ML20209D074
| ML20209D074 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1999 |
| From: | Zwolinski J NRC (Affiliation Not Assigned) |
| To: | Sheron B NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9907130026 | |
| Download: ML20209D074 (8) | |
Text
p l
'd July 8, 1999 L
MEMORANDUM TO: Brian W. Sheron Associate Director for Project Licensing and Technical Analysis l
f Office of Nuclear Reactor Regulation i
FROM:
John A. Zwolinski, Director Original signed by Division of Licensing Project Management Office of Nuclear Reactor Regulation k
SUBJECT:
FORTHCOMING MEETING WITH STAKEHOLDERS ON REDEFINING THE ROLE OF THE DIVISION OF LICENSING PROJECT MANAGEMENT IN THE OFFICE OF NUCLEAR REACTOR REGULATION DATE & TIME:
Friday, July 23,- 1999 9 a.m. to 4 p.m.
LOCATION:
Auditorium - Two White Flint North 11545 Rockville Pike Rockville, MD PURPOSE:
To discuss the responsibilities of the Division of Licensing Project Management and solicit feedback on the Division's ongoing redefinition process from interested stakehelders. A summary of the discussion topics is attached.
PARTICIPANTS:
NRC UTILITIES and OTHER J. Zwolinski, NRR Representatives of various nuclear S. Black, NRR utilities, other groups, and the public are E. Adensam, NRR invited to participate.
I H. Berkow, NRR i
C. Thomas, NRR S. Richards, NRR g/$0
Attachment:
Summary of discussion topics g i
\\
l 0
i
'{)_. \\
CONTACT:
Marsha Gamberoni, NRR i
(301) 415-3024 l
l l
DOCUMENT NAME: G:\\PDill-2\\skay\\mtgnotice.wpd To receive a copy of this document, indicate in the box: 'C" = Copy without attachment / enclosure "E" =
l Copy with attachment / enclosure "N" = Nopopy f
OFFICE TA:DLPMp[ N lag))D,3l@
PM:LPD3 (
SC:LPD37 D:LPD3g D:DLPM,l, f i
NAME MGAMBd WI WC$RE SBAILEY S$
AMEN 6lOLA CTHQNIAS JZWOLIN$KI DATE 07/ 'd /99 L 07K/ /99 7/ 4 /99 07f /99 071
/99 07/ 6 /99 v
OFFICIAL RECORD COPY e
4 0nDM 6 ] y(& f(&h by
9907130026 990708 l
PDR ORG NRRA I
4 REDEFINING THE ROLE OF THE DMSION OF LICENSING PROJECT MANAGEMENT IN THE OFFICE OF NUCLEAR REACTOR REGULATION The Division of Licensing Project Management (DLPM), in the Office of Nuclear Reactor Regulation (NRR), is in the process of redefining its responsibilities. Previous audits and reviews had indicated that the function of project managers (PMs) needed to be reevaluated, clearly defined, and communicated. In addition, the staff is attempting to correlate the functions of DLPM with the four strategic objectives of maintaining safety, reducing unnecessary regulatory burden, increasing pubic confidence, and increasing efficiency and effectiveness.
DLPM management has determined that the PMs have responsibility for the following three major program areas: (1) licensing authority, (2) interactions, and (3) regulatory improvements.
Within each area are several specific tasks and goals regarding timeliness, effectiveness, and quality. A summary of each program area is given below. DLPM is sharing these proposed responsibilities with extemal stakeholders to solicit feedback so that the responsibilities can be further refined. The purpose of this workshop is for the staff to gain insights into the stakeholders' views on the functions of the projects organization. Specific questions that the staff is requesting feedback on are listed at the end of this discussion.
PROGRAM AREAS Licensina Authority 1
Licensing Authority is the core program area for DLPM. The PM is expected to be the single most knowledgeable member of the staff regarding the licensing agenda for a given facility. The PM is also expected to be the most informed member of the staff in matters pertaining to a facility's licensing basis and any activities undertaken to modify or change the licensing basis.
