ML20237E859

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Forwards Staff Plan of Short & long-term Actions to Respond to Issues Raised During 980730 Hearing Before Senate Subcommittee on Clear Air,Wetlands,Private Property & Nuclear Safety & 980717 Commission Meeting W/Stakeholders
ML20237E859
Person / Time
Issue date: 08/25/1998
From: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Shirley Ann Jackson, The Chairman
NRC COMMISSION (OCM)
References
FRN-64FR12117 AG12-1-039, AG12-1-39, M980717A, NUDOCS 9809010233
Download: ML20237E859 (58)
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UNITED STATES f

NUCLEAR REGULATORY COMMISSION COMSECY-98-024_

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MEMORANDUM TO:

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FROM:

L. Joseph Calla i

Executive Director fo perations

SUBJECT:

RESPONSE TO ISSUES RAISED WITHIN THE SENATE AUTHORIZATION CONTEXT AND JULY 17,1998 l

STAKEHOLDER MEETING

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Attached for your information is the staffs plan of short-and long-term actions to respond to issues raised during the July 30,1998 hearing before the Senate Subcommittee on Clean Air, Wetlands, Private Property, and Nuclear Safety and the July 17,1998 Commission meeting with stakeholder.

As you noted in your August 7,1998, memorandum to me, concems were raised about several issues: the predictability, objectivity, and timeliness of NRC decisions; the focus of NRC activities; the quality of NRC-licensee interactions; the implementation of NRC programs; and the size of the NRC staff. The Staff Requirements Memorandum on the July 17,1998 Public Meeting on Stakeholder' Concerns (SRM M980717A) dated August 18,1998, provided possible improvements in NRC activities that were identified during the public meeting. The j

SRM contains fifteen activities, most of which would address the concerns expressed by the Senators.

The attached plan's organization follows the outline of your testimony for the July Senate Oversight Subcommittee hearing in order to facilitate preparation of testimony for the upcoming hearing in January 1999. By reference to the former testimony, the staff will be able to show the progress made by the NRC toward responding to the concerns of the Senators, All of the items and issues in the August 7,1998, memorandum have been addressed. The improvements in NRC activities described in SRM M980717A have also been addressed, with the exception of item 12, "The Establishment of an Assessment Team to improve the Regulatory Process," which will be addressed separately. In light of the scope of the tasks outlined in this plan, there will be an impact upon the staffs ability to complete certain activities and previously assigned projects.

As we proceed with the implementation of the plan and complete the associated updates to the j

p agency's planning and budgeting process, those items requiring deferral or termination, in light

]I of higher priorities, will be identified and communicated to senior management. Such an i

example is the suspension of the Systematic Assessment of Licensee Performance (SALP) 4 f o/ l process, which is proposed in item Ill.A.

V The plan should be considered a living document which will be updated on a periodic basis and focus on improving NRC's regulatory processes in several key areas. These efforts will demonstrate our commitment to regulatory effectiveness. The objectives stated for each section of the plan are outcome-oriented and the progress toward the associated milestones will be actively monitored by the senior managers. Furtt eer, a number of tasks within the plan involve O9f l

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2 interactions with our external stakeholder, not only to understand their concerns, but also to achieve agreement on issues of scope and schedule for industry efforts.

I note, in particular, that the staff views the development of a revised plant performance assessment process as pivotal. Our success in improving NRC's enforcement and inspection policies is closely linked to this effort. The outcomes will be a more efficient and effective assessment process, a risk-informed baseline inspection program, and a less burdensome enforcement policy. In addition, licensing activities will be improved by streamlining the license renewal, adjudicatory hearing and license transfer processes. Lastly, the plan highlights specific areas for improvement including the agency's transition to a risk-informed framework, revisions to 10CFR50.59, and restructuring the line organization.

Managers assigned responsibility in the action plan will ne accountable for the timely completion of the tasks. Because of the need to affect change in the short term, I will review the progress with senior managers in each responsible office on a frequent basis. As we implement these tasks any emergent policy issues will be brought promptly to the Commission. The staff will provide informal briefings to the Chairman and Commissioners on a periodic basis on the key j

focus areas, highlighting the important decision points during the development of new processes in order to ensure that the final products meet the Commission's expectations.

The attached plan is aggressive in content and schedule. Many of the planned tasks, such as enforcement and reactor licensee performance assessment, will require fundamental change in l

the way NRC conducts its business. As a consequence, extensive two-way communication will l

be required to ensure that a consistent, coherent message reaches the staff about the expectations for implementation of the new processes. This is one of the challenges that I will focus on as the process changes are formulated.

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Attachment:

As stated i

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Commissioner Diaz Commissioner McGaffigan i

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Distnbution:

B. John Garrick, ACNW -

' Gary Holohan, NRR Robert L. Seale, ACRS Tom King, NRR l

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~JohnT. Larkins, ACRS/ACNW M. Johnson, NRR B. Paul Cotter, Jr., ASLBP -

F. Gillespie, NRR ~

Karen D. Cyr, OGC-D. Gamberoni, NRR.

' John F. Cordes, Jr., OCAA C. Grimes, NRR '

N Anthony J. Galante, CIO -

J. Roe, NRR 1

' Jesse L. Funches, CFO D. Matthews, NRR

! Hubert T. Bell, IG ~

B. Boger, NRR 3

Carlton R. Stoiber, OIP -

J. Stolz, NRR -

Dennis K. Rathbun, OCA

' B. Sheron, NRR William M. Beecher, OPA -

John C. Hoyle, SECY S. Weiss, NRR

Hugh L. Thompson, Jr., OEDO R. Wood, NRR -

William D. Travers, OEDO T. Quay, NRR -

Patricia G. Norry, OEDO -

W. Kane, NRR LJames L.' Blaha, OEDO S. Shankman, NRR Edward L. Halman, ADM

. D. Allison, AEOD

' Thomas T. Martin, AEOD J. Jacobson, NRR James Lieberman, OE J. Flack, RES

. Guy P. Caputo, OI.

EDO Staff

Paul E. Bird, HR EDO R/F-Irene P. Little, SBCR' DEDR R/F 4

Carl J. Paperiello, NMSS

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Samuel J. Collins, NRR Ashok C. Thadani, RES Richard L. Bangart, OSP

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- Hubert J. Miller, RI

- Luis A. Reyes, Ril.

-. James L. Caldwell, Rill '

Ellis W,' Merschoff, RIV l

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e STAFF RESPONSE TO TASKING MEMORANDUM AND STAKEHOLDER CONCERNS Attachment

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1. TOPIC AREA: Risk-Informed and Performance-Based Reaulation SES Managers: Gary Holahan, Director, DSSAINRR and Thomas King, Director, DST /RES A. Specific lasue: Evaluation of Industrv Proposals and Rulemakina Objective: The objectives are enhancing safety decisions, efficiently utilizing NRC resources, reducing unnecessary conservatism, as well as soliciting industry insights.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Conduct Licensing workshop to discuss streamlining 07/98C G. Kelly, DSSA the review process for risk-informed (RI) applications
2. Conduct Periodic PRA Steering Committee Meetings 8/20/98C RES/DSSA (Monthly)
3. Establish agreement with industry on formation of 8/98C RES industry PRA steering committee to interface with NRC Steering Committee and an industry licensing panel to interface with the NRC RI Licensing Panel.
4. Meet w/ South Texas Project on industry perspective 09/98 G. Kelly, DSSA to develop lessons learned
5. Follow-up to licensing workshop w/UCS/NEl TBD M. Caruso DSSA
6. Conduct discussions with ACRS on risk-informed, 8/98-R. Barrett, DSSA/

performance-based Regulation initiatives 12/98 M. Cunningham, RES

7.. Request ACRS letter on staff options paper 8/98 R. Barrett, DSSA
8. DSI-13 Role of Industry stakeholder meeting 9/1/98 J. Craig,RES
9. Reach agreement with NEl on scope, schedule, 9/98 M. Drouin, RES l

approach and groundrules for NEl Whole Plant Study (tasks 1-6)

10. Issue paper to Commission identifying options on 1/99 R. Barrett, DSSA/

modifying Part 50 to be risk-informed (including M. Cunningham, RES definition of " safety" and backfitting implications)

11. Issue safety evaluation on WOG ISI topical report 01/99 S. Ali, DE RES
12. Meeting on NEl pilot plant preliminary risk results TBD M. Drouin, RES I

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2 THROUGH JUNE 30,1999 Milestone Date Lead

13. Workshop on insights from NEl Whole plant study TBD M. Drouin,RES risk results and options for using them to enhance risk-informed regulation
14. Develop Rulemaking Commission paper based on TBD R. Barrett, DSSA/

Commission response to options paper (inc!uding M. Cunningham, RES i

consideration of NEl Whole Plant Study (tasks 1-6))

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15. Issue safety evaluation on EPRI ISI topical report early S. Ali, DE CY99 RES BEYOND JUNE 30,1999 Milestone Date Lead
16. Endorse ASME RI-ISI code cases via Regulatory 3/00 D. Jackson,RES Guide 1.147, contingent upon ASME completing code S. Ali, DE l

case by 6/31/99.

Comments:

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2. Committee has met on 7/29/98 and 8/20/98. Charter includes:

Coordination of inter-office PRA Implementation Plan activities Resolution of key issues Identification of new activities Interaction with public and industry

3. Meetings will be held with NEl pilots and lead plant pilots (ISI, task 0) 3-5. PRA Steering Committee meeting required.

