ML20195H238
| ML20195H238 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/1998 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Colvin J NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9811230290 | |
| Download: ML20195H238 (6) | |
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/#% 'g UNITED STATES NUCLEAR REGULATORY COMMISSION r#
/Prb.//?QSr[u WASHINGTON, D.C. 20665-0001 t
[ November 10, 1998 CHARMAN Mr. Joe F. Colvin President and Chief Executive Officer .
Nuclear Energy Institute 1776 i Street, NW., Suite 400 Washington, D.C. 20006-3708
Dear Mr. CoMn:
I am responding to your letter of August 28,1998, in which you identify several industry-proposed regulatory changes that have been pending before the U.S. Nuclear Regulatory Commission (NRC) for periods far longer than either NEl or the Commission would have preferred. Specifically, the actions pertain to Quality Assurance, Emergency Preparedness Programs (10 CFR 50.54(q)), Fitness-for-Duty Rulemaking (10 CFR Part 26), Event Reporting, and initial Licensed Operator Examination. I have enclosed information on the status and the planned completion date of each action you noted in your letter. If you would like to provide feedback on the staff's plan on any of these actions, I hope you wili raise the matter at this month's stakeholder meeting.
I agree with your suggestion that the NRC thoroughly examine its review process, and as you know, the agency has already initiated steps to examine and improve our regulatory processes, including the review process. On August 7,1998, I tasked the Executive Director for Operations (EDO) with identifying areas for near-term attention that will support our long-term performance goals. In doing so, I highlighted the fact that recent criticisms of the NRC included, among other things, the predictability and timeliness of NRC decisions. Your concems appear to fit squarely into these areas. In an August 25 memorandum, the EDO presented the Commission with a plan, which, among other things, highlights specific areas for improvement, including the agency's transition to a risk-informed framework, revisions to 10 CFR 50.59, and restructuring of the line organization. I have enclosed the latest update to the EDO's plan schedule and you will find two of the issues you highlighted included. It is my expectation that, through sound planning, and self-assessment and management oversight, we will speed the resolution of these and other issues of industry interest.
We look forward to continued interactions with all our stakeholders on approaches to further improve our regulatory processes. If you wish to pursue this matter, or if you have additional questions or comments, please contact me or William Travers at (301) 415-1700.
,_n, Sincerely, 4 g . _
9811230290 991110 L PDR COMMS NRCC CORRESPONDENCE PDR i Shirley Ann Jackson j
Enclosures:
As stated l
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Pending industry-Proposed Regulatory Changes Quality Assurance When the Nuclear Energy Institute (NEI) petition for this action was received in 1995, the staff considered the question of whether the 10 CFR 50.59 change process could be used to allow a broader range of unilateral changes to licensee quality a'ssurance (QA) programs. The Commission published the notice of the petition's receipt in the FederalRegister and asked for comments on attematives to 10 CFR 50.54(a). The staff considered the comments received and the guidance materials developed by NEl and met with NEl in 1996 to investigate how 10 CFR 50.59 might be used for this purpose or whether some other standard could be used to replace the current " reduction in commitment" standard in 10 CFR 50.54(a). The staff had concerns about the use of 10 CFR 50.59 for QA program changes because it required a determination that a change does not constitute an unreviewed safety question and it was not ;
clear how this would be determined for QA program changes.
The staff met with NEl in a public meeting on August 27,1998, to discuss its proposed action ,
on the 10 CFR 50.54(a) rulemaking petition. The staff expressed its view that licensees should )
be given greater latitude to make unilateras changes to their QA plans. However, the staff continues to believe that 10 CFR 50.59 is not the appropriate change control mechanism. The staff is anticipating making a recommendation to the Commission in November that will provide some relief and flexibility in the area and significantly move the disposition of the petition forward.
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Emeraency Preparedness Proarams (10 CFR 50.54(a))
Section 50.54(q) permits licensees to make changes to their emergency plans without NRC's approval if the changes do not decrease the effectiveness of the plans and if the plans, as changed, continue to meet regulatory requirements. Proposed changes that decrease the effectiveness of the plans may not be implemented without NRC's approval. NEl has stated that no useful guidance is available to the industry to determine what " reduced effectiveness" means, and industry efforts since April 1996 to establish meaningful guidelines have not been successful. After questions arose among NRC regional staff concerning whether some licensee emergency plan changes constituted a decrease in the effectiveness of the plans, the NRC and the industry initiated separate efforts to develop guidance on this issue. The industry developed draft guidance for NRC's consideration, and two public meetings were held in April 1996 and January 1998 to discuss the industry approach. The NRC staff offered general comments on NEl's presentations and found the dialogue with the industry useful in the development of the staff guidance on the subject. The NRC issued draft guidance to its staff for determining the acceptability of emergency plan changes in January 1998 in the form of an emergency preparedness position (EPPOS). The NRC approach to determining reduction in effectiveness was shared with the industry at a regional utility planning group meeting in February 1998 and at the NEl Emergency Planning Information Forum in Alexandria, Virginia, on June 9,1998. At the June 9 meeting, the NRC staff committed to issue guidance to licensees on changes to emergency plans following issuance of final guidance for staff use.
Final staff guidance, EPPOS No. 4," Emergency Preparedness Position on Emergency Plan and Implementing Procedure Changes,"is in final preparation. Although EPPOS documents are intended to provide guidance to the NRC staff, they are placed in the Public Document Room after issuance in final form and thus are available to the public and the industry. This guidance will be issued in November 1998 and will enhance the consistency of the NRC approach to this issue.
As both the NRC and NEl staffs are fully engaged in the development of assessment, inspection, and enforcement processes for operating power reactors, resources have not been avai!able for the cooperative development of generic industry guidance on this subject. As resources become available to both the NRC and NEl, work will be planned and will begin on generic guidance development.
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Fitness-for-Duty Rulemakina (10 CFR Part 26)
Making changes to the fitness-for-duty rule (10 CFR Part 26) to address several complex technical, legal, and policy issues has been a major project that is now in the final stages of the rulemaking process. The rulemaking has taken longer than expected owing both to the complexity of the subject and the volume of comments received from the public on the proposed rule.
More than 1,000 public comments were received in response to the May 1996 proposed rulemaking. The final rulemaking package is being finalized and is currently scheduled to be forwarded to the Commission in December 1998.
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i Event Reportina in the fall of 1989, the NRC staff surveyed personnel from 13 nuclear power utilities to obtain their views on the potential effect that NRC regulatory activities were having on the safe ;
operation of their nuclear plants. This survey was documented in draft NUREG-1395, " Industry Perceptions of the impact of the U.S. Nuclear Regulatory Commission on Nuclear Power Plant Activities," March 1990. l Partially in response to the reporting concems expressed in draft NUREG-1395, four regional workshops on event reporting were held from September to November 1990. It was I determined that additional clarification of the reporting guidance was needed.
In parallel with these efforts to revise the guidance in NUREG-1022, rule changes to 10 CFR 50.72 and 50.73 were developed to eliminate the requirement to report certain events that had been determined to be of little or no safety significance. These were events that resulted in invalid actuation of several specific engineered safety features. The proposed rule was l
published in June 1992, and the final rule was published in September 1992.
Beginning in late 1994, a rulemaking was initiated to obtain reliability and availability data for risk-significant systems equipment in order to support the Commission's r.iove toward more risk-informed regulation. This effort was concluded in mid-1997 when the Commission accepted an industry-proposed voluntary approach in lieu of the proposed rule. ,
l In mid-1997, the effort to finalize Revision 1 of NUREG-1022 was resumed, and the final document was published in January 1998. In the process of f;nalizing this guidance, it was determined that some issues should be addressed by additional rulemaking. This rulemaking l would identify areas where event reporting requirements can be risk-informed and/or simplified.
A rulemaking plan was approved by the Commission in May 1998. The schedule proposed for l comment in the advance notice calls for publishing a proposed rule in April 1999 and a final rule in January 2000. An advance notice of proposed rulemaking was published for comment in July 1998.
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l Initial Licensed Operator Examination 1 !
l Since October 1995, with the exception of a brief interruption from April to August 1996, ,
! license 0s have had the option of preparing their own examinations, as originally requested by j Virginia Fawer Company in its 1994 petition. During this time, a pilot program has been conducted hnd, based upon the results of that program, a proposed rule was developed and issued for comment in August 1997. The staff expects to send the final rulemaking to the Commission in November 1998.
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NUCLEAR RESULATORY COMMILW[ON WASHINGTON, D.C. 20666 0001 J p% ,,,o / October 9, 1998 MEMORANDUM TO: Chairman Jackson FROM: L. Joseph Callan Executive Director to perations
SUBJECT:
UPDATE TO STAFF RESPONSE TO TASKING MEMORANDUM AND STAKEHOLDER CONCERNS l
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Attached for your information is the staff's first monthly update to the plan of short- and long-term actions to respond to selected issues raised during the July 30,1998 hearing before the l Senate Subcommittee on Clean Air and Wetlands, Private Property, and Nuclear Safety and l the July 17,1998 Commission meeting with stakeholders. l The attached plan's organization continues to follow the outline of your testimony for the July Senate Oversight Subcommittee hearing with several notable exceptions. In response to the SRM associated with COMSECY 98-024, Response to issues Raised within the Senate Authorization Context and July 17,1998 Stakeholder Meeting, the staff has added two topic areas that address issues associated with uranium recovery facilities (topic area Vil) and changes to the NRC hearing process (topic area Vill). The SRM also directed the staff to consider stricter application of the backfit rule. Specific issue IV.K, Application of the Backfit Rule, has been added to address this issue. In addition, more detail has been provided on l pending licensing actions for shutdown plants in topic area VI.D, Decommissioning Decisions, j
Overall, the staff is successfully meeting the scheduled milestones. Several noteworthy accomplishments include: completion of the performance assessment workshop, issuance of improved standard Technical Specifications for McGuire and Catawba, and issuance of the final design approval for AP-600. Several topic area schedules have undergone considerable change, the most significant being that associated with proposed Kl rulemaking. Explanations for the changes are provided in the associated remarks. Additions and changes to the original tasking memo response are marked in redline and strike out.
The plan will continue to be considered a living document which will be updated monthly. The next update will be provided to the Commission the first week of November 1998.
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Attachment:
As stated cc: Commissioner Diaz Commissioner McGaffigan l OGC CFO CIO l
SECY l 4g ((R 02S$ ' l 1
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l l STAFF RESPONSE TO TASKING MEMORANDUM AND STAKEHOLDER CONCERNS as of October 9.1998 L
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' ABLE OF CONTENTS T
- 1. TOPIC AREA: Risk-Informed and Performance-Based Regulation . . . . . . . . . . . . . . . . . . . 1 A. Specific issue: Evaluation of Industry Proposals and Rulemaking . . . . . . . . . . . . 1 B. Specific issue: Pilot Applications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 C. Specific issue: Plant-Specific Licensing Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . 5 D. Specific issue: Guidance Documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
- 11. Topic Area: Reactor Inspection and Enforcement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 A. Specific Issue: Risk Informed Baseline Core Inspection Program . . . . . . . . . . . . . . 9
- 8. Enforcement Program initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 C. Escalated Enforcement Program initiatives " Regulatory Significance"/ Risk . . . . 16 111. Topic Area: Reactor L;censee Performance Assessment . . . . . . . . . . . . . . . . . . . . . . . . 17 A. Specific issue: Performance Assessment Process Improvements (IRAP, Industry's Proposal, and Performance Indicators) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 IV. Topic Area: Reactor Licensing and Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 A. Specific issue: License Renewal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 B. Specific issue: 50.59 Rule making . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 C. Specific Issue: FSAR Update Guidance ...............................26 D. Specific issue: Define Design Basis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 E. Specific issue: Improved Standard TS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 F. Specific Issue: Generic Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 G. Specific issue: C A Ls . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . 3 3 H. Specific issue: Applicability of Backfit Rule to Decommissioning Activities . . . . . 34
- l. Specific Issue: Requests for Additional information . . . . . . . . . . . . . . . . . . . . . . . . 36 J. Specific issue: 2.206 Pe titions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 K. Specific issue: Application of the Backfit Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 V. Topic Area: NRC Organizational Structure and Resources . . . . . . . . . . . . . . . . . . . . . . . 40 A. Specific issue: Reorganization - Restructuring Line Organizations . . . . . . . . . . . . 40 B. Specific issue: Achieving 1:8 supervisor / manager-to-employee ratios . . . . . . . . . 41 C. Specific issue: Increased staff responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 VI. Topic Area: Other Agency Programs and Areas of Focus . . . . . . . . . . . . . . . . . . . . . . . 44 A. Specific issue: License Transf ers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 B. Specific issue: AP-600 Design Certification Rulemaking . . . . . . . . . . . . . . . . . . 46 C1. Specific issue: TN-68 (Dual Purpose) Cask Review . . . . . . . . . . . . . . . . . . . . 47
.C2. Specific issue: BNFUSNC TranStor (Dual Purpose) Cask Review . . . . . . . . . . 48 C3. Specific issue: Holtec HISTAR 100 (Dual-Purpose) Cask Review . . . . . . . . . . . 49 C4. Specific issue: Westinghouse WESFLEX (Dual Purpose) Cask Review . . . . . . 50 C5. Specific issue: NAC-STC/MPC (Dual Purpose) Cask Review . . . . . . . . . . . .. 51 C6. Specific issue: NAC-UMS (Dual Purpose) Cask Review . . . . . . ........... 52 C7. Specific issue: TN-West MP-187 (Dual-Purpose) Cask Review . . . . . . . . . . . . . 53 i
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L October 9,1998 D. Specific issue: Decommissioning Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 L
E. Specific issue: PGE-Trojan Reactor Vessel Shipment Application . . . . . . . . . . . . 56 i F. Specific issue: Event Reporting Rulemaking . . .~ . . . . . . . . . . . . . . . . . . . . . . . . . 58 G. Specific issue: Proposed Kl Rulemaking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 H. Specific issue: NEl Petitions - Petition for modifying 50.54(a) . . . . . . . . . . . . . . . . 62 l 1. Specific issue: Revised Source Term Rulemaking . . . . . . . . . . . . . . . . . . . . . . . . 64 l Vll. TOPIC AREA: Uranium Recovery Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 l A. Specific issues: Uranium recovery concerns raised in Senate report . . . . . . . . . 66 l Vill. TOPIC AREA: Changes to NRC's Hearing Process . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 A: Use of informal Adjudicatory Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 l
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4 October 9,1998 I. TOPIC AREA: Risk-Informed and Performance-Based Reaulation SES Managers: Gary Holahan, Director, DSSA/NRR and Thomas King, Director, DST /RES A. Specific issue: Evaluation of Industry Proposals and Rulemakina l Objective: The objectives are enhancing safety decisichs, efficiently utilizing NRC resources, ,
reducing unnecessary conservatism, as well as soliciting industry insights. J PRIOR TO JANUARY 28,1999 Milestone Date Lead l
- 1. Conduct Licensing workshop to discuss streamlining 7/22/98C G. Kelly, DSSA the review process for risk-informed (RI) applications I
- 2. Conduct Periodic PRA Steering Committee 8/20/98C RES/DSSA l Meetings (Monthly)
- 3. Establish agreement with industry on formation of 8/98C RES industry PRA steering committee to interface with NRC Steering Committee and an industry licensing panel to l interface with the NRC R! Licensing Panel. l
- 4. Meet.w/ South Texas Project on industry perspective 9/15/98C G. Kelly, DSSA to develop lessons learned
- 5. Follow-up to licensing workshop meeting TBD M. Caruso, DSSA w/UCS/NEl
- 6. Conduct discussions with ACRS on risk-informed, 6/98- R. Barrett, DSSA/
performance-based Regulation initiatives 42/90 M. Cunningham, RES 8/26/98C 9/24/980 9/30/980 11/19/98 12/3/98
- 7. Meet with ACRS Subcommittee and request ACRS 6/96 R. Barrett, DSSA letter on views and recommendations for staff options 9/24/98C paper
- 8. DSI-13 Role of Industry stakeholder meeting 9/1/98 C J. Craig, RES
- 9. Reach agreement with NEl on scope, schedule, 9/96 M. Drouin, RES approach and groundrules for NEl Whole Plant Study Sub-(tasks 1-6) sumed in 10 (see note)
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1 l 2 October 9,1998 PRIOR TO JANUARY 28,1999
- 10. Issue paper to Commission identifying options on H99 R. Barrett, DSSA/
modifying Part 50 to be risk-informed (including the'use 11/98 M. Cunningham, RES of.the term defln;;;en of " safety" and backfitting implications)(9800152) (NRR)
- 12. Meeting on NEl pilot plant preliminary risk results TBB M. Drouin, RES l Sub-sume' d in 10 (see note) l THROUGH JUNE 30,1999 Milestone Date Lead
- 13. Workshop on insights from NEl Whole plant study TBB M. Drouin,RES
! risk results and options for using them to enhance risk- Sub-informed regulation sumed in l
10 (see note)
!- 14. Develop Rulemaking Commission paper based on TBD R. Barrett, DSSA/
Commission response to options paper (lncluding M. Cunningham, RES considere;lon of NE Who'e I'lent Otudy (;&sks bO))
(9800154) (NRR)
- 15. Issue safety evaluation on EPRI ISI topical report early S. Ali, DE GY49 RES TBD BEYOND JUNE 30,1999 Milestone Date Lead
- 16. Endorse ASME RI-ISI code cases via Regulatory 3/00 D. Jackson,RES Guide 1.147, contingent upon ASME completing code S. Ali, DE
- case by 6/31E 9.
