ML20209G833
| ML20209G833 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1999 |
| From: | Zwolinski J NRC (Affiliation Not Assigned) |
| To: | Sheron B NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9907200024 | |
| Download: ML20209G833 (33) | |
Text
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4 UNITED STATES l
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WASHINGTON, D.C. 2056M001 p..@..f /
July 8,1999
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).N1 MEMORANDUM TO: Brian W. Sheron Associate Director for Project Licensing and Technical Analysis m
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Office of Nuclear Reactor Regulation l
FROM:
John A. Zwolinski, Director Division of Licensing Project Mana ment Office of Nuclear Reactor Regulatio
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 stakeholders. 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.
H. Berkow, NRR C. Thomas, NRR S. Richards, NRR
Attachment:
Summary of discussion topics QN' f, i' CONTACT:
Marsha Gamberoni, NRR (301)415 3024 o -\\ u L ud Gn 200020' 9907200024 990708 PDR ORG NRRA PDR
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July 8,1999 h
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MEMORANDUM TO: Brian W. Sheron l
Associate Director for Project Licensing I
and Technical Analysis Office of Nuclear Reactor Regulation I
FROM:
John A. Zwolinski, Director Original signed by Division of Licensing Project Management Office of Nuclear Reactor Regulation
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 stakeholders. A summary of the discussion topics is attached.
PARTICIPANTS:
HEQ UTILITIES and OTHEP J. Zwolinski, NRR Representatives of various nuclear S. Black, NRR utilities, other groups, and the public are E. Adensam, NRR invited to participate.
H. Berkow, NRR C. Thomas, NRR S. Richards, NRR
Attachment:
Summary of discussion topics CONTACT:
Marsha Gamberoni, NRR (301) 415-3024
. 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" =
Copy with attachment / enclosure "N" = Nopopy OFFICE TA:DLPMt(tN LMPD,3 l@
PM:LPD3 (
SC:LPD3/
D:LPD34 D:DLPM.
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AMENdlOLA CTHpfi4AS JZWOLIN$Kl DATE 07/'O /99 I 07/G /99 7/4;2/99 0?f /99 07/
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OFFICIAL RECORD COPY j
REDEFINING THE ROLE OF THE DIVISION 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 needed to be reevaluated, clearly defined, and conimunicated. 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 project managers have responsibility for the following three major program areas: (1) licensing authority, (2) interactions, and (3) regulatory improvements. Within each program area are a multitude of specific tasks grouped into categories based on functional commonality. For example the licensing authority program area tasks are grouped into the following categories: licensing actions mandated controls and other licensing tasks. A summary of each program area and respective categories are given below.
Associated with each program area and category are performance measures and outcome goals. DLPM is sharing these proposed responsibilities with external stakeholders to solicit feedback so that the responsibilities can be further refined.
Licensina Authority Prooram Area Licensing Authority is the core program area for DLPM. The project manager (PM) is expected to be the single most knowledgeable member of th9 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 of issues involving the licensing basis of power reactors require each PM to have a technical background in terms 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 ecmpared 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.
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ATTACHMENT
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-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 j
l amendments to their licenses, requests for reliefs from or alternatives to the requirements
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specified in the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,
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L 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, 1
tests and experiments submitted in accordance with 10 CFR 50.59, updates to the, Quality I
. Assurance, Security, and Emergency plans submitted in accordance with 10 CFR 50.54, and
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regulatory commitments not addressed by specific NRC regulations.
Other licensing tasks include those items associated with NRR's role as the licensing i
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 (TIA) procedure.
Operating Reactor Licensing Assistants provide a comprehensive review and quality assurance of licensing correspondence. These reviews ensure licensing products comply with management directives, office letters, and rules in addition to improving uniformity and consistency of effort for all licensees.
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 licensee's performance in the licensing area, evaluate licensees' efforts to make improvements in licensing submittals, and help evaluate key licensee activities that may or may not have a direct bearing on the licensing agenda for the plant. Specifically, requiring the PMs to maintain a
- sound awareness of the 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 scrutinized 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 concem associated with these products include assuring high quality, I
uniformity, 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 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 J
confidence is derived from the quality of NRR products that are technically sound and defensible, completed on schedule, and well communicated to all stakeholders.
b.
Performance Measures for Licensing Authority Program Area:
Timeliness:
Work is completed within the NRR Timeliness goals for Licensing Actions.