9,12,13 and 14. Schedule depends upon NEl pilot project schedules which at present are TBD A meeting with NEl is tentatively scheduled for 8/28/98 to finalize the schedufe.

11 and 15. Risk-informed licensing panel (RILP) meetings are required.

i 1-6,10. Some items budgeted in DSSA, such as support for SMMs, use of PRA in generic issue resolution, events assessment (except for high risk events) participation in planned or reactive inspections, and quarterly updating of PRA plan (move to annually) may be deferred in l

order to meet the above schedules in developing an options paper. Work suggested to be dropped to support these milestones is the modification of Part 52 regarding use of PRAs beyond Design Certification. RES work on proposed revision to Safety Goal Policy will be deferred from 3/99 to 7/99. Status report on this effort will be deferred from 12/98 to 3/99.

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Additional Activities: The Center for Strategic and International Studies (CSIS) is conducting a study of the NRC regulatory process. Chairman Jackson and Commissioner McGaffigan are members of the Steering Committee. Ashok Thadaniis on the working group. This activity will involve several meetings over the next several months and the CSIS schedule calls for a final report by 4/15/99.

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1. TOPIC AREA: Risk-Informed and Performance-Based Reaulation SES Manager: Gary Holahan, Direc+or, DSSA/NRR B. Specific Issue: Pilot Applicatio.ia Objective: The goal of the pilot programs is to complete first of a kind risk-informed licensing reviews such that lessons leamed may be utilized for future staff reviews. The pilot applications have provided a forum for developing guidance documents for both the staff and the industry.

l PRIOR TO JANUARY 28,1999 Milestone Date Lead l

1. Risk-informed Licensing Panel (RILP) Meetings -

Ongoing G. Holahan, DSSA assists in focusing management attention, as necessary, to identify other pilots and ensure lessons learned are developed from pilots

2. Issue safety evaluation on Comanche Peak IST 8/14/98C D. Fischer, DE pilot DSSA support
3. Issue safety evaluation on Surry ISI pilot 12/31/98 S. Ali, DE DSSA support
4. Issue safety evaluation on Vermont Yankee ISI pilot 11/30/98 S. Ali, DE DSSA support
5. Issue safety evaluation on ANO-2 ISI pilot 12/31/98 S. Ali, DE DSSA support
6. Issue safety evaluation for ANO-2 H, monitoring 9/98 M. Snodderly, DSSA BEYOND JUNE 30,1999 Milestone Date Lead
7. Issue safety evaluation on ANO-1 ISI pilot 07/99 S. Ali, DE Comments:

Alllicensing actions dates are contingent upon timely, technically acceptable industry responses to staff inquiries.

3,4,5 and 6. Risk-informed Licensing Panel (RILP) meetings required.

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1. TOPIC AREA: Risk-Informed and Performance-Based Reaulation SES Manager: Gary Holahan, Director, DSSA, NRR C. Specific legge: Plant-Specific Licensina Reviews Objective: The use of probabilistic risk assessment in risk-informed decision making for changes to plant-specific licensing basis is intended to enhance safety decisions, efficiently utilize NRC resources and reduce unnecessary conservatism. The goal is to complete first of a kind risk-informed licensing reviews such that lessons learned may be utilized for future staff reviews.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Establish Lead PM for risk-informed licensing actions Complete J. Harold, DRPE
2. Risk-Informed Licensing Panel (RILP) Meetings -

Ongoing G. Holahan, DSSA assists in focusing management attention, as necessary, on risk-informed licensing actions.

3. Issue safety evaluation on North Anna 1/2 EDG AOT 8/98 O. Chopra, DE extension DSSA support
4. Create special reporting mechanism in WISP for risk-9/98 J. Harold, DRPE informed licensing actions to facilitate monitoring and tracking
5. Issue Commission paper related to staff's evaluation of 09/98 G. Carpenter, DE probabilistic assessment of "BWR Reactor Pressure DSSA support Vessel Shell Weld Inspection Recommendations"
6. Issue safety evaluation on Oyster Creek proposal on 9/98 O. Chopra, DE EDG online testing DSSA support
7. Issue safety evaluation on San Onofre 2/3 EDG AOT 9/98 O. Chopra, DE extension DSSA support
8. Issue safety evaluation for ANO-2 H monitoring 9/98 M. Snodderly, 2

DSSA

9. Issue safety evaluation on safety injection tank AOT 11/98 E. Weiss, DSSA extension for 6 CEOG facilities
10. Issue safety evaluation on Comanche Peak charging 11/98 E. Weiss, DSSA pump AOT extension
11. Issue safety evaluation on Pilgrim EDG AOT 12/98 O. Chopra, DE extension '

DSSA support

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PRIOR TO JANUARY 28,1999 Milestone Date Lead

12. Issue re'axation on H monitoring for other plants 12/98 ADPR/DSSA 2

THROUGH JUNE 30,1999 Milestone Date Lead

13. Issue safety evaluation on Sequoyah proposal on 06/99 O. Chopra, DE EDG AOT extension DSSA support
14. Issue reliefs from augmented examination 6/99 G. Carpenter, DE requirements for various licensees on BWR reactor pressure vessel circumferential welds 1
15. Issue safety evaluation on Browns Ferry 2/3 proposal 06/99 O. Chopra, DE I

on EDG AOT extension DSSA support Comments:

7 and 8. RILP meetings required.

14. CRGR meeting needed in 10/98. Contingent upon receipt of relief requests from licensees 13-15. Dates to be evaluated during prioritization of risk-informed licensing actions.

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1. TOPIC AREA: Risk-informed and Performance-Based Reaulation SES Manager: Gary Holahan, Director, DSSA, NRR and Thomas King, Director, DST /RES D. Specific lasue: Guidance Documents Objective: To provide guidance for the staff and the industry which will enhance consistency and provide a infrastructure for use in risk-informed regulation.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. NRC/ Utility Workshop on Risk-Informed Regulation 07/98C Completed 7/22/98
2. Communicate about process with Licensing 07/98C Completed 7/20-counterparts from industry (NRC/ Utility Licensing 21/98.

Workshop)

3. Issue ISI trial use RI RG/SRP to Commission 06/98C RES S. Ali, DE 1

4a Complete review of second draft of Phase 1 PRA 8/98 M. Drouin, RES standard 4b. Paper to Commission on status of PRA standards 10/98 M. Drouin, RES development effort 4c. Phase 1 draft PRA standard submitted for ASME 11/98 M. Drouin, RES review and comment 4d. Phase 1 draft PRA standard issued for public 1/99 M. Drouin, RES comment

5. Revise NRR internal guidance to raise the priority of 09/98 D. Dorman, ADPR risk-informed licensing actions
6. Communicate revised priority to industry via 09/98 D. Dorman, ADPR PM/ Licensing interaction
7. Communicate revised priority to industry via 10/98 D. Dorman, ADPR l

Administrative Letter

8. Issue NRR Office Letter on implementation of Risk-10/98 G. Kelly, DSSA informed Regulation for use
9. Issue final GQA inspection procedure for use following 12/98 R. Gramm, DRCH implementation of South Texas GQA program

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10. Integrate risk attributes into revised licensee 01/99 DISP j

P. Wilson, DSSA l

performance assessment process

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8 PRIOR TO JANUARY 28,1999 Milestone Date Lead

11. Initiate work on Phase 2 PRA draft standard 1/99 M. Drouin, RES THROUGH JUNE 30,1999 Milestone Date Lead
12. Phase 1 PRA standard comments received and final 4/99 M. Drouin, RES draft developed
13. Phase 1 PRA standard issued as final by ASME 6/99 M. Drouin, RES
14. Develop risk attributes for revising enforcement early CY99 OE policies, input to ll.C.5.

G. Kelly, DSSA BEYOND JUNE 30,1999 Milestone Date Lead

15. First Phase 2 PRA standard developed TBD M. Drouin, RES
16. Completion of Phase 2 PRA standard TBD M. Drouin, RES Comments:
2. Draft procedure due out 10/98 and training of NRC inspection staff will be completed in 6/99.
9. RILP meeting required.
10. ACRS & Commission review, industry workshop (09/98), and PRA Steering Committee meeting required.
14. ACRS & Commission review, a public workshop, and PRA Steering Committee meeting required.

Sa-d,11-13,15,16. Phase 1 is a standard for full power operation, internal events only. Phase 2 is for external events and shutdown. Dates are tentative due to uncertainty associated with the number and nature of comments that may be received, the ASME review and approval process and the success of the working group in writing the Phase 2 standard. This is an ASME initiative and; therefore, the schedules are set by ASME.

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9 ll. Toolc Area: Reactor inspection and Enforcement SES Manager: M. Johnson, Acting Chief, PIPB/ DISP /NRR and J. Lieberman, Director, OE A. Specific issue: Risk Informed Baseline Core inspection Progg!Lm i

Program Manager - Jeffrey Jacobson, NRR and John Flack, RES l

Objective: To develop and implement a more risk informed, efficient, and effective baseline core inspection program. By risk informed, it is meant that the inspection program's scope will be

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defined primarily by those areas that are significant from a risk perspective and that the j

inspection methods used to assess these arcas will take advantage of both generic and plant

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Coordination; issues ll.A. " Risk Informed Baseline Core Inspection Program," ll.B. " Enforcement Program Initiatives," II.C. " Escalated Enforcement Program," lll.A. " Performance Assessment

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I Process improvements," and VI.G " Event Reporting Rulemaking," require close coordination and the integration of specific tasks by the NRC staff. Responsible project managers are coordinating these activities by assessing the impact of proposed program changes with the other ongoing activities and ensuring that the overall objectives for each project are achieved.