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Comments 2.' Committee in$Etiiipproxir6ately rhon'thly/ L3siiriesting 10/O98. hee met en 7/20/00 end 8/90/90: Charterincludes:
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- Coordination of inter-office PRA implementation Plan activities -
Resolution of keyissues -
- Identification of new activities
- Interaction with public and industry O. '.t;;; age J.ill be he:d wl:h NCl pllete and lxd p eat p;;ete (10l, :eek 0) 0-5. Pr.A 0:eerlag 0 mm : ee mee;;ag reqe: red.
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9,12,13. Pilotibeing treatsd As part of NEl option to be addressed in Milestone'10. Verbal
! agreement on this reached with NEl and pilot licensees at 9/15/98 public meeting.
.. _ l 10.LStaff has developed new plan and schedule for identifying and evaluating options. Plan l l provides for interaction with the public, the nuclear industry, the ACRS, and the CRGR in the l development and evaluation of options.
J and-14, Schedule depends upon NC: plle; project eehedelee whleh et preeeat are TOO. A l . meet ag w:h NC;je teate;.seri .ehede:ed for 0/20/00 to llnel ee the echedel6 Commission ;
response to ' options pape'r at Milestone 10.
4-6;-10 and 1_4. Some items budgeted in DSSA, such as support for SMMs, use of PRA in
. generic issue resolution, events assessment (except for high risk events) participation in planned l or reactive inspections, and quarterly updating of PRA plan (9500047 RES) (move to annually), i and IPE foliosup, may be deferred in order to meet the above schedules in developing an j' options paper. Work suggested to be dropped to support these milestones is the modification of
- Part 52 regarding use of PRAs beyond Design Certification. RES work on proposed revision to Safety Goal Policy will be deferred from 3/99 to 7/99. Status report on this effort will be deferred i . from 12/98 to 3/99. (9700262) (RES) l- ;11 and 15. Risk-informed licensing panel (RILP) meetings are required.
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- 15. Work has beeridelayed due' to need for additional information from EPRI (RAI issued in June 1997).1 Staff continues to interact periodically with EPRI and will resume its' efforts after
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i ' staff receives. responses to RAls from'EPRI. EPRI submitted topical prior to issuance of ISI Reg l Guide'and Standan;i Review Plan and as'a result did not address certain risk issues or how the changes in' program would impact risk.4 l
' Additional Activities: The Center for Strategic and International Studies (CSIS) is conducting a study of the NRC regulatory process. Chairman Jackson and Commissioner McGaffigan are members of the Steering Committee. Ashok Thadaniis on the working group. This activity will
- involve several meetings over the next several months and the CSIS schedule calls for a final
. report by 4/15/99.
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- 1. TOPIC AREA: Risk-informed and Performance-Based Reaulation SES Manager: Gary Holahan, Director, DSSA/NRR 1 B. Specific Issue: Pilot Applications
~ Objective: The goal of the pilot programs is to complete first of a kind risk-informed licensing i reviews such that lessons learned may be utilized for future staff reviews. The pilot applications have provided a forum for developing guidance documents for both the staff and the industry.
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- PRIOR TO JANUARY 28,1999 ;
! l Milestone Date Lead
- 1. Risk-Informed Licensing Panel (RILP) Meetings - Ongoing G. Holahan, DSSA assists in focusing management attention, as l
i necessary, to identify other pilots and ensure lessons learned are developed from pilots
- 2. Issue safety evaluation on Comanche Peak IST 8/14/98C D. Fischer, DE l' pilot DSSA support l &3. Issue safety evaluation for ANO-2 H2 monitoring 9/28/98 C M. Snodderly, DSSA
&5. Issue safety evaluation on Surry ISI pilot 12/31/98 S. Ali, DE i j DSSA support !
E6. Issue safety evaluation on ANO 2 ISI pilot 12/31/98 S. Ali, DE DSSA support BEYOND JUNE 30,1999 Milestone Date Lead
- 7. Issue safety evaluation on ANO-1 ISI pilot 07/99 S. Ali, DE Coinments All licensing actions dates are contingent upon timely, technically acceptable industry responses to staff inquiries.
i S; 4,5 and 6. Risk-informed Licensing Panel (RILP) meetings required.
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5 October 9,1998 1.TOPlc AREA: Risk-informed and Performance-Based Reaulatio_n SES Manager: Gary Holahan, Director, DSSA, NRR C. SDecific issue: Plant-SDecific Licensina Reviews Objective: The use of probabilistic risk assessment in risk-informed decision making for changes to plant-specific licensing basis is intended to enhance safety decisions, efficiently utilize NRC resources and reduce unnecessary conservatism. The goal is to complete first of a kind risk-informed licensing reviews such that lessons learned may be utilized for future staff reviews.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 2. Risk-Informed Licensing Panel (RILP) Meetings - Ongoing G. Holahan, DSSA assists in focusing management attention, as necessary, on risk-informed licensing actions.
- 3. Issue safety evaluation on North Anna 1/2 EDG AOT 8/26/98 C O. Chopra, DE extension DSSA support 6-4. Issue safety evaluation on Oyster Creek proposal on 9/8/98 C O. Chopra, DE EDG online testing DSSA support ES: Issue safety evaluation on San Onofre 2/3 EDG AOT 9/9/98 C O. Chopra, DE extension DSSA support 5-6. Issue Commission paper related to staff's evaluation 9/21/98 C G. Carpenter, DE of probabilistic assessment of "BWR Reactor Pressure DSSA support Vessel Shell Weld inspection Recommendations" (9700209) (NRR) 8:7. Issue safety evaluation for ANO-2 H2 monitoring 9/28/98 C M. Snodderly, DSSA 4-8. Create special reporting mechanism in WISP for 9/98 J. l l&reld, risk-informed licensing actions to facilitate monitoring and 10/2/98 C R. Hall, DRPE tracking
- 9. Issue safety evaluation on safety injection tank AOT 11/98 E. Weiss, DSSA extension for 6 CEOG facilities
- 10. lasue safety evaluation on Comanche Peak charging 11/98 E. Weiss, DSSA pump AOT extension
6 October 9,1998 PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 12. Issus relaxation on H, monitoring for other plants 12/98 ADPR/DSSA THROUGH JUNE 30,1999 Milestone Date Lead
- 13. Issue safety evaluation on Sequoyah proposal on 06/99 O. Chopra, DE EDG AOT extension DSSA support
- 14. Issue reliefs from augmented examination 06/99 G. Carpenter, DE requirements for various lironsees on BWR reactor pressure vessel circumferential welds l
l 15. Issue safety evaluation on Browns Ferry 2/3 proposal 06/99 O. Chopra, DE on EDG AOT extension DSSA support j Comments 7 &nd O. nlLi' .T.eetings requ; red.
- 14. 0000.T.eeting needed in 10/90. Oontingent upon receipt of relief requests from licensees
+S 14-15. Dates to be evaluated during prioritization of risk-informed licensing actions.
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- 1. TOPIC AREA: Risk-Informed and Performance-Based Reaulation SES Manager: Gary Holahan, Director, DSSA, NRR and Thomas King, Director, DST /RES l D. Specific lasue: Guidance Documents Objective: To provide guidance for the staff and the industry which will enhance consistency l and provide a infrastructure for use in risk-informed regulation.
j PRIOR TO JANUARY 28,1999 l Milestone Date Lead
! 1. NRC/ Utility Workshop on Risk-informed Regulation 07/980 Completed 7/22/98 l 2. Communicate about process with Licensing 07/98C Completed 7/20-counterparts from industry (NRC/ Utility Licensing 21/98.
Workshop)
- 3. Issue ISI trial use RI RG/SRP to Commission 06/98C RES S. Ali, DE 4a Complete review of second draft of Phase 1 PRA 8/98C M. Drouin, RES l standard
( 4b. Paper to Commission on status of PRA standards 10/98 M. Drouin, RES
! development effort (9800041)(RES) 4c. Phase 1 draft PRA standard submitted for ASME 11/98 M. Drouin, RES review and comment 4d. Phase 1 draft PRA standard issued for public 1/99 M. Drouin, RES comment
- 5. Revise NRR internal guidance to raise the priority of 09/98 D. Dorman, ADPR risk-informed licensing actions 10/1/98 C
- 6. Communicate revised priority to industry via 09/98 O. Deimen, PM/ Licensing interaction 10/98 R. Hall, ADPR
- 7. Communicate revised priority to industry via 10/98 D. Derman,
! Administrative Letter R. Hall, ADPR
! 8. Issue Nnn Off;ce Letter Technical Guidance on 10/98 G. Kelly, DSSA l Implementation of Risk-informed Regulation for-tsse i
l 9. Issue final GQA inspection procedure for use following 12/98 R. Gramm, DRCH implementation of South Texas GOA program a 10. Integrate risk attributes into revised licensee 01/99 DISP performance assessment process (9700238)(NRR) P. Wilson, DSSA l
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8 October 9,1998 PRIOR TO JANUARY 28,1999 Milestone Date Lead )
i
l THROUGH JUNE 30,1999 j Milestone Date Lead l
- 14. Develop risk attributes for revising enforcement early CY99 OE policies. Input to ll.C.S. (9800155) (OE) G. Kelly, DSSA BEYOND JUNE 30,1999 Milestone Date Lead l
l 15. First Phase 2 PRA standard developed TBD M. Drouin, RES
- 16. Completion of Phase 2 PRA standard TBD M. Drouin, RES Comments 2-Omft piecedure due cut 10/90 and tr&ining of NTIC inspectica st&ff vi!ll be camp lsted in C/99.
- 6. Oriainally due 9/98. PMs received internal guidance on 10/1/98 and are informing licensees accordingly,
- 9. Draft inspection procedure issued for comment by Regions 9/29/98. CRGR meeting scheduled for 12/9/98. RILP meeting required.
- 10. ACRS & Commission review, industri vicrkshop (09/90), and PRA Steering Committee l meeting required. Public workshop completed 9/30/98.
Sa-d,11-13,15,16. Phase 1 is a standarri for full power operation, internal events only. Phase 2 is for external events and shutdown. Dates are tentative due to uncertainty associated with the number and nature of comments that may be received, the ASME review and approval process and the success of the working group in writing the Phase 2 standard. This is an ASME initiative and; therefore, the schedules are set by ASME.
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l t e i 9 October 9,1998 j
- 11. Toolc Area: Reactor Inspection and Enforcemen_t SES Manager: M. Johnson, Acting Chief, PIPB/ DISP /NRR and J. Lieberman, Director, OE i
A. Specific lasue: Risk Informed Basaiine Core inspection Proaram Program Manager - Jeffrey Jacobson, NRR and John Fiack, RES l
Objective: To develop and implement a more risk informed, efficient, and effective baseline core inspection program. By risk informed, it is meant that the inspection program's scope will be defined primarily by those areas that are significant from a risk perspective and that the '
inspection methods used to assess these areas will take advantage of both generic and plant specific risk insights.
l Coordination: Issues ll.A. " Risk Informed Baseline Core inspection Program," ll.B " Enforcement Program Initiatives," II.C. " Escalated Enforcement Program," til.A. " Performance Assessment Process improvements," and VI.G
- Event Reporting Rulemaking," require close coordination and the integration of specific tasks by the NRC staff. Responsible project managers are l coordinating these activities by assessing the impact of proposed program changes with the l other ongoing activities and ensuring that the overall objectives for each project are achieved.
