ML20212A206
| ML20212A206 | |
| Person / Time | |
|---|---|
| Issue date: | 08/10/1999 |
| From: | Black S NRC (Affiliation Not Assigned) |
| To: | |
| References | |
| NUDOCS 9909160111 | |
| Download: ML20212A206 (18) | |
Text
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NUCLEAR REGULA TORY COMMISSION Summary of Workshop on Redefining the Role of NRR Projects AGENCY: Nuclear Regulatory Commission ACTION: Notice of Availability FUDLIC COCUMENT ROOM
SUMMARY
- On July 23,1999, the Nuclear Regulatory Commission sponsored a public 99 AUG 16 D19 workshop involving NRR Division of Licensing Project Management, licensing officials representing the nuclear industry, and other stakeholders. The purpose of the meeting was to provide a forum for constructive dialogue on the agency's efforts to redefine the responsibilities of the Division of Licensing Project Management. The discussion focused on three program areas: Licensing Authority, Interface, and Regulatory improvements. A brief version of the meeting summary is attached. The complete summary of the July 23,1999, meeting with all attachments dated August 9,1999, is available for public inspection at the Commission's public document room located at the Gelman Building,2120 L Street, NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT: Sheri Peterson, Mail Stop O-8-G-9, U.S. Nuclear Regulatory Commission,11555 Rockville Pike, Rockville, MD 20852-2738; Telephone: (301) 415-1193; internet:SRP8NRC. GOV Dated at Rockville, Maryland, this 10th day of August,1999.
For the Nuclear Regulatory Commission.
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SUMMARY
- JULY 23,1999, MEETING WITH STAKEHOLDERS ON i
REDEFINING THE ROLE OF THE DIVISION OF LICENSING PROJECT MANAGEMENT I
IN THE OFFICE OF NUCLEAR REACTOR REGULATION On July 23,1999, representatives of various licensees and members of the public met in a l
public meeting with members of the U.S. Nuclear Regulatory Commission (NRC) staff at NRC Headquarters in Rockville, Maryland. The NRC invited representatives of various nuclear i
utilities, other groups, and the public to padicipate in a workshop to discuss the responsibilities
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of the Division of Licensing Project Management (DLPM) and solicit feedback on the Division's ongoing redefinition process from interested stakeholders. A list of attendees is provided as. The workshop agenda is provided as Attachment 2. The Division's re-invention report provided during the meeting is included as Attachment 3. The feedback obtained from the meeting participants during the breakout sessions is included as Attachment 4. The written comments received to date on the role of DLPM are included as Attachment 5.
DLPM is in the process of redefining its responsibilities. Previous audits and reviews had indicated that the function of operating reactor licensing project managers 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 public confidence, and increasing efficiency and effectiveness of key NRC processes. DLPM shared the results of its redefinition process with external stakeholders to solicit feedback so that the responsibilities can be further refined.
After introductory remarks, the meeting participants broke into four groups to discuss the questions summarized in Attachment 4 (also published in the Federal Reoister. Volume 64, Number 133 dated July 13,1999). Discussions focused on the project manager being the primary NRC interface for licensees and the public on operating plant licensing matters, the need for consistency, cost and schedular control of licensing actions, and the importance of maintaining staff with the required knowledge, skills and abilities for effectively carrying out the project manager function. The feedback presented by the various participants during the breakout sessions, and included as Attachment 4, was very extensive and will be useful to the
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NRC in DLPM's initiatives involving the project manager function within the Office of Nuclear Reactor Regulation.
Attachments:
- 1. Attendance List
- 2. Agenda (available in PDR)
- 4. Feedback from breakout sessions
2 ATTACHMENT 1 PURPOSE:
REDEFINING THE ROLE OF THE DIVISION OF LICENSING PROJECT MANAGEMENT DATE:
July 23,1999 LOCATION: TWFN Auditorium NAME AFFILIATION Steve Wideman WCNOC Pat Nugent PGBE Roger DeWolfe TXU Kenneth Russel!
First Energy John A. Zwolinski NRR-DLPM Philip A. Rose SCE&G Jeff Sobotka NAFISCO j
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George Wrobel RG&E Mike Krupa Entergy Mike Brandon Entergy W3 Paul Blanch Millstone Mark J. Ajiuni Southern Nuclear Oper.Co.