Examples include, intra-project task force participation, workshop attendance, concurrent review of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory Oversight Process are being reviewed by all project groups and evaluated for impact.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Establish management oversight panel (performance 9/98 C. Holden, DISP assessment and risk informed inspection program)
2. Issue detailed plan and team charter 9/98 J. Jacobson, DISP l
3. Brief Commission TA's 9/98 J. Jacobson, DISP l
4. Select improvement team members 9/98 C. Holden, DISP J. Jacobson, DISP
5. Support NRR public workshop on soliciting input on 9/28/98 J. Flack, RES approaches to risk-informed inspection (RES to present options at workshop).
6. Solicit input from stakeholder on scope of inspection at 9/28-J. Jacobson, DISP regulatory assessment public workshop, coordinating with 10/1/98 issue Ill.A.
7. Re-define core inspection program objectives based 10/98 J. Jacobson, DISP upon oversight concept

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PRIOR TO JANUARY 28,1999 I

8. Draft boundary conditions for core inspection program 10/98 J. Jacobson, DISP changes
9. Develop guidance for assessing current core inspection 10/08 J. Jacobson, DISP program
10. Prepare draft recommendations on core inspection 10/30/98 J. Flack, RES based on review of BWR and PWR PRA.
11. Discuss with ACRS propm ad scope and approach 11/15/98 J. Flack, RES
12. Research to provide insights on formulation of a risk 12/98 J. Flack, RES informed inspection program
13. Assess current program and propose changes 12/98 J. Jacobson, DISP
14. Bri af Commission TA's 12/98 J. Jacobson, DISP
15. Communicate proposed changes to staff 12/98 C. Holden, DISP
16. Develop transition strategy 1/99 J. Jacobson, DISP C. Holden, DISP
17. Brief Commission on reconimended program changes 1/99 J. Jacobson, DISP re -

pe THROUGH JUNE 30,1999 Milestone Date Lead

18. Begin making program changes and conduct training of 2/99 J. Jacobson, DISP staff
19. Begin implementation of new core inspection program 3/99 J. Jacobson, DISP BEYOND JUNE 30,1999 Date Lead Milestone
20. Complete transition to risk informed core inspection 10/99 J. Jacobson, DISP program

11 Comments:

1. The establishment of a management oversight panel will ensure timely guidance on policy issues both prior to and during the development of the process. The oversight panel will also help to ensure organizational alignment and buy-in on the new process. The panel should include representatives from key stakeholder groups within the agency, primarily NRR and the Regions.

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3 and 14. Briefings of commission TA's will be conducted at key milestones to help ensure

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l organizational buy-in of the completed process. Formal briefings of the full commission will be conducted as part of a comprehensive briefing on the overall assessment process. These full commission briefings are indicated on the action plan for Performance Assessment Process l

Improvements.

4. Improvement team members should include representatives from key internal stakeholder l

groups, primarily regional and resident inspectors.

6. The scope of the inspection program is scheduled to be discussed during the assessment process public workshop. During this workshop, feeocack will be solicited from industry representatives as well as members of the general public. Also, the workshop results will be published and used to communicate to the staff the issues currently being considered in developing the new inspection program.
7. The inspection program objectives will be re-defined after agreement is reached on a redefined assessment process framework.
13. A team approach will be utilized in assessing the current program and proposing changes.

Included within the team will be a representative from the Office of Research who will help in ensuring the new inspection program is risk informed.

15. An important part of the change management strategy for implementing the new inspection and assessment programs will be communication with the staff both during and after development.
16. " Change management" concerns should be addressed as part of developing the transition strategy.
18. Training to include overview of specific program changes as well as restatement of selected inspection fundamentals regarding interfaces with licensees.

l Deferrals and Suspensions:

Upon Commission approval, the staff will suspend SALP in a structured manner. Plant performance will continue to be addressed by Plant Performance Reviews (PPRs). The resources to accommodate the accelerated efforts of the Tasking Memorandum pertaining to inspection, enforcement and performance assessment will be derived from a combination of those efforts planned previously in these areas, staff redirection over the next year, and the resources derived from st.spension of the SALP process. The expectation is that by January, i

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12 1999 progress on the enhanced assessment process will be sufficient to determine whether the SALP process will be conducted in the future.-

RES work assessing tha effectiveness of the station blackout and anticipated transient without scram rules and generic safety issue A-45 (decay heat removal) will be deferred from 12/98 to 4/99.

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13 II. Reactor Inspection and Enforcement SES Manager: James Lieberman, Director, Office of Enforcement B. Enforcement Proaram initiatives issues / Lead Individual:

1) NRC-licensee documentation and disposition of non-risk significant violations Mark Satorius
2) Severity Level IV violations Mark Satorius
3) Industry Enforcement Process Proposals Mark Satorius Due to the manner that these three issues are linked, all are being considered under one Plan of Action.

Objective: Reduce licensee burdens associated with responding to non-risk significant violations (Issues Nos.1 and 2) utilizing initial stakeholder inputs and proposals and solicitirg stakeholder feedback following implementation of Enforcement Program changes (Issue No. 4), without losing the NRC's ability to detect licensee problems in a timely manner.

Coordination: Issues ll.A. " Risk Informed Baseline Core inspection Program," ll.B. " Enforcement Program Initiatives," ll.C. " Escalated Enforcement Program," lil.A. " Performance Assessment Process improvements," and VI.G " Event Reporting Rulemaking," require close coordination and l

the integration of specific tasks. y the NRC staff. Responsible project managers are coordinating these activities by assessing the impact of proposed program changes with the other ongoing activities and ensuring that the overall objectives for each project are achieved.

Examples include, intra-project task force participation, workshop attendance, concurrent review of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory Oversight Process are being reviewed by all project groups and evaluated for impact.

PRIOR TO JANUARY 28,1999 Date Milestone

1. Implement an Enforcement Guidance Memorandum (EGM) to EGM issued on clarify guidance under the existing Enforcement Policy that provides 7/27/98 licensees incentives to self-identify and correct problems in order to avoid the issuance of notices of violations.
2. Monitor the success of EGM 98-006 on lessening the burden to Begin 9/1/98 and licensees by reducing the volume of Severity LevelIV violations, continue including violations not cited and both those requiring and not requiring a response.
3. Conduct a public meeting with stakeholder to solicit input on the 9/3/98 manner that the Enforcement Policy may be revi%i i

14 PRIOR TO JANUARY 28,1999

4. Utilize previously received written inputs from external 9/18/98 stakeholder that provides positions on the manner that the objectives should be accomplished.
5. Submit a Commission Paper incorporating the views of internal 10/16/98 and external stakeholder that provides the Commission several options (and the staffs recommendation) on the manner to achieve the objectives by proposing an Enforcement Policy change. This paper and the proposed changes will also address the agency's response to industry's concems in the use of " regulatory significance."
6. Commission approves staff Enforcement Policy revision and the 11/16/98 s

Revised Policy is published in the Federal Register, with the message to stakeholder that six months after implementation of the Revised Policy, public meeting / workshops will be held for stakeholder feedback.

7. Conduct Regional Enforcement Coordinator meeting / training on 12/1/98 the Revised Enforcement Policy.
8. Conduct video conferencing with Regional managers to outline Week of 12/7/98 the changes to the Enforcement Policy and provide agency expectations.
9. Conduct training in the Regional offices, with a focus on agency Late November-Early December 1998 expectations for the Revised Enforcement Policy.

EDO/DEDE/DEDR provides senior management's expectations at the scheduled counterpart meetings attended by those individuals.

10. Implement revised Enforcement Policy.

30-days after the Policy is published in the Federal Register (assume 12/16/98)

11. Evaluate inspection data to determine the extent of success 12/16/98, and update that EGM 98-006 had in reducing burden to licensees. Provide this until the time of the information to the Chairman for the Senate Hearing.

hearing

12. Collect enforcement data following the implementation of the Begin 12/16/98, and Revised Enforcement Policy, for later use in determining the continue success of the changes in accomplishing the objectives.

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THROUGH JUNE 30,1999 l

Milestone Date

13. Solicit feedback from regional management, the inspection Spring 1999 staff, and headquarters staff on the successes or failures of the Revised Enforcement Policy.
14. Conduct public meetings / workshops with stakeholder, one in 6/16/99 the Washington area and one in an area around a Region, to solicit feedback on the successes and shortcomings of the Revised Enforcement Policy.

BEYOND JUNE 30,1999 Milestone Date

15. Assemble the collective views of the staff and stakeholder to 9/1/99 determine whether the Revised Enforcement Policy has accomplished the objectives, or whether further staff action is needed. Submit Commission paper.

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16 ll. Reactor inspection and Enforcement SES Manager: James Lieberman, Director, Office of Enforcement C. Escalated Enforcement Program initiatives "Reaulatory Significance"/ Risk Objective: Incorporate clearer risk-informed enforcement guidance in the treatment of escalated violations.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Conduct a public meeting with stakeholder to solicit input on 9/3/98 M. Satorius, the manner that risk should be incorporated into the OE Enforcement Policy
2. Submit a Commission Paper incorporating the views of 10/16/98 M. Satorius, internal and external stakeholder that provides the Commission OE several options (and the staff's recommendation) on the manner to achieve the objectives by proposing an Enforcement Policy change. This paper and the proposed changes will also address the agency's response to industry's concerns in the use of " regulatory significance."

