ML20249A168
| ML20249A168 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1998 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-225-C, SECY-98-065, SECY-98-065-01, SECY-98-065-R, SECY-98-65, SECY-98-65-1, SECY-98-65-R, NUDOCS 9806160131 | |
| Download: ML20249A168 (107) | |
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Aoril 2.1998 SECY-98-065
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FROM L. Joseph Callan Executive Dimetor for Operations SUBJERI:
FY 1998 NRC EXCELLENCE PLAN PURPOSE:
To provide a plan for implementing a proactive approach to improving regulatory effectiveness l
and efficiency with the goal of excellence and to respond to the January 14,1998, Staff Requirements - SECY-97-225 - Enhancing NRC Effectiveness and Efficier cy.
MQKGROUND:
1 in August 1995, the staff initiated a Strategic Assessment and Rebaselining Project. This project was intended to take a new look at the NRC by conducting a reassessment of NRC activities in order to redefine the basic nature of the work of the agency and the means by which i
that work is accomplished, and to apply to these redefined activities a rigorous screening process to produce (or rebaseline) a new set of assumptions, goals, and strategies for the NRC.
DSI-23, Enhancing Regulatory Excellence, was a key Direction Setting Issue of this effort.
In October 1997 the staff submitted SECY-97-225, Enhancing NRC Effectiveness and Efficiency, which provided a discussion of how quickly and broadly the sta'f could proceed to phase in a comprehensive, systematic, agency-wide approach to program assessment and improvement pursuant to DSI-23. SECY-97-225 provided a basic framework for these activities and described, in general,13 excellence strategies to initiate this effort. Twelve of these 13 strategies, most already ongoing, involve initiatives to assess or improve specific aspects of the NRC's regulatory and administrative functions. One involved a new process, designed to function within the agency's planning, budgeting, and performance management process, to systematically identify areas for improvement. Further description of these activities and details of the 13 excellence strategies are provided in the FY 1998 NRC Excelience Plan, attachment 1 1
of this paper. Attachment 2 provides a response to the January 14,1998, Staff Requirements -
g SECY-97-225 - Enhancing NRC Effectiveness and Efficiency.
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Contact:
Thomas O. Martin, OEDO NOTE: TO BE MADE PUBLICLY AVAILABLE 415-7999 WHEN THE FINAL SRM IS MADE AVAIALBLE 9006160131 990402 PDR SECY t
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As pointed out in SECY-97-225, these 13 strategies are not the only improvement activities i
. being undertaken by the staff. However, they have been singled out through the review of the Program Review Committee (PRC) and Executive Council (EC) as those initiatives which are of sufficient significance to warrant special oversight as part of the Excellence Plan. Other more l ~
routine initiatives are part of the staff operating plans that are monitored by the PRC within the j
context of the planning, budgeting, and performance management process.
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The initiatives described in this paper were developed to be consistent with the Strategic Plan; DSI-23; the staff requirements memoranda (SRM) issued March 27,1997, Staff Requirements -
COMSECY-96-067, Enhancing Regulatory Excellence; June 17,1997, Staff Requirements -
Briefing on Prograrr,5 improve Regulatory Effectiveness; and January 14,1998, Staff Requirements - SECY-97-225 - Enhancing NRC Effectiveness and Efficiency. They also extend to matters covered in a number of DSis, many of which are interrelated among themselves and l
integral to regulatory excellence activities.
l, DISCUSSION l
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In response to the Commission's request on how broadly and how quickly the staff can l
realistically phase ln an agency-wide approach to program assessment and improvement of the l
NRC's infrastructure, the FY 1998 Excellence Plan builds on and integrates with existing initiatives, many of which are either directly rnandated by the Commission or being undertaken as part of staff actions in response to Commission final decisions on Direction Setting lasues.
Consistent with this approach, the goals and strategies developed for the FY 1998 Excellence Plan constitute a unique spectrum of initiatives which may not be typical of the types of activities l
that will emerge in future versions of the plan.
l The FY 1998 Excellence Plan represents an initial step in development of an agency-wide approach to improving the NRC and implementing the NRC's Strategic Plan goal to " carry out L
the NRC regulatory program efficiently and effectively." The Excellence Plan also supports the l
NRC Performance Plan goals to " evaluate and implement needed improvements for five major
' NRC processes by July 1,1999," and " implement the ageney's plan for regulatory excellence".
L To accomplish this, the Excellence Plan contains three goals as shown in Figure 1. Each of L
these goals are supported by various strategies. These Excellence Plan goals and strategies L
are expected to change as part of a periodic update process. Diagrams of the strategies l-included in the Excellence Plan show how the outputs of the strategies contribute to program l
outputs which, in tum, contribute to outcomes that support the agency's goals.
The activities associated with the Excellence Plan will be integrated into the agency's plannmg processes. Figure 2 shows the relationship of the Excellence Plan activities with various other l
agency plans and activities.
j The Excellence Plan w;ll be periodically updated from a selection of assessment and improvement indiatives. Each office will periodically develop proposed plans for assessment and improvement initiatives that would be included !n their operating plans. These initiatives will be compiled and prioritized along with candidate issues for improvement developed from other sources and presented to the PRC. The PRC will provide recommendations to the Executive Council (EC) on the scope of issues to be addressed and which of these initiatives wairant 4
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oversight at the PRC/EC level. The EC will then select the assessment and improvement initiatives that will be describeg detail in the NRC Excellence Plan. The prioritization and extent of response to these candidate issues will be based on considering the impact on safety, the potential for improving the ability of the agency to meet its goals, resource impact to the
- NRC and licensees, impact on quality of agency work, and public confidence in NRC activities.
}
The initiatives not included in the Excellence Plan will either be incorporated in operating plans and considered by the PRC and EC as part of the planning, budgeting, and performance management process or, because of narrow impact or small resource implications, be t
implemented at the discretion of the lead office.
l trategic Plan Goali I
..D*_"Y_*"'_the NRC regulatory program efficiently and effectively Performance Plan Goals:
> Evaluate and implement needed improvements for five major NRC processes by July 1,1999
(>tmplement the agency's plan for regulatory excellence j
Excellence Plan Goal #1 - -
stratogles 1 - 8 Improve a manageable but broad Focus on enhancing the range of NRC regulatory
,m effectiveness of the regulatory programs, rules, standards, and framework and enhancing the regulatory guidance g~ efficient use of nuclear materialsY l
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Excellence Plan Goal 82 strategies 7 -12 i
l' improve the NRC's processes and Focus on enhancing the management and support functions so effectiveness and efficiency of as to enhance the efficiency and the NRC staff by improving performance of the NRC staff.
(NRC processes j.
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. Excellence Plan Goal #3
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strategy 13
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Create an environment that win Focuses on identifying and promote enhanced effectiveness and addressing organizational i
efficiency of NRC activities in an open culture issues that could manner with the support and input of our intomal and extemal stakeholder (impede staff performance
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i' Figurs> 1 Relationship of Strategic and Performance Goals to Excellence Plan Goals and Strategies Candidate issues for improvement will be developed from self-assessments, program reviews, and a variety of other sources such as the labor / management partnership, any NRC staff member, the Commission, OlG, GAO (or other outside entities), and meetings with the public I
. and industry. Staff assigned to the Deputy Executive Director for Regulatory Effectiveness
- (DEDE) will compile, review, and synthesize these candidate issues for improvement. A point
- of contact will be identified and an e-mail address established to allow any NRC staff member to input a candidate issue for improvement directly to the DEDE staff.
