 A+C4D+E+F+G 275 375 hQ 4! -E+F+G+I 42.5 207.5 HQ ~5 A+D+G 217.5 132.5 Region 6 D+E+G+H+I-61.5 291 H0 = 7

A 180 20 Region 8

D. 25 100 HQ -9 B+E+G 50 200 HQ 10 B 17.5 157.5 HQ 11. A+I 182.5 42.5 Region .12' A+G+I 195 55 Region 13 C 30 70 HQ 14* A+C+D+I 237.5 212.5 HQ -15 B+C+D+G+H+I 89 511 HQ ' 16 AvB+C+D+F 260 490 HQ 17 A+D+H 206.5 268.5 HQ 18 A+B+C+D+E 272.5 377.5 HQ 19 A 180 20 Region 20 A+D+E 225 150 Region HQ 21* Null Set 22* A+C+F 217.5 232.5 HQ 23 F+G-20 155 HQ 24* A+F 187.5 162.5 HQ

• Discrimination is weak 18 1

f,RC P oou 335 U.S. NUCLEAR REGULATORY COMMISSICW tslBLIOGRAPHIC DATA SHEET h0 REG-1075 / g O. ViTLE A SUBTITLE (Add Voturne No., sf apprenstel

2. ILeave $1m41 Decent lization of Operating Reactor Licensing Reviews:

NRR F*1 Program

3. RECIPIENT'S ACCEplON NO.

j 7 AUTHORIS)

5. DATE REPORICOMPLL )ED John N. Ha on goyTw lg

9. PE RF ORMING ORGA' ATION NAME AND MAILING ADDRESS (inclue Isp Code /

OATEMEPORT ISSUE D Division of L1.nsing uoura lvtaa Office of Nucle Reactor Regulation Jsly 1984 U.S. Nuclear Reg atory Commission aftte=e ueki Washington, D.C. 55 j j' 8 (Leave Nek)

12. SPONGORING ORGAN'ZATION N E AND MAILING ADDRESS //riclu* lip Code / [

10 PROJECT /T ASK/ WORK UNIT NO. Same as above /

11. FIN NO.

p / t

13. TYPE OF REPORT

' PE RIOD COV E RE D (l' ictus.ve danas) anagement re ) ort (Final) f i

15. SUPPLEMENTARY NOTES

14. fleave ote&#

k#

16. ABSTRACT (200 words or less/

T:iis report, which has incorporated *) %,isents received from the Commission and ACRS, on describes the program for decentr.a zat1"gn of selected operating reactor licensing technical review activities. 2-yea (pilot program will be reviewed to verify that safety is enhanced as anti ated by t e incorporation of prescribed management techniques and application of

sources, I 'the program fails to operate as designed, it will be termina d.

The 2-year pilot program 1 be limited to two sperating power plants in each of three regions and will be impl ented to: (1)testthehethodofselectinglicensingactions for technical review in he regions,(2) evaluate p' dicted improvements in the effective-ness of licensing and spection programs,and (3) ify that safety is enhanced (as anticipated)by i rporating prescribed manageme techniques and applying regional 1 resources to this t nical review function. ~ i

17. CIE Y WORDS AND D ENT AN ALYSl$

17a DESCRIPTORS pilot progr decentrali ion regionali tion ^ l 17t> IDE NT IE RS/OPEN EN DE D TE RMS 18 AV AIL A81LITY ST ATE ME NT 19 SE CURS TV CL A$S ITh,s reporrt 21 NO OF PAGES Unclassified Unlinited 2gSggs,Tg AgS ITa. part 22 PRICE ' ~ =ac some us in eu 4

i UNITED STATES pouarn ciass en 2 NUCLEAR REGULATORY COMMISSION N5 FAG,8),E3'O j 3 g WASHINGTON, D.C. 206Ei6 wasa o PENAL FR R TE E, 8300 OS 018877 L 9999's AO M-OI V OF TIOC 0 Y f. PUB MGT t> R - P O R NU R E ri WASHINGTON OC 20555 l l l l L... _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _. _. _ _}}