Joe Sheppard STPNOC Jon Hopkins NRC/NRR/DLPM Patrick Sekerak NRC/NRR/DLPM Alan Wang NRC/NRR/DLPM Helen Pastis NRC/NRR/DLPM Jack Cushing NRC/NRR/DLPM Marsha Gamberoni NRC/NRkiDLPM Lee Berry NRC/f;RR/DLPM James Perselter North Atlantic Mike Runchark AEP
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Norm Peterson Detroit Edison l
R. M. Kruch Coned Jerry Roberts.
Entergy Ops GGRS Roger Huston Licensing Support Services James Priest PSE&G
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d Nate Haskell Consumers Energy i
Stuart Richards NRC/NRR/DLPM i
Ram Subbaratnam ~
NRC/NRR/DLPM Chris Jozwick NRC/NRR/DLPM L. N. Olshan NRC/NRR/DLPM Bob Martin NRC/NRR/DLPM Harold Chirnoff CP&L Rich Laufer NRC/NRR/DLPM
'L Byran Ford Millstone 1 William Heyser EPU Nuclear Sheri Peterson NRC/NRR/DLPM Steve Bethay Entergy-Pilgrim Bill Reckley NRC/NRR/DLPM Jim Clifford NRC/NRR/DLPM Al Passwater AmenemVE Johnny Eads.
CP&L-Glenn Michael Arizona Public Service Co.
Merrill Atkins Yankee Atomic /DE&S S.Singh Bajwa NRC/NRR/DLPM C. Stephen Brennigan Entery, PNPS John Hufnagel PECO Energy Don Palmrose NUSIS George W. Busch GPU Nuclear Inc.
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Suzanne Black NRC/NRR/DLPM i
Frank Rinaldi NRC/NRR/DLPM j
Duke Wheeler NRC/NRR/DLPM
'l Gordon Edison NRC/NRR/DLPM Claudia Craig NRC/NRR/DLPM Paulinserra Energy Northwest Gene Eckholdt NSP C. Jeff Thomas Duke Energy I
Paul Pace TVA Steve Bennett Entergy-ANO Paul Willoughby Northeast Nuclear Mike Schoppman NEl Tom Elwood lilinois Power Marc Koth Northern States Power Bob Gramm NRC/NRR/DLPM Scott Hega STP Nuclear Op.
Elaine Chobanan Northeast Utilities Donna Skay NRC/NRR/DLPM John Harrison NRC/NRR/DLPM John Kelly NYPA Kathy Harvey Gibson NRC/Ril Eileen McKenna NRC/NRR Thomas Shaub VA Power Bill Gleaves NRC/NRR/DLPM Tom Elwood Illinois Power
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Feaion 1 ATTACHMENT 4 1.
Principal role of projects.
General comment: 72 tasks are too many to er.ut an individual to perform well.
i-(1) Support / Process licensing actions (a) Make it happen (authority)
Active, up-front planning with licensees to facilitate NRC and licensee resource planning.
Effective use of RAl process.
(2) Serve as the conscience of the staff.
(3) Be the advocate for the project.
(4) Focal point for resolving staff and licensee concerns (and other stakeholders).
(5) Balancing / accomplishing NRC and licensee priorities.
2.
Five activities most important.
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(1) Timely completion of licensing actions (on agreed-upon schedule)
(2) Communicate, manage difficulties with licensing actions effectively.
(3) Tasks 1-4,8,22,37,19,26,29,59. - most important overall are tasks 1 through 12 (alllicensing actions).
3.
Reasons these activities are important (2)
(1) Keep plants safe.
(2) Allow efficient operation of the plant.
4.
Other activities projects should perform (1) Manage public documents (ensuring incoming and outgoing documents are rapidly and readily available to the public and to licensees..
(2) Ensure timely notification of meetings.
(3) Communication clearing house (timely transmittal to licensee, particularly for those requiring responses).
(4) Manage / Control potential Violations during resolution of ongoing generic reviews.
- (5) Cost management (fee billing)/ Communicate targets up front, PM monitor during review (hold both staff and licensee accountable).
(6) Development / training / qualifications in project management skills and communication skills.
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2 5.
Reasons these activities are important (4).
(1) Reduce licensee burden (efficiency).
(2) Improve public confidence.
6.
What types of performance indicators would be useful?
(1) Age oflicensing actions.
(2) Accuracy of product.
- number of correction letters
- rework (3) Stakeholier approval rating (including PM evaluation).
(4) Number of teleconferences per action.