Achieve a licensing action inventory age distribution as follows: 80 % s 1 year old,95% s 2 years old and 100% s 3 years old in FY 1999; and 95%
s 1 year old and 100% s 2 years old in FY 2000. Manage review to meet schedules negotiated with licensees for about 3 power uprates in FY 1999 and FY 2000. Help to maintain schedules to complete conversions to improved Standard Technical Specifications (iSTS). Work is completed to support licensee schedules for outages, restart, or continued operation.
Effectiveness:
Products are responsive to requests as measured by voluntary feedback from licensees (also see LATF). Applicable 10 CFR 50 requirements are
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met.
Efficiencv:
Work is completed within negotiated timetables and office priority guidelines.
Quality:
Completed work is of the highest quality and does not need to be reissued to correct technical errors. A high level of licensing expertise is evident.
Quantity:
Budgeted Goal for number of license actions completed is met. Complete the processing of approximately 1670 licensing actions in FY 1999 and 1640 in FY 2000, of which about 40% of the reviews will be performed by DLPM staff. Achieve a licensing action inventory of 1000 actions by the end of FY 1999 and 600 in FY 2000. The target for totalinventory size is based on the assumption of approximately 1400 licensing action requests in FY 1999 and 1400 in FY 2000. The licensing action backlog does not increase.
Other Licensing action performance measures will be adjusted based on revisions to the NRR Operating Plan.
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Outcomes for Licensing Authority Program Area:
Maintain Completed tasks continue to have a high importance to maintaining safety.
Safety.
Reduce Licensing authority tasks are completed without undue burden on the Unnecessary regulated industry. Predictability in completing licensing actions in a timely Burden:
manner can aid licensees in planning and scheduling, thereby reducing burden.
Increase Competent and thorough evaluations of requested licensing actions will Public assure that the health and safety of the public are protected. In addition, the Confidence:
public is given the opportunity to comment on changes proposed during the license amendment process.
Increase Relying on licensing action precedents and continued efforts to enhence Effectiveness processes and procedures, the staff will seek to realize a 15% efficiency
& Efficiency:
gain in FY00.
Enhance decision-makina:
Other:
0 i
5-Licensina Action Cateaorv The Licensing Actions category covers tasks involved with the processing of licensee requested actions. These actions require NRC review and approval prior to licensee implementation. The Division of Licensing Project Management (DLPM) has the lead interface role between the NRC and the licensee for these tasks. DLPM takes the lead to coordinate and/or conduct NRC review activities, to engage the staff and licensee to resolve identified issues, and to process the NRC licensing documentation.
Licensing actions include the following items: license amendments (including Unresolved Safety Questions or USQs); exemptions to regulatory requirements; Code relief and alternatives; license transfers; Notices of Enforcement Discretion (NOEDs); lead plant reviews in areas such as risk-informed changes; plant specific topical report reviews; and plant program (QA, Security, and Emergency Plan) changes that require prior NRC approval.
Based primarily on the complexity of the item and the existence of precedents, a decision is made whether DLPM or the technical staff will perform the associated technical review and generate a safety evaluation. DLPM estimates it will take the lead on performing the technical review for approximately 40% of the FY 00 licensing actions.
For those cases where the review is performed by the technical staff, DLPM will concur on the work product. DLPM takes the lead in all cases to coordinate interactions with the licensee including meetings, phone conferences, and issuance of Requests for Additionalinformation to resolve issues and obtain more information. DLPM further issues licensing action documentation, such as Notices, No Significant Hazards Consideration Determinations, and the completed Safety Evaluation package for transmittal to the licensee.
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-6 1 Performance Measures for Licensing Actions Category:
Timeliness:
Work is completed within the NRR Timeliness goals for Licensing Actions.
Achieve a licensing action inventory age distribution as follows: 80% s 1 year old,95% s 2 years old and 100% s 3 years old in FY 1999; and 95%
s 1 year old and 100% s 2 years old in FY 2000. Manage review to meet schedules negotiated with licensees for about 3 power uprates in FY 1999 and FY 2000. Help to maintain schedules to complete conversions to improved Standard Technical Specifications (iSTS). Work is completed to support licensee schedules for outages, restart, or continued operation.
Effectiveness:
Products are responsive to requests as measured by voluntary feedback from licensees (also see LATF). 10 CFR 50.90, 50.91, and 50.92 requirements are met.
Efficiency:
Work is completed within negotiated timetables and office priority guidelines. A 15% efficiency gain in FYOO, for example Project Manager effort on producing SE packages is expected to go from 48 to 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br />.