Examples include, intra-project task force participation, workshop attendance, concurrent review of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory Oversight Process are being reviewed by all project groups and I evaluated for impact.
l PRIOR TO JANUARY 28,1999 Milestone Date Lead l 1. Establish management oversight panel (performance 9/98 C C. Holden, DISP assessment and risk informed inspection program)
- 2. Issue detailed plan and team charter 9/98 C J. Jacobson, DISP
- 3. Brief Commission TA's 9/98 C J. Jacobson, DISP
- 4. Select improvement team members 9/98 C C. Holden, DISP l J. Jacobson, DISP
- 5. Support NRR public workshop on soliciting input on 9/28/980 J. Flack, RES approaches to risk-informed inspection (RES to present l options at workshop).
- 6. Solicit input from stakeholders on scope of inspection at 9/28- J. Jacobson, DISP regulatory assessment public workshop, coordinating with 10/1/980 issue Ill.A.
- 7. Re-define core inspection program objectives based 10/98 J. Jacobcon, DISP upon oversight concept
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e-i 10 October 9,1998 l
l PRIOR TO JANUARY 28,1999 l 8. Dieft bounda;i conditions for core insp3ctlen progrem 10/98 C J. Jacobson, DISP i changes Meet with ACRS to discuss workshop results l
- 9. Ocyclsp guidence for assessing current core inepection 40/96 J.Jacobsen,Ol0P l program 409. Prepare draft recommendations on core inspection 10/30/98 J. Flack, RES based on review of BWR and PWR PRA.
140. Discuss with ACRS subcommittee proposed scope 11M5/98 J. Il6ck, CEO and approach J. Jacobson, DISP 121. neeearch to provide lneights en formulstion of & r;3k +N90 J. Ilack, CEO j lnfermed lnepection progrem Develop draft inspection 11/98 J. Jacobson, DISP
! program objectives 102. Assess current progrem &nd propc5e changes 12/98 J. Jacobson, DISP l Develop Commission Paper proposing a risk-informed l baseline core inspection program (9800156) (NRR) 143. Brief Commission TA's 12/98 J. Jacobson, DISP 154. Communicate proposed changes to staff to obtain 12/98 C. Holden, DISP l
internal stakeholder feedback l
J. Jacobson, DISP 165. Develop transition strategy 1/99 C. Holden, DISP 176. Brief Commission on recommended program changes 1/99 J. Jacobson, DISP (9800156) (NRR)
THROUGH JUNE 30,1999 Milestone Date Lead 187. Begin meking drafting program changes and conduct 2/99 J. Jacobson, DISP training of staff 198. Begin implementation of new core inspection program 3/99 J. Jacobson, DISP l
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11 October 9,1998 BEYOND JUNE 30,1999 Milestone Date Lead 20i J. Complete transition to risk informed core inspection 10/99 J. Jacobson, DISP program Comments:
Status:[ 11 milestones are on track, there are no schedule changes, and no expected delays.
Changes to original milestones 8,9,12, and 13 reflect deliverables of program review.
- 1. The establishment of a management oversight panel will ensure timely guidance on policy issues both prior to and during the development of the process. The oversight panel will also heip to ensure organizational alignment and buy-in on the new process. The panel should include representatives from key stakeholder groups within the agency, primarily NRR and the Regions.
3 and 14. Briefings of commission TA's will be conducted at key milestones to help ensure organizational buy-in of the completed process. Formal briefings of the full commission will be conducted as part of a comprehensive briefing on the overall assessment process. These full commission briefings are indicated on the action plan for Performance Assessment Process improvements.
- 4. Improvement team members should include representatives from key internal stakeholder groups, primarily regional and resident inspectors.
- 6. Tr.a scope of the inspection program is scheduled to be discussed during the assessment process public workshop. During this workshop, feedback will be solicited from industry representatives as well as members of the general public. Also, the workshop results will be published and used to communicate to the staff the issues currently being considered in developing the new inspection program, t
- 7. The inspection program objectives will be re-defined after agreement is reached on a redefined assessment process framework.
- 13. A team approach will be utilized in assessing the current program and proposing changes.
Included within the team will be a representative from the Office of Research who will help in ensuring the new inspection program is risk informed.
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- 15. An important part of the change management strategy for implementing the new inspection l and assessment programs will be communication with the staff both during and after i
development.
- 16. " Change management" concerns should be addressed as part of developing the transition strategy.
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12 October 9,1998
- 18. Training to includo overview of specific program changes as well as restatement of selected inspection fundamentals regarding interfaces with licensees.
Deferrals and Suspensions: I Upon Commission approval, the staff wiH suspended SALP in a structured manner. Plant performance wiH continues to be addressed by Plant Performance Reviews (PPRs). The l resources to accommodate the accelerated efforts of the Tasking Memorandum pertaining to l inspection, enforcement and performance assessment will be derived from a combination of
! those efforts planned previously in these areas, staff redirection over the next year, and the resources derived from suspension of the SALP process. The expectation is that by January, l 1999 progress on the enhanced assessment process will be sufficient to determine whether the SALP process will be conducted in the future.
RES work assessing the effectiveness of the station blackout and anticipated transient without scram rules and generic safety issue A-45 (decay heat removal) will be deferred from 12/98 to 4/99. (9700346)(NRR)
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13 October 9,1998 I
- 11. Reactor inspection and Enforcement SES Manager: James Lieberman, Director, Office of Enforcement ,
B. Enforcement Proaram initiatives issues / Lead Individual:
- 1) NRC-licensee documentation and disposition of non-risk significant violations Mark Satorius
- 2) Severity LevelIV violations Mark Satorius
- 3) Industry Enforcement Process Proposals Mark Satorius Due to the manner that these three issues are linked, all are being considered under one Plan of Action.
Objective: Reduce licensee burdens associated with responding to non-risk significant violations (Issues Nos.1 and 2) utilizing initial stakeholder inputs and proposals and soliciting stakeholder feedback following implementation of Enforcement Program changes (Issue No.-43), without losing the NRC's ability to detect licensee problems in a timely manner.
Coordination: Issues li.A. " Risk Informed Baseline Core Inspection Program," II.'B. " Enforcement Program Initiatives," ll.C. " Escalated Enforcement Program," lll.A. " Performance Assessment Process improvements," and VI.G " Event Reporting Rulemaking," require close coordination and the integration of specific tasks by the NRC staff. Responsible project managers are coordinating these activities by assessing the impact of proposed program changes with the other ongoing activities and ensuring that the overall objectives for each project are achieved.
Examples include, intra-project task force participation, workshop attendance, concurrent review of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory Oversight Process are being reviewed by all project groups and evaluated for impact.
PRIOR TO JANUARY 28,1999 Milestone Date Lead i
- 1. Implement an Enforcement Guidance Memorandum EGM M. Satorius (EGM) to clarify guidance under the existing issued on Enforcement Policy that provides licensees incentives 7/27/98C to self-identify and correct problems in order to avoid l the issuance of notices of violations.
I 2. Monitor the success of EGM 98-006 on lessening Begin M. Satorius the burden to licensees by reducing the volume of 9/1/98 and E.everity Level IV violations, including violations not continue cited and both those requiring and not requiring a response.
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14 October 9,1998 j PRIOR 10 JANUARY 28,1999 3.1 Conduct a public meeting with stakeholders to solicit 9/3/98C M. Satorius l input on the manner that the Enforcement Policy may !
be revised.
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- 4. . Utilize previously received written inputs from 9/18/98C M. Satorius extemal stakeholders that provides positions on the i: manner that the objectives should be accomplished.
1
- 5. Submit a Commission Paper incorporating the views HV+fW98 M. Satorius l of intemal and extemal stakeholders that provides the 10/23/98 L Commission several options (and the staff's j recommendation) on the manner to achieve the i objectives by propuing an Enforcement Policy change. .
It,l; papes and to prepe;;d ;t,ange; # l ;l;e addio;; !
- he agency's reapenas to ;adust,-/a concerne in :he use
- . of "regu;e
- esy e go;f' ace." (0000009) (OC) (9800174) l (OE)
- 6. Commission approves staff Enforcement Policy 11/16/98 M. Satorius revision and the Revised Policy is published in the ,
- Federal Register, with the message to stakeholders j that six months after implementation of the Revised !
L Policy, public meeting / workshops will be held for i
stakeholder feedback.
> 4
- 7. Conduct Regional Enforcement Coordinator 12/1/98 M. Satorius 1 meeting / training on the Revised Enforcement Policy. i i- 8. Conduct video conferencing with Regional Week of M. Satorius l l managers to outline the changes to the Enforcement 12/7/98 Policy and provide agency expectations.
- 9. Conduct training in the Regional offices, with a - Late M. Satorius
!- focus on agency expectations for the Revised November-Enforcement Policy. EDO/DEDE/DEDR provides Early senior management's expectations at the scheduled December counterpart meetings attended by those individuals. 1998 l 10. Implement revised Enforcement Policy. 30-days M. Satorius l after the i
Policy is
! published in the Federal 4 Register (assume
- 12/16/98) u l
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15 October 9,1998 PRIOR TO JANUARY 28,1999
- 11. Evaluate inspection data to determine the extent of 12/16/98, M. Satorius success that EGM 98-006 had in reducing burden to and update licensees. Provide this information to the Chairman for until the the Senate Hearing. (9800158)(OE) time of the hearing
- 12. Collect enforcement data following the Begin M. Satorius implementation of the Revised Enforcement Policy, for 12/16/98, later use in determining the success of the changes in and accomplishing the objectives. continue THROUGH JUNE 30,1999 Milestone Date Lead
- 13. Solicit feedback from regional management, the Spring M. Satorius inspection staff, and headquarters staff on the 1999 successes or failures of the Revised Enforcement Policy.
- 14. Conduct public meetings / workshops with 6/16/99 M. Satorius stakeholders, one in the Washington area and one in an area around a Region, to solicit feedback on the successes and shortcomings of the Revised Enforcement Policy.
BEYOND JUNE 30,1999 Milestone Date Lead
- 15. Assemble the collective views of the staff and 9/1/99 M. Satorius stakeholders to determine whether the Revised Enforcement Policy has accomplished the objectives, or whether further staff action is needed. Submit Commission paper. (9800159) (OE)
- 5. Reflects SRM guidance, i
1 i 16 October 9,1998 l
IlJeactor Inspection and Enforcement l
l SEE Manager: James Lieberman, Director, Office of Enforcement l
l Q, E.igniated Enforcement Proaram Initiatives "Reaulatory Slanificance"/ Risk Objective: Incorporate clearer risk-informed enforcement guidance in the treatment of escalated violations.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Conduct a public meeting with stakeholders to solicit input 9/3/98C M. Satorius, on the manner that risk should be incorporated into the OE Enforcement Policy
- 2. Submit a Commission Paper incorporetlng the views of 10/10/90 M. Satorius, intern &l &nd extem&l stekehclders th&t provides the 10/30/98 OE Ocmm:se:en sever &l cptlcas (&nd the steff's recommendetica) en the menner 10 schiave the objectives by proposing en Enforcement Icl icy ch&nge. This peper end the picpesed chenges wlll &!5c eddie5e the egency's response te industry's conceme-in that addresses the use of " regulatory significance."
(9800069) (OE)
THROUGH JUNE 30,1999 Milestone Date Lead
- 3. Develop risk-info med examples for inclusion in the 3/15/99 M. Satorius, supplements of the Enforcement Policy. OE
- 4. Discuss examples with stakeholders and solicit feedback 3/29/99 M. Satorius, OE
- 5. Submit a Commission Paper utilizing the input from issue 5/1/99 M. Satorius, l.D.14 and the examples developed above to revise the OE Enforcement Policy. (9800155)(OE)
Comments:
- 2. Following Commission action on Milestone 2 the staff will proceed with the implementation l ' actions discussed in Specific Issue ll.B. Due date change based on OE concentrating its efforts
! to develop the Commission paper on making changes to the enforcement policy to reduce
' unnecessary licensee burdens in the area of non-escalated enforcement action.
3-5 Input will be provided by NRR and RES.
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.~* _ l 17 October 9,1998 l
l 111.Toolc Area: Reactor Licensee Performance Assessmen1 SES Manager: M. Johnson, Acting Chief, PIPB/ DISP /NRR A. Specific lasue: Performance Assessment Process improvements (IRAP. Industry's ;
Proposal. and Performance Indicators)
Program Manager: David Gamberoni i
Objective: The objective of this task is to develop and implement improvements to the NRC plant performance assessment process to make it more risk-informed, efficient, and effective while combining the best attributes of the IRAP effort, the regulatory oversight approach proposed by NEl, and the staff efforts designed to develop risk-informed performance indicators.
Coordination: Issues ll.A. " Risk Informed Baseline Core inspection Program," ll.B. " Enforcement Program Initiatives," ll.C. " Escalated Enforcement Program," lll.A. " Performance Assessment Process improvements," and VI.G " Event Reporting Rulemaking," require close coordination and the integration of specific tasks by the NRC staff. Responsible project managers are coordinating these activities by assessing the impact of proposed program changes with the other ongoing activities and ensuring that the overall objectives for each project are achieved.
Examples include, intra project task force participation, workshop attendance, concurrent review of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory Oversight Process are being reviewed by all project groups and evaluated for impact.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Transition to an annual senior management meeting C J. Isom, DISP
- 2. Review and discuss with NEl their proposed assessment 8/98C D. Gamberoni, process DISP
- 3. Suspend SALP upon Commission approval TBB- D. Csinberen!
l 9/98 C T. Boyce, DISP l 4. Hold public workshop to obtain external stakeholder input 9/98 C T.Frye, DISP D.Gamberoni, DISP l 5. Research to provide risk insights on oversight framework 9/98 C M. Cunningham, (corner stones) RES l
l 6. End of public comment period for performance 10/6/98 T. Frye, DISP l assessment process improvement
18 October 9,1998 PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 7. Brief ACRS to obtain their input 10/98 C M. Johnson, DISP
- 8. Brief Commission on results of public comments 10/98 M. Johnson, DISP
- 10. Research to provide recommendations on formulation of 12/98 M. Cunningham, a risk-informed assessment and inspection concept. RES
. 11. Hold regional and headquarters meetings to obtain 11/98 M. Johnson, DISP internal stakeholder input
- 12. Brief ACRSlto obtain their. input 11/98 M. Johnson, DISP 123. Brief Commission TAs 12/98 M. Johnson, DISP 104. Provide results of review o' public comments and 1/99 M. Johnson, DISP recommendation for cha,nges to the assessment process to the Commission. Submit Commission paper. (9700238)
(NRR) 145. Brief Commission on recommendations (9700238) 1/99 M. Johnson, (NRR) DISP r
THROUGH JUNE 30,1999 1
Milestone Date Lead 156. Obtain Commission approval for implementation of 3/99 M. Johnson, DISP recommended changes 167. Obtain Industry approval to make public the data used 6/99 T. Wolf, AEOD in Indust 's proposed Indicators for monitoring plant performance. Begin phase out of current Performance -
Indicator Program.