(5) Number of review hours vs. complexity of item.
(6) Performance to schedule (specific tasks).
7.
Five activities least important.
(1) Task #39(from attachment 3 available in PDR)- Enforcement actionn (2) #28 - Transition of assignments (3) #70 - Future rule changes (4) #57 - Section meetings (5) #23 - Petitions and requests from non-licensees (6) #60 - Web page management (7) #64 - Freedom of Information Act (FOIA) requests post-ADAMS (Agencywide document access and management system) 8.
Reasons these activities (7) are less important.
(1) Not role of PM in meeting licensee priorities.
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9.
Any activities projects organization should not perform?
(1)see response to 7 10.
Additional input.
(1) Periodic face to face feedback sessions.
(2) Planning for peak periods.
(3) PMs need guidance of how much authority they have and when.
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3 (4) Training of PMs (including behavioral skills).
1 (5) Ensure consistency with prior NRC approvals.
(6) PM should facilitate, coordinate, and manager accomplishment oflicensing actions (7) ' Allow PM to focus on licensees as customers, maintaining his other obligations.
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(8) Does PM have the authority commensurate with his responsibilities?
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Other issues.
(1) None
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Realon il 1.
Principal role of projects.
(1) Process Technical Specificatic,n changes / licensing actions.
(2) Deliverer of licensee information for licensing actions.
(3) Primary interface with licensee and r gion (single point of contact).
(4) Coordinate / ensure communication (filter out unnecessary interactions) - requires PM knowledge of submittal and licensing basis.
(5) Coordinate meetings.
(6) Cource of information on NRC policy / procedures (important for " filter" mentioned in 4 above).
(7) Contact on plant issues.
(8) Facilitate licensing work / streamline process.
(9) Owner of licensing basis.
2.
Five activities most important.
(1) Process licensing actions [ Federal Register notice, processing Requests for Additional Information, Environmental Assessments); including all actions tha require prior NRC approval before the licensee implements- [10 CFR 52.90; 50.54);
Determine review method, schedule [ work planning), and be responsible for implementation - Project Manager; Writing Safety evaluations, and other licensing tasks.
(2) Interface with licensee.
(a) Headquarter interfaces (provide filter for unnecessary regulatory burden)
(3) Administrative / Coordinator of NRC business functions; (a)
Review fees (billing licensee for staff review effort / cost control and adrninistrative oversight).
(b) Manage to Office Letter 803 staff review time estimates / hours (for alllicensing actions and other licensing tasks beyond amendments) and communicate with licensees / ensure accountability for hours charged to a review (4) Other licensing tasks: Conflict resolution, ensuring consistent treatment of licensing actions / licensees, provide feedback on quality of licensee's submittals, and maintaining licensing basis.
(5) Interface with Office of General Counsel / Hearings
5 3.
Reasons these activities are important (2)
(1) Licensing actions
- Reduce unnecessary burden
- Maintain safety 1
(a) Project managers writing Safety evaluations
- Effectiveness and Efficiency, maintain safety.
(2) Interface with Licensee (as well as, NRC headquarters and Region)
- Efficiency and effectiveness
- Public confidence (accuracy of information).
(3) Administration / Cost control
- Reduce unnecessary burden
- Effectiveness and efficiency (4) Other licensing tasks 1
- Public confidence (lack of "open" safety issues)
- Maintain w%ty
- Reduce un: ecessary burden 4.
Other activities projects should perform (1) Cost control (look at Nuclear Energy Institute (NEl) talking points in enclosure 5).
(2) Task-oriented project management, i.e., license renewal, SG issues / replacement, Power uprates, etc.
(3) Skill development / maintenance for effective project management.
5.
Reasons these activities are important (4).
(1) Cost control
- Reduce burden
- Safety (best use of $$)
(2) Task-oriented Project Managers
- Effectiveness and efficiency (3) Skills / Development
- Effectiveness and efficiency 6.
What types of performance indicators would be useful?
(1) Supported NEl proposal (provided in enclosure 5)
(2) Overall timeliness, schedule adherence (3) Average modian ages (encourage staff to post data on the Web, including comparisons between NRC groups)
(4) NRC staff should conduct Benchmarking
6 (5) Customer surveys and feedback at the individual level (up to performance appraisal input on effectiveness of being the focal point.)
(6) Comparison of actual performance compared to a work plan vs. averages (ages, etc.)
7.