DLPM is targeting a 25% reduction in like LA process variability in FYOO.
Qualitv:
Completed work is of the highest quality and does not need to be reissued to correct technical errors. A high level of licensing expertise is evident.
The backlog does not increase.
Quantity:
Budgeted Goal for number of license actions completed is met. Complete the processing of approximately 1670 licensing actions in FY 1999 and 1640(1500) in FY 2000, of which about 40% of the SEs will be written by DLPM staff. Achieve a licensing action inventory of 1000 actions by the end of FY 1999 and 600 in FY 2000. The target for total inventory size is based on the assumption of approximately 1400 licensing action requests in FY 1999 and 1400 in FY 2000.
Other:
Performance measures will be adjusted based on revisions to the NRR j
Operating Plan.
4
4
- 1 Outcomes for Licensing Actions Category:
Maintain Completed Licensing Actions continue to have a high I cportance to Safety; maintaining safety. Technical Specifications establish the fundamental operating limits the NRC has independently reviewed and approved.
Adherence to these limits ensures the health and safety of the public and quality of the environs.
Reduce The NRR licensing action process is completed without urbue burden on Unnecessary the regulated industry. Predictability in completing licensing actions in a Burden:
timely manner can aid licensees in planning and scheduling thus reducing burden.
Increase Competent and thorough evaluations of requested licensing actions will Pyhfic assure that the health and safety of the public are being ensured. In Confidence:
addition, the public is given opportunity to comment on changes proposed during the various licensing action processes.
Increase Relying on precedents and continued efforts to enhance processes and Effectiveness procedures, the staff will seek to realize a 15% efficiency gain in FYOO.
& Efficiency:
Enhance decision-plakina-Other:
i I
.g.
Mandated Controls Cateaory The mandated controls category involves those DLPM tasks associated with the control of the licensing basis information that is subject to change-control and reporting requirements specified in NRC regulations. The implementation of most changes to the licensing bases in accordance with these programs does not require prior NRC approval but the changes are nevertheless reported to the NRC in order to allow post-implementation reviews and to maintain the NRC's ability to retrieve the current licensing basis information for its licensed facilities. The tasks included in this category include DLPM's reviews of Updated Final Safety Analysis Reports (UFSARs) submitted in accordance with 10 CFR 50.71, descriptions of changes, tests and experiments submitted in accordance with 10 CFR 50.59, TS Bases changes (for non-iSTS plants),
and updates to the QA, Security and Emergency plans submitted in accordance with 10 CFR 50.54. Also included in this category is a proposed programmatic review and sampling of specific evaluations performed by licensees in accordance with 10 CFR 50.59 (this function has historically been conducted as an inspection activity). It is advantageous to incorporate this task into DLPM along with other licensing authority functions (especially given recent changes to 10 CFR 50.59 that introduce criteria associated with licensing acceptance limits and analytical methodologies).
It should be noted that the NRC staff, and the projects staff in particular, has traditionally performed little or no review of the information submitted in accordance with mandated controls. Staff deficiencies in these areas resulted, at least in part, in recent controversies associated with the maintenance of UFSARs and changes made by licensees in accordance with 10 CFR 50.59. The definition of clear roles and responsibilities and associated performance measures is intended to prevent such problems in the future and thereby serve to maintain both safety and public confidence.
Performance Measures for Mandated Controls Category:
Timeliness:
Review of licensee submittals and programs are completed on schedule as defined by NRR or DLPM guidance documents.
Effectiveness:
Reviews ensure accuracy of licensing basis information as indicated by low number of issues identified by other sources (licensee programs, inspection program, allegations, etc.)
Efficiencv:
Work is completed within negotiated timetables and office priority guidelines.
Quality:
Completed work is of the highest quality. A high level of licensing expertise is evident.
j Quantity:
Other:
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L 9
Outcomes for Mandated Controls Category:
l l
Maintain Maintaining a plant's licensing basis will ensure that the plant is operating Safety.
within design limits and that the public's health and safety are maintained.