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Strategic and Performance P!ans )
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Programs 2 8 Ctandidate issues for Reactor ReguWory Programs f {E 4
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Wstorials Regulatory Programs Regulatory Support Programs l
(Excellence Plan strategy 5)j Administrative Support Program C
j A-A Assessment of performance',
. agairast goals and plans,'
Figure 2 Relationship of Excellence Plan with Overall Planning Process Excellence Plan strategy 5 will be a key component in the planning, budgeting, and performance assessment process in that it will provide a systematic approach to propose potential improvements in the effectiveness and efficiency of rules, standards, regulatory guidance, and their application. The strategy 5 process is described in detail in the attached
' Excellence Plan and will consist of an issue identification phase, an issue analysis phase, and an issue proposal phase. Issues will be proposed at various times and be input into the normal planning and budgeting process. Criticalissues of a more immediate nature may occasionally be' proposed that could result in the reprogramming of resources.
The role of the Excellence Plan is intended to be a seamless and integrated part of the agoney's planning and budgeting process. Eventually, as more experience is gained with the agency's planning, budgeting, and performance management process as supplemented by strategy 5 as a mechanism to identify new areas for improvement, it may become unnecessary to continue to maintain the Excellence Plan as a formal agency document. Impacting the decision to maintain
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the Excellence Plan will be whether the key principles incorporated into the Excellence Plan strategies, such as stakeholder involvement, criteria for measuring success, and clear cost / benefit considerations become integrated into the more routine agency improvement
_ activities. When this occurs, the activities shown enclosed in a dashed line in Figure 2 can cease to exist, and the maintenance and revision of the Excellence Plan can be " sunset" as a separate management activity.
5 RESOURCES-Details of the resources required to implement each of the FY 1998 Excellence Plar: strategies are discussed in the attached Plan, These assessment and improvement activities have been included in the FY 1998 budget as discussed in the details of each strategy. The resources required to implement the planning, budgeting, and performance management process have been budgeted and will come pnmarily from the overhead costs of implementing each of the NRC's programs. The resources required to implement the excellence program plannir'; and support are estimated at less than one FTE and have been budgeted. Attachment 3 depicts the resource estimates associated with each strategy.
COORDINATION:
The Office of the General Counsel has no legal objection to this paper. The Office of the Chief Financial Officer has reviewed this paper for resource implications and has no objections, and the Chief Information Officer has conarred in this paper.
RECOMMENDATION.
The Excellence Plan strategies are proceeding consistent with the descriptions in this plan and other staff commitments on these issues. Unless directed otherwise by the Commission, the staff plans to continue implementation of the FY 1998 NRC Excellence Plan and remove the draft designation of this plan within 10 days of the date of this paper.
L. J pp allan Ex
- ive Director for Operations 4
Attachments:
As Stated i
SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Monday, April 20, 1998 that the Commission, by negative consent, assents to the action proposed in this paper.
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i UNITED STATES NUCLEAR REGULATORY COMMISSION i
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FY 1998 EXCELLENCE PLAN Draft, Predecisional l
April 1998 l
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Note: This document will be considered draft, predecisional until final approval is made by the Commission.
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i U. S. Nuclear Regulatory Commission DRAFT Table of Contents l
Table of Contents Page Message from the C hai rman.................................................................................................. 1 Introduction.............................................................................................................................2 l
1 1
Relationship of the Excellence Plan to the Planning, I
. Budgeting and Performance Management Process.............................................................. 4 Organizational Culture Improvement initiatives................................................................... 6 Excellence Plan Coordination and Support......................................................................... 7 a
Excellence Plan Goals and Strategies................................................................................. 9
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Details of Strateg ies........................................................................................................... 12 NRC's Strategic Plan in the Strategic Arena of Excellence............................................... 95 l
I L
L FY 1998 Pagell ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Message from the Chairman Message from the Chairman 1
i This document outlines an approach that will guide the NRC in its efforts to enhance its effectiveness and efficiency in its goal of attaining excellence.
This plan !s not intended to represent a quick fix to any specific problem but rather describes a process of sustainable improvement.
As the environment in which we operate continues to change, the NRC must keep pace by examining our processes, challenging existing assumptions, and demonstrating the results of our actions. As Chairman I intend to fully support these efforts in a positive manner and ask the same of each staff member.
Chairman j
U. S. Nuclear Regulatory Commission i
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l FY 1990 Page 1 ExceIIence Plan
U. S. Nuclear Regulatory Commission DRAFT Introduction Introduction Recent events as well as the historical performance of the NRC has caused us to reexamine our organization and to revisit our vision, values, and key principles. This has resulted in the development of a clearer vision for ourselves that calls for the achievement of excellence in all facets of our activities.
In August 1995, the staff initiated a Strategic Aseessment and Rebaselining Project. This project was intended to take a new look at the NRC by conducting a reassessment of NRC activities in order to redefine the basic nature of the work of the agency and the means by which that work is accomplished, and to apply to these redefined activities a rigorous screening process to produce (or rebaseline) a new set of assumptions, goals, and strategios for the NRC. DSI-23, Enhancing Regulatory Excellence, was a key output of this effort.
Regulatory excellence was defined in DSI-23 as "a dedication to safety, a commitment to the principles of good regulation, and the pursuit of superior staff performance" and further described as involving both " regulatory effectiveness" and " regulatory efficiency" components.
Regulatory excellence can be further described as the overall ideal toward which we strive, in which NRC regulations, processes, procedures, personnel, and interactions are an embodiment of the highest standards of performance, including the Principles of Good Regulation, the elemeMs of the NRC Safety Philosophy, and the NRC Organizational Values. Regulatory excellence involves an organizational culture that fosters a motivating attitude at all levels, manifested in superior performance in individual and collective actions.
Regulatory effectiveness denotes a regulatory framework for ensuring public health and safety
. that is clear, coherent, logical, consistent, reliable, and technically sound. Regulatory effectiveness can be further described as the successful execution of the set of strategies to be used in striving for excellence, which should include: (1) grass roots participation, feedback and consensus-building; (2) incorporating the input and needs of extemal stakeholder; (3) incorporating existing strategies for improving performance; and (4) producing regulatory outputs that contribute to desired outcomes. Regulatory effectiveness involves the estabimhment of goals for improving performance, the development of strategies for achieving those goals, and the measurement of progress according to agreed-upon success criteria.
Regulatory effectiveness implies a willingness to listen to divergent views, a determination to leam from experience, and a questioning attitude. Regulatory efficiency is directed at ensuring that the NRC implements programs in an efficient and cost-effective manner for both the govemment and its licensees.