178. Complete development of implementation plan. Start 6/99 M. Johnson, DISP phase-in of the revised assessment process.
109. Begin trial application of risk-based performance 6/99 T. Wolf, AEOD indicators.
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19 October 9,1998 BEYOND JUNE 30,1999 Milestone Date Lead
+920. Complete trial application, brief Commission, and publish 11/99 T. Wolf, AEOD candidate risk-based indicators for public comment. (9800160)
(AEOD) 201. Publish last Performance Indicator Report using current 1/00 T. Wolf, AEOD Pls 2+2. Hold public workshop on candidate risk-based 2/00 T. Wolf, AEOD performar,ce indicators.
223. Complete phase-in of the revised assessment process 6/00 M. Johnson, DISP 234. Brief commission on proposed risk-based performance 10/00 T. Wolf, AEOD indicators developed cooperatively by NRC and industry (9800161) (AEOD) 245. Implement Commission approved risk-based performance 1/01 T. Wolf, AEOD indicators developed cooperatively by NRC and industry M. Johnson, DISP 256. Complete evaluation of implementation and effectiveness 6/01 M. Johnson, DISP of the revised assessment process Comments:
- 4. The public vverkshop is scheduled for Oeptember 20 - October 1, t300.
Status: All milestones are on track, there are no schedule changes, and there are no expected delays.
- 12. Additional milestone was added to meet the objective.
Deferrais and Suspensions:
Upon Commission approval, the staff wH suspended SALP in a structured manner. Plant performance wilt-continues to be addressed by plant performance reviews (PPRs). The resources to accommodate the accelerated efforts of the Tasking Memorandum pertaining to inspection, enforcement and performance assessment will be derived from a combination of those efforts planned previously in these areas, staff redirection over the next year, and the resources derived from suspension of the SALP process. The expectation is that by January, 1999 progress on the enhanced assessment process will be sufficient to determine whether the SALP process will be conducted in the future.
The Agency intends to use the proposed Industry performance indicators in the assessment of plant performance to the maximum extent possible. Their impact on the regulatory process will depend on their ability to provide information needed to assure that key safety " cornerstones" are being met. A phased approach is envisioned wherein consensus on the " cornerstones" and the attributes of indicators will be reached. The proposed industry indicators will be used
e 20 October 9,1998 accordingly and the current NRC Performance Indicators will be phased out. In parallel, the agency will work with industry and other stakeholders to develop a more comprehensive set of risk-based performance indicators to more directly assess plant performance relative to the
" cornerstones". These risk-based indicators will be phased in as part of an evolutionary approach to increasing the risk-informed, performance based nature of regulation.
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21 October 9,1998 i
IV.ToDic Area: Reactor Ucensina and Overslaht SES Manager: Chris Grimes, Director, PDLR/DRPM/NRR A. SDecific issue: License Renewal (includes Calvert Cliffs, Oconee and Generic Process improvements)
Objective: Demonstrate that license renewal applications submitted under 10 CFR Parts 54 & 51 can be reviewed effectively, efficiently and promptly.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Maintain Calvert Cliffs and Oconee schedules Ongoing C. Grimes, DRPM
- 2. Conduct bi-monthly meetings with license renewal bimonthly C. Grimes, DRPM applicants
- 3. Issued Policy Statement " Conduct of Adjudicatory 7/28/98C OGC Proceedings" issued 63 FR 41,872 (8/5/98)
- 4. Issued case specific order- Calvert Cliffs 8/19/98C OGC
- 5. Steering Committee meeting with NEl Working Group 6/18/98C C. Grimes, DRPM 8/20/98C
- 6. ACRS subcommittee meeting on renewal process 7/16/980 C. Grimes, DRPM
- 7. Agree on generic issue inventory / priority with NEl 9/98C C. Grimes, DRPM
- 8. Increased emphasis on renewal with EC and LRSC Ongoing C. Grimes, DRPM 9., Staff complete technical RAls - Calvert Cliffs 9/7/980 C. Grimes, DRPM
- 10. Staff complete environmental RAls - Calvert Cliffs 10/7/90 C. Grimes, DRPM 9/28/98C l 11. ACRS subcommittee briefing on renewal activities 11/18/98 C. Grimes, DRPM 4412. Staff complete technical RAls - Oconee 12/4/98 C. Grimes, DRPM l-4213. Staff complete environmental RAls - Oconee 1/3/99 C. Grimes, DRPM l
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22 October 9,1998 i THROUGH JUNE 30,1999 Milestone Date Lead 4014. Issue Draft Env;ronmental Statement for comment 3/6/99 C. Grimes, DRPM
- Calvert Cliffs 4415. Complete Safety Evaluation Report (SER) and 3/21/99 C. Grimes, DRPM identify open items - Calvert Cliffs
- 17. ACRS full committee meeting on Calvert Cliffs SER 5/99 C. Grimes, DRPM and open items 4518. Issue Draft Environmental Statement - Oconee 6/2/99 C. Grimes, DRPM 4f19. Complete SER and identify open items - Oconee 6/17/99 C. Grimes, DRPM BEYOND JUNE 30,1999 Milestone Date Lead
- 21. ACRS full committee meeting on Ocnnee SER and 9/99 C. Grimes, DRPM open items 4722. Issue Supplemental SER and Final Environmental 11/16/99 C. Grimes, DRPM
< Statement - Calvert Cliffs
- 24. ACRS full committee meeting on Calvert Cliffs 2/00 C. Grimes, DRPM Supplemental SER 4625. Issue Supplemental SER and Final Environmental 2/12/00 C. Grimes, DRPM ;
Statement - Oconee
- 26. ACRS subcommittee meeting on Oconee. 3/00 C. Grimes, DRPM l
Supplemental SER 4
4928. Complete staff review of initial applications within Ongoing C. Grimes, DRPM
(
30-36 months I
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, BEYOND JUNE 30,1999 t
l l 9029. Hearing (if request granad) Per Comm.
l Sched.
! Comments:
! 1. Commission approves detailed license renewal schedules in terms of significant review milestones that will be included in the Operating Plan and monitored for Congressional reports.
6 & 7. Steering Committee meetings with industry and ACRS subcommittee meetings with staff will continue periodically to ensure effective resolution of technical and process issues. The Steering Committee will periodically report progress to the Executive Council in accordance with the memo to Chairman Jackson dated 3/6/93.
- 19. Next (third) application expected by late 1999.
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! 24 October 9,1998 IV. Topic Area: Reactor Licensina and Overslaht SES Manager: Jack Roe, Acting Director, DRPM/NRR l B. Specific issue: 50.59 Rulemaking l l
Objective: To provide clarity and flexibility in existing requirements l
PRIOR TO JANUARY 28,1999 Milestone Date Lead i
- 1. Issue SECY 98-171 providing proposed revisions to 7/10/98C E. McKenna, DRPM 10CFR50.59 for Commission review and approval ;
1
- 2. Issue DOMSECY 98-013 forwarding staff response 5/27/98 C E. McKenna, DRPM to issues raised in SRM on SECY 97-205 (3/24/98)
- 3. Conduct meeting with industry /public to solicit views 8/98C M. Drouin, RES i on options for making 50.59 risk-informed l
- 4. Issue proposed rule changes on 10CFR50.59 for 8/98 E. McKenna, DRPM !
l public comment 10/98
- 5. Trial application of actual 50.59 test cases to assess 10/98 M. Drouin, RES options 1
- 7. End of public comment period 44/98 12/98 E. McKenna, DRP.M l
- 11. Resolve issues identified durina comment period 1/99 E. McKenna, DRPM l
THROUGH JUNE 30,1999 Milestone Date Lead
2/99 DRPM
- 13. Issue paper containing final 10CFR50.59 rule to the S/992/99 E.McKenna, Commission (9700191) (NRR) and provide DRPM recommendation on scope of 10 CFR 50.59 (9800044)(NRR)
_ _ - _ . _ _ . ~ - . _. _ _ _ . _ _ _ _ - .. _ . _ _ _ . - _ . . _ _ _
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l 25 October 9,1998 THROUGH JUNE 30,1999 l
- 14. Publish final rule change 10CFR50.59 6M4/99 E. McKenna, l DRPM l
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Comments:
l 3,5,6,8-10. RES assessing options and recommending approach to make 50.59 risk-informed.
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l 4. "eper en prepoed Iule at the Comm;eeien evial ting eppreval SRM issued 9/26/98.
NMSS/SFPO is working in conjunction with NRR to modify 10 CFR 72.48 which is comparable to 10 CFR 50.59 (Contact: W. Kane) 4 and 7,11-14. These milestones changes reflect delsys ln prev ously establl5hed schedujea to
! refleet the deliberations occurring at the Commission on policy issues. Any further delays in
! getting the ruls pubi;shed for comment velll result in addition &l delays in pub ll5hing the fine: rule.
l Deferrals; The start of RES work on low power and shutdown risk will be deferred from 10/98 to 1/99.
(9800039) (RES) 1 1
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i 26 October 9,1998 i
i IV. Topic Area: Reactor Licensina and Overslaht l
SES Manager: Dave Matthews, Deputy Director, DRPM, NRR l
C. Specific issue: FSAR Update Guidance I
! l l Objective: To provide consistent guidance on information to be contained in FSAR l
l PRIOR TO JANUARY 28,1999 Milestone Date Lead l
- 1. Submit SECY 98-087 to Commission which contains 4/20/98C T. Bergman,
- proposed guidance on information to be contained in DRPM FSAR l 2. SRM/SECY 98-087 directs staff to work with industry to 6/30/98C T. Bergman, resolve issues and endorse industry guidance DRPM
- 3. Issue staff comments on NEl 98-03 dated 7/8/98 8/98/98 T. Bergman, ;
9/1/98C DRPM i l
l 4. Receive revised NEl 98-03 earirect: T. Bergman, l
+998 DRPM l
9/30/98C ,
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- 5. Resolve final staff comments early Nov. T. Bergman, 1998 DRPM
! guide which endorses industry guidance 1998 DRPM
- 7. Submit paper with draft regulatory guide to 42/24/90 T. Bergman, Commission (9700198)(NRR) 12/31/98 DRPM
- 8. Publish draft regulatory guide endorsing NEl 98-03 for 1/28/99 T. Bergman, comment (60 days) DRPM l
l THROUGH JUNE 30,1999 Milestone Date Lead
- 9. Resolve issues identified during public comment period 5/30/99 T. Bergman, l
DRPM i
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27 October 9,1998 1
THROUGH JUNE 30,1999 1
BEYOND JUNE 30,1999 Milestone Date Lead 4 1
- 11. Submit paper and final regulatory guide to 8/1/99 T. Bergman, DRPM Commission (9700198)(NRR) l I
Comments:
- 1. If closure can be reached with NEl, a regulatory guide will be the product l if not, a generic letter will be used.
- 2. negarding M;lestone No. 4, a meeting ls planned for lste August or early Oeptember.
- 7. Reflects SRM guidance.
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- 4 28 October 9,1998 1
IV. Toolc Area: Reactor Licensina and Overslaht SES Manager: Dave Matthews, Deputy Director, DRPM/NRR D. Specific issue: Lefine Deslan Basis Objective: To provide a clear definition of what constitutes design bases information. l PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. NEl submits 97-04 for information 10/8/97C
- 2. SRM/SECY 97-205 directs staff to continue to 3/24/98C S. Magruder, DRPM develop guidance regarding design bases issues l 3. Issue preliminary staff comments on NEl 97-04 8/18/98C S. Magruder, DRPM
- 4. Meet with NEl to discuss staff comments on early S. Magruder, DRPM NEl 97-04 Sept-4996 9/18/98C
! 5. NEl submits revised NEl 97-04 for review and early
! endorsement Dec.
l 1998
- 6. Resolve final staff comments late Jan. S. Magruder, DRPM 1999 THROUGH JUNE 30,1999 51ilestone Date Lead
- 7. ACRS and CRGR review of SECY and draft early S. Magruder, DRPM regulatory guide that endorses NEl 97-04 Feb.
1999
- 8. Submit paper with draft regulatory guide to 2/26/99 S. Magruder, DRPM Commission (9800044) (NRR)
- 9. Publish draft regulatory guide for public comment 3/19/99 S. Magruder, DRPM (60 days) i
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- 10. Resolve issues identified during public comment 7/19/99 S. Magruder, DRPM l period l
1999 l
- 12. Submit paper and final regulatory guide that 10/1/99 S. Magruder, DRPM endorses NEl 97-04 to Commission (9800044) (NRR)
Comments:
- 5. a. Schedule depends on NEl resctlor, of review of staff comments and willingness to submit NEl 97-04 for staff endorsement.