Reduce l-Unnecessarv L
Burden:
l Increase Maintaining the fidelity of a plant's licensing basis will ensure that the plant l
l Public is operating within design limits and enables improved communications with l
Confidence:
the public Increase Maintaining an integrated approach to the control of licensing bases Effectiveness supports reductions in overlapping controls and reporting requirements J
& Efficiencv:
Enhance Maintaining the fidelity of a plant's licensing basis improves confidence in decision-available information and thereby enhances timely and appropriate makina:
decisionmaking Other; i
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r Other Licensina Task Cateoorv Other Licensing Tasks include all DLPM tasks that do not fall within the other Licensing Authorization categories (Licensing Actions or Mandated Controls). These tasks involve regulatory commitment management program, pre-application reviews, Generic Topical Reports reviews, plant specific multi-plant actions (MPAs), Task Interface Agreements (TIAs), petitions submitted pursuant to 10 CFR 2.206, support to Hearings,10 CFR 50.54(f) letters, backfits, and proprietary information reviews.
Several of these licensing tasks facilitate the licensee's efforts to streamline the regulatory process. Providing pre-application reviews allows the licensee to focus resources on regulatory issues that need to be addressed in the subsequent request.
Reviews of Generic Topical Reports expedites the undertaking of complex technical upgrades and allows licensees to recover costs incurred for these upgrades.
PMs ensure that generic issues (as they apply to their plant) are resolved in a timely manner commensurate with the safety significance of the issue. Technical support to the Regions that cannot immediately be resolved are handled via Task Interface Agreements (TIAs). TIAs are invaluable in addressing these technicalissues and PIAs ensure that the resolution is distributed to all Regions providing consistency throughout the Regions.
PMs provide technical and administrative support for the 10 CFR 2.206 petition process, Hearings, issuance of 10 CFR 50.54(f) letters, backfit evaluations and proprietary information reviews.
11 -
Performance Measures for Other Licensing Tasks Category:
Timeliness:
Closure of MPA is consistent with division goals established. Proprietary l
information letteris issued within 2 months of receipt of request. TIA l
responses are issued within NRR timeliness goals. 2.206 petitions are concluded within the NRR timeliness goals for 2.206 packages as l
described in Division or Office Operating Plan (reviews are conducted within the timeliness goals of MD 8.11). Backfits are imposed in a time frame commensurate with their safety significance and requirements of OL901. OGC's ability to support the hearing schedule is not impacted by the performance of the DLPM staff. 50.54(f) letters are issued promptly upon determination of need Effectiveness:
TIA are responsive to regional requests and permit the Office or Region to disposition open items on a sound technical and ragulatory basis. 2.206 products are responsive to the Petition issues and have supportable bases. With respect to 50.54(f) letters, no clarification of information request is needed and the request is adequately justified.
Efficiencv:
Work associated with MPAs is completed utilizing generic guidance to the maximum extent so that resources do not exceed those programmed.
With respect to TIAs, Regional decisions on closure of inspection finsings I
or enforcement actions are reached with the minimum expediture of l
resources by utilizing inter-organizational expertise. Labor rates to complete actions do not exceed those budgeted and are commensurate I
with safety significance of petitioner's concems.
Qualitv:
Proprietary information determinations are based on sound engineering and legal positions. MPA closure documentation complies with guidance provided by Lead PM and substantive changes are not required as a result of management review. TIA is responsive to regional requests and permits disposition of open items without additional NRR input (OL 1201 guidance is followed). With respect to 2.206 petitions, Director's Decision is accurate and responsive and is accepted with little re-work. Backfit conclusions and analyses are technically supportable, conform with current policy (OL 901,10 CFR 50.109) and do not require any substantive changes upon management review.
Quantity:
QUlE i
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. Outcomes for Other Licensing Task Category:
Maintain Closure of issues comports with goals established by Lead PM and
- Safety, supports safety significance of issue. TIA responses provide sound basis for requiring appropriate licensee actions that maintain or improve safety.
Imposition of backfits should restore safety to the licensed level or enhance safety.
Reduce The withholding of proprietary information is meant to reduce unnecessary Unnecessary burdens that would result in economic repercussions. With respect to TIAs, Burden:
appropriate regulatory decisions may prevent resident or regional inspectors from imposing unnecessary requirements on licensees. Proper management of backfits avoids inappropriate imposition.
Increase Proper handling of 2.206 petitions shows responsiveness to public Public concerns. Correct and timely proprietary determinations enhance NRC Confidence:
credibility and improve public confidence. Completion of generic safety issues identified by NRC which often have high public visibility, could increase public confidence in the agency's commitment to maintaining safety. When 2.206 Director's Decisions are fair and supportable, they contribute to public confidence in the process. Imposition of backfits, when warranted, could contribute to increased public confidence.
Increase The MPA process is more efficient than plant specific resolutions. Closure Effectivengan of generic safety issues could lay the groundwork for improved plant
& Efficiency:
performance, making NRC regulation more efficient. Broad dissemination of TIA resolutions can provide guidance to all regions and avoid duplication of effort.