The NRC Strategic Plan commits the NRC to implement a plan for regulatory excellence. In addition to the considerations in the Strategic Plan, the NRC Excellence Plan was developed with consideration of Commission guidance, the changing environment in which the staff and its licensees operate, current thinking regarding good management practices, and staff input obtained through several workshops on excellence conducted in July 1997. The plan was formulated to become an ongoing effort to achieve a comprehensive and systematic approach to assessment and improv9 ment. Several of the principal considerations that helped shape the FY 1998 Page 2 ExceIIence Plan
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I U. S. Nuclear Regulatory Commission DRAFT Strategic Plan direction of the plan, include:
1 NRC management should nurture a commitment to excellence for all employees.
Initial efforts to enhance excellence should build on and integrate with existing initiatives.
Bui!d on existing NRC standards of excellence such as the principles of good regulation, the principles of good financial management, and the NRC organizational values.
In addition to improving the processes under which the NRC operates, organizational l
culture issues must be addressed, Focus on meeting the requirements of the Govemment Performance and Results Act.
Integrate with the agency planning, budgeting, and performance management process.
I Program outputs should lead to desired program outcomes.
The day-to-day work of the agency should be aligned with its strategic and performance plans.
Work processes and products of the agency need to take into consideration the needs of the intemal and extemal stakeholder.
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I FY 1998 Page 3 Excellence Plan t
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U. S. NuclearRegulatory Commission DRAFT Ongoing Efforts i
Relationship of the Excellence Plan to the Planning, Budgeting and Performance Management Process Although the Excellence Plan strategies will change periodically as some are completed and new strategies are identified, the planning, budgeting, and performance management process will be an ongoing effort that will enhance the effectiveness and efficiency of the NRC.
The Agency Planning, Budgeting, and Performance Management Process A significant aspect of the effort to enhance NRC excellence will be to set mmsurable goals, establish sound strategies, ensure that the day-to-day work of the agency is consistent with the goals and strategies in the Strategic Plan, and ensure that programs and activities are achieving desired outcomes at the feast cost. Maintaining a clearer understanding, on all organizational levels, of how individual and group contributions fit into the goals of the agency will help focus the conduct of our activities, leading to better effectiveness and efficiency.
An initiative is currently undenway implementing a new NRC-wide planning, budgeting, and performance management (PBPM) process. This process will focus on setting the strategic direction and performance expectations for the organization; determining programs, resources, and planned accomplishments to meet those expectations; measuring and monitoring performance against esta' lished expectations; s'id assessing performance and making it better u
by capturing lessons leamed and applying consequences. Activities that no longer add value or add limited value toward achieving NRC's goals will be identified and eliminated. The program assessments and evaluations that will be conductd as part of this process will be an essential ingredient of the effort to improve NRC effectiveness and efficiency. Other key features of this initiative are the development of operating plans and periodic program reviews.
The scope of this effort is intended to be broad, and applies to all NRC technical and support programs that come under the purview of the Executive Director for Operations, the Chief information Officer, and the Chief Financial Officer. Operating plans will be developed by each office, containing a level of detail below the Performance Plan. Program reviews, held in each program area on an annual basis, will be a structured presentation by the various offmes to the Program Review Committee (PRC), focusing on actual and planned accomplishments and how they relate to the Strategic and Performance Plans. This will provide an opportunity for key decision makers to review the results of program performance and assessments in order to make appropriate adjustments in the direction of these efforts. A comprehensive, systematic program of self-assessments will be conducted, and a generic program evaluation checklist will be available to promote consistency and a comprehensive evaluation. The Chief Financial Officer will play a key role in the development of this agency-wide assessment guidance.
FY 1996 Page 4 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Ongoing Efforts Integration of the Excellence Plan with the PBPM Process The Excellence Plan and future updates is intended to be the seatdess end result of the l
agency's planning and budgeting process.
Candidate issues for improvement will be developed from self-assessments, program reviews, and from a variety of other sources including the labor / management partnership, any NRC staff member, the Commission, OlG, GAO (or other outside entities), and meetir.as with the public and industry. The Deputy Executive Director for Regulatory Effectiveness (DEDE) staff offices l
will compile, review, and synthesize these candidate issues for improvement. A point of contact will be identified and an e-mail address established to allow any NRC staff I? ember to input a candidate issue for improvement directly to the DEDE staff.
Periodically, each office will submit plans for assessments and improvement initiatives to the DEDE who will then develop a prioritized list of initiatives using the input from the offices as well as other candidate issues for improvement developed from other sources and present this integrated list to the PRC. The PRC will provide recommendations to the Executive Council
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- (EC) on the scope of issues to be addressed and which of these initiatives warrant oversight at J
l the PRC/EC level.- The EC will then select the assessment and improvement initiatives that will be described in detail in the NRC Excellence Plan, which will be periodically updated. These issues are intended to be considered as part of the normal agency planning and budgeting process, however critical issues of a more immediate nature may o' casionally be proposed that l
could result in the reprogramming of resources. The prioritiration and extent of recponse to these candidate issues will be based on considering the impact on safety, the potential for improving the ability of the agency to meet its goals, resource impact to the NRC and licensees, impact on quality of agency work, and public confidence in NRC activities. The initiatives not
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included in the Excellence Plan will either be incorporated in operating plans and considered by the PRC and EC as part of the planning, budgeting, and performance management process or, because of narrow impact er small resource implications, be implemented at the discretion of the lead office.
It is expected that most of the assessments done will be self-assessments. However, the PRC l
may recommend broader participation from other offices with the appropriate expertise in instances where a program may involve more than one office or for major efforts where a l
l degree of independence may be warranted.
l The lead responsibility for addressing the candidate issues will reside with the NRC uffice responsible for the affected program. Tne DEDE staff, or staff from other offices, may participate as part of the team addressing the issue or provide assistance in the methodology used to develop recommendations.
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An improvement team will be identified in instances where a candidate issue for improvement l
has significant implications across organizational boundaries. The improvement team will
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include representatives from affected offices, usually both management and non-management.
l The makeup of these teams and whether they function on a full-time or part-time basis will l
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FY 1998 Page5 Excellence Plan i
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U. S. Nuclear Regulatory Commission DRAFT Ongoing Efforts depend on the complexity, scope, and importance of the issue under consideration. The improvement team will develop recommendations and a plan of action for improvements based on addressing the performance gap, the difference between the "as-is" condition and the f
desired state.
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Organizational Culture improvement initiatives A significant theme developed from the excellence workshops was the realization that certain issues warranting improvement may affect many programs and be significant obstacles to enhancing effectiveness and efficiency. At three workshops with a cross section of NRC staff held during the summer of 1997, many of these issues were discussed, such as, staff empowerment, poor communications between management and staff, organizational inconsistency and parochialism, and acceptance of differing views. There was a consensus among workshop participants that it would be appropriate to conduct periodically a cultural survey of NRC employees and managers in order to identify areas for improvement and to initiate a baseline for comparison measurement. It will be necessary to achieve a broad understanding of the views of the staff and address these issues through avenues such as better communications or policy and program changes. Identifying and addressing these issues will require mechanisms to tap grass roots participation as well as interaction with the National Treasury Employees Union (NTEU).