The wide range ofissues involving the licensing basis of power reactors require each PM to have a technical background in tenns of understanding overall plant design and operating practices as well as a thorough understanding of NRC rules, processes, and licensing requirements. The PMs are, therefore, expected to be " generalists"in that they must have the ability to work on a diverse number of assignments, which may or may not be interrelated. This is especially relevant when DLPM assesses its contribution and mission in support of office level goals, noting that specific technical expertise resides in other NRR divisions. Having an adequate number of generalists results in routine efficiency gains as well as providing flexibility for and improving the responsiveness of the overall organization. The DLPM example can be readily compared to the regional projects organizations in which residents are viewed as generalists and technical specialists from the regional office or NRR are called upon, as necessary, to address specific issues or inspection needs.
Activities covered in this program area include all DLPM tasks associated with carrying out the regulatory requirements contained in Title 10 of the Code of Federal Reaulations, Part 50
'(10 CFR Part 50) with regard to specific plant activities. These tasks include (1) licensing actions that require prior NRC approval before licensees may proceed with an activity, (2) review of licensing basis documents controlled and submitted to the NRC in accordance with specific regulations or licensee administrative controls, (3) management of NRC processes associated with these activities, and (4) other licensing tasks required by regulation or established NRC procedures.
i ATTACHMENT
f
.2-
- DLPM activities associated with completing licensing actions comprise the majority of the division's efforts in this program area. Evaluating and responding to licensee requests for amendments to their licenses, requests for reliefs from or alternatives to the requirements specified in the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, and requests for exemptions from NRC regulations are examples of licensing action tasks. The tasks included in the mandated controls category include DLPM's reviews of Updated Final
- Safety Analysis Reports submitted in accordance with 10 CFR 50.71, descriptions of changes, tests and experiments submitted in accordance with 10 CFR 50.59, updates to the Quality l
Assurance, Security, and Emergency plans submitted in accordance with 10 CFR 50.54, and i
regulatory commitments not addressed by specific NRC regulations.
l Other licensing tasks include those items associated with NRR's role as the licensing authority for power reactors but not addressed by the aforementioned categories. DLPM tasks in this
- area include evaluating information received from licensees in response to requests for information (e.g., generic letters and bulletins), responding to petitions from parties requesting NRC actions pursuant to 10 CFR 2.206, and responding to requests for assistance from other NRC organizations made via the Task Interface Agreement (TlA) procedure.
Operating Reactor Licensing Assistants provide a comprehensive review and quality assurance oflicensing correspondence. These reviews ensure licensing products comply with management directives, office letters, and rules in addition to improving uniformity and consistency of effort for alllicensees.
The Agency and NRR benefit from having a designated point of contact for all licensing issues associated with each power reactor facility. The project management staff can assess a l
licensee's performance in the licensing area, evaluate a licensee's efforts to make l
improvements in licensing submittals, and help evaluate key licensee activities that may or may f
not have a direct bearing on the licensing agenda for the plant. Specifically, requiring the PMs to maintain a sound awareness of the 10 CFR 50.59 process and to participate in NRC's evaluation of each licensee's program for determining which changes require NRC review and approval has a clear nexus in this program area.
in assessing products and evaluating outcomes for this area, the staff has identified products primarily in the licensing action and activity categories. These products are serv.inized by a myriad of stakeholders. NRR products continue to be closely analyzed and evaluated by the industry, individual licensees, and other stakeholders, including public interest groups. Issues of paramount concern associated with these products include assuring high quality, uniformity, j
consistency, and timeliness. Thus, high importance is placed in assuring all products being issued by the staff can withstand close scrutiny, and are predictable and repeatable. To this end flows the conclusion that the program area of licensing authority receives high marks when weighed against the four pillars. Specifically, licensing actions have a direct bearing on maintaining and assuring safety while also reducing unnecessary regulatory burdens. The ability to process documents in a timely manner, relying on precedents and the broad-based t
knowledge of plant-specific project managers, is key to ensuring effective and efficient work force outputs and the associated outcomes from this program area. Enhanced public confidence is derived from the quality of NRR products that are technically sound and defensible, completed on schedule, and well communicated to all stakeholders.