Enhance decision-makino:
Other:
l
ca
. Interfaces Prooram Area 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 e 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 PM 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 j
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 submittals, and the appropriate prioritization of licensing reviews. In addition to interacting with specific licensees, DLPM has recently assumed project management and interface responsibilities for licensing activities sponsored by owners groups, vendors and other collective groups of licensees (other than the Nuclear Energy Institute).
DLPM serves as the primary interface between NRC Headquarters organizations and i
licensees or regional offices in matters pertaining 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 j
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 i
knowledge of plant design features and licensing basis.
Given its licensing authority responsibility and other interface functions, DLPM is often called upon to support the NRC's interactions with the public and other external stakeholders.
These activities include responding to public inquiries and supporting the NRC's allegation process. DLPM will participate in the redesign of and long-tsrm maintenance of NRC Intemet web pages that provide plant-specific information to the public.
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14 Performance Measures for Interfaces Program Area:
Timeliness:
Responses or other deliverables are provided in accordance with NRC, NRR, or DLPM guidance docments. Feedback from stakeholders is that i
DLPM provides timely responses.
Effectiveness:
Feedback from stakeholders is that DLPM provides information in a manner that satisfies agency needs Efficiencv:
Feedback from NRC headquarters organizations and regional offices that system is providing necessary support with minimal impact on regional operations Quality:
Completed work is of the highest quality and does not need to be reissued to correct technical errors. A high level of licensing expertise is evident.
Feedback from stakeholders is that quality of information provided is adequate.
Quantity:
As requested Other:
- Outcomes for Interfaces Program Area:
Maintain -
Interface functions can help to maintain safety by ensuring that issues are Safety:
Identified and associated information is appropriately disseminated j
Reduce Providing a single headquarters point of contact reduces unnecessary Unnecessary burden by reducing the number of inquiries to licensees and ensuring those Burggr requests that are forwarded to licensees are for only that information necessary to make a regulatory decision increase Ensuring that headquarters personnel are able to obtain and provide Public information in a timely manner increases public confidence in the agency.
Confidence:
1 increase Providing a single headquarters point of contact and utilizing information Effectiveness gathered in support of core activities limits demands placed on regional
& Efficiency:
personnel (i.e., an additional return on investment on interactions with regions and licensees).
Enhance decision-1 makina:
Other:
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Licensee Interfaces Cateoorv The Interfaces with Licensees / Owners Groups category includes all DLPM tasks involving routine communication with licensees and Owners Groups which may or may not be associated with specific docketed issues. Good communication and productive interactions with Licensees / Owners Groups are vitally important to the success of the Office mission. This is especially true when assessed against Performance Measures such as Effectiveness and Efficiency and the Maintain Safety Outcome.
Since the Project Manager _ is the single point of contact for each licensee, it is paramount that the staff remain updated with respect to plant status, organizational changes, and other emerging issues. Routine and regular communications with plant Licensing and, if l
l necessary, techn: cal staff keeps the PM knowledgeable about plant issues and allows j
the PM to be the Headquarter's point for "one-stop-shopping" with respect to obtaining information about his/her plant. Daily calls are held to discuss plant status, status of l
. docketed licensing actions and activities, operating schedules, etc. It is also expected that the PM will communicate with the licensee to discuss specific and/or emerging
- issues. Communications are routinely held via phone, e-mail and fax.
l l
Another primary interface with the licensee is the review of routine reports to include the l
Core Operating Limits Report (COLR), Occupational Radiation Exposure Report, Radiological Environmental Report, Radioactive Effluent Release Report, Offsite Dose Calculation Manual (ODCM), and the Monthly Operating Report. These reports, l
submitted as required by regulation, keep the NRC informed of a variety of plant activities.
The PM interface with the Owners Groups (and vendors) has two portions First, there is j
l a specific PM for each of the Owners Group. The Owners Group PM interfaces with the Owners Groups in much the same way a PM interfaces with a licensee and produces j
much the same outcomes. The second interface is one that a plant specific PM may have with the Owners Group if his/her plant is the lead plant for review and/or i
implementation of a topical report. The PM typically works with the licensee, Owners l
Group, NRR technical divisions, and the Lead PM for the specific Owners Group to ensure a timely, successful review. These are very important efforts as the end result can have a significant resource savings for many other plants. Effectiveness and efficiency are significant attributes.