- b. NEl's initial reaction at 9/18/98 meeting was that NEl 97-04 should not be submitted for staff review and endorsement. However, NEl agreed to discuss this with their design basis working group and get back to the staff. Should NEl decide not to submit NEl 97-04 for review and endorsement, this topic area issue will need to be revised significantly, i
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30 October 9,1998 IV. Toolc Area: Reactor Licensina and Overslaht SES Manager: Bruce Boger, Acting Associate Director for Projects, NRR E. Specific issue: Improved Standard TS Lead: TSB Lead PM for each facility conversion Objective: Conversion of facility technical specifications to the appropriate improved standard technical specifications will promote more consistent interpretation and application of technical specification requirements, thereby reducing the need for interpretations and frequent changes to the technical specifications. The goal for each milestone listed below is to complete the conversions currently under review such that the above objectives are met for the affected facilities.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Issue iSTS Amendments for McGuire 1&2 and Catawba 1&2 09/98 ADPR C
- 2. Issue iSTS Amendments for Oconee 1/2/3* 40/98 ADPR 12/98
- 3. Issue ISTS Amendments for Byron 1&2* and Braidwood 1&2* 44/98 ADPR 12/98
- 4. Issue iSTS Amendments for Comanche Peak 1&2*, Wolf 12/98 ADPR Creek *, Callaway*, and Diablo Canyon 1&2*
THROUGH JUNE 30,1999*
Milestone Date Lead
- 5. Issue iSTS Amendments for Farley 1&2* 03/99 ADPR 5/99
- 6. Issue ISTS Amendment for Fermi 2* 04/99 ADPR 5/99
! BEYOND JUNE 30,1999*
- Milestone Date Lead
- 7. Issue iSTS Amendment for Palisades
- 07/99 ADPR
l 31 October 9,1998 ConNeniN 2[33 arid 6.EThe'new due' dates are a result of recent interactions with the affected licensee
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and are based upon licensee schedules to respond to issues and licensee desires for additional review time of the' draft SER.' The accelerated due dates previously provided did not permit sufficient time 1, The'new dates do not adversely impact licensee implementation schedules.
- Completion of the milestones as listed depends upon the quality of the licensee's submittals and timeliness of response to staff RAls.
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- 32 October 9,1998 IV. Toolc Area
- Reactor Licensina and Overslaht SES Manager: John Stolz, Acting Director, DRPM/NRR F. Specific issue: Generic Communications Objective: Ensure the appropriate use of generic communicatir- . increasing the efficiency of issuance, and utilizing the rulemaking process when appropriato.
PRIOR TO JANUARY 28,1999 l
! Milestone Date Lead
- 1. Issue memorandum on immediate changes to generic 8/7/980 J. Stolz, DRPM letter process (ET review of strategy; graded approach)
- 2. Meet with NEl for input on industry views on generic 8/27/98C J. Stolz, DRPM l
l communications
- 3. Complete self assessment and needed improvement to 12/98 R. Dennig, DRPM generic communications process. Issue report.
l THROUGH JUNE 30,1999 Milestone Date Lead
- Process improvements based upon self-assessment results completed in 12/98 BEYOND JUNE 30,1999 Milestone Date Lead None Comments:
- 1. Generic communications discussed with INPO in telephone conference 7/31/98 t
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33 October 9,1998 l .1V. Topic Area: Reactor Licer sina and Overslaht l
SES Manager: Bruce Boger, Acting Associate Director for Projects, NRR l
G. Specific Issue: CALs l
l Objective: Confirmatory Action Letters (CALs) are issued to emphasize and confirm a licensee's l or vendor's agreement to take certain actions in response to specific issues. The NRC expects
! licensees / vendors to adhere to any obligations and commitments addressed in a CAL and will j issue appropriate orders to ensure that the obligations and commitments are met. The goal of
! the milestones listed below is to ensure that staff guidance on the use of CALs is appropriate l and that the staff exercises appropriate discipline in the duvelopment and issuance of CALs.
l PRIOR TO JANUARY 28,1999 l Milestone Date Lead l 1. Review existing CALs (all future CALs must be reviewed by 9/30/98 C ADPR
! Director, NRR) l l 2. Reinforce expectations regarding use of current CALs to 9/24/98 C D. Pickett, l ADPR/ Region management ADPR
- 3. Review / issue revised guidance documents for threshold for 11/98 D. Pickett, ;
issuance of CALs (i.e., IMC 0350, procedures, etc.) to ensure ADPR I the existence of clear criteria for consistent decision making.
- 4. Reinforce expectations regarding revised guidance on use of 11/98 D. Pickett, l CALs to ADPR/ Region management ADPR l
l Comments Status: All milestones are on track, there are no schedule changes, and there are no expected delays.
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l 34 October 9,1998 i
j IV. Topic Area: Reactor Licensina and Oversicht j l
SES Manager: Jack Roe, Acting Director, DRPM/NRR l
H. SMcific issue: Applicability of Backfit Rule to Decommissionina Activities Objective: Resolve issue regarding proper interpretation and application of the Backfit Rule to decommissioning activities
! PRIOR TO JANUARY 28,1999 Milestone Date Lead
! 1. Issue initial determination on Maine Yankee backfit 4/21/98C J. Roe, DRPM claim l
- 2. Maine Yankee appeals backfit determination and 6/9/98C S. Weiss, DRPM presents backfit position to staff
- 5. Forward draft Commission paper on backfit rule to EDO 10/23/98 S. Weiss, DRPM (9800162) (NRR)
- 6. Meeting with Maine Yankee regarding backfit issues 10/26/98 S. Weiss, DRPM i 7. Issue Commission paper on backfit rule 11/30/98 S. Weiss, DRPM
- 8. Brief NEl on Commission decision 12/31/98 S. Weiss, DRPM j 1
i THROUGH JUNE 30,1939 Milestone Date Lead None l
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BEYOND JUNE 30,1999 l
Milestone Date Lead None 1
i
,_...m .m. m._. . . _ . _ . _ . . _ . _ _ .. . . _..m._._.__...._._
=.. ____.__.__._..______.______..__.1
. i 35 October 9,1998 Comments
- 3. Reflects additional time necessary to complete staff review of the backfit appeal. l J
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36 October 9,1998 IV. Topic Area: Reactor Licensino and Overslaht SES Manager: Brian Sheron, Acting Associate Director for Technical Review, NRR I. SDecificissue: Requests for AdditionalInformatio_q Objective: To refine / define RAI process and ensure that staff RAl's are adding value to the regulatory process.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Discuss issue of ensuring appropriateness of RAl's with Complete B. Sheron, ADT management and staff (including content, quality and continued oversight)
- 2. Communicate with licensees via telecon prior to issuing Ongoing ADPR .
RAl.
- 3. Meet with intemal stakeholders to discuss possible 9/14/98C B. Sheron, ADT closure of amendments with outstanding RAls and improved tracking of amendments with outstanding RAls.
- 4. Form panel of staff reviewers to brainstorm on 9/15/98C B. Sheron, ADT suggested improvements to the RAI process.
- 5. Stakeholder meeting with NEl on license amendment 10/5/98C B. Sheron, ADT/
and RAI process to solicit feedback from licensees. ADPR
- 6. Discussissues with each technical branch in NRR. Ongoing B. Sheron, ADT
- 7. Discuss issues with regional division directors at 12/1/98 B. Sheron, ADT DRS/DRP counterpart meetings. DRS
- 8. Issue guidance to staff on content, quality and threshold 12/98 S. Peterson, ADT of RAl's and commencement of initial acceptance review. RES, NMSS-G-9. Monitor outgoing RAls and responses Ongoing B. Sheron, ADT RES, NMSS
- 10. Solicit feedback from licensee's on RAls Periodic ADPR/
B. Sheron, ADT Comments l Status : All milestones on are track, there are no schedule changes and there are no expected delays.
l l 2-7. Additional milestones were added to meet the objective.
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37 October 9,1998 l
IV. Toolc Area: Reactor Licensina and Overslaht i
SES Manager: Bruce Boger, Acting Associate Director for Projects, NRR l J. Specific issue: 2.206 Petitions Objective: The objectives of the 2.206 Petition review process include ensuring the public health l
and safety through the prompt and thorough evaluation of any potential safety problem I
addressed by a petition filed under 10 CFR 2.206 and to ensure effective, timely communication with the petitioner (Management Directive 8.11). The objective of the actions listed below is to identify and implement measures to improve the timeliness of staff response to petitions.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Establish a Petition Review Board to ensure 10/97C R. Subbaratnam, management involvement early in the process ADPR
- 2. Establish public availability of monthly 2.206 Petition 04/98C R. Subbaratnam, Status Reports at the NRC Web site ADPR (http //www.nrc. gov /NRC/PUBLIC/2206/index.html)
- 3. Assess timeliness of resolution of 2.206 petitions and 10/30/98 R. Subbaratnam, brief EDO on the results and any proposed process ADPR improvements
- 4. Implement proposed 2.206 process improvements (if 12/98 R. Subbaratnam, any) ADPR THROUGH JUNE 30,1999 Milestone Date Lead
- 5. Show measured improvement in timeliness of 03/99 R. Subbaratnam, resolution of 2.206 petitions ADPR Comments Status: All milestones are on track, there are no schedule changes, and there are no expected delays.
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38 October 9,1998 IV Toolc Area: Reactor Licensina and Overslaht SES Manager: John F. Stolz, Chief, PECB/DRPM/NRR K. Specific lasue: Application of the Backfit Ru.'e Objective: Ensure that the staff closely adheres to the backfit rule,10 CFR 50.109 in evaluating ,
all additional requirements, expansion in scope or unique interpretations against actual impact l on public health and safety.- Focus wi!! be directed on risk-informed, performance based regulation; also coordinating with backfit related concerns on Generic communications (IV.F) and Decommissioning (IV.H) and Evaluation of Industry Proposals and Rulemaking (l.A). )
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Response to NEl letter 8/11/98. NEl recommendation for 10/98 R. Dennig, DRPM Near-Term Reg. Improvement - Recommendation 4,
" Application of the Backfit Rule"(a. Decommissioning;
- b. Averted On-site Costs)
- 3. Prepare staff positions on 12/98 R. Dennig, DRPM backfit related issues
- a. Averted on-site Costs R. Dennig, DRPM
- b. Handling of compliance backfit considering risk of 12/98 non-compliance (1) consider Exemptions per 10 CFR 50.12 (2) Early industry involvement in Generic Comrnunications process (Topic IV. Issue F Milestone .T
- 4. Meeting with EDO on items 3 a, b 12/98 R. Dennig, DRPM
- 5. Meeting with NEl on items 12/98 R. Dennig, DRPM
- a. Items 3a & b
- b. Commission decision on backfit to Decommissioning 12/98 S. Weiss, DRPM Activities (Topics IV. Issue H Milestone 8)
- 6. Commission Papers 11/98 R. Barrett, DSSA
- a. Options on Backfitting implications from modifying M. Cunningham, RES Part 50 to be risk-informed (Topic 1. Issue A.
Milestone 10) (9800152) (NRR)
- b. on items Sa. b (9800175) (NRR) 1/99 R. Dennig, DRPM
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! 39 October 9,1998 l
l THROUGH JUNE 30,1999 Elitestone Date Lead
hIllestone Date Lead l
8ICRGR Annual Report - includes Industry Feed back on Summer 99 CRGR l Effectiveness of Backfitting Process i
- 9. Backfit Training 'at Headquarters and Regions FY99 AEOD/NRR/HR Comments:
- Reference milestone on other Topic / Specific Issues noted.
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l 40 October 9,1998 l
V. Topic Area: NRC Oraanizational Structure and Resources SES MANAGER: Paul E. Bird, Director, HR l
A. Specific issue: Reoraanization - Restructurina Line Oraanizations Lead Manager: James F. McDermott, Deputy Director, HR Objective: To improve organizational effectiveness and determine resources required to carry out l
NRC activities through internal functional realignments and human resource reallocations.
l l PRIOR TO JANUARY 28,1999 i Milestone Date Lead
- 1. Offices initiate plans for proposed restructuring 8/19/980 J. McDermott l 2. All Employees Meeting 9/3/980 J. McDermott l
l 3. Restructuring proposals submitted to Commission 9/30/980 J. McDermott (9800163) (HR) 10/1/980
- 4. Completion of Commission review of res'ructuring 10/28/98 J. McDermott j proposal
! 5. Partnering process completed for reorganization 11/28/98 J. McDermott packages
- 6. Reorganization plans finalized 12/31/98 J. McDermott
- 7. Implementation begins 1/19/99 J. McDermott l
THROUGH JUNE 30,1999 Milestone Date Lead
- 8. Implementation completed 3/31/99 J. McDermott
- 3. Memo to Chairman Jackson 9/20/98 and SECY 98-228 dated 10/1/98.
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41 October 9,1998 V. Toolc Area: NRC Oraanizational Structure and Resources l
SES MANAGER: Paul E. Bird, Director, HR B. Specific lasue: Achievina 1:8 supervisor /manaaer-to-emploveo ratios Lead Manager: James F. McDermott, Deputy Director HR Objective: To reduce supervisory and SES positions to achieve an agency-wide supervisor / manager-to-employee ratio target of one supervisor / manager for every eight NRC employees.
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Continue existing supervisor / manager-to-employee Ongoing J. McDermott ratio reduction efforts
- 2. All Employees Meeting 9/3/98C J. McDermott
- 3. Quarterly assessment of supervisor / manager-to- 10/98 J. McDermott employee ratio
- 4. Develop targeted strategies to achieve supervisory 10/98 J. McDermott ratio goals
- 5. Year end assessment of supervisor / manager-to- 1/99 J. McDermott employee ratio incorporating the results of attrition, including the effect of early outs or buy outs (should buyouts be authorized by Congress)
THROUGH JUNE 30,1999 Milestone Date Lead
- 6. Complete implementation of reorganizations 3/31/99 J. McDermott developed to achieve streamlining goals
- 7. Implement strategies to achieve supervisory ratio 3/31/99 J. McDermott targets
- 8. Quarterly assessment of supervisor / manager-to- 4/99 J. McDermott employee ratio
- 9. Implement strategies to achieve supervisory ratio 5/31/99 J. McDermott l targets
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42 October 9,1998 I
l l BEYOND JUNE 30,1999 1
! Milestones Date Lead
- 10. Quarterly assessment of supervisor / manager-to- 7/99 J. McDermott employee ratio
- 11. Implement strategies to achieve supervisory ratio 7/15/99 J. McDermott targets l
Comments:
The milestones in the table above focus only on those aspects of the streamlining effort that address the supervisor / manager-to-employee ratio. Activity extends beyond the March 31,1999, deadline established for the structural changes contained in issue 1 since the human resources side of the effort are the most complex and difficult aspects of the overall reorganization to implement.
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43 October 9,1998 V. Topic Area: NRC Oraanizational Structure and Resources SES MANAGER: Paul E. Bird, Director, HR C. Specific lasue: Increased staff responsibilities Lead Manager: Individual Office and Regional managers Objective: To enhance organizational effectiveness under the specific conditions imposed by the agency-wide streamlining effort, including functional realignments, reductions in supervisory / managerial personnel, and increased spans of management control by delegating greater responsibility and accountability to individual employees and fostering greater interactive communications between employees and management. Issue 3 builds on existing efforts to increase staff responsibilities using these same techniques.