A specdic goal and strategy were developed to address this issue. The goal is to create an environment that will promote enhanced effectiveness and efficiency of NRC activities in an open manner with the support and input of our internal and extemal stakeholder. Strategy 13 was developed to address this goal by assessing the NRC organizational culture and making recommendations for improvement.
The Office of the inspector General (OlG) also has an ongoing initiative in this area to assess NRC safety culture. As a result and as specified in the SRM dated January 14,1998, the activity on strategy 13 will be held in abeyance pending review of the results of the OlG initiative. If after 1 year from the Commission approval of the Excellence Plan the results of the OlG initiative do not dovetail with the stafrs objectives, the staff may propose to the Commission to proceed with the plans described in this strategy.
l FY 1998 Page 6 ExceIIence Plan
U. S. Nuclear Regulatory Commission DRAFT Ongoing Efforts Excellence Plan Coordination and Support The responsibility for the overall coordination, support, and promotion of the NRC Excellence
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Plan will reside with the DEDE. Specific activities in this regard willinclude developing, l
collecting, and synthesizing candidate issues for assessment or improvement, conducting workshops with the public and industry for the purpose of describing ongoing efforts and soliciting candidate issues for improvement, promoting employee awareness of the program and results, conducting or participating in independent assessments on a limited basis, and providing a resource to assist improvement teams in selecting and implementing methods for i
developing recommendations for improvement.
i The development, collection, and synthesis of candidate issues for improvement will be conducted both within the DEDE direct staff as well as the DEDE staff offices of AEOD, RES,
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01, and OE, referred to as the Regulatory Effectiveness Organization. The major roles of the Regulatory Effectiveness Organization in the implementation of the Excellence Plan will be to 4
provide coordination of the excellence program activities and to identify candidate issues for I
improvement of the regulatory framework (rules, standards, regulatory guidance and their application.) The unique expertise and independence of these offices from the day-to-day licensing and inspection activities provides an opportunity to evaluate and recommend potential improvements with a degree of objectivity. The four offices in the Regulatory Effectiveness Organization will work synergistically, through data gathering, integration of issues, and establishing the priority of issues for further examination. AEOD and RES will have major roles in this effort as evidenced by their involvement in the implementation of strategies 3,5, and 6.
AEOD will coordinate the identification of candidate issues from all sources. They will develop i
a process to synthesize this information, including insights obtained from the Accident
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Sequence Precursor program, databases of operational information, and coordination of inputs from the other offices. This process is described in more detail in excellence plan strategy 5.
Potential candidate issues for improvement will be prioritized with consideration given to cost-
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benefit analysis and regulatory effectiveness attributes such clarity, coherence, logic, consistency, reliability, and technical soundness.
I RES will assist AEOD with the identification of candidate issues for improvement of the regulatory framework as well as analyzing selected regulations to determine their effectiveness.
These activities will involve the review of the results of research, piant risk analyses (including IPE and IPEEE results and o'.her industry effortt.), generic issues, human factors information, and other agency program outputs. RES will also provide assistance with cost-benefit analysis and evaluation of regulatory effectiveness attributes in order to prioritize issues. These activities will be integrated with RES activities regarding performance based regulation, strategy 3 regarding risk informed regulation, and strategy 6 with regard to industry initiatives and adoption of consensus codes and standards.
Ol will also expand the focus of its investigation activities to identify issues that may be beyond the scope of specific investigations. This will be done in conjunction with normalinvestigative activities. This initiative would use the information gathering expertise of investigators to identify FY 1998 Page 7 Excellence Plan
j U. S. NuclearRegulatory Commission DRAFT Ongoing Efforts r
potential safety issues as well as issues pertaining to management oversight, training, organizational culture / climate, and potential areas for improving or clarifying NRC requirements.
These issues will be coordinated with the technical staff on a timely basis and be provided as candidate issues for effectiveness enhancement.
The Office of Enforcement will work closely with AEOD to ensure that enforcement data is available. OE will also focus on ensuring the consistency of both escalated and non-escalated enforcement actions, improving the assessment of both licensee and NRC performance, and identifying weaknesses in NRC requirements through the analysis of enforcement results.
FY 1998 Page6 ExceIIence Plan
U. S. Nuclear Regulatory Commission DRAFT Goals and Strategies Excellence Plan Goals and Strategies The goals and strategies described in this portion of the FY 1998 Excellence Plan were introduced in SECY-97-225, Enhancing NRC Effectiveness and Efficiency, dated October 2, 1997. They were identified primarily from ongoing major assessment and improvement activities that were considered to war. ant a high priority and a relatively high level of management oversight. This approach was intended to minimize the potential inefficiency of disrupting these important ongoing activities. However, strategies 5,8, and 13 were added and the scope of strategies 1 and 2 were modified as a result of the formulation of this plan. The 13 strategies support 3 separate goals which, in turn, support the agency's strategic and performance goals for excellence as shown in the figure.
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trategic Plan Goal:
> Carry out the NRC regulatory program efficiently and effectively Performance Plan Goals:
> Evaluate and implement needed improvements for five major NRC processes by July 1,1999
(>lri piement the agency's plan for regulatory excellence j
Excellence Plan Goal #1 Strategies 1 - 8 Improve a manageable but broad Focus on enhancing the effectiveness of the regulatory range of NRC regulatory programs, rules, standards, and framework and enhancing the regulatory guidance efficient use of nuclear materials N
)
Excellence Plan Goal #2 Strategies 7 -12 Improve the NRC's processes and Focus on enhancing the management and support functions so 4
effectiveness and efficiency of as to enhance the efficiency and the NRC staff by improving performance of the NRC staff.
(NRC processes N
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Excellence Plan Goal #3
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Strategy 13
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Create an environment that will Focuses on identifying and promote enhanced effectiveness and addressing organizational efficiency of NRC activities in an open culture issues that could manner with the support and input of (impede staff performance
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our internal and extemal stakeholder Relationship of Strategic and Performance Goals to Excellence Plan Goals I
FY 1998 Page 9 Excellence Plan t
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I U. S. Nuclear Regulatory Commission DRAFT Goals and Strategies Excellence Plan Goal #1: Improve a manageable but broad range of NRC regulatory programs, rules, standards, and regulatory guidance.
Strategies:
- 1. Evaluate the reactor inspection program to determine if it achieves its intended goals in an efficient and effective manner and make recommendations for improvement.
Phase 1 ongoing in FY98, Phase 2 to begin in FY99.
- 2. Evaluate the licensing support and regulatory oversight of the operating reactors program to determine if it achieves its intended goals in an efficient and effective manner and make recommendations for improvement.
- 3. Enhance safety decision making, make more efficient use of NRC resources and reduce burden on licensees through use of PRA insights.
- 4. Improve the medical regulatory program by modifying 10 CFR Part 35 to be more risk-informed and performance based.
- 5. Develop a process and identify candidate issues for improving the effectiveness and efficiency of rules, standards, regulatory guidance and their application.
- 6. Increase effectiveness and efficiency of the regulatory process by expediting evaluation of industry initiatives and promoting more rapid adoption of consensus standards FY 1998 Page 10 Excellence Plan
U. S. Nuclear Regulatory Commission DRAFT Goals and Strategies Excellence Plan Goal #2: Improve the NRC's processes and management and support functions so as to enhance the efficiency and performance of the NRC staff Strategies:
- 7. Assess core capability needs by comparing requirements to current availability.