DLPM also reviews unsolicited information to understand the scope and breadth of future regulatory action requeets. These reviews also allow DLPM to screen for safety issues that may require a formal process to be adopted.
l' 1
[
. Parformance Measures for Licensee Interfaces Category:
Timeliness:
Reports are reviewed within 2 weeks of receiving. Communicate with licensee / Owners Group at least weekly.
Effectiveness:
Significant issues identified during report reviews are brought to management's attention. All safety issues are identified with appropriate follow-up. With respect to routine communications with the licensee / Owners Group, a back-up PM will be identified. Focus licensee / Owners Group through a single point of contact.
Efficiency:
Increased knowledge of licensee / Owners Group issues. Avoid repeat communication due to inappropriate coordinatie (single point of contact).
Staff responses are not changed by NRC management or the Commission.
Quality:
Staff responses succinctly and accurately address concerns.
Quantity:
Report reviewed as assigned.
Other:
Outcomes for Licensee Interfaces Category:
Maintain Reports are reviewed with a safety focus. Communications will tend to Safety:
focus on safety significant issues.
Reduce Routine and effective communication with the licensee / Owners Group i
Unnecessarv facilitates the regulatory process. Conveying NRC policies and /or positions
)
Burden:
can aid licensee / Owners Group in planning and scheduling and thus reduce
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unnecessary burden.
PM serves as plant expert an[ focal point for plant / Owners Group increase Public information.
J Confidence:
j lacrease Effective Communication between PM and Licenaae/ Owners Group Effectiveness facilitates regulatory process for both the Licensee / Owners Group and NRC.
3 Efficiencv:
Enhance riecision-makina:
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. Reaional Interfaces Cateoorv The Regional Interface Category covers all DLPM tasks during interaction with Regional persorinel such as the DRP Branch Chief and Resident inspectors. This interaction is invaluable in giving the Project Manager (PM) a unique perspective of licensee performance and plant status. This allows the PM to be more knowledgeable as the 3
Headquarters focal point.
l The most common interface with the Region is via the morning status calls. The PMs
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are able to gain insight on plant status and also update the Region on any pertinent licensing issues. The PMs are also kept current on Regionalissues and changes. The morning calls also help establish a good working relationship between the PMs, Region DRP personnel and the residents.
The improved working relationship facilitated by the morning calls allows the PM to carry out his/her other regionalinterface duties more effectively. The PMs field Technical I
Specification interpretation questions on a regular basis. Resolution of technical questions from the resident are handled in a timely manner in order to support inspection and assessment efforts. If not able to answer the technical question outright, the PM j
forms a technical team comprised of Headquarters staff and manages the resolution of the issue.
The PMs provide event follow-up support to the Regions as appropriate, coordinating Headquarters involvement in the near term. Immediate event follow-up includes response to management and/or media questions regarding the event.
PMs keep current on licensee performance by thoroughly reviewing the inspection Reports and noting trends and emerging issues. In support oflicensee assessment efforts, PMs provide input to the Plant Information Matrix (PIM) and attend Plant Performance Reviews (PPR). PPRs are held on a biannual basis and PMs provide assessment of the licensees licensing performance and offer unique insights to overall plant performance. PMs also participate in enforcement activities offering their insight and perspective.
When appropriate and necessary, PMs will be an integral member of a Management Oversight Panel.
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. Performance Measures for Regional Interfaces Category:
f Timeliness:
Participate on calls with the regional staff on a daily basis. Technical information, Tech spec interpretations, event follow-up information and support to the Region and OE on enforcement issues are provided in a timely manner consistent with the safety significance of the issue. PIM inputs are provided within two weeks of documentation. Inspection reports are reviewed in a timely manner.
Effectiveness:
Feedback from Region reveals that DLPM knowledge of plant issues is useful and communication is effective. Consistency is provided with regard to Tech Spec interpretations. Significant events are identified promptly. PIM inputs provide the Region with insights to licensee performance. Appropriate issues identified in inspection Reports are brought to management's attention.
Efficiency:
Information is efficiently disseminated on NRC positions, policies and Tech Spec interpretations. Resources experided on RegionalInterfaces are commensurate with safety and risk significance of the issue. Interface has little or no adverse impact as measured by feedback from the Regions.
Quality:
Information provided is accurate per feedback from stakeholders.
Quantitv:
PM participates in 2 PPRs per year.