THROUGH JUNE 30,1999 l

Milestone Date Lead

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3. Develop risk-informed examples for inclusion in the 3/15/99 M. Satorius, OE supplements of the Enforcement Policy.
4. Discuss examples with stakeholder and solicit feedback 3/29/99 M. Satorius, OE
5. hiubmit a Commission Paper utilizing the input from issue 5/1/99 M. Satorius, OE l.D.14 and the examples developed above to revise the Enforcement Policy.

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Comments:

2. Following Commission action on Milestone 2 the staff will proceed with the implementation i

actions discussed in Specific Issue ll.B.

l 3-5 Input will be provided by NRR and RES.

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l 17 111. Tonic Area: Reactor Licensee Performance Assessment SES Manager: M. Johnson, Acting Chief, PIPB/ DISP /NRR I

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A. Specific lasue: Perbmance Assessment Process Improvements (IRAP. Industrv's l

Proposal. and Performance indicators)

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Program Manager: David Gamberoni i

Objective: The objective of this task is to develop and implement improvements to the NRC plant performance assessment process to make it more risk-informed, efficient, and effective i

while combining the best attributes of the IRAP effort, the regulatory oversight approach proposed by NEl, and the staff efforts designed to develop risk-informed performance indicators.

l Coordination: Issues ll.A.

  • Risk Informed Baseline Core Inspection Program," II.B. " Enforcement 1

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Program initiatives," II.C. " Escalated Enforcement Program," lil.A. " Performance Assessment Process improvements," and VI.G " Event Reporting Rulemaking," require close coordination and i

the integration of specific tasks by the NRC staff. Responsible project managers are coordinating these activities by assessing the impact of proposed program changes with the other ongoing activities and ensuring that the overall objectives for each project are achieved.

Examples include, intra-project task force participation, workshop attendance, concurrent review i

of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory Oversight Process are being reviewed by all project groups and evaluated for impact.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Transition to an annual senior management meeting C

J. Isom, DISP

2. Review and discuss with NEl their proposed assessment 8/98C D. Gamberoni, DISP process-
3. Suspend SALP upon Commission approval TBD D. Gamberoni, DISP
4. Hold public workshop to obtain external stakeholder input 9/98 T.Frye, DISP D.Gamberoni, DISP
5. Research to provide risk insights on oversight framework 9/98 M. Cunningham, RES (corner stones)
6. End of public comment period for performance 10/6/98 T. Frye, DISP assessment process improvement
7. Brief ACRS to obtain their input 10/98 M. Johnson, DISP L

18 PRIOR TO JANUARY 28,1999 Milestone Date Lead i

8. Brief Commission on results of public comments 10/98 M. Johnson, DISP
9. AEOD awards contract for risk-based performance 11/G8 T. Wolf, AEOD indicator development.

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10. Research to provide recommendations on formulation of 12/98 M. Cunningham, l

a risk-informed assessment and inspection concept.

RES

11. Hold regional and headquarters meetings to obtain 11/98 M. Johnson, DISP l

internal stakeholder input

12. Brief Commission TAs 12/98 M. Johnson, DISP
13. Provide results of review of public comments and 1/99 M. Johnson, DISP l

recommendation for changes to the assessment process to the Commission. Submit Commission paper.

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14. Brief Commission on recommendations 1/99 M. Johnson, DISP l

l THROUGH JUNE 30,1999 Milestone Date Lead 15 Obtain Commission approval for implementation of 3/99 M. Johnson, DISP recommended changes

16. Obtain industry approval to make public the data used in 6/99 T. Wolf, AEOD l

Industry's proposed Indicators for monitoring plant performance. Begin phase out of current Performance indicator Program.

17. Complete development of implementation plan. Start 6/99 M. Johnson, DISP phase-in of the revised assessment process.
18. Begin trial application of risk-based performance 6/99 T. Wolf, AEOD indicators.

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Milestone Date Lead

19. Complete trial application, brief Commission, and publish 11/99 T. Wolf, AEOD candidate risk-based indicators for public comment.
20. Publish last Performance Indicator Report using current Pts 1/00 T. Wolf, AEOD
21. Hold public workshop on car.didate risk-based performance 2/00 T. Wolf, AEOD indicators.

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22. Complete phase-in of the revised assessment process 6/00 M. Johnson, DISP
23. Brief commission on proposed risk-based performance 10/00 T. Wolf, AEOD l

indicators developed cooperatively by NRC and industry

24. Implement Commission approved risk-based performance 1/01 T. Wolf, AEOD indicators developed cooperatively by NRC and industry M. Johnson, DISP
25. Complete evaluation of implementation and effectiveness of 6/01 M. Johnson, DISP the revised assessment process Comments:
4. The public workshop is scheduled for September 28 - October 1,1998.

i Deferrals and Suspensions:

l Upon Commission approval, the staff will suspend SALP in a structured manner. Plant performance will continue to be addressed by plant performance reviews (PPRs). The resources to accommodate the accelerated efforts of the Tasking Memorandum pertaining to inspection, enforcement and performance assessment will be derived from a combination of those efforts planned previously in these areas, staff redirection over the next year, and the resources derived from suspension of the SALP process. The expectation is that by January, i

1999 progress on the enhanced assessment process will be sufficient to determine whether the SALP process will be conducted in the future.

The Agency intends to use the proposed Industry performance indicators in the assessment of l

plant performance to the maximum extent possible. Their impact on the regulatory process will depend on their ability to provide information needed to assure that key safety "comerstones" are being met. A phased approach is envisioned wherein consensus on the "comerstones" and l

the attributes of indicators will be reached. The proposed industry indicators will be used accordingly and the current NRC Performance Indicators will be phased out. In parallel, the agency will work with industry and other stakeholder to develop a more comprehensive set of risk-based performance indicators to more directly assess plant performance relative to the

" cornerstones", These risk-based indicators will be phased in as part of an evolutionary approach to increasing the risk-informed, performance based nature of regulation.

20 IV. Toolc Area: Reactor Licena.ina and Overslaht SES Manager: Chris Grimes, Director, PDLR/DRPM/NRR A. Specific lasue: License Renewal (includes Calvert Cliffs, Oconee and Generic Process improvements)

Objective: Demonstrate that license renewal applications submitted under 10 CFR Parts 54 & 51 can be reviewed effectively, efficiently and promptly.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Maintain Calvert Cliffs and Oconee schedules Ongoing C. Grimes, DRPM
2. Conduct bi-monthly meetings with license renewal bimonthly C. Grimes, DRPM applicants
3. Issued Policy Statement " Conduct of Adjudicatory 7/28/98C OGC Proceedings" Issued 63 FR 41,872 (8/5/98)
4. Issued case specific order-Calvert Cliffs 8/19/98C OGC
5. Steering Committee meeting with NEl Working Group 6/18/98C C. Grimes, DRPM 8/20/98C
6. ACRS subcommittee meeting on renewal process 7/16/98C C. Grimes, DRPM
7. Agree on generic issue inventory / priority with NEl 9/98 C. Grimes, DRPM
8. Increased emphasis on renewal with EC and LRSC Ongoing C. Grimes, DRPM
9. Staff complete technical RAls - Calvert Cliffs 9/7/98 C. Grimes, DRPM
10. Staff complete environmental RAls - Calvert Cliffs 10/7/98 C. Grimes, DRPM
11. Staff complete technical RAls - Oconee 12/4/98 C. Grimes, DRPM
12. Staff complete environmental RAls - Oconee 1/3/99 C. Grimes. DRPM THROUGH JUNE 30,1999 Milestone Date Lead
13. Issue Draft Environmental Statement for comment -

3/6/99 C. Grimes, ORPM Calvert Cliffs

14. Complete Safety Evaluation Report (SER) and identify 3/21/99 C. Grimes, DRPM open items - Calvert Cliffs

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15. Issue Draft Environmental Statement - Oconee 6/2/99 C. Grimes, DRPM
16. Complete SER and identify open items - Oconee 6/17/99 C. Grimes, DRPM l

BEYOND JUNE 30,1999 Milestone Date Lead

17. Issue Supplemental SER and Final Environmental 11/16/99 C. Grimes, DRPM Statement - Calvert Cliffs
18. Issue Supplemental SER and Final Environmental 2/12/00 C. Grimes, DRPM Statement - Oconee
19. Complete staff review of initial applications within Ongoing C. Grimes, DRPM 30-36 months
20. Hearing (if request granted)

Per Comm.

Sched.

Comments:

1. Commission approves detailed license renewal schedules in terms of significant review milestones that will be included in the Operating Plan and monitored for Congressional reports.

6 & 7. Steering Committee meetings with industry and ACRS subcommittee meetings with staff will continue periodically to ensure effective resolution of technical and process issues. The Steering Committee will periodically report progress to the Executive Council in accordance with the memo to Chairman Jackson dated 3/6/98.