PRIOR TO JANUARY 28,1999 .
MILESTONE DATE Lead
- 1. Continue previous general efforts to foster Ongoing J. McDermott delegations of responsibility and accountability to employees and more interactive communications between employees and managers. Monitor office progress
- 2. All employees meeting 9/3/98C J. McDermott
- 3. Provide guidance to managers on the need to 9/30/90 J. McDermott consider greater use of delegations of responsibility 10/9/98 and accountability to employees.
- 4. Begin implementing delegations of responsibility and 1/19/99 J. McDermott accountability as techniques to enhance agency effectiveness on an office-by office basis THROUGH JUNE 30,1999 Milestone Date Lead
- 5. Continue implementation of delegations of 3/31/99 J. McDermott responsibility and accountability as individual office reorganizations are completed and implemented Comments:
The milestones for this issue establish a logical time period for beginning the local office process of employee delegations / empowerment planning and a logical point at which the local office environment should be transformed to a new culture.
- 3. In OEDO as of 10/6/98.
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44 October 9,1998 i VI. ToDie Area: Other Aaency Proarams and Areas of Focus SLS: Robert Wood, DRPM/NRR SES Manager: Joe Gray, OGC A. SDecific issue: License Transfers -
Objective: To ensure that license transfers are conducted in a timely and technically correct manner and that review and submittal guidance is appropriately disseminated. ,
PRIOR TO JANUARY 28,1999 Milestone Date Lead.
- 1. Issued proposed 10CFR Part 2 Subpart M hearing 8/14/98C J. Gray, OGC process - paper to Commission (SECY 98-197)
- 2. Publish proposed rule on license transfer (see SECY- 8/28/96 J. Fitzgerald, OGC 98-197) 9/11/98C ,
i
- 3. Submit final rules to Commission 11/3/98 J. Fitzgerald, OGC
- 4. Commission approves / affirms final rules 11/17/98 J. Fitzgerald, OGC
- 5. Publish final rules in Federal Reaister. 12/24/98 J. Fitzgerald, OGC
- 6. Final rules are effective. 12/24/98 J. Fitzgerald, OGC
- 7. Complete technical review of TMI-1 transfer See R. Wood, DRPM comment THROUGH JUNE 30,1999 Milestone Date Lead
- 8. Provide Commission with proposed final criteria for 0/10/99 R. Wood, DRPM triggering a review under 10CFR50.80 regarding the 6/25/99 transfer of operating authority to non-owner operators (i.e.,
use of contract service operating companies). (9800015)
(NRR)
- 9. Issue lessons learned from Ameroen TMI-1 transfer 6/99 R. Wood, DRPM BEYOND JUNE 30,1999 Milestone Date Lead
- 10. Issue precess improvement re: foreign ownership 12/99 S. Hom,0GC R. Wood, DRPM
45 October 9,1998 BEYOND JUNE 30,1999
- 11. Develop SRP on technical qualifications 12/99 DRCH 2 12. Develop SRP on license transfer process TBD S. Hom, OGC R. Wood,DRPM Comments: 52 R5flects SRM guidance. . .
Status::. All milestones are on track, there are no schedule changes, and there are no expected delays'
- 4. Submittal + 3 months i
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46 October 9,1998 VI. Topic Area: Other Aaency Proarams and Areas of Focus SES Manager: Chris' Grimes, Director, PDLR/DRPM/NRR B. Specific lasue: AP-600 Deslan Certification Rulemakina Objective: Issue FDA and design certification rule PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Issue FDA 9/3/98C T. Quay, DRPM THROUGH JUNE 30,1999 Milestone Date Lead issue proposed rule [PRM] 3/99 J.N. Wilson, DRPM_
BEYOND JUNE 30,1999 Milestone Date Lead issue Final Rule (FRN] 10/99 J.N. Wilson, DRPM_
Comments:
1ssues: Public availability of design documentation Approach: 1. Review Design Control Document (DCD)
- 2. Work with Westinghouse and the Office of the Federal Register to provide suitable public access to the DCD
- 3. Issue proposed design certification rule for public comment
- 4. Conduct public hearing,if requested
- 5. Evaluate and respond to public comments
- 6. Issue Final design certification rule
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47 October 9,1998 l l
VI. Topic Area: Other Aaency Proarams and Areas of Focus 1 I
SES Manager: William F. Kane, Director, Spent Fuel Project Office l C1. SDecific issue: TN-68 (Dual Purpose) Cask Review
. Ongoing technical review Mary Jane Ross-Lee Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the TN-68 dual purpose cask system (Comment 1)
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Staff receives response to storage RAI 09/98 M. Ross-Lee, SFPO j 09/14/98C
- 2. Staff issues second storage RAI, if necessary 12/98 M. Ross-Lee, SFPO
- 3. Staff receives response to second storage RAI 01/99 M. Ross-Lee, SFPO .
THROUGH JUNE 30,1999 Milestone Date Lead
- 4. Staff issues user need memorandum /rulemaking 03/99 E. Easton, SFPO
- 5. Staff issues draft SER and CoC for rulemaking 05/99 M. Ross-Lee, SFPO BEYOND JUNE 30,1999 Milestone Date Lead _
- 6. Staff completes rulemaking; issues CoC for use 04/00 E. Easton, SFPO/
under Part 72 P. Holahan, IMNS Comment:
- 1. The storage review is being completed prior to the transportation review; the transportation review schedule will be determined at a subsequent time. The review schedule is based upon the assumption that the applicant will supplement its application and response to staff requests for additionalinformation on the schedule noted. At this time, no significant issues have been identified.
The licensee for Peach Bottom 1 & 2 intends to utilize this cask system.
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48 October 9,1998 VI. Topic Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C2. Specific issue: BNFUSNC TranStor (Dual Purpose) Cask Review
. Ongoing technical review T. Kobetz Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the BNFUSNC dual purpose cask system (Comment 1)
PRIOR TO JANUARY 28,1999 Milestone Date Lead None THROUGH JUNE 30,1999 Milestone Dato Lead
- 1. Staff issues user need memorandum /rulemaking 44/90 E. Easton, SFPO 03/99
- 2. Staff receives updated SAR from applicant 02/99 T. Kobetz, SFPO 06/99
- 3. Staff issues draft SER and CoC for rulemaking 03/99 T. Kobetz, SFPO 07/29/99 BEYOND JUNE 30,1999 Milestone Date Lead
- 4. Staff completes rulemaking; issues CoC for use 02/00 E. Easton, SFPO/
under Part 72 06/00 P. Holahan, IMNS Comment:
- 1. The storage review is being completed prior to the transportation review;.the transportation review schedule will be determined at a subsequent time. At this time, no significant issues have been identified, but the applicant must update the safety analysis report by Februari June 1999. This review is associated with the Part 72 Trojan ISFSI (site-specific) license application, PFS, LLC intends to utilize this cask system as well.
By letter dated 09/18/98, the applicant notified the NRC that its response to the staff's 12/29/97 ,
request for additionalinformation will be delayed a month due to the need to support closure of issues associated with the VSC-24 cask system, to support the Trojan ISFSI application, to support existing cask users, and to ensure a complete and quality RAI response. The applicant indicated that its
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j 49 October 9,1998 i l
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response will bejissue'd by10/30/98.- The staff is currently evaluating the impact of the applicant's !
delay'on the previously issued schedule. j 5 2,'3f& 4. Bssed on SFPO's current work schedule and in accordance with its staff interactions with applicant's approach, theTranStor storage cask technical review has been rescheduled for completion on July 29, '1999. A letter advising the applicant of the revised schedule was issued on l October 2,1998; j VI. Toolc Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C3. Specific Issue: floltec HISTAR 100 (Dual-Purpose) Cask Review
. Technical review ongoing M. Delligatti Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the Holtec HISTAR 100 dual purpose cask system (Comment 1)
PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Staff issues user need memorandum /rulemaking 07/24/98C E. Easton, SFPO
THROUGH JUNE 30,1999 Milestone Date Lead
- 3. Staff issues transportation (Part 71) CoC 03/99 M. Delligatti, SFPO BEYOND JUNE 30,1999 Milestone Date Lead
- 4. Staff completes rulemaking; issues CoC for use 08/99 E. Easton, SFPO/
under Part 72 P. Holahan, IMNS
- Comment:
- 1. While the final review phase is ongoing and nearing completion, it is still unclear regarding the scope of the staff's approval on the storage component of the design. This review is being performed to support spent fuel storage requirements at Dresden 1 and Hatch 1 & 2, and PFS, LLC intends to utilize this cask system.
- 2. The' draft storage sER and CoC were issued on 09/30/98. The package was sent to NMSS/lNMS i to commence the rulemakirig process on 09/30/98.
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.l 50 October 9,1998 VI. Toolc Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C4. Specific issue: Westinahouse WESFLEX (Dual Purnose) Cask Review
= Ongoing technical review M. Bailey Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the Westinghouse WESFLEX dual purpose cask system (Comment 1) J PRIOR TO JANUARY 28,1999 Mi!estone Date Lead
- 1. Staff issues RAI for base storage system and W21 10/98 M. Bailey, SFPO canister
- 2. Staff issues RAI for W44 canister 11/98 M. Bailey, SFPO
- 4. Staff receives responses to RAls 03/99 M. Bailey, SFPO BEYOND JUNE 30,1999 Milestone Date Lead
- 5. Staff issues final RAI, if necessary 07/99 M. Bailey, SFPO
- 6. Staff receives response to RAI,if necessary 10/99 M. Bailey, SFPO
- 7. Staff issues user need memorandum /rulemaking 12/99 E. Easton, SFPO
- 9. Staff complete rulemaking; issues CoC for use under 12/00 E. Easton, SFPO/
Part 72 P. Holahan, IMNS Comment:
- 1. The storage review is being completed prior to the transportation review. The transportation application was resubmitted in May 1998, and the transportation review schedule will be determined at a subsequent time. The storage review has just cummenced, and at this time, no significant issues have been identified. Big Rock Point and Palisades intend to utilize this cask system.
. - - _ _ . - .-._ . - ~ . . - - -- - - . - . - . . --. . .- -.
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l VI. Toolc Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C5. SDeCIfiC lasue: NAC-STC/MPC (Dual Purpose) Cask Review
. Ongoing technical review T. McGinty
- Objective
- To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the NAC-STC/MPC dual purpose cask system i
. (Comment 1) l l
PRIOR TO JANUARY 28,1999 ,
I Milestone Date Lead
- 1. Staff receives response on transport RAI 08/07/98C T. McGinty, SFPO
- 2. Staff receives response on storage RAI 10/98 T. McGinty, SFPO
- 3. Staff issues user need memorandum /rulemaking 12/98 E. Easton SFPO I THROUGH JUNE 30,1999 Milestone Date Lead i
- 4. Staff issues Part 71 (transportation) CoC 04/99 T. McGinty, SFPO 03/99
BEYOND JUNE 30,1999 Milestone Date Lead
- 6. Staff complete rulemaking; issue CoC for use under 03/00 E. Easton, SFPO/
Part 72 02/00 P. Holahan, IMNS Comment:
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! 1. The storage and transportation review are being conducted concurrently. At this time, no i significant issues have been identified, but the applicant must respond by the time-frame noted in order for the staff to maintain this schedule. The licensee for Yankee /Rowe intends to utilize this cask system.
l 4,5, & 6. The dates were modified to be consistent with the schedule provided to the applicant.
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52 October 9,1998 VI. Topic Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C6. Specific issue: NAC-UMS (Dual Purpose) Cask Review i
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- Ongoing technical review T. McGinty j
! Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the NAC-UMS dual purpose cask system (Comment 1) l l PRIOR TO JANUARY 28,1999 Milestone Date 1
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- 1. Staff issues storage RAI 11/98 T. McGinty, SFPO ;
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- 2. Staff receives RAI response 01/99 T. McGinty, SFPO l THROUGH JUNE 30,1999 l
Milestone Date
- 3. Staff issues second storage RAI, if necessary 06/99 T. McGinty, SFPO
! BEYOND JUNE 30,1999 l
Milestone Date j
- 4. Staff receives second storage RAI response 08/99 T. McGinty, SFPO
- 5. Staff issues user need memorandum /rulemaking 08/99 E. Easton, SFPO
- 7. Staff completes rulemaking; issues CoC for use 10/00 E. Easton, SFPO/
under Part 72 P. Holohan, IMNS ,
Comment:
- 1. The storage review is being completed prior to the transportation review; the transportation review
' schedule will be determined at a subsequent time. At this time, no significant issues have been identified, but applicant must respond by the time-frame noted in order for the staff to maintain this schedule. The licensees for Fitzpatrick and Palo Verde 1,2 & 3 intend to utilize this cask system.
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53 October 9,1998 l l
VI. Topic Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office I C7. Specific issue: TN-West MP-187 (Dual-Purpose) Cask Review l
= lssue Part 71 certificate of compliance M. Raddatz Objective: To issue Part 71 (transportation) certificate of compliance for MP-187 transportation cask system PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Staff starts final review and SER compilation phase 08/03/980 M. Radditz, SFPO
- 2. Staff issues Part 71 certificate of compliance 09/10/98C M. Radditz, SFPO (Comment 1)
THROUGH JUNE 30,1999 Milestone Date Lead None BEYOND JUNE 30,1999 Milestone Date Lead None Comment:
- 1. This transportation system is the transport component of the TN-West NUHOMS storage design.
l As initially certified, its authorized contents will be limited to B&W fuel, although it may be amended at l a later date to address other fuel types. This action supports the decommissioning of the Rancho Seco spent fuel pool.
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f I 54 October 9,1998 VI. Topic Area: Other Aaency Proarams and Area of Focus SES Manager: Seymour Weiss, Director, PDND/DRPM/NRR D. Specific issue: Decommissionino Decisions Objective: Provide timely decisions on current issues and provide framework for decommissioning activities.
l PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Provide response to SRM for SECY-98-075 (DSI-24) 10/09/98 M. Masnik, DRPM (9700089) (NRR) 1a. Form task team to develop and provide input for 7/24/98C T. Markley, DRPM Commission paper 1b. Evaluate applicability of using templates for 8/21/98C P. Harris, DRPM decommissioning licensing actions 1c. Develop integrated set of milestones for addressing 8/21/98C R. Dudley, DRPM decommissioning initiatives under development or contemplated 1d. Complete draft Commission paper for concurrence 9/2/980 T. Markley, DRPM 1e. Submit paper to Commission (9700089) (NRR) 10/09/90 T. Markley, DRPM 10/23/98
- 2. Meeting with NEl and industry to present Commission 1/15/99 S. Weiss, DRPM integrated milestones for decommissioning initiatives necessary for above rules and existing rules
- 3. Complete the following pending licensing actions.