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. Outcomes for Regional Interfaces Category:
Maintain PM perspective provides an integrated view c f each site anci ensures safety Safetv:
concems and events are factored into daily work. Risk significant issues and events are discussed during morning calls. Communications with the Regions often involve conveying NRC pos'tions regarding safety issues.
Support to regional staff in conducting inspection program helps identify safety and compliance issues at specific site or problems with content of technical specifications. Identification of significant events can lead to risk reduction, ensure appropriate agency response, and quickly identify potential generic concems.
Reduce A knowledgeinble PM can prevent unnecessary questions forwarded to the Unnecessary licensee.
Burden:
Increase PM knowledge of plant results in ability to share knowledge during Pubhc interactions with the public resulting in increased public trust. Involvement Confidence:
in Management Oversight Panels demonstrates that the NRC is proactive with respect to safety concems.
Increase Sharing of information allows routine processes to be more efficient.
Effectiveness Regional Interface allows NRR to perform some interface roles which can
& Efficiencv:
be more efficiently performed by HQ staff, thereby minimizing impact on regional staff.
Enhance decision-makina:
Other:
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. NRC Headcuarters Interfaces Cateoorv DLPM serves as the primary interface between NRC headquarters organizations and licensees or regional offices in matters pertaining to specific power reactor facilities. The 1
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, in addition, DLPM's ability to discuss requests for information first-hand with those posing the questions or requesting briefings and to incorporate related discussions into routine exchanges with other NRC staff and licensees greatly reduces the burden on regional staff or licensees in terms of providing information. As the NRC headquarters point of contact for information about specific reactor facilities, DLPM personnel are able to provide support to senior managers at headquarters; the Commission; other offices such as research, public affairs and congressional affairs offices; the advisory committee on reactor safeguards; and other organizations within NRR. The available support comes in the forms of answering isolated inquiries, helping to evaluate events, preparing briefing packages, coordinating site visits, conducting surveys, and reviewing draft reports or evaluations.
DLPM also supports other headquarters organizations in terms of answering questions about and coordinating activities with the licensing programs. Examples include interactions with the office of research regarding accident sequence precursor evaluations or investigation of safety issues, with the office of nuclear material safety and safeguards regarding spent fuel storage and transportation issues, and assisting the office of the general counsel prepare for and participate in legal proceedings. The NRC's incident response program also calls upon the DLPM staff for support due to their knowledge of plant design features and licensing bases.
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, Performance Measures for NRC HQ interfaces Category:
Timeliness:
Briefing packages, surveys, or other deliverables are provided in accordance with NRC, NRR, or DLPM guidance documents. Feedback from NRC headquarters organizations is that DLPM provides timely support.
Effectiveness:
Feedback from NRC headquarters organizations is that DLPM support is necessary to fulfill agency needs.
Efficiencv:
Feedback from NRC headquarters organizations and regional offices that system is providing necessary support with minimal impact on regional operations Quality:
Completed work is of the highest quality and does not need to be reissued to correct technical errors. A high level of licensing expertise is evident.
Feedback from NRC headquarters organizations is that quality of information provided is adequate to fulfill agency needs.
Quantity:
As requested i
Other:
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, Outcomes for NRC HQ Interfaces Category:
Maintain Support to other NRC headquaders organizations can help to maintain
- Safety, safety by ensuring necessary information is provided to appropriate personnel.
Reduce Providing a single headquarters point of contact reduces unnecessary Unnecessary burden by reducing the number of inquiries to licensees and ensuring those Burden:
requests that are forwarded to licensees are for only that information necessary to make a regulatory decision increase Ensuring that headquarters personnel are able to obtain information in a Public timely manner increases oublic confidence in the agency.
Confidence:
Increase Providing a single headquarters point of contact and utilizing information Effectiveness gathered in support of core activities limits dem ends placed on regional
& Efficiencv:
personnel (i.e., an additional return on investment on interactions with regions and licensees).
Enhance decision-makina:
Other:
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Public Interfaces Cateaorv 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 from outside of the NRC. This limits the numbers and types of requests for information that are forwarded to the regional offices or the licensees. DLPM will participate in the redesign of and long-term maintenance of NRC intemet web pages that provide plant specific information to the public as well as NRC personnel. Their knowledge of plant design and licensing basis information for power reactor facilities makes DLPM personnel routine' participants in responding to allegations, controlled and routine correspondence, and other requests for information from the public (requests made under the freedom of information act).
1 Performance Measures for Public Interfaces Category:
Timeliness:
Responses or other deliverables are provided in accordance with NRC, NRR, or DLPM guidance documents. Feedback from public is that DLPM provides timely responses.