Five activities least important.
(1) Maintaining licensing documents (need to do but shouldn't interfere with work).
(2) 50.59 reviews of annual report.
(3) Conducting surveys.
(4) Collateral duties /LPMs.
8.
Reasons these activities are less irnportant (7).
(1) Do not contribute to the four goals 9.
Any activities projects organization should not perform?
(1) As determined by priorities above.
10.
Additional input.
(1) NRC budget process should be more timely and in advance.
(2) Role of Project Manager supervisor
- budget control
- conflict resolution (various staff and licensees)
- schedule adherence (3) Customer orientation (NRR-licensee, NRR-region, NRR public; watch out for escalating cost of public interaction).
(4) Redefining - Reprioritizing for current effort.
(5) Move toward approaches like inspection / oversight process
- define need to do/ safety significance.
(6) Maintain separation oflicensing and oversight.
11.
Other issues.
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1 Reason III 1.
Principal role of projects.
(1) PMs should run interference to ensure reviewers are being consistent.
- (2) PMs need decision authority to actively manage their issues.
(3) PMs need knowledge of licensing basis - tools -i.e., use a " licensing notebook,"
evaluate a plant against its licensing basis vs. Standard review plan (SRP should not be imposed on non-SRP plants).
(4) Still need to work on Office Letter 803 implementation. Some PMs read requests for r:tditionr! information (RAI) questions instead of faxing them to licensee. Some PMs don't review RAI questions to ensure they are appropriate (e.g., consistent with design basis) before sending them to licensee.
(5) PMs need to work with licensee for most efficient way to do review.
l (6) Proactive PM/ " advocate" of efficient / effective review.
(7) PMs should provide for timely Technical Specification interpretations / commitments / regulation.
(8) "DLPM should initiate " Task Interface Agreement-like" process for questions from licensee.
(9) Continue daily interface with region (10) Improvement with PM doing own reviews.
(11) Staff should be consistent with past decisions.
2.
Five activities most important (only 4 were selected).
(1) Management of licensing issues (including notices of enforcement discretion).
(2) Routine interface during licensing action reviews.
(3) Reduce regulatory burden through reduced reporting requirements.
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(4) Communications - bring balance and perspective to regulation of power plant.
3.
Reasons these activities are important (2) 1 I
(i) Maintains safety, improves efficiency and effectiveness and enhances public confidence.
(2) Reduce unnecessary regulatory burden.
8 (3) Reduce unnecessary regulatory burden, improve safety by allowing licensees to q
concentrate on safety significant issues.
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(4) Improve public confidence, improve efficiency and effectiveness and decrease unnecessary regulatory burden.
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4.
Other activities projects should perform
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(1) Maintain a licensing notebook for licensing basis reference.
(2) Develop a standard process for PM turnover, etc.
(3) Communication / plant visits on open item (i.e, TAC list, etc.). Include reviewers on a case-by-case basis.
(4) Prioritize generic issues by risk significance so licensee's don't have to work them all at once.
5.
Reasons these activities are important (4).
(3) Improves efficiency and effectiveness and improves safety (through better PM knowledge of plant).
(4) Improves efficiency and effectiveness.
(5) Improves efficiency and effectiveness, decreases regulatory burden and increases public confidence.
(6) Improves safety, decreases regulatory burden and hereases public confidence.
6.
What types of performance indicators would be useful?
(1) Rating PM behaviors, attributes and leadership (2) Formal feedback mechanism - surveys, errors in safety evaluation reports (SERs).
l-(3) Self assessments.
l (4) Schedule vs. priority (5) Measure percentage of closed activities as a multiple of how fast they were requested to be closed out.
(6) Internal review to ensure quality; develop a standard. SERs should be reviewed by independent group.
J (7) At licensing workshops, get attributes for quality submittals and SERs.
7.
Five activities least important.
' (1) Use of PMs as acting resident.
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9 (2) Collateral duties (e.g., lead PM assignments).
(3) Requirement to submit routine reports that don't appear to receive NRC review.
(4) Should review 10 CFR 50.54 changes on audit basis instead of reviewing and approving each change.
(5) PMs should not be responsible for ensuring accuracy of licensing basis. That's the licensee's responsibility.
8.
Reasons the activities are less important (7).
l (1) Not effic;ent or effective use of PM.
(2) Not efficient or effective use of PM, could harm safety by distracting PM from primary responsibility.