Improve core competencies through recruitment, training, and development of staff and/or identification and acquisition of contractor services.
- 8. Evaluate headquarters and regional support to determine if it achieves its intended goals in an efficient and effective manner and make recommendations for improvement.
- 9. Assess the effectiveness, including integration and data sharing, ofinformation systems supporting NRC's major business areas.
- 10. Improve information systems supporting resource management (STARFIRE)
- 11. Improve information systems supporting document and records management (ADAMS).
- 12. Improve information systems supporting the reactor inspection and licensing programs (Reactor Program System - RPS)
Excellence Plan Goal #3: Create an environment that will promote enhanced effectiveness and efficiency of NRC activities in an open manner with the support and input of our internal and external stakeholder.
Strategy:
- 13. Assess the NRC organizational culture and make recommendations for improvement.
' FY 1998 Page 11 Excellence Plan
4 U. S. NuclearRegulatory Commission DRAFT Strategy 1 Details of Strategies Strategy 1 Evaluate the reactor inspection program to determine if it achieves its intended goals in an efficient and effective manner and make recommendations for improvement.
Purpose The purpose is to improve effectiveness and efficiency of both the inspection program and those processes and activities the NRC relies upon to integrate individual performance insights to arrive at an integrated view of licensee performance. This strategy consists of two phases.
Phase one consists largely of activities already underway to develop improvements to the agency's assessment processes such as Plant Performance Review (PPR), Systematic Assessment of Licensee Performance (SALP), and the Senior Management Meeting (SMM).
Lessons leamed from Millstone and Maine Yankee experience are being factored into these efforts. Because the results of this review and the resultant improvements will impact the inspection program (e.g., a decision to change the NRC's template for evaluating licensees' performance would necessitate a restructuring of the core inspection program), the evaluation of the inspection program will be completed as phase two of this excellence strategy. In the interim, changes will be made as necessary to address the findings of phase one. The purpose of the specific activities that make up phase one follows. Phase two will be further defined as phase one nears completion.
1.
Activity: Conducting an integrated review of assessment process (IRAP)
Purpose:
To evaluate the processes used by the NRC to assess the performance of licensees; to develop a revised process that is more effective, objective, efficient and produces consistent results; to eliminate redundancies; and match the process to staff resources.
2.
Activity: Improving the Senior Management Meeting process (SMM)
Purpose:
To improve the objectivity and effectiveness of the SMM process by developing improved and objective information, and meaningful performance indicators forjudging plant performance.
3.
Activity: Performing a job task analysis (JTA)
Purpose:
To perform a JTA of regional DRP inspection functions and positions to (1) identify and address problems related to task assignments and variations in regional task and function distribution; (2) identify if specific tasks are best performed on site or in the regions; (3) optimize the use of available resources; and (4) identify and develop needed training.
FY 1998 Page 12 ExceIIence Plan
i l
V' U. S. NuclearRegulatory Commission DRAFT Strategy 1 4.
Activity: Developing task specific labor rates
Purpose:
To develop task-specific labor rates to improve monitoring of program implementation.
l Approach This excellence plan strategy consists of two phases. Although some changes in the inspection program are being made in direct response to the above activities in phase one, a comprehensive evaluation of the reactor inspection program and broader recommendations to improve the structure, size, and focus of the inspection program will be developed in phase two.
l.
A better definition of the phase two activities will be avai;cble as phase one nears completion, i
The specific approach for each of the above phase one ;ctivities is described below.
4 I
188E l
The staff is using accepted process re-engineering and continuous quality improvement techniques to perform an integrated review of the assessment processes. This review will be conducted via a series of focus group sessions with NRC subject matter experts (SME) drawn from HQ, regional and resident inspection staff directly involved with the assessment process.
The first step will be to identify assessment objectives, critical activities, and boundary 1
l conditions. _The outputs, inputs, resources, communication requirements, and management systems required to support the critical activities will then be identified. Continuous quality improvement methods will be used to improve existing processes and systems in addition to developing new ones in areas where the existing processes and methods do not meet the l
identified needs.
l At the direction of the Commission, the staff began efforts to improve the objectivity, consistency, and scrutability of decisions made at the SMMs. The first phase of the effort was completion of a study of the existing process by a consultant (Arthur Andersen Consulting).
l
' After Arthur Andersen's report was issued on December 30,1996, the staff provided the -
l Commission its plan for improving the timeliness and thoroughness of this piece of the
. assessment process (SECY-97-072). Recommended improvements focus on making the SMM process more objective and scrutable. Specific activities include: (1) a trending methodology that will be a numerical representation of integrated plant performance based on a variety of indicators; (2) improvements to the SMM nuclear power plant performance evaluation template; j.
(3) development of objective criteria to be used in conjunction with the template to support SMM decisions; (4) development of leading indicators of licensee management and operational effectiveness; (5) development of economic indicators; and (6) development of a structured and consistent approach for presentation of information at the SMM.
JTb i
FY 1998 Page 13 ExceIIence Plan l
r-
U. S. NuclearRegulatory Commission DRAFT Strategy 1 The JTA involved all four regions and the technical training center (TTC) in Chattanooga, TN.
The JTA analyzed the five primary positions in the regional divisions of reactor projects (DRP):
senior resident inspector, resident inspector, project engineer, branch chief, and division director. A traditional job task analysis approach was used for developing a task list and gathering initial data. The overlap in functions and tasks, and the variety of arrangements in different regions, also required that a functional analysis be incorporated into the JTA. The traditional JTA approach was augmented by the use of a gap analysis that combined satisfaction measures with frequency, importance, and difficulty of the tasks to identify tasks or functions requiring further diagnosis. The project also incorporated a limited amoun; af activity-based, on-site observations, or " shadowing," as a means of (1) gaining additional insights, (2) assessing the "value added" in performance of certain tasks, and (3) supplementing the JTA survey information. The final report is being reviewed by a group consisting of regional, NRR, TTC, and Office o' Enforcement (OE) representatives. This review will identify recommended agency actions with priorities assigned.
Labor Rates To improve monitoring of program implementation, the staff is working to define and establish task specific labor rates applicable to the reactor inspection and performance assessment processes, including regional work activities. This work will allow calculation of the number of work items expected for a given amoun;.)f budgeted resources (FTE and program support dollars). Definition of labor rates will consider budget subactivities, functional work categories, or a combination of both. Budget subactivities include power reactor inspections, allegation follow-up, laboratory / technical suppod, and licensee performance assessment and oversight such as SALP, PPR, and SMM. Functional work categories include direct inspection effort (further divided into core, regional initiatives), inspection preparation and documentation, training, administration, and leave. Different labor rates may be needed to account for differences in operating reactor performance. Labor rates will be calculated by comparing actual hours data (from RITS) against work item completion data (from SINET systems then RPS upon deployment). It is planned that FY 1996 and 1997 data will be used to establish and validate labor rate data for trial use in monitoring FY 1998 performance. Full implementation is planned for FY 1999.