I t
Interfaces The DLPM interface program area covers DLPM tasks involving interactions with NRC internal and external stakeholders. These DLPM interactions include the NRC regional offices, other NRR divisions, other offices at NRC Headquarters, power reactor licensees, owners groups and other industry organizations, government organizations (local, State, and Federal), and the public. From the perspective of DLPM, the interfaces are either integral to its core activity (serving as the licensing authority for power reactor facilities), directly support the licensing authority role by providing its staff with an awareness of plant issues, or result from the project managers serving as a convenient point of contact at NRC Headquarters for plant-specific information. The interface program area presents some challenges in terms of measuring performance because many of the activities do not involve a deliverable product. Feedback from stakeholders as a measure of performance may result in some changes in or additions to NRC processes.
Project Managers in DLPM routinely interact with their counterparts in the regional offices and with inspectors at reactor sites. A common interface with regional personnel is in the form of participation by the PMs in routine status calls between the resident inspectors and the projects organization in the regional office. The PMs' participation in these calls allows DLPM to maintain an awareness of plant status, operating issues, inspection issues, and significant activities being conducted or planned by licensees. This information is used to ensure that ongoing issues are considered in the management of a plant's licensing agenda and that the NRC's inspection / assessment activities can properly account for licensing activities. The project managers also maintain an awareness of, and occasionally offer insights into, licensee performance issues through routine interactions, participation in assessment processes, and reviews of various reports.
Project Managers in DLPM act as the primary interface between NRR and licensees. The primary function of the routine interactions between DLPM and licensees is to ensure that the licensing processes are working effectively. Licensees and project managers discuss plant issues, technical positions, process or procedural matters, generic activities, future licensing j
submittals, and the appropriate prioritization of licensing reviews. In addition to interacting with 1
specific licensees, DLPM has recentiy assumed project management and interface responsibilities for licensing activities sponsored b) owners' groups or other collective groups of licensees (other than the Nuclear Energy institute).
OLPM serves as the primary interface between NRC Headquaders organizations and licensees or regional offices in matters pedaining to specific power reactor facilities. The need to communicate frequently with the regional offices and the licensees as part of their core activities enables personnel within DLPM to respond to many inquiries. This limits the numbers and types of requests for information to both the regional offices and licensees from the various organizations at NRC Headquarters. DLPM also supports other Headquarters organizations in terms of answering questions about and coordinating activities with the licensing programs.
The NRC's incident response program also calls upon the DLPM staff for support due to their knowledge of plant design features and licensing basis.
.e.
Given its licensing authority responsibility and other interface functe'n. '
'A h often called upon to support the NRC's interactions with the public ma other exh. c ieoiders. These activities include responding to public inquiries and syperting. D.? N"D allegation process.
DLPM will participate in the redesign of and long-term mutanar ce of NRC Intemet web pages that provide plant-specific information to the public.
RaaWorv imorovements The regulatory improvements program area includes tasks and activities undertaken by DLPM either at the request of licensees or in response to problems identified by NRC staff. By interacting with licensees and owners' groups in various forums, DLPM has an opportunity to address those issues that result in inefficient or ineffective use of resources and unnecessary regulatory burden. A logical role for DLPM in improving regulatory processes is drawn from the routine responsibilities that DLPM has in the licensing authority program area and the associated knowledge and skills of the DLPM staff. In general, the changes in procedures, policy, and guidance documents are undertaken to simplify existing processes associated with licensing actions and other licensing tasks. As licensee and NRC resources become more scarce, these efforts will become even more important.
The Licensing Action Task Force is currently addressing issues or processes identified by industry and the NRC staff as potential areas ofimprovement. The improvements being pursued include changing the request for additional information (RAl) process, developing a mechanism to address minor discrepancies in the wording of requirements in the technical specifications, refining the process for issuing changes to technical specification bases sections, enhancing the process for the staff's handling of generic or repetitive licensing actions, refining the guidance for the staff's preparation of safety evaluations, and addressing miscellaneous policy issues such as limiting the use of TIAs to address generic issues. Interactions with owners' groups are invaluable in sharing technical and process information. DLPM interactions with owners' groups and management of generic topical reports facilitates improving the working relationships between licensees and NRC, resulting in a more effective and efficient regulatory process. It is expected that industry groups will play an increasing role in resolving safety concems by undertaking voluntary initiatives in lieu of responding to generic communications issued by the NRC. NRC resource expenditures will be reduced due to efficiency gains resulting from these interactions. Additionally, public confidence may be enhanced by the increased consistency that comes from resolving issues generically.