3a Maine Yankee M. Webb, DRPM Exemptions from Financial Protection Requirements of 12/15/98
< 10 CFR 50.54(w) and 10 CFR 140.11 Technical Specification change to spent fuel pool water 11/15/98 l level 3b. Haddam Neck T. Fredericks, Exemptions from Financial Protection Requirements of 11/30/98 DRPM l
10 CFR 50.54(w) and 10 CFR 140.11 Technical Specification change to seismic monitoring 12/31/98 3c. Big Rock Point P. Harris, DRPM Defueled Technical Specifications revision 11/30/98 Defueled Emergency Plan exemption 10/15/98 Def,ueled Emergency Plan approval 10/15/98 Defueled QA Plan 11/30/98 l
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THROUGH JUNE 30,195U Milest"one Date Lead l
- 1. Compiete th's foll6 wing pending licensing actions.
la.' Maine'Yahked M. Webb, DRPM Exemption from 10 CFR 70.24 Criticality Accident 4/15/99 Monitoring Requirements l 1b. LZion . .. .
T. Markley, DRPM Exemption from 10 CFR 70.24 Criticality Accident 4/16/99 l iMonitoring requirements .
l BEYOND3UNE 30,1999 Milestone Date Lead
- 1. Complete the following pending licensing actions.
Ia. Maine Yankee M. Webb, DRPM Modification of License Conditions 7/30/99 Technical Specifications change to liquid and gaseous 8/15/99 release limits Ib. Haddam Neck T. Fredericks, Technical Specification change _to refueling and admin 9/30/99 DRPM requirements Comments:
- 1. Schedules are based on meeting established Commission due dates for DSI-24 SRM response.
1e. Extension due to workload demands.
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! 56 October 9,1998 l
l l VI. Toolc Area: Other Acency Proarams and Areas of Focus SES Manager: Susan F. Shankman, Dep. Director, Licensing and inspection Directorate, SFPO E. Specific issue: PGE-Troian Reactor Vessel Shloment Acolication
- Part 71 exemption (SER and EA) J. Cook l
. Waste classification,if necessary J. Hickey l Objective: To issue Part 71 (transportation) approval to ship the Trojan reactor vessel, with internals, for disposalin the State of Washington PRIOR TO JANUARY 28,1999 i Milestone Date Lead
- 1. Staff prepares SER for Part 71 approval 09/98 J. Cook, SFPO 09/30/980
- 2. Staff prepares EA 09/98 J. Cook,SFPO l 09/30/98C L 3. Staff waste classification, if necessary (separate 08/17/98C J. Hickey, DWM l SECY memorandum) (NMSS) l 4. Staff prepares negative consent SECY paper on 40/98 J. Cook, SFPO transportation and FONSI (9800022) (NMSS) 10/2/98C l 5. Commission issues SRM, if appropriate, on Part 71 10/98 OCM exemption (Comment 1)
- 6. Staff issues Part 71 decision 11/98 S. Shankman, SFPO l
l THROUGH JUNE 30,1999 Milestone Date Lead None l
BEYOND JUNE 30,1999 Milestone Date Lead
- 7. Inspection follow-up prior to and during shipment 08/99 B. Spitzberg, (Comment 2) RIV Comments:
- 1. In parallel to staff action: (1) the State of Washington must prepare a technical evaluation for disposal, tentatively scheduled for September 1998; (2) the Department of Transportation must grant J an exemption, tentatively scheduled for November 1998; and (3) the State of Oregon must approve this as a change to the utility's Decommissioning Plan, tentatively scheduled for November 1998.
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57 October 9,1998
- 2. PGE's decision to grout the reactor vessel is scheduled to occur in November 1998. The actual grouting would commence in December 1998, and vessel shipment would occur in August 1999.
Staff actions at these points would be to inspect as appropriate.
The State of Washington has prepared its technical evaluation report on the waste classification. The State of Washington will not issue a final technical evaluation report until after the closure of its public comment period.
EPapeitschinm.T0/2/98l E
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58 October 9,1998 i
l VI. Toolc Area: Other Aaency Proarams and Areas of Focus '
- SES Manager
- John Stolz, Chief, PECB/DRPM/NRR j F. Specific issue: Event Reportina Rulemakina Objective: Revise event reporting requirements to reduce the reporting burden associated with events of little or no risk significance, obtain information better related to risk, and extend reporting time limits consistent with the need for prompt NRC action.
Coordination: Issues li.A. " Risk Informed Baseline Core Inspection Program," II.B. " Enforcement l Program Initiatives," ll.C. " Escalated Enforcement Program," lil.A. " Performance Assessment Process
! Improvements," and VI.G " Event Reporting Rulemaking," require close coordination and the l integration of specific tasks by the NRC staff. Responsible project managers are coordinating these !
activities by assessing the impact of proposed program changes with the other ongoing activities and ensuring that the overall objectives for each project are achieved. Examples include, intra-project task force participation, workshop attendance, concurrent review of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory l
Oversight Process are being reviewed by all project groups and evaluated for impact.
1 PRIOR TO JANUARY 28,1999 Milestone Dato Lead
. 1. Issue ANPR 7/28/98C D. Allison, AEOD
- 3. Public workshop / stakeholder meetina (Chicano) 9/1/98C T. Essia. DRPM THROUGH JUNE 30,1999 Milestone Date Lead
- 4. Conduct a public meeting (" tabletop exercise") 11/13/98 D. Allison, AEOD 5.TCRGR Briefing 2/26/99 D. Allison, AEOD 6.' ACRS Briefing 3/5/99 D. Allison, AEOD 7.' Proposed rule' to the Commission (9800096) (AEOD) 3/26/99 D. Allison, AEOD
- 48. Publish proposed rule (10CFR50.72 and 50.73) 4/2/99 DRPM 5/14/98
- 9. Conduct a public workshop 5/28/99 D. Allison. AEOD 1
- BEYOND JUN2 30,1999 Milestone Date Lead
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- I 59 October 9,1998 1
BEYOND JUNE 30,1999
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D. Allison, AEOD 157 Fin'al RUleld 60mmisslori (9800096) (AEOD) 12/24'99 /
513. Publish Final rule 4/00 DRPM 2/00 C$'mments
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4.'In re'sponse t'o public comments on the advance notice of proposed rulemaking (ANPR), an additional public meeting (' tabletop exercise") has been scheduled. The purpose is to test key aspects of the contemplated amendments to 10 CFR 50.72 and 50.73 for clarity and consistency, early in the process of drafting them, by discussing how reportability decisions could be made for example events. This_will provide insights to be used in completing the draft requirements and guidance.- it will extend the overall rulemaking schedule by 5 weeks.
- 9. In response to public comments on the ANPR, a public meeting (" workshop") has been added, early in the comment period for the proposed rule. It does not change the overall schedule.
5,6,10, and 11. These are not associated with any developments. They'are added merely to provide additional detail.
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l i 60 October 9,1998 VI. Topic Area: Other Agency Programs and Areas of Focus SES Manger: Jack Roe, Acting Director, DRPM/NRR l G. Specific issue: Proposed Kl Rulemaking
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l Objective: To implement Commission decision regarding the use of KI as a protective measure for the l general public after a severe reactor accident. In addition, to work with other Federsi agencies to
- revise the Federal policy on the use of Kl in the event of a severe nuclear power plant emergency and I to develop aids to assist the states in applying the revised Federal policy.
PRIOR TO JANUARY 28,1999 Milestone Date Lead l
- 1. Commission direction received 6/26/98 C A. Mohseni
- 2. Draft and send to Commission Federal Register 7/98 C A. Mohseni notice on Federal KI policy
- 3. Revise Kl technical paper (NUREG 1633) to 40/96 A. Mohseni address public comments and provide to Commission 9/99 (9700193) (AEOD)
! 4. Revise KI Federal Policy FRN and provide to 11/98 A. Mohseni l FRPCC for review
Sa. Publish Proposed Rule (9800173)(NRR) 11/30/98 M. Jamgochian, NRR
- 6. Publish final technical paper (NUREG-1633) 1998 A. Mohseni 10/99 l
- 7. Develop description of available Federal Kl 1/99 A. Mohseni stockpiles and availability to states
- 8. Develop final Kl Federal policy FRN reflecting 1/99 A. Mohseni FRPCC review and send to Commission (9700193)
(AEOD)
- 9. Draft a public brochure on use of Kl and provide for 1/99 A. Mohseni
! Federal agency and public comment THROUGH JUNE 30,1999
- 10. Final review of K1 Federal policy FRN by FRPCC 4/99 A. Mohseni
- 11. Establish procedures to access Federal stockpiles 5/99 A. Mohseni l with FEMA I
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61 Caober 9,1998
- 12. Publish KI Federal Policy FRN 6/99 A. Mohseni
- 13. Final brochure on use of Kl provided to 6/99 A. Mohseni l l
l Commission for review (9700193) (AEOD)
- 14. Publish Final Rule change (9800173) (NRR) -
TBD M. Jamgochian, NRR BEYOND JUNE 30,1999 l
l 15. Finalize the public brochure on use of Kl and 8/99 A. Mohseni provide to FEMA for publication Comments:
l 1. Complete (June 26,98 SRM)
distribution to FRPCC members (10/1/98)
- 3. Based on 9/30/98 SRM new direction. Comments received. Comment period ended 9/15/98.
- substantially revise and reissue. ' Staff requested removal of draft NUREG from NRC WEB site. Staff
' prepared FRN of withdrawal.
Requested an FRPCC meeting on this matter.
- 5. Obtaining office concurrence.
- 6. Based on 9/30/98 SRM new direction.
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l The staff intends to form a review group comprising representatives from such organizations as FDA, FEMA, EPA, CRCPD, other states and NEl to review comments and develop the next version of NUREG-1633 l
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62 October 9,1998 i
l l VI. Toolc Area: Other Aaency Proarams and Areas of Focus SES Manager: Brian Sheron, Acting Associate Director for Technical Review, NRR H. Specific issue: NEl Petitions - Petition for modifyina 50.54(a)
J I
f Objective: Complete the NEl Petition, accepting in part to modify 10 CFR Part 50.54(a), as it pertains l to Quality Assurance Program Change Control and is intended to reduce burdens on industry.
PRIOR TO JANUARY 28,1999 l Milestone Date Lead
- 1. Submit to the' Commission a memorandum stating 10/98 R. Gramm, DRCH l the staff's' proposal to accept the NEl Petition in part j to modify 50.54(a) and propose a Direct Final Rule.
l (9800166) (NRR) l
- 2. Meet with stakeholders to discuss contents of 10/98 R. Gramm, DRCH proposed Direct Final Rule.
- 43. Submit to the Commission a SECY Paper accepting 40/98 R. Gramm, DRCH I the NEl Petition in part, proposing a Direct Final 11/98 l l Rule, and a longer term additional rule change.
l (9800166) (NRR) ;
- 24. Decision by the Commission on the Direct Final Rule 4998 R. Gramm, DRCH and the Petition's disposition. 1/99 i
THROUGH JUNE 30,1999 Milestone Date Lead S 5. Publication of a Federal Register Notice to accept in 02/99 R. Gramm, DRCH part the NEl petition for rulemaking and proposing a l Direct Final Rule (9800166) (NRR)
- 6. Direct Final Rule effective if no adverse comments 04/99 R. Gramm, DRCH received.'
l Comments: 1&2. These milestones &re expected to lmpsci the 5teff's efforts for time ly completion of vendcr/ccatrector ln5pectlcn5 ln P/ 90 end SS. Oudgeted P/99 resocices v.ill require redirection depending on the fin &; Comm:33;ca decision. Commi33;ca dec;5!cn to eccept the staff proposaHs expected by 12/30.
1-6. The staff delayed the SECY Paper 1 month in order to include a Direct Final Rule with the i
Federal Register Notice which accepts the petition in part. The original schedule did not l
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63 October 9,1998
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15clu' d e 56brnitiih6% Directhhal'Rdle with thi SEC .lThis will ' expedite the effective date'of the Direct. Final Rule by about 4 months, i
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64 October 9,1998 l
VI. Topic Area: Other Aaency Proarams and Areas of Focus l l
I SES Manager: Jack Roe, Acting Director, DRPM/NRR I. SDOClflC lasue: Revised Source Term Rulemakina I
Objective: To revise Part 50 to allow holders of operating power reactor licences to voluntarily amend the facility design basis to use revised source terms in design basis accident radiological analyses.
This action would allow these facilities to pursue risk-informed licensing actions made possible through the use of the revised source term.
PRIOR TO JANUARY 28,1999 Milestone Date Lead i
C. Miller, DRPM
- 1. Commission approval of rulemaking plan (submitted 9/4/98(C) 6/30/98)
- 2. Complete proposed rule package 10/98 C. Miller, DRPM
- 3. Office concurrence 11/98 C. Miller, DRPM
- 4. ACRS review 11/98 C. Miller, DRPM
- 5. CRGR concurrence 12/98 C. Miller, DRPM
- 7. Submit proposed rule package to Commission 12/15/98 C. Miller, DRPM
- 8. Publish in Federal Register 1/99 C. Miller, DRPM THROUGH JUNE 30,1999 Milestone Date Lead
- 9. Complete draft guide; draft SRP section 5/99 C. Miller, DRPM
- 10. End of Public Comment Period 4/99 C. Miller, DRPM
- 11. Office concurrence on final rule; draft guide; draft SRP 6/99 C. Miller, DRPM
65 October 9,1998 l
l i BEYOND JUNE 30,1999 Milestone Date Lead l 12. ACRS review 7/99 C. Miller, DRPM
- 13. CRGR review 7/99 C. Miller, DRPM
(NRR)
- 15. Final rule; draft guide; draft SRP to Commission 7/30/99 C. Miller, DRPM l 16. End of public comment period 11/99 C. Miller, DRPM
- 17. Office concurrence on final guide; final SRP 12/99 C. Miller, DRPM l
- 19. CRGR concurrence on final guide; final SRP 1/00 C. Miller, DRPM l 20. Final guide; final SRP to EDO (9700025) (NRR) 1/00 C. Miller, DRPM
- 21. Final guide; final SRP to Commission 1/24/00 C. Miller, DRPM Meetings with ACRS and CRGR would be expected to occur in conjunction with the scheduled reviews.