Criteria for Measuring Success The integrated assessment, SMM improvement and the JTA are all assessments of the current processes to determine the needed improvements in NRC's inspection and assessment of licensee performance. These activities share some common qualitative measures of success consisting of: (1) development of improved, objective performance indicators to be used as a basis forjudging plant performance; (2) a scrutable and repeatable process that produces consistent results with the same data base; and (3) a process that is transparent to the customers and the stakeholder and produces timely decisions with a level of resource expenditure below the current level. Specific measures of success for each activity are defined as follows:
FY 1998 Page 14 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 1 l!EP_
l Implementation of the revised process will result in 10 percent FTE savings below the existing process.
The new assessment process must lead to timely decisions based on current data. All data greater than 45 days old must be considered when decisions are made. Data less than 45 days old should be considered if significant..
The new assessment process must be accurate. The number of substantiated changes to NRC assessment of licensee performance based on licensee appeal should be less than 10 percant.
SMfd The performance trend methodology and assessment criteria will be validated against l
some known standard or other assessment model such as degree of correlation with historical SMM discussion plants or another standard or model not yet determined.
The performance trend methodology will minimize false positives and missing l
candidates plants (no more than 10 percent error).
l Improvements to the SMM process, including the performance trend methodology and assessment criteria, are generally accepted by the outside stakeholder.
JIA
. The validity of the data collected by the JTA was assured by full participation of the regions throughout the JTA process and the large response (averaging 72 percent) to the initialjob task surveys.
The JTA results and recommendations will be validated through reviewing the final report by a group of knowledgeable, experienced personnel from the regions, HQ and L
the TTC. The group must find at least 80 percent of findings and recommendations to i
be valid for the JTA effort to be considered successful.
Criteria for successful implementation of recommendations will be determined after the recommendations are selected for implementation.
I Labor Rates L
The success criterion will be validation of the projected rates by the actual rates (rates developed from the actual expended resources).
Stakeholder involvement ifMP_
The IRAP effort will involve both internal (NRC staff) and extemal (industry, public) stakeholder. The staff conducted a public meeting to solicit early input to the IRAP from extemal stakeholder. In addition, the staff will seek public comments after a draft of the new FY 1998 Page 15 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 1 assessment process concept is prepared. The staff will review all stakeholder comments and revise the process, as necessary, to address valid concems before submitting it to the Commission for their final approval.
. Ir,temal stakeholder include NRR, AEOD, OE, OPA, RES, and the regions. They are involved directly in the IRAP effort. In addition, intemal stakeholder will be trained in the new assessment process before it is implemented.
SMM The SMM improvement process will involve both intemal (NRC staff) and extemal (industry, public) stakeholder. The staff conducted a public meeting to solicit early input from the extemal stakeholder. The industry will have an opportunity to respond during the staff presentation to the ACRS. The staff will review all stakeholder' comments and revise the process, if necessary, to address valid concems.
Intemal stakeholder include NRR, AEOD, OE, RES,01, and the regions. The stakeholder are involved directly in the SMM improvement effort. As improvements to the SMM information base are implemented, appropriate guidance and training wil! be provided to respective stakeholder.
I E6 i
Regional DRP personnel have oeen an integral part of the JTA at each stage of the process.
The JTA effort centered on use of panels of SMEs, which consisted of representatives from all the regions in all of the DRP positions that benefitted from an SME group, throughout their analysis. All DRP personnel had an opportunity to participate when the initial survey for collecting the raw data on the functions and tasks was sent to all persons in the associated positions.
For the cum nt effort, representatives from all four regions, the TTC, OE, and NRR are involved in reviewing the JTA results and are key participants in recommending the actions the agency should pursue.
Schedule and Milestones IB6P_
Define IRAP and assemble integrated review team 9/97 (C)
Finalize facilitatory contract 9/97 (C)
L Perfona integrated review
- Focus group meeting #1 10/97 (C)
- Public meeting 11/97 (C)
- Focus group meetings 11/97 thru 2/98 (C)
FY 1996 Page 16 Excellence Plan L
j.-
t I
t]. S. NuclearRegulatory Commission DRAFT Strategy 1 Finalize results 4/98 Publication for industry and public comments 5/98 Provide final recommendations to the Commission 10/98 Devalop implementing precedure / train personnel 10/98 Implement new assessment process 1/99 1
E i
j Develop preliminary trending methodology data 10/97(C)
)
l Develop economic indicators 10/97(C) l Revise SMM nuclear po.vor plant performance evaluation template and provide guidance to the regions on its use 10/97(C) l Commission paper on the staff's final recommendation l
for use of various indicators and tools 7/98 l
Award JTA contract to LANL 4/96 (C) l Data collection and analysis 7/97 (C)
Final report from contractor 8/97 (C) l Review final report and validate results 12/98 Recommend actions to NRC management 3/99 l
Begin implementing recommendations 6/99 Laha Rates l
_ Develop labor rates for inspection and performance assessment 3/98 i
Regional staff review and comment resolution 6/98 l
Analysis refinement 9/98 l
Fullimplementation 10/98 We plan to complete the review : ortcon of phase two by 3/99. Implementation will depend upon the scope of the changes identified but are not expected to take less than six months.
. Resources h '
1 The resources for the IRAP effort havn been budgeted and include 5.0 FTE and $229K. The
. majority of these resources will be expended in FY 1998, witn a small percentage being expended during the first quarter of FY 1999. To pass the success criteria, the new i
l assessment process has to be imple,m ented below the current level of resource expenditure.
Resources for the SMM improvement hetivities have also been budgeted and include 5.5 FTE and $460K.' These resources will be e xpended in FY 1998.
Resources for the JTA included $500K and approximately 0.5 FTE for the analysis of regional DRP positions (completed 8/97). The review of the analysis report will cost approximately FY 1998 Page 17 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 1 another 0.75 FTE. The resources needed to implement the recommended actions will be determined as part of the implementation effort.
l Staff resources for labor rate development is estimated at 0.4 FTE in FY 1998 for the development and validation efforts. Ongoing resource requirements for data analysis are estimated at 0.1 FTE per year.
Cost-Benefit Considerations While the costs associated with conducting the various activities (identifying necessary changes, implementing revised processes) are expected to be moderate (approximately 12 FTEs) and short term (one to two years), the potential benefit may be substantial. IRAP, JTA, and SMM improvements will result in direct staff savings through effectiveness obtained by eliminating redundancies and discontinuing activities that provide marginal safety benefits.
Similarly, these activities are expected to result in less financial cost to the licensees. More importantly, they will provide for greater effectiveness of the inspection and assessment processes evidenced through improved recognition of issues before they become significant problems, clearer communication of performance concems to the licensee and the public, and increased regulatory focus on performance issues that present the most risk to safety.
Improvements in the NRC inspection and assessment programs will address the need to assure appropriate regulatory emphasis is placed on the licensees that presents the most risk to safety.