19. Next (third) application expected by late 1999.

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22 IV. Toolc Area: Reactor Licensina and Oversiaht l

SES Manager: Jack Roe, Acting Director, DRPM/NRR l

I B. Specific issue: 50.59 Rulemaking Objective: To provide clarity and flexibility in existing requirements PRIOR TO JANUARY 28,1999 1

Milestone Date Lead l

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1. Issue SECY 98-171 providing proposed revisions to 7/10/98C E. McKenna, DRPM 10CFR50.59 for Commission review and approval
2. Issue COMSECY 98-013 forwarding staff response to Complete E. McKenna, DRPM issues raised in SRM on SECY 97-205 (3/24/98) l
3. Conduct meeting with industry /public to solicit views 8/98 M. Drouin, RES on options for making 50.59 risk-informed
4. Issue proposed rule changes on 10CFR50.59 for 8/98 E. McKenna, DRPM

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5. Trial application of actual 50.59 test cases to assess 10/98 M. Drouin, RES options
6. ACRS Subcommittee Meeting 10/98 M. Drouin, RES
7. End of public comment period 11/98 E. McKenna, DRPM
8. Draft Options paper to ACRS 11/15/98 M. Drouin, RES
9. ACRS Full Committee 12/98 M. Drouin, RES
10. Report to NRR on options and recommendations 12/15/98 M. Drouin, RES
11. Resolve issues identified during comment period 1/99 E. McKenna, DRPM THROUGH JUNE 30,1999 Date Lead Milestone
12. ACRS and CRGR review of final rulemaking package early E. McKenna, DRPM 3/99
13. Issue paper containing final 10CFR50.59 rule to the 3/99 E. McKenna, DRPM Commission
14. Publish final rule change 10CFR50.59 6/99 E. McKenna, DRPM u

23 Comments:

3,5,6,8-10. RES assessing options and recommending approach to make 50.59 risk-informed.

4. Paper on proposed rule at the Commission awaiting approval. NMSS/SFPO is working in conjunction with NRR to modify 10 CFR 72.48 which is comparable to 10 CFR 50.59 (Contact:

W. Kane) 4 and 7,11-14. These milestones reflect delays in previously established schedules to reflect the deliberations occurring at the Commission on policy issues. Any further delays in getting the l

rule published for comment will result in additional delays in publishing the final rule.

Deferrals:

The start of RES work on low power and shutdown risk will be deferred from 10/98 to 1/99.

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24 IV. Toolc Area: Reactor Licensina and Oversigitt SES Manager. Dave Matthews, Deputy Director, DRPM, NRR C. Specific issue: FSAR Undate Guidance Objective: To provide consistent guidance on information to be contained in FSAR PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Submit SECY 98-087 to Commission which contains 4/20/98C T. Bergman, DRPM proposed guidance on information to be contained in FSAR
2. SRM/SECY 98-087 directs staff to work with industry to 6/30/98C T. Bergman, DRPM resolve issues and endorse industry guidance
3. Issue staff comments on NEl 98-03 dated 7/8/98 8/28/98 T. Bergman, DRPM
4. Receive revised NEl 98-03 early Oct.

T. Bergman, DRPM 1998

5. Resolve final staff comments early Nov.

T. Bergman, DRPM 1998

6. ACRS and CRGR review of SECY and draft regulatory early Nov.

T. Bergman, DRPM guide which endorses industry guidance 1998

7. Submit paper with draft regulatory guide to Commission 12/24/98 T. Bergman, DRPM
8. Publish draft regulatory guide endorsing NEl 98-03 for 1/28/99 T. Bergman, DRPM comment (60 days)

THROUGH JUNE 30,1999 Milestone Date Lead

9. Resolve issues identified during public comment period 5/30/99 T. Bergman, DRPM
10. ACRS and CRGR review of SECY and final regulatory early June T. Bergman, DRPM 1999 guide 1

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25 BEYOND JUNE 30,1999 Milestone Date Lead

11. Submit paper and final regulatory guide to Commission 8/1/99 T. Bergman, DRPM Comments:
1. If closure can be reached with NEl, a regulatory guide will be the product; if not, a generic letter will be used.
2. Regarding Milestone No. 4, a meeting is planned for late August or early September.

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IV. Tonic Area: Reactor Licensing and Oversight SES Manager: Dave Matthews, Deputy Director, DRPM/NRR j

D. Specific lasue: Define Design Basis Objective: To provide a clear definition of what constitutes design bases information.

PRIOR TO JANUARY 28,1999

{

Milestone Date Lead

1. NEl submits 97-04 for information 10/8/97C
2. SRM/SECY 97-205 directs staff to continue to 3/24/98C S. Magruder, DRPM

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develop guidance regarding design bases issues

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3. Issue preliminary staff comments on NEl 97-04 8/18/98C S. Magruder, DRPM l
4. Meet with NEl to discuss staff comments on early S. Magruder, DRPM NEl 97-04 Sept.

1998 1

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5. NEl submits revised NEl 97-04 for review and early endorsement Dec.

1998

6. Resolve final staff comments late Jan.

S. Magruder, DRPM 1999

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THROUGH JUNE 30,1999 Milestone Date Lead

7. ACRS and CRGR review of SECY and draft early S. Magruder, DRPM regulatory guide that endorses NEl 97-04 Feb.

1999

8. Submit paper with draft regulatory guide to 2/19/99 S. Magruder, DRPM Commission
9. Publish draft regulatory guide for public comment 3/19/99 S. Magruder, DRPM (60 days) i L

27 BEYOND JUNE 30,1999 Milestone Date Lead

10. Resolve issues identified during public comment 7/19/99 S. Magruder, DRPM period
11. ACRS and CRGR review of paper and final early S. Magruder, DRPM regulatory guide Aug.

1999

12. Submit paper and final regulatory guide that 10/1/99 S. Magruder, DRPM a endorses NEl 97-04 to Commission Comments:
5. Schedule depends on NEl reaction to staff comments and willingness to submit NEl 97-04 for l

staff endorsement.

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1 28 IV. Toolc Area: Reactor Licensina and Oversicht SES Manager: Bruce Boger, Acting Associate Director for Projects, NRR EJioecific issue: Imoroved Standard TS Lead: TSB Lead PM for each facility conversion Objective: Conversion of facility technical specifications to the appropriate improved standard technical specifications will promote more consistent interpretation and application of technical specification requirements, thereby reducing the need for interpretations and frequent changes l

to the technical specifications. The goal for each milestone listed below is to complete the conversions currently under review such that the above objectives are met for the affected facilities.

PRIOR TO JANUARY 28,1999 Date Lead Milestone Issue iSTS Amendments for McGuire 1&2 and Catawba 1&2 09/98 ADPR l

lssue ISTS Amendments for Oconee 1/2/3*

10/98 ADPR lssue iSTS Amendments for Byron 1&2* and Braidwood 1&2*

11/98 ADPR I

lssue iSTS Amendmer,ts for Comanche Peak 1&2*, Wolf Creek *,

12/98 ADPR CaNaway*, and Diablo Canyon 1&2*

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THROUGH JUNE 30,1999*

Date Lead Milestone Issue iSTS Amendments for Farley 1&2*

03/99 ADPR issue iSTS Amendment for Fermi 2*

04/99 ADPR BEYOND JUNE 30,1999*

Date Lead Milestone Issue iSTS Amendment for Palisades

  • 07/99 ADPR

- Completion of the milestones as listed depends upon the quality of the licensee's submittals and timeliness of response to staff RAls.

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29 IV. Toolc Area: Reactor Licensina and Overslaht SES Manager: John Stolz, Acting Director, DRPM/NRR F. Specific lasue: Generic Communications Objective: Ensure the appropriate use of generic communications, increasing the efficiency of issuance, and utilizing the rulemaking process when appropriate.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Issue memorandum on immediate changes to generic 8/7/98C J. Stolz, DRPM letter process (ET review of strategy; graded approach)
2. Meet with NEl for input on industry views on generic 8/27/98 J. Stolz, DRPM communications
3. Complete self assessment and needed improvement to 12/98 R. Dennig, DRPM generic communications process. Issue report.

THROUGH JUNE 30,1999 Date Lead Milestone

    • Process improvements based upon self-assessment results completed in 12/98 BEYOND JUNE 30,1999 Date Lead Milestone None Comments:

1, Generic communications discussed with INPO in telephone conference 7/31/98 i

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30 IV. Tonic Area: Reactor Licensina and O_yarsicht SES Manager: Bruce Boger, Acting Associate Director for Projects, NRR G. Specific lasue: CALs Objective: Confirmatory Action Letters (CALs) are issued to emphasize and confirm a licensee's or vendor's agreement to take certain actions in response to specific issues. The NRC expects licensees / vendors to adhere to any obligations and commitments addressed in a CAL and will issue appropriate orders to ensure that the obligations and commitments are met. The goal of the milestones listed below is to ensure that staff guidance on the use of CALs is appropriate and that the staff exercises appropriate discipline in the development and issuance of CALs.