The eteff l5 vierking viith NEl to schedvle & 5 etus ineeting in ear ly October 1990. Staff conducted a public meeting with NEl and Industry on 10/1/98. The staff expects to conduct additional meetings as the need arises. -There is currently no planning for a workshop. Such a workshop may be appropriate once the staff has issued the final rule, the draft guide, and the draft SRP.
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66 October 9,1998 l
- Vil7 TUPIC AR'EAS Ur'anium'Recoverv issues SES Maidder
- !Joh6W. Hickey, Chief, Uranium Recovery Branch A
~ '.iS$e$1fic IEs'ues: ~ Uranium recovery concerns raisedin' Senate report
! = Duair'ddulition 6f ground was at in situ' leach (ISL) facilities .
i -- Expanded use~of mill tailings impoundments to dispose'of other material l
- Eliminate' consideration of economics in the processing of alter'nate feedstock
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! Ob}sct'ive: To look for ways toi . .,
j 1) eliminate dual re'gulation of ISLs fac!!ities;
, 2) reduce the regulatory burden on uranium mill wanting to expand the use of impoundments for disposal of other materials besides mill tailMgs; and l
- 3) encourage uranium mills who want to engage in recycling of rnaterials for their uranium content PRIOR TO JANUARY 28,1999 Milestone Date Lead
- 1. Commission paper on ways to eliminate dual 11/98 J. Park /D. Gillen, regulation at ISLs (9800176) (NMSS) URB
- 2. Commission paper on revising guidance for 11/98 J. Park /D. Gillen, expanding disposal capability of uranium mill tailings URB l impoundments, and ask for Commission policy on hearing orders conceming need to consider economics in alternate feedstock evaluations (9800176) (NMSS)
- 3. . Complete hearing on alternate feedstock 12/98 P. Block, ASLBP amt.ndment to see how State of Utah concerns about staff not appropriate applying economics criteria is determined.
THROUGH JUNE 30,1999 Milestone Date Lead
- 4. Implement any changes in review of alternate 01/99 D. Gillen, URB l
l feedstock that result from hearing and Commission l review of previous hearing orders
- 5. Complete Part 41 rulemaking plan, including 04/99 M. Haisfield, NMSS 1
recommendations on regulatory changes to address M. Fliegel, NMSS the three issues (9800177) (NMSS)
- 6. Revise ISL Standard Review Plan to implement staff 06/99 W. Ford, URB
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recommendations if approved by Commission
- 7. Issue revised draft guidance on disposal capability 06/99 D. Gillen, URB with Commission-approved revisions l
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l BEYOND JUNE 30,1999 l l
Milestone Date Lead
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8'. Publish brop8sid Paii41 for public comment, 04/00 M. Haisfield, NMSS l including ' reg 0latory changes to address three issues M. Fliegel, NMSS (9800177)(NMSS)
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- 9. Publish final Part 41 c'odifying agency policy on 12/00 M. Halsfield, NMSS :
resolution of three issues. (9800177) (NMSS) M. Fliegel, NMSS I l
Com'merlits:
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General comment re: objective stated above: Three issues raised in the Senate report are presented in the National Mining Associstion white paper that was presented to the Commission in April 1998.
1.& 2. Staff will provide recommendations to Commission on ways to address issues on
! eliminating dual regulation and on disposai of materialin tailings impoundments. if approved by l Commission, staff will begin to implement those recommendations in its review practices, and j recommend that they be codified in Part 41.
l l 3.& 4. The most recent alternate feedstock amendment issued by the staff is being contested by the State of Utah and Envirocare. One of the contentions is that the staff failed to conduct the appropriate economics test in accepting the amendment application. A decision from this hearing could help provide guidance to the staff on how economics should be considered in future reviews.
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! 68 October 9,1998
- Vill. TOPIC AREA
- Channes to NRC's Hearina Process SES Manager: Joe Gray, OGC
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l A: Use of Informal Adiudicatory Procedures i .' PRIOR TO JANUARY 28,1999 i Milestone Date Lead
- 1. Paper to Commission on legislative and rulemaking 12/31/98 J. Fitzgerald, OGC options to enhance Commission's ability to utilize informal Adjudicatory Procedures.
- 2. Commission Guidance 1/21/99 J. Fitzgerald, OGC THROUGH JUNE 30,1999
- 4. Prepare notice of proposed rulemaking for TBD J. Fitzgerald, OGC Cornmission review. i BEYOND JUNE 30,1999
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NUCLEAR ENERGY INSIITUTE Joe F. Colvin August 28,1998 ['C'Jl[Z c,,m,,
The Honorable Shirley A. Jackson Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Chairman Jackson:
This letter is in response to your request that the nuclear industry provide you with some areas in which changes could be made to the regulations in order to improve their focus on safety, while at the same time reducing the burden on licensees. As you are aware, the industry has previously provided similar information in the past, and we are pleased to have the opportunity to do so again.
l Unfortunately, the current NRC review process is often a major impediment to achieving effective or expedient change, and, in fact, serves to dissuade the industry i from proposing additional changes. We would suggest that a thorough examination i of the agency's review process could bear fruit in determining the steps needed for I improvement. l Enclosed is a description of several examples ofindustry proposed regulatory changes that have been pending before the agency for a considerable time. These items could serve as case studies for a task analysis to identify ways to improve both the effectiveness and efficiency of the review process. The quality assurance item has a !
particularly long history that is especially disappointing to the industry -- as I am sure it is to you -- as it was viewed by both the industry and the NRC as an opportunity to make a substantive improvement in the safety focus of a major regulation.
Sincerely, M**O5 l
1033 M 0.01 1 Joe P. Colvin En losure c: The Honorable Nils J. Diaz, Commissioner, NRC The Honorable Edward McGaffigan, Jr., Commissioner, NRC Mr. L. Joseph Callan, Executive Director for Operations, NRC
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LONG-STANDING INDUSTRY-PROPOSED REGULATORY CHANGES (as of August 28,1998)
QUALITY ASSURANCE Appendix B to 10 CFR 50 Appendix B provides quality assurance criteria for the design, construction and operation of nuclear power plants. These criteria ensure the l safety related functions of systems, structures and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. NRC's interpretation of the appendix, and the requirements for reporting changes in 10 CFR 50.54(a), have stifled industry's efforts to apply a graded approach, which is an approach based on risk-significance, that l would focus resources on those systems, structures and components most significant in preventing or mitigating consequences from postulated accidents. As the chronology below shows, industry has tried for over five years, through pilot projects, draft guidelines, and a rulemaking petition, to reach agreement with the NRC to more appropriately focus safety efforts in quality assurance. NRC's reluctance to accept the results of performance-based experience and the insights of mature risk analysis in quality assurance programs is disturbing. NRC persistence in deeming almost any change in a quality assurance program as a " reduction in commitment,"
even when that change improves the quality assurance program effectiveness, is an i impediment to moving with risk informed regulatory approaches.
i June 1993 l NUMARC (NEI) formed the Appendix B Working Group to coordinate and develop
! 1mproved methods for implementing 10 CFR 50 Appendix B.
December 1993 NRC introduced the concept of an improved process for quality assurance based on
- risk significant insights developed during implementation of the NRC Maintenance Rule. NRC's concept was consistent with the Appendix B Working Group's provisional recommendations.
January - July 1994 Industry-NRC meetings were held to discuss a pilot program for testing quality assurance improvements. NRC visited the pilot plants.
July 1994 Draft industry guideline was forwarded to NRC. It was intended as the basis for the pilot project and was to be revised based on pilot plant experiences.
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.- . 1 September 1994 NRC rejected the pilot project guideline. Incorporation of NRC comments into the
' industry guideline would have added, not reduced, the regulatory burden without improving safety focus.
December 1994 Industry decided to postpone pilot project and instbad to petition for rulemaking on Appendix B.
April 1995 Draft rulemaking petition was sent by the industry working group to the industry for comment.
June 1995 Petition on 10 CFR 50.54(a) submitted to the NRC. The proposed rule change would allow a licensee to make changes to its Appendix B quality assurance program without NRC prior approval, providing the change did not introduce an unreviewed oafety question or result in a change to the Technical Specifications. The proposed change would allow a licensee to implement a risk-informed, performance based approach to quality assurance.
September 1995 Petition noticed in Federal Register for public comment.
November 1995 Public and industry responded to NRC request for comment and additional information. NEI attached a draft guidance document that could become a regulatory guide, thereby trying to ease NRC's work effort and speed implementation.
January - June 1996 NEI NRC meetings to discuss draft guideline for implementing the petition.
Industry offered additional proposals on the guidance that would still meet the intent of the petition, attempting to achieve closure. The pilot utilities continued to interact with NRC in attempting to make improvements to their quality assurance program descriptions. Based on industry NRC discussions, the industry published NEI 90-02, Guideline for Implementing a Graded Approach to Quality.
July 1996 Based on pilot project interactions and industry-NRC interactions on a risk-informed, performance based approach to quality assurance, industry developed a draft revision to NEI 96-02 and forwarded the guideline to NRC for comment.
October 1996 Industry requested a meeting with NRC senior management to discuss graded (performance based) quality assurance to determine how NRC concerns could be 2
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resolved in a manner that would result in a quality assurance prccess that was better focused on safety significant matter o more efficient and effective.
February 1997 Four months later, industry met with NRC senior management (Director NRR) to
. discuss the need to address the 1995 rulemaking petition and come to final resolution on a risk-informed, performance based approach to' quality assurance.
Current Status (August 1998)
NRC decision on petition for rulemaking submitted in June 1995 still pending.
EMERGENCY PREPAREDNESS PROGRAMS (10 CFR 50.54(a))
Licensees cannot change their emergency preparedness plans without prior NRC approvalif the change is deemed to have " reduced the effectiveness" of the plans (even if the changed plans are judged to remain effective and are in full compliance with the regulations). There is no useful guidance available to industry to determine
- what " reduced effectiveness" means. Industry efforts since April 1996 to establish meaningful guidelines have not achieved results, despite the following industry initiatives.
April 1996 Industry provided draft guidance for NRC review at a public meeting. The guidance provided criteria for determining when an emergency plan change may constitute a decrease in the effectiveness of the plan.
September 1997 NEI sent a letter to the NRC asking for review and endorsement of the guidance provided in April 1996.
January 1998 Public meeting held at the request of NEI to discuss status of NRC review. NRC
- indicated they might be able to provide comments on the industry guidance, but were not ready to endorse it. No timetable was given for providing comments or developing staff guidance.
Current Status (August 1998)
Staffis now preparing guidance for its inspectors but has yet to endorse industry's guidance or provide its own guidance to industry.
FITNESS FOR DUTY RULEMAKING (10 CFR 26)
Fitness for duty programs have been successfulin preventing the use of drugs and alcohol at commercial nuclear power plants, and based on feedback, employees recognize the benefits of fitness for duty programs. However, the industry has been trying for seven years to obtain relief from some cumbersome and unnecessary 3
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L aspects of the rule. The chronology of attempts to obtain changes that would make the programs more efficient and cost effective, without diminishing the excellent L results achieved to date, follow.
l . April 1991 NUMARC identified 51 specific rule changes in an April 17,1991 letter to the NRC.
July 1992 NUMARC sent a letter to the NRC dated July 24,1992, that provided supplementary and clarifying information on the industry's top eight FFD issues.
December 1992
' NUMARC sent a letter to Chairman Selin on December 21,1992, that reiterated industry's request for action on the FFD rule.
L I May 1996 .
i L Some three and a half years later, NRC published a proposed rule to modify FFD !
l ' requirements on May 9,1996.
i~ August 1996 I
Industry provided comments on the proposed rule by letter dated August 7,1998.
l Current Status (August 1998)
Some two years later, industry has been informally advised that a final rule package
[ may be presented to the Committee for the Review of Generic Requirements in l
~ September and to the Commission in October 1998'.-
l EVENT REPORTING
! Licensees are required to report certain information at certain timeframes to the NRC in accordance with 10 CFR 50.72 and 10 CFR 50.73. The guidance provided by NRC on how to comply with these regulations is not sufficiently clear. Licensees have been cited and civil penalties have been issued because of the unclear guidance. For the past eight years, the industry has been trying to get clear guidance that both the regulator and the licensee can understand and comply with.
1990 Industry and NRC staffinitiated activity to clarify event reporting criteria. ;
1991
. A revision to NUREG 1022 was prepared and discussed at NRC sponsored workshop.
4 1994 l- Draft NUREG 1022, Revision 1 issued for comment.
i 4
f -_. _ _ . . _ .__ _ -- . __.
y' .
December 1997 NRC determined that some valid issues, identified in the 1994 NEI comments, could not be resolved without rulemaking.
January 1998
- NRC issues NUREG 1022, Revision 1 as a final document.
July 1998 NRC issues advanced notice of proposed rulemaking.
September 1998 ~
Industry comments due on ANPR.
Current Status (August 1998)
Final rulemaking action not expected for at least two more years.
INITIAL LICENSED OPERATOR EXAMINATION -
Over four years ago, a utility requested that it be allowed to prepare the initial licensed operator examination instead of the NRC. The advantage of this approach would be that the exam would reflect the greater specific plant knowledge of the licensee's training and operations departments, and it would also be cost beneficial to
- the NRC and the licensee. The chronology shows the inability of the NRC to resolve this simple request since April 1994.
August 1994 Virginia Power submitted a Cost Beneficial Licensing Action request that licensees be allowed to prepare the initial licensed operator examination.
March 1995 The NRC staff proposed a revision to the program in SECY-95 075 that would allow
' licensees to prepare their own exams.
May 1995 Commission approved a pilot program to validate the changes.
April 1996
- The NRC staff reported to the Commission that licensees could prepare exams at the right level of difficulty, based on the results of the pilot program and revised guidance.
i May 1996 .
CRGR determined that rulemaking was necessary to allow the change in practice.
August 1997 NRC issues proposed rule for comment.
l 9
- .4 s: -
~
,e
- October 1997 Industry provides comments on proposed rule.
Current Status (August 1998)
Final agency action on proposed rule is pending.
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