(3) Regulatory burden with no benefit.
(4) Regulatory burden with no benefit.
(5) Not efficient or effective use of PM.
9.
Any activities projects organization should not perform?
(1) DLPM should not be doing technical specifications bases reviews in some cases (Distinguish between improved technical specifications (ITS) and non-lTS plants for TS bases changes (bases control program)).
10.
Additional input /Other issues.
(1) " Cherry picking"- NRC should issue Generic Letter identifying what new improved j
technical specifications items they can get.
(2) Administrative support
- OGC - work of OGC should be better controlled tu improv: process
- Concurrence chain ' empowerment" - concurrences should be minimized j
- There should be enough administrative support to prevent typing / distribution causing delays in the licensing process.
(3) Clarify role of PM/NRR in new oversight process
- ensure consistency
- role in 50.59 inspection '
- SDP - NRR may need to support regional Senior Risk Analysts /others l
- Plant performance reviews i
1 (4) NRR should have input to new process (PMs)
(5) Need more informal ways of taking advantage of generic resolutions
10 (6) Need to define role of PM in license renewal and decommissioning. Need to retain same PM.
(7) Need the Infrastructure to support PM.
(8) For informal surveys, need to ensure consistency; timeliness; NRC expectations, (9) TIA process should be more open to allow licensee input.
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l1 Reaion IV There was a fair bit of discussion about the need to distinguish between what PMs should do, and what DLPM/NRR should do when the group considered the following questions. In some cases, the group has delineated their responses accordingly.
4 1.
Principal role of projects.
(1) Coordination (2) Interface with NRR/ Licensee l
- advocate for licensee l
- (or) representative of licensee
- on schedule l
(3) Screening Requests for additionalinformation (RAls) and staff decisions for regulatory l
basis / achieve burden reduction Advance reactor safety by providing a knowledgeable interface oetween NRC and licensees and l
ensuring licensing actions are processed efficiently.
2.
Five activities most important.
The following items are important for PMs:
,y (1) Licensing action coordination (true project management role)
. (1a) licensing action review / approval performed by PM (personal approval)
(2) Communication with licensees - explain what is needed/ required by the staff, and why it is needed (regulatory basis)
(3) Screening RAls, and guarding the licensing basis.
(4) Keep senior NRO management informed of activities at that plant The following items are important for DLPM:
(5) Coordination /prioritization with other divisions (6) NRR/ region interface l
(7) Regulatory improvements 3.
Reasons these activities are important (2)
(1) PM should evaluate licensing actions, RAls, work priorities, etc. against outcome goals and reject those that don't conform with outcome goals..
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12 4.
Other activities projects should perform (1) Relationship with media, and maintain sensitivity when providing information that has l
financial or commercial consequences.
(2) Participate in site inspections (3) Be more involved with enforcement (4) Be more involved with new performance assessment process 5.
Reasons these activities are important (4).
(1) Relationship to outcome goals.
6.
What types of performance indicators would be useful?
(1) Number of days deviation from project schedule (joint agreement between staff and licensee on schedule).
(2) Current goals, e.g.,95% < 1 year,.n_ot appropriate for all licensing actions.
(3) Number of RAls.
(4) Quality of licensing action, e.g., number of errors.
(5) Percentage of licensing actions performed by project manager.
7.
Five activities least important.
(1) 2.206, other Federal agency interface (this is important for DLPM, not PM).
(2) 50.59 evaluation reviews.
(3) Review of inspection reports.
(4) Maine Yankee, Millstone lessons learned.
(5) Support for Congressional Affairs.
8.
Reasons these activities are less important (7).
(1) Not supporiive of outcome goals and primary licensing action work.
9.
Any activities projects organization should not perform?
(1) None identified.
10.
Additional input.
See 11.
11.
Other issues.
(1) Dedicated project manager for plant is key ingredient for success
- Ir. some cases 1 PM could handle more than 1 plant (if plants were similar)
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- is billing an issue?-
- varies by commonality of licensing tasks j
- varies with workload
- decision to assign PM to more than 1 plant, and assignment of significant co-lateral duties should include licensee input f
- NRR needs to have flexibility.
(2) TIA process
- need licensee involvement to provide information for NRR consideration.
- currently little communication with licensee until decision is made.
(3) Better coordination of generic issues - need for generic issue project managers, not necessarily plant PMs.
(4) Should review 72 items against the priorities in Question 2.
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