PRIOR TO JANUARY 28,1999 i,tilestone Date Lead

1. Review existing CALs (all future CALs must be reviewed by 9/98 ADPR q

Director, NRR)

2. Reinforce expectations regarding use of current CALs to 9/98 D. Pickett, ADPR ADPR/ Region management
3. Review / issue revised guidance documents for threshold for 11/98 D. Pickett, ADPR issuance of CALs (i.e., IMC 0350, procedures, etc.) to ensure the existence of clear criteria for consistent decision making.
4. Reinforce expectations regarding revised guidance on use of 11/98 D. Pickett, ADPR CAls to ADPR/ Region management 1

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31 IV. Toolc Area: Reactor Licensino and Oversicht SES Manager: Jack Roe, Acting Director, DRPM/NRR 4

H. Specific issue: Applicability of Backfit Rule to Decommissioning Activities Objective: Resolve issue regarding proper interpretation and application of the Backfit Rule to i

decommissioning activities PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Issue initial determination on Maine Yankee backfit 4/21/98C J. Roe, DRPM claim
2. Maine Yankee appeals backfit determination and 6/9/98C S. Weiss, DRPM presents backfit position to staff
3. Determination of Maine Yankee backfit appeal 8/28/98 J. Zwolinski, DRPE
4. Brief EDO on the status of Commission paper on backfit 9/18/98 S. Weiss, DRPM rule
5. Forward draft Commission paper on backfit rule to EDO 10/23/98 S. Weiss, DRPM
6. Issue Commission paper on backfit rule 11/30/98 S. Weiss, DRPM
7. Brief NEl on Commission decision 12/31/98 S. Weiss, DRPM THROUGH JUNE 30,1999 Milestone Date Lead None BEYOND JUNE 30,1999 Milestone Date Lead None l

32 IV. Toolc Area: Reactor Licensina and Overslaht SES Manager: Brian Sheron, Acting Associate Director for Technical Review, NRR I. Specific lasue: Reauests for AdditionalInformation Objective: To refine / define RAI process and ensure that staff RAl's are adding value to the regulatory process.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Discuss issue of ensuring appropriateness of RAI's with Complete B. Sheron, ADT management and staff (including content, quality and continued oversight) 2, Issue guidance to staff on content, quality and threshold 12/98 S. Peterson, ADT of RAl's and commencement of initial acceptance review.

RES, NMSS

3. Monitor outgoing RAls and responses Ongoing B. Sheron, ADT RES, NMSS 4, Solicit feedback from licensee's on RAls Periodic ADPR/

B. Sheron, ADT t

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33 IV. Toolc Area: Reactor Licensina and Oversiaht SES Manager: Bruce Boger, Acting Associate Director for Projects, NRR J. Specific issue: 2.206 Petitions Objective: The objectives of the 2.206 Petition review process include ensuring the public health and safety through the prompt and thorough evaluation of any potential safety problem addressed by a petition filed under 10 CFR 2.206 and to ensure effective, timely communication with the petitioner (Management Directive 8.11). The objective of the actions listed below is to identify and implement measures to improve the timeliness of staff response to petitions.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Establish a Petition Review Board to ensure 10/97C R. Subbaratnam, ADPR management involvement early in the process
2. Establish public availability of monthly 2.206 Petition 04/98C R. Subbaratnam, ADPR Status Reports at the NRC Web site (http://www.nrc. gov /NRC/PUBLIC/2206/index.html)
3. Assess timeliness of resolution of 2.206 petitions and 10/30/98 R. Subbaratnam, brief EDO on the results and any proposed process ADPR improvements
4. Implement proposed 2.206 process improvements (if 12/98 R. Subbaratnam, ADPR any)

THROUGH JUNE 30,1999 Date Lead Milestone

5. Show measured improvement in timeliness of 03/99 R. Subbaratnam, ADPR resolution of 2.206 petitions l

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V. Tonic Area: NRC Orn_anizational Structure and Resources SES MANAGER:

Paul E. Bird, Director, HR l

A. Specific lasue: Reorganization - Restructuring Line Organizations Lead Manager:

James F. McDermott, Deputy Director, HR Objective: To improve organizational effectiveness and determine resources required to carry

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out NRC activities through internal functional realignments and human resource reallocations.

PRIOR TO JANUARY 28,1999 Milestone Date

1. Offices initiate plans for proposed restructuring 8/19/98
2. All Employees Meeting 9/3/98
3. Restructuring proposals submitted to Commission 9/30/98
4. Completion of Commission review of restructuring proposal 10/28/98
5. Partnering process completed for reorganization packages 11/28/98 12/31/98
6. Reorganization plans finalized 1/1999
7. Implementation begins

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THROUGH JUNE 30,1999 Date Milestone 3/31/99

8. Implementation completed I

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I V. Tonic Area: NRC Organizational Structure and Resources l

j SES MANAGER:

Paul E. Bird, Director, HR B. Specific issue: Achievina 1:8 supervisor /manaaer-to-emoloyee ratios Lead Manager:

James F. McDermott, Deputy Director, HR Objective: To reduce supervisory and SES positions to achieve an agency-wide i

l supervisor / manager-to-employee ratio target of one supervisor / manager for every eight NRC

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PRIOR TO JANUARY 28,1999 l

1 Milestone Date

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1. Continue existing supervisor / manager-to-employee ratio Ongoing reduction efforts 9/3/98
2. All Employees Meeting

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3. Quarterly assessment of supervisor / manager-to-employee 10/98 ratio
4. Develop targeted strategies to achieve supervisory ratio 10/98 goals I
5. Year end assessment of supervisor / manager-to-employee 1/99 ratio incorporating the results of attrition, including the effect of early outs or buy outs (should buyouts be authorized by Congress)

THROUGH JUNE 30,1999 Date Milestone

6. Complete implementation of reorganizations developed to 3/31/99 achieve streamlining goals 3/31/99
7. Implement strategies to achieve supervisory ratio targets 4/99 l
8. Quarterly assessment of supervisor / manager-to-employee ratio l

5/31/99

9. Implement strategies to achieve supervisory ratio targets l

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10. Quarterly assessment of supervisor / manager-to-employee 7/99 ratio l

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11. Implement strategies to achieve supervisory ratio targets 7/15/99 l

Comments:

The milestones in the table above focus only on those aspects of the streamlining effort that address the supervisor / manager-to-employee ratio. Activity extends beyond the March 31, 1999, deadline established for the structural changes contained in issue 1 since the human resourris side of the effort are the most complex and difficult aspects of the overall reorganization to implement.

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37 V. Toolc Area: NRC Oragnizational Structure and Resources SES MANAGER:

Paul E. Bird, Director, HR C. Specific issue: Increased staff responsibilities Lead Manager:

Individua' Office and Regional managers Objective: To enhance organizational effectiveness under the specific conditions imposed by the agency-wide streamlining effort, including functional realignments, reductions in supervisory / managerial personnel, and increased spans of management control by delegating greater responsibility and accountability to individual employees and fostering greater interactive communications between employees and management. Issue 3 builds on existing efforts to increase staff responsibilities using these same techniques.

PRIOR TO JANUARY 28,1999 MILESTONE DATE

1. Continue previous general efforts to foster delegations of Ongoing responsibility and accountability to employees and more j

interactive communications between employees and managers.

l Monitor office progress 9/3/98 1

2. All employees meeting
3. Provide guidance to managers on the need to consider 9/30/98 greater use of delegations of responsibility and accountability to employees.
4. Begin implementing delegations of responsibility and 1/19/99 accountability as techniques to enhance agency effectiveness on an office-by office basis I

THROUGH JUNE 30,1999 Date I

Milestone

5. Continue implementation of delegations of responsibility and 3/31/99 l

accountability as individual office reorganizations are i

completed and implemented Comments:

The milestones for this issue establish a logical time period for beginning the local office process l

of employee delegations / empowerment planning and a logical point at which the local office l

environment should be transformed to a new cultute.

38 VI. Toolc Area: Other Aaency Proarams and Areas of Focus l

SLS: Robert Wood, DRPM/NRR A. Specific lasue: License Transfers Objective: To ensure that license transfers are conducted in a timely and technically correct manner and that review and submittal guidance is appropriately disseminated.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Issued proposed 10CFR Part 2 Subpart M hearing 8/14/98C OGC process - paper to Commission (SECY 98-197)
2. Publish proposed rule on license transfer (see SECY-8/28/98 OGC 98-197)
3. Publish final rule on license transfer 11/98 OGC
4. Complete technical review of TMI-1 transfer See R. Wood, DRPM comment THROUGH JUNE 30,1999 Milestone Date Lead
5. Provide Commission with proposed final criteria for 6/18/99 R. Wood, DRPM triggering a review under 10CFR50.80 regarding the transfer of operating authority to non-owner operators (i.e., use of contract service operating companies).
6. Icsue lessons learned from Amergen TMI-1 transfer 6/99 R. Wood, DRPM BEYOND JUNE 30,1999 Milestone Date Lead
7. Issue process improvement re: foreign ownership 12/99 OGC R. Wood, DRPM
8. Develop SRP on technical qualifications 12/99 DRCH
9. Develop SRP on license transfer process TBD OGC R. Wood,DRPM _

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' Comments:

4. Submittal + 3 months

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Vj. Toolc Area: Other Aaency Proarams and Areas of Focus SES Manager: Theodore Quay, Director, PDST/DRPM/NRR B. Specific Issue: AP-600 FDA Objective: Issue FDA PRIOR TO JANUARY 28,1999 i

Milestone Date Lead

1. Issue FDA 9/4/98 T. Quay, DRPM l

THROUGH JUNE 30,1999 Milestone Date Lead None 1

BEYOND JUNE 30,1999 Date Lead Milestone None I

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40 VI. Tonic Area: Other Aaency Proarams and Areas of Foggs SES Manager: William F. Kane, Director, Spent Fuel Project Office C1. Specific issue: TN-68 (Dual Purpose) Cask Review Ongoing technical review Mary Jane Ross-Lee Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the TN-68 dual purpose cask system (Comment 1)

PRIOR TO JANUARY 28,1999 Date Milestone

3. Staff receives response to storage RAI 09/98
2. Staff issues second storage RAI,if necessary 12/98
3. Staff receives response to second storage RAI 01/99 THROUGH JUNE 30,1999 Milestone Date l

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4. Staff issues user need memorandum /rulemaking 03/99 l

S. Staff issues draft SER and CoC for ru!emaking 05/99 BEYOND JUNE 30,1999 Date Milestone

6. Staff completes rulemaking; issues CoC for use under Part 72 04/00 Comment:
1. The storage review is being completed prior to the transportation review; the transportation review schedule will be determined at a subsequent time. The review schedule is based upon the assumption that the applicant will supplement its application and response to staff requests for additional information on the schedule noted. At this time, no significant issues have been identified. The licensee for Peach Bottom 1 & 2 intends to utilize this cask system.