Luad Office Staff and Staff from Supporting Offices IRAP Lead office / program manager NRR Supporting offices Regions, AEOD, OE, RES, and OEDO Contractor LANL SMM Lead office for developing improvements AEOD Lead office forimplementation NRR Supporting offices NRR, RES, regions J.Th Lead office / Program manager NRR Supporting offices Regions, OE, TTC Contractor LANL Labor Rates Lead office for the development of the methodology NRR Lead offices for implementation NRR, Regioris Supporting offices during development of methodology Regions FY 1998 Page 18 ExceIIence Plan
U S. NuclearRegulato/y Commission DRAFT Strategy 1 Figure ia-Improve inspection Program o
Enhance NRC Effectiveness Enhance Efficient Use E
of NRC Resources (Senior Management Meeting)
)N
)N
[ betegy Outputs) + (Program Outputa]
(Strategy Outputs)+(Program Outputs)
Revised guidance on Risk informed and FTE projection for input for inspection budget
. screening /SMM 8/97C performance based future program assessment of plants by activitses Master inspection Plan Pro / Con charts & PPR NRC senior managers (Tle to Strategy 7)
Executive Summary 9/97C
$ Standard format for SMM plant
)
S performance discussion 12/97C l
3 O
Revised PPR guidance to incorporate SMM template 10/97C issue guidance on full use of SMM improvements and incorporate use of method in revised process that results from IRAP j
l AN AN AN
)N r
, Regulatory Activities Strategy Developmental Regulatory Activities r
Strategy Developmental
<A ctivities and Programs
, Activities
<and Programs s
Pubbsh template / trend Trial use of economic data Spread sheet for 1998 tabor inspect.on Planning
! (method for pubhc comment and trend models in plant rates (3/98)
Process 4/96) assessment screening (The to strategy 2)
(The to Strategy 3) g meetings (ongoing) o Commission approval of staff E acten plans in response to Periodic senior Spread sheet for 1997 data g Arthur Anderson (6/97C) management meetings (3/98)
(Tse to stratesy 3)
(Tie to stratesy 2)
,3 Maine Yankee / Millstone g lessons learned (ongoing)
Validation of 1997 spread
=
sheet with 1996 data (4/98)
J Develop trend method /
(Tle to Strategy 2) economic indcators (9/98)
D*
Benchmark /vahdation of new methodology (7/98)
I Commir,sion paper on final E
proposal (7/98)
FY 1998 Page 19 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 1 i
Strategy 1b-Improve inspection Program Enhance Efficient Use of Enhance NRC Effectiveness C escurces 0
(Integrated RetAew of Assessment Process)
(
pob TasunaWis) j Mk Mk
[ Strategy Outputs) 4 (Program Outputs) htrategy Outputs )--)- ( Program Outputs)
Revised Management implementation of implementation of Redefine jobs and Directives 8.6,8.13,8.14 revised assessment appropriate JTA requalifcation 3a process for reactor recommendations S Revised inspection licensees Conduct additional y Manual Chapters (MC)
Revised position training as needed 0304,2515. and 0610 Conduct of initial descriptions and assessment elements and standards Training on ne v or of regionalinspection revised process Assessment results with staff actions forwarded to (Tle to Strategy 7) licensees Revised inspection staff training AN AN AN AN Strategy Developmental] ' Regulatory Activities)
Strategy Developmental Regulatory Activities
. Activities J <and Programs J
, Activities
,and Programs IRAP team focus groups Plant specific JTA contract 4/96C Implementation of the e
E established 2/98C application of integrated regional reactor
[
Review and Conduct JTA inspection program o
Maine Yankee / Millstone Assessment E
lessons learned (ongoing)
Final contractor report as 8/97C e
Development of j
preliminary concept (4/98)
Develop and implement g
(Tle to Strategy 3) recommendations v*
Benchmark and validate b new process (7/98) 2 j
Public coinment on new e assessment process j
(7/98)
Provide final recommendations to Commission (10/98)
FY 1998 Page 20 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 2 Strategy 2 Evaluate the licensing support and regulatory oversight of the operating reactors program to determine if it achieves its intended goals in an efficient and effective manner and make recommendations for improvement.
Purpose The licensing support and regulatory oversight of operating reactors is a major function of NRR that is currently being assessed primarily as a result of lessons leamed from problems identified at Millstone and Maine Yankee Nuclear Stations. Phase 1 of this initiative will focus on improving the effectiveness and efficiency of the licensing support and regulatory oversight of operating reactors. Specific activities are (1) the continued implementation c.f the Associate Director for Projects Process improvement Plan, (2) the formalization of the icensing oversight function, and (3) use of a contractor to assist staff in assessing performance. Phase 2 will focus on developing improvements in the effectiveness and efficiency of the licensing area.
Approach The first phase of this effort will focus on the completion of assessment and improvement activities already ongoing in this program area. Following completion of these activities and determination of the as-is conditions described in the criteria section below, a second phase of this effort will involve broader recommendations to improve the effectiveness and efficiency of this program.
In response to concems raised at Millstone and Maine Yankee, the Office of Nuclear Reactor Regulation (NRR) formed several task groups to assess the lessons leamed, to identify problems or deficiencies in NRR's programs, and to make recommendations for NRR's programs and processes to permit earlier identification of similar issues if they arise at other plants.
To address concems regarding the NRC's licensing process that were raised at Millstone, and Maine Yankee, NRR established an Associate Director for Projects (ADP) Process improvement Plan (PIP). The ADP PIP is presently an ongoing system for addressing improvements in the 6ensing process and encompasses the Millstone-Maine Yankee lessons leamed that apply to the project management area. As additional items are identified, they are added to the ACP PIP for tracking, and individuals and due dates are assigned to develop the guidance training, or other appropriate actions. As a result, the ADP PIP currently identifies a total of 156 action items, of which more than 100 are completed and a number of others are in final concurrence. Three of the more significant activities on the ado PIP are addressed below.
1.
NRG Commitment Manaaement Procram:
As described in SECY-96-135, the staff is reviewing options to modify its processes to FY 1998 Page 21 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 2 clearly identify those licensee commitments that the staff relied on to make regulatory decisions for licensing actions. The staff is also reviewing appropriate mechanisms for following up on licensee commitments and NRC requireme'nts, determining the appropriate office to conduct the verification, and communicating between NRR and the regions for follow-up verification. The management of commitments made to the staff in licensing activities and to the regions will be addressed in the future.
- 2. '
Ligan_see Commitment Manaaement Proaram Audits:
The staff is auditing 8 licensee programs for implementing commitments and managing subsequent changes to commitments made to the NRC. In 1995, the NRC accepted a guidance document prepared by the Nuclear Energy institute (NEI) for managing changes to commitments made to the NRC and the audit will determine the success of that industry initiative. The results of the pilot program and audits, in coordination. with related activities pertaining to 10 CFR 50.59 and 50.71(e), will be assessed to determine the stafs future recommendations and actions related to improving both the industry's and NRC stafs handling of commitments. The stafs recommendations will be presented to the Commission for resolution of related policy issues.
3.