Effectiveness:
Feedback from senior management, public affairs, congressional affairs or other stakeholder is that DLPM provides information to the public in a manner that satisfies agency needs Efficiencv:
Feedback from NRC headquarters organizations and regional offices that system is providing necessary support with minimal impact on regiulal operations Quality:
Completed work is of the highest quality and does not need to be reissued to correct technical errors. A high level of licensing expertise is evident.
Feedback from NRC organizations and other stakeholders is that quality of information provided is adequate to fulfil agency needs.
Quantity:
As requested Other:
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, Outcomes for Public Interfaces Category:
Maintain Response to allegations or other public inquiries can help to maintain safety Safety:
by ensuring that issues are identified and associated information is
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appropriately disseminated.
Reduce Unnecessarv Burden:
Increase Addressing concerns raised by the public or simply providing information in Public response to requests increases public confidence in the NRC and its I
Confidence:
processes and procedures. Having a point of contact in headquarters
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supports responses and avoids perception that NRC is not in touch with activities at specific facilities.
Increase Providing a single headquarters point of contact and utilizing information Effectiveness gathered in support of core activities limits demands placed on regional
& Efficiencv:
personnel (i.e., an additional return on investment on interactions with regions and licensees).
Enhance decision-makina:
Other:
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,, Reoulatory lmorovements 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 j
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 i
associated knowledge and skills of the DLPM staff. In general, the changes in procedures, I
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 m'>re important.
The Licensing Action Task Force is currently addressing issues or processes identified by industry and the NRC staff as potential areas of improvement. The improvements being pursued include changing the request for additional information (RAl) process, developing a mechani?m to address minor discrepancies in the wording of requirements in the technical specificat/>ns, refining the process for issuing changes to technical specification bases sections, enhar.cing 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 j
owners groups are invaluable in sharing technical and process information. DLPM interactions 1
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 l
concerns by undertaking voluntary initiatives in lieu of responding to generic communications issued by the NRC NRC resource expendit,ures 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.
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 1
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.
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.i., r Performance Measures for Regulatory Improvements Program Area:
Ilmeliness:
Meet established schedule for closure of issues agreed upon by NRC and DLPM contingent upon industry ability to support issues. Interactions are conducted in a timely manner as to promote reaching closure on regulatory issues. Internal regulatory improvements meet established schedules.
Effectiveness:
Interactions are effective methods of communication between the NRC, Owners Groups and licensees. Topics address idded value to the regulatory improvement process. Internal efforts result in increased regulatory effectiveness.
Efficiencv:
All interactions involving regulatory improvements facilitate resolution of issues through topical reports or industry initiatives to reduce NRC resource expenditures.
Qualitv:
Completed work is of the highest quality as measured through voluntary licensee feedback. Policy and Rule changes are clear and add value to regulatory process.
Quantity:
Five or more safety significant issues are resolved by Owners Groups rather than through NRC. Hold 8 Licensing Workshops in FY00 as directed by Office Director.
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l Outcomes for Regulatory improvements Program Area:
Maintain.
Working with groups of licensees to resolve safety concerns through the Safety:
use of voluntary industry initiatives helps to maintain safety Reduce By focusing efforts and resources (NRC and licensee) on generic resolution Unnecessary of safety issues, regulatory burden is reduced and NRC efficiency is gained.
Burden:
Increased communication with licensees leads to increased understanding of NRC information needs which results in elimination of unnecessary regulatory burden and increased NRC efficiency.
Increase By assuring the public that safety significant issues are being resolved in a Public consistent manner for all affected licensees, public confidence will be Confidence:
increased, i
increase improved communication with licensees and better policy / rules / guidance 1
Effectiveness leads to increased effectiveness and efficiency.
& Efficiencv:
4 Enhance decision-makina:
Other:
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3 QUESTIONS: During the course of the July 23,1999, public workshop, the staff would l
appreciate feedback from participants on the following questions. This information will be most L
useful as the staff proceeds with the process to define the role of the NRR/ Projects licensing i
organization for the future.
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- 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 intemal efficiency and effectiveness.
'1.
What do you believe should be the principle role of the Projects organization?
i 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 4
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?
6.
What types of performance indicators would be useful for the staff to employ to objectively determine its effectiveness in performing licensing activities?
' 7.~
What five activities contained 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?
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, l
and provide an explanation why.
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- 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.
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- 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: mkoante oov l
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