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I 41 VI. Toolc Area: Other Aaency Proa_ rams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C2. Specific issue: BNFUSNC TranStor (Dual Purpose) Cask Review l-l Ongoing technical review T. Kobetz Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the BNFUSNC dual purpose cask system (Comment 1) l PRIOR TO JANUARY 28,1999 Milestone Date

1. Staff issues user need memorandum /rulemaking 11/98 THROUGH JUNE 30,1999 l

Milestone Date

2. Staff receives updated SAR from applicant 02/99 t
3. Staff issues draft SER and CoC for rulemaking 03/99 I

BEYOND JUNE 30,1999 Milestone Date

4. Staff completes rulemaking; issues CoC for use under Part 72 02/00 Comment:
1. The storage review is being completed prior to the transportation review; the transportation review schedule will be determined at a subsequent time. At this time, no significant issues have been identified, but the applicant must update the safety analysis report by February 1999.

l This review is associated with the Part 72 Trojan ISFSI (site-specific) license application, PFS, LLC intends to utilize this cask system as well.

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42 VI. Tonic Area: Other Aaency Pronrams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C3. Snacific lasue: Holtec HISTAR 100 (Dual-Purpose) Cask Review 1

l Technical review ongoing M. Delligatti Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) j and a Part 71 (transportation) certificate of compliance for the Holtec HISTAR 100 dual purpose l

cask system (Comment 1) 1 PRIOR TO JANUARY 28,1999 l

Milestone Date

1. Staff issues user need memorandum /rulemaking 08/98 l
2. Staff issues draft storage SER and CoC for rulemaking (Part 72) 09/98 i

THROUGH JUNE 30,1999 l

Milestone Date

3. Staff issues transportation (Part 71) CoC 03/99 BEYOND JUNE 30,1999 Milestone Date
4. Staff completes rulemaking: issues CoC for use under Part 72 08/99 Comment:
1. While the final review phase is ongeing and nearing completion, it is still unclear regarding the scope of the staff's approval on the storage component of the design. This review is being performed to support spent fuel storage requirements at Dresden 1 and Hatch 1 & 2, and PFS, LLC intends to utilize this cask system.

43 VI. Toolc Area: Other Aaency Procrams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C4. Specific lasue: Westinghouse WESFLEX (Dual Purpose) Cask Review Ongoing technical review M. Bailey j

l Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the Westinghouse WESFLEX dual purpose cask system (Comment 1)

PRIOR TO JANUARY 28,1999 Date Milestone l

1. Staff issues RAI for base storage system and W21 canister 10/98

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2. Staff issues RAI for W44 canister 11/98
3. Staff issues RAI for W74 canister 12/98 THROUGH JUNE 30,1999 Date Milestone
4. Staff receives responses to RAls 03/99 BEYOND JUNE 30,1999 Date Milestone 07/99
5. Staff issues final RAI, if necessary 10/99
6. Staff receives response to RAI, if necessary -
7. Staff issues user need memorandum /rulemaking 12/99
8. Staff issues draft SER and CoC for rulemaking 01/00
9. Staff complete rulemaking; issues CoC for use under Part 72 12/00 Com. ment:
1. The storage review is being completed prior to the transportation review. The transportation application was resubmitted in May 1998, and the transportation review schedule will be determined at a subsequent time. The storage review has just commenced, and at this time, no significant issues have been identified. Big Rock Point and Palisades intend to utilize this cask
system, i

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4 44 VI. Tonic Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C5. Specific issue: NAC-STCIMPC (Dual Purpose) Cask Review Ongoing technical review T. McGinty

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Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) and a Part 71 (transportation) certificate of compliance for the NAC-STC/MPC dual purpose cask system (Comment 1)

PRIOR TO JANUARY 28,1999 Milestone Date

1. Staff receives response on transport RAI 08/98

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2. Staff receives response on storage RAI 10/98 l

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3. Staff issues user need memorandum /rulemaking 12/98

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THROUGH JUNE 30,1999 Milestone Date

4. Staff issues Part 71 (transportation) CoC 04/99 I
5. Staff issues draft storage SER and CoC for rulemaking 04/99 BEYOND JUNE 30,1999 Milestone Date
6. Staff complete rulemaking; issue CoC for use under Part 72 03/00 Comment:

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1. The storage and transportation review are being conducted concurrently. At this time, no significant issues have been identified, but the applicant rnust respond by the time frame noted in order for the staff to maintain this schedule. The licensee for Yankee /Rowe intends to utilize this cask system.

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I 45 VI. Tuaic Area: Other Aaency Proarams and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C6. Specific lasue: NAC-UMS (Dual Purpose) Cask Review Ongoing technical review T. McGinty Objective: To issue a Part 72 (storage) SER and certificate of compliance (through rulemaking) l and a Part 71 (transportation) certificate of compliance for the NAC-UMS dual purpose cask sy tem (Comment 1) i PRIOR TO JANUARY 28,1999 Date Milestone

1. Staff issues storage RAI 11/98 01/99
2. Staff receives RAI response
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THROUGH JUNE 30,1999 Date

', Milestone

3. Staff issues second storage RAI, if necessary 06/99 BEYOND JUNE 30,1999 Date Milestone l
4. Staff receives second storage RAI response 08/99
5. Staff issues user need memorandum /rulemaking 08/99
6. Staff issues draft storage SER and CoC for rulemaking 11/99
7. Staff completes rulemaking, issues CoC for use under Part 72 10/00 Comment:
1. The storage review is being completed prior to the transportation review; the transportation review schedule will be determined at a subsequent time. At this time, no significant issues have been identified, but applicant must respond by the time-frame noted in order for the staff to maintain this schedule. The licensees for Fitzpatrick and Palo Verde 1,2 & 3 intend to utilize this cask system.

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e 46 VI. Tonic Area: Other Aaency Programs and Areas of Focus SES Manager: William F. Kane, Director, Spent Fuel Project Office C7. Specific issue: TN-West MP-187 (Dual-Purpose) Cask Review lssue Part 71 certificate of compliance M. Raddatz Objective: To issue Part 71 (transportation) certificate of compliance for MP-187 transportation cask system PRIOR TO JANUARY 28,1999 Date M.lestone

1. Staff starts final review and SER compilation phase 08/98
2. Staff issues Part 71 certificate of compliance (Comment 1) 09/98 THROUGH JUNE 30,1999 Date Milestone None BEYOND JUNE 30,1999 Date Milestone None Comment:
1. This transportation system is the transport component of the TN-West NUHOMS storage j

design. As initially certified, its authorized contents will be limited to B&W fuel, although it may be amended at a later date to address other fuel types. This action supports the decommissioning of the Rancho Seco spent fuel pool.

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l 47 VI. Toc!c Area: Other Aaency Proarams and Areas of Focus l

SES Manager: Seymour Weiss, Director, PDND/DRPM/NRR D. Specific issue: Decommissioning Decisions l

Objective: Provide timely decisions on current issues and provide framework for l

decommissioning activities.

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PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Provide response to SRM for SECY 98-075 (DSI-24) 10/09/98 M. Masnik, DRPM 1a. Form task team to develop and provide input for 7/24/98C T. Markley. DRPM Commission paper 1b. Evaluate applicability of using templates for 8/21/98 P. Harris, DRPM decommissioning licensing actions ic. Develop integrated set of milestones for addressing 8/21/98 R. Dudley, DRPM decommissioning initiatives under development or contemplated 1d. Complete draft Commission paper for concurrence 9/2/98 T. Markley, DRPM 1e. Submit paper to Commission 10/9/98 T. Markley, DRPM
2. Meeting with NEl and industry to present Commission 1/15/99 S. Weiss,DRPM integrated milestones for decommissioning initiatives necessary for above rules and for existing rules THROUGH JUNE 30,1999 Date Lead Milestone None Comments:
1. Schedules are based on meeting established Commission due dates for DSI-24 SRM response.