4 Licensing workshops offer a unique and invaluable way for licensees and DLPM to interact on a working level. A goal of the workshops is to improve licensing submittals and associated NRC reviews.~ Licensees and DLPM staff share experiences and knowledge of their own processes to improve the licensee-NRC regulatory interface. DLPM prepares revisions to existing policies, rules, and guidance documents including office letters (or provides assistance to those with the lead for these activities). DLPM's experience with the licensee-NRC interface can provide valuable insights when process changes or rules are being developed.
QUESTIONS: During the course of the July 23,1999, public workshop, the staff would appreciate feedback from participants on the following questions. This information will be most useful as the staff proceeds with the process to define the role of the NRR/ Projects licensing i
organization for the future.
l When providing feedback on the importance of activities, it would be helpful to the staff if comments from the public could be related to the outcome goals that are used by the staff.
These outcome goals are: maintaining reactor safety; reducing unnecessary regulatory burden on licensees; increasing public confidence; and increasing NRC internal efficiency and effectiveness.
1.
What do you believe should be the principle role of the Projects organization?
2.
Given the proposed descriptions of activities encompassed by the licensing authority, interfaces, and regulatory improvements program areas, what five activities do you consider most important for the Projects organization to perform?
3.
Why do you consider the five activities identified in response to Question 2 important with respect to the staff outcome goals? If you consider these activities important for a reason not related to the staff outcome goals, what is the reason these activities are important to you?
4.
Are there any activities not identified in the licensing authority, interfaces, and regulatory improvements program areas that you consider the Projects organization should perform?
5.
Why do you consider the activities identified in response to Question 4 important with respect to the staff outcome goals? If you consider these activities important for a reason not related to the staff outcome goals, what is the reason these activities are important to you?
l 1
6.
What types of performance indicators would be useful for the staff to employ to objectively l
determine its effectiveness in performing licensing activities?
7.
What five activities containeu in the proposed descriptions of activities encompassed by the licensing authority, interfaces, and regulatory improvements program areas do you consider least important for the Projects organization to perform?
8.
Why do you consider the activities identified in response to Question 7 of less importance with respect to the staff outcome goals?
I 9.
Identify any activities in the proposed descriptions for the licensing authority, interfaces, and regulatory improvements program areas that the Projects organization should not perform, and provide an explanation why.
- 10. As a customer of the licensing organization's output, the staff welcomes any additional input that you feel would be germane to the process of redefining the role of the Projects organization.
JL._
=
FOR FURTHER INFORMATION CONTACT: Marsha Gamberoni, U.S. Nuclear Regulatory Commission,11555 Rockville Pike, Mail Stop O 13 E4, Rockville, Maryland 20852-2738; Telephone 301-415-3024; Internet: mkg@nrc. gov l
h
. -w a
ISTRIBUTION FOR MEETING NOTICE DATED July 8,1999 E-Mail S. Collins /R. Zimmerman(SJC1/RPZ)
J. Zwolinski/ S. Black E. Adensam (EGA1)
' H. Berkow (HNB)
S. Richards(SAR)
C. Thomas (COT)
A. Mendiola(AJM)
C. Craig (CMC 1)
S. Bajwa(SSB1)
J. Clifford(JWC).
R. Emch (RLE)
S. Peterson (SRP)
R. Gramm (RAG)
S. Dembek(SXD)
M. Masnik(MTM2)
M. Tschiltz (MDT)
M. Satorius (MAS)
T. Hiltz (TGH)
D. Lange (DJL)
D. Screnci(DPS)
K. Clark (KMC2)
J. Strasma (RJS2) l B. Henderson (BWH)
PMNS (Meeting Announcement Coordinator)
Hard Coov Central File PUBLIC PD3 r/f M. Gamberoni S. Bailey OWFN and W/FN receptionists OGC,015B18 ACRS, T2E26 l
i 1
4 L._