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48 VI. Toolc Area: Other Aaency Proarams and Areas of Focus

' SES Manager: Susan F. Shankman, Dep. Director, Licensing and Inspection Directorate, SFPO l

l E. Specific issue: PGE-Trolan Reactor Vassel Shloment Anolication Part 71 exemption (SER and EA)

J. Cook Waste classification,if necessary J. Hickey l

Objective: To issue Part 71 (transportation) approval to ship the Trojan reactor vessel, with l

l intemals, for disposal in the State of Washington PRIOR TO JANUARY 28,1999 i

Date 1

Milestone i

1. Staff prepares SER for Part 71 approval 09/98 09/98 l
2. Staff prepares EA I
3. Staff waste classification, if necessary (separate SECY paper) 09/98
4. Staff prepares SECY paper on transportation and FONSI 10/98
5. Commission issues SRM on Part 71 exemption (Comment 1) 10/98
6. Staff issues Part 71 decision 11/98 r

THROUGH JUNE 30,1999 Date Milestone None f

BEYOND JUNE 30,1999 Date i

Milestone 08/99

_7. Inspection follow-up prior to and during shipment (Comment 2)

Comments:

1. In parallelto staff action: (1) the State of Washington must prepare a technical evaluation for disposal, tentatively scheduled for September 1998; (2) the Department of Transportation must grant an exemption, tentatively scheduled for November 1998; and (3) the State of Oregon must approve this as a change to the utility's Decommissioning Plan, tentatively scheduled for November 1998.
2. PGE's decision to grout the reactor vesselis scheduled to occur in November 1998. The actual grouting would commence in December 1998, and vessei snipment would occur in August 1999. Staff actions at these points would,ae to inspect as appropriate.

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l 49 VL Toolc A. tea: Other Aaency Proarams and Areas of Focus 4

SES Manager: John Stolz, Chief, PECB/DRPM/NRR G. Specific lasue: Event Reportina Rulemakina

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i Objective: Revise event reporting requirements to reduce the reporting burden associated with j

events of little or no risk significance, obtain information better related to risk, and extend l

reporting time limits consistent with the need for prompt NRC action.

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Coordination: Issues ll.A. " Risk informed Baseline Core inspection Program," II.B. " Enforcement Program Initiatives," II.C. " Escalated Enforcement Program," lll.A. " Performance Assessment Process improvements," and VI.G " Event Reporting Rulemaking," require close coordination and the integration of specific tasks by the NRC staff. Responsible project managers are coordinating these activities by assessing the impact of proposed program changes with the l

1 other ongoing activities and ensuring that the overall objectives for each project are achieved.

Examples include, intra-project task force participation, workshop attendance, concurrent review of projects and periodic senior management briefings. In addition, industry-developed initiatives such as the NEl New Regulatory Oversight Process are being reviewed by all project groups l

and evaluated for impact.

PRIOR TO JANUARY 28,1999 Date Lead Milestone 7/28/98C D. Allison, AEOD

1. Issue ANPR
2. Conduct public meeting to discuss ANPR 8/21/98 D. Allison, AEOD
3. Public workshop / stakeholder meeting (Chicago) 9/1/98 T. Essig, DRPM THROUGH JUNE 30,1999 Date Lead Milestone
4. Publish proposed rule (10CFR50.72 and 50.73) 4/2/99 r' RPM BEYOND JUNE 30,1999 Date Lead Milestone 1/00 DRPM
5. Publish Final rule i

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50 VI. Toolc Area: Other Aaency Proarams and Areas of Focus i

SES Manager: Jack Roe, Acting Director, DRPM/NRR l

H. Specific is : -,: Proposed Kl Rulemaking Objective: To implement Commission decision regarding the use of Ki as a protective measure for the general public after a severe reactor accident. In addition, to work with other Federal agencies to revise the Federal policy on the use of K1 in the event of a severe nuclear power plant emergency and to develop aids to assist the states in applying the revised Federal policy.

I PRIOR TO JANUARY 28,1999 Date Lead Milestone

1. Commission direction received 6/26/98C A. Mohseni, AEOD/lRD
2. Draft and send to Commission Federal Register notice 7/98C A. Mohseni, AEOD/lRD on Federal Kl policy
3. Revise KI technical paper (NUREG-1633) to address 10/98 A. Mohseni, AEOD/lRD public comments and provide to Commission 4, Revise Kl Federal Policy FR notice and provide to 11/98 A. Mohseni, AEOD/lRD FRPCC for review
5. Pubiish proposed rule 11/30/98 T. Essig, DRPM 6 Publish final technical paper (NUREG-1633) 12/98 A. Mohseni, AEOD/lRD
7. Develop description of available Federal Ki stockpiles 1/99 A. Mohseni, AEOD/lRD and availability to states
8. Develop final KI Federal Policy FR notice reflecting 1/99 A. Mohseni, AEOD/lRD FRPCC review and send to Commission
9. Draft a public brochure on use of KI and provide for 1/99 A. Mohseni, AEOD/lRD Federal agency and public comment THROUGH JUNE 30,1999 Date Lead Milestone
10. Final review of KI Federal Policy FR notice by FRPCC 4/99 A. Mohseni, AEOD/lRD

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51 THROUGH JUNE 30,1999

11. Establish procedures to access Federal stockpiles with 5/99 A. Mohseni, AEOD/lRD FEMA
12. Publish Kl Federal Policy FR notice 6/99 A. Mohseni, AEOD/lRD
13. Final public brochure on use of KI provided to 6/99 A. Mohseni, AEOD/lRD Commission for review
14. Publish final rule TBD T. Essig, DRPM BEYOND JUNE 30,1999 Date Lead Milestone
15. Finalize the public brochure on use of Kl and provide to 8/99 A. Mohseni, AEOD/lRD FEMA for publication.

Comments:

2-8 The schedule requires approximately one ful1 time FTE and the impact on development and maintenance of the response program was not assessed.

3. Contingent on completion of Commission review by 9/30/98
4. This assumes that only a moderaio number of public comments are received and all the comments can be addressed without further research.

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O 52 VI. Tonic Area: Other Aaency Proarams and Areas of Focus SES Manager: Brian Sheron, Acting Associate Director for Technical Review, NRR I. Specific lasue: NEl Petitions - Petition for modifyina 50E Ma)

Objective: Complete the NEl Petition, accepting in part to modify 10 CFR Part 50.54(a), as it pertains to Quality Assurance Program Change Control and is intended to reduce burdens on industry.

PRIOR TO JANUARY 28,1999 Milestone Date Lead

1. Submit to the Commission a SECY Paper accepting the 10/98 R. Gramm, DRCH NEl Petition in part to modify 50.54(a)
2. Decision by the Commission to accept the staff proposal.

12/98 R. Gramm, DRCH THROUGH JUNE 30,1999 Date Lead Milestone

3. Publication of a Federal Register Notice to accept in part 02/99 R. Gramm, DRCH the NEl petition for rulemaking.

Comments:

1&2. These milestones are expected to impact the staffs efforts for timely completion of vendor / contractor inspections in FY98 and 99. Budgeted FY99 resources will require redirection depending on the final Commission decision. Commission decision to accept the staff proposal is expected by 12/98.

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I 53 VI. Toolc Area: Other Aaency Proarams and Areas of Focus i

SES Manager: Jack Roe, Acting Director, DRPM/NRR I

J. Specific lasue: Revised Source Term Rulemakina Objective: To revise Part 50 to allow holders of operating power reactor licences to voluntarily amend the facility design basis to use revised source terms in design basis accident radiological analyses. This action would allow these facilities to pursue risk-informed licensing actions made possible through the use of the revised source term.

PRIOR TO JANUARY 28,1999 Milestone Date Lead 1.

Commission approval of rulemaking plan (submitted Pending C. Miller, DRPM 6/30/98) 2.

Complete proposed rule package 10/98 C. Miller, DRPM 3.-

Office concurrence of proposed rule package 11/98 C. Miller, DRPM l

4.

ACRS review of proposed rule 11/98 C. Miller, DRPM 5.

CRGR concurrence of proposed rule 12/98 C. Miller, DRPM 6.

Proposed rule package to EDO 12/98 C. Miller, DRPM 7.

Submit proposed rule package to Commission 12/15/98 C. Miller, DRPM l

8.

Publish in Federal Register 1/99 C. Miller, DRPM THROUGH JUNE 30,1999 Milestone Date Lead 9.

Complete draft guide; draft SRP section 5/99 C. Miller, DRPM

10. End of Public Comment Period 4/99 C. Miller, DRPM
11. Office concurrence on final rule; draft guide; draft SRP 6/99 C. Miller, DRPM l

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54 BEYOND JUNE 30,1999 Milestone Date Lead

12. ACRS review 7/99 C. Miller, DRPM
13. CRGR review 7/99 C. Miller, DRPM
14. Final rule; draft guide; draft SRP to EDO 7/99 C. Miller, DRPM
15. Final rule; draft guide; draft SRP to Commission 7/30/99 C. Miller, DRPM 15a. Publish Final Rule and draft guide 9/10/99 C. Miller, DRPM
16. End of public comment period 11/99 C. Miller, DRPM
17. Office concurrence on final guide; final SRP 12/99 C. Miller, DRPM
18. ACRS review on final guide; final SRP 12/99 C. Miller, DRPM
19. CRGR concurrence on final guide; final SRP 1/00 C. Miller, DRPM
20. Final guide; final SRP to EDO 1/00 C. Miller, DRPM
21. Final guide; final SRP to Commission 1/24/00 C. Miller, DRPM Meetings with ACRS and CRGR would be expected to occur in conjunction with the scheduled

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reviews.

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J The staff is working with NEl to schedule a status meeting in early October 1998. The staff l

expects to conduct additional meetings as the need arises. There is currently no planning for a

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workshop. Such a workshop may be appropriate once the staff has issued the final rule, the j

draft guide, and the draft SRP.

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