Job Task Analvsis:
As part of the overall drive towards regulatory excellence, and carrying out the Agency's mission, a job task and functional analysis (JTA) was initiated to reassess the roles and responsibilities of the headquarters Divisions of Reactor Projects (DRP). The objectives of the NRR DRP JTA are to evaluate the tasks performed by Headquarters Divisions of Reactor Projects personnel, and to analyze and present the data so that the following tasks may be accomplished: (1) identify various job and training requirements, (2) update management expectations for adequate job performance, and (3) provide a basis for comparing actual to desired performance. Following the recommendations from the NRR DRP JTA, it is expected that training will be identified for DRP personnel, and qualifications will be established. Additionally, position descriptions and elements and standards will be reviewed and revised, as necessary. The JTA is being conducted by Los Alamos National Laboratories (LANL) and involves both headquarters Divisions of Reactor Projects.
In addition to implementation of the ADP PlP, Phase 1 of this initiative also includes the stafs efforts to formalize the licensing oversight function to evaluate the effectiveness and implementation of the licensing program for commercial reactors and other NRR programs.
The activities formalized in this functional area will. include developing and reviewing licensing program policy and guidance, evaluating the implementation of the licensing program, obtaining j
feedback on the impact of NRC activities on licensees, and assessing the overall effectiveness of the licensing program. These functions are analogous to the functions currently performed in the oversight of the inspection program. In addition, the licensing oversight function will include assisting in monitoring and assessing the goals and performance measures established in the
}
Division of Reactor Projects East / West Operating Plans. Further, the staff is pursuing the use FY 1998 Page 22 ExceIIence Plan a
U. S. NuclearRegulatory Commission CRAFT Strategy 2 of contractor services to assist the staff in evaluating its current practices for planning, budgeting, monitoring, and assessing whether performance goals are being met, and in performing self-assessments of the planning and budgeting process.
Criteria for Measuring Success Process improvement issues (Phase 1 activitiesh 1)
Implementation of the ADP PIP:
There are currently 156 separate action items identified on the ADP PIP. These activities share a common qualitative measure of success, namely, improvements in the licensing process. Specific measures of success for three of the more significant action items are identified below.
a)
NRC Commitment Management Program Completion of the remaining action items associated with this program by the second quarter of 1999 b)
Licensee Commitment Management Program Audits l
Completion of 8 audits within established schedule Coordination of findings with other licensing basis initiatives and presenting l
recommendations to Commission by established schedule j'
management oversight into routine inspection program, development of Implementation of follow-up activities such as incorporation of commitment regulatory guidance, or promulgating rulemaking c)
Job Task Analysis of ADPR Project Management Completion of job task analysis within time frames established by contract i
Receipt of results from contractor's efforts sufficient to develop a list of recommendations for staff actions, including Recommendations sufficient to develop Headquarters Division of Reactor Projects training requirements and qualification Update of management expectations for adequate job performance Revision, if appropriate, of position descriptions and elements and standards of licensing assistants and project managers 2)
Formalization of licensing oversight function Licensing oversight function established, with clear duties and responsibilities l
formalized and documented.
3)
Use of Contractor Assistance Selection of qualified contractor Receipt of appropriate plans for conducting a review and analysis of NRC's and NRR's planning, budgeting, and performance management process Two staff trained in assessment techniques Program Assessment Manual prepared for staff use FY 1998 Page 23 ExceIIence Plan
r l
l U. S. Nuclear Regulatory Commission DRAFT Strategy 2 Licensina Goals (addressed in Phase 2h Complete 1200 licensing actions in FY98 and 1500 licensing actions in FY99; size of the inventory will be 1500.
Complete 600 other licensing tasks per year in fy98-99.
Issue revised guidance (office letter) on prioritization of work activities in NRR (target date - 5/98)
Evaluate conduct of an assessment, by an experienced contractor, to determine if reactor licensing program achieves the desired goals in an efficient and effective manner and whether the activities in the program should be continued, modified or sunset.
Meet overall age goals:
80%<= 1 year old 95%<= 2 years old and 100%,= 3 years old (note: NRR is evaluating whether this timeliness goal should be modified)
Count documents needing revisions after issuance because of administrative, technical or legal errors and review a 1-2% sample of completed actions and activities by a peer panel for overall quality Strive to complete 85% of docket specific controlled correspondence by the assigned due date Strive to complete 90% of the 10CFR2.206 petitions within 120 days from the acknowledgment letter Strive to achieve a median age of the 10 CFR 2.206 petition inventory at or below 4 months, assuming about the same recent historical level of incoming petitions Strive to complete 75% of the responses to regional Task interface Agreement (TIA) requests within 6 months of receipt Strive to improve the median age of the TIA inventory to 6 months, assuming about the same recent historical level of incoming TIAs Stakeholder involvement During the development of many of the assessment and improvement activities that were already ongoing in this program area, a number of stakeholder were and continue to be consulted. Stakeholder include NRC program offices, the regions, the NRR Labor-Management Partnership Committee, the public, power reactor licensees, the Nuclear Energy Institute, and the AEOD technical training center. Working groups have been utilized when appropriate during the development and review of program activities, and peer review panels have been and will continue to be utilized. Workshops have been held intemally with appropriate groups to gain additional information, and to disseminate information.
FY 1998 Page 24 Excellence Plan
U. S. Nuclear Regulatory Commission DRAFT Strategy 2
. Schedule and Milestones 1)
Implementation of activities on the ADP PIP:
Dates and rr ilestones are as delineated on the ADP PIP (there are currently 156 separate action items, with 107 complete as of March 3,1998). Schedules and milestones for three of the significant activities are addressed below, i
a)'
- Implementation of NRR Commitment Management for licensing actions:
Issuance of interim guidance on commitment management April 30,1998 Issue generic communication on staff actions on commitment May 30,1998 management Issuance of final guidance as Office Letter on commitment October 30,1998 management incorporating staff and public comments b)
Audits of licensee commitment management program:
Completion of about 8 audits of licensee commitment May 30,1998 management programs Provide findings and recommendations to Commission August 31,1998 c)
Award JTA contract Complete Completion of Job Task and Functional Analysis June 30,1998 and submittal of JTA final report by contractor Revision, if appropriate, of position descriptions and January 30,1999 elements and standards for licensing assistants and l
Project Managers Development of Headquarters Divisions of Reactor Projects October 30,1999 training requirements and qualification joumal.
2)
Formalization of licensing ovcsight function:
Licensing oversight function established, with clear July 1,1998 duties and responsibilities formalized and documented.
3)'
Use of Contractor Assistance to assist staff in assessing l'
performance l
Award contract April 1998 Completion of Task i of Contract June 1998 Implementation of Plans from contract TBD f
FY 1996 Page 25 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 2 Resources The total resources currently budgeted for this work are $366 K and 3.7 FTE in FY 1998 and 2.6 FTE in FY 1999. The resources to conduct the efforts of the job task analysis and some of the ADP PIP have been budgeted in the NRR Budget. Implementation of the NRR/ADP process improvement plan for the licensing area is budgeted for 1.0 FTE in FY 1998 through FY 2001. Also,1.3 FTE is budgeted in FY 1998 and 1.1 FTE in FY 1999 through FY 2001 to continue to implement a controlled correspondence, task interface agreement, and licensee commitment tracking and response systems and development of project manager qualifications training. The conduct of about 8 audits of licensee commitment management programs is expected to take approximately 0.83 FTE in FY 1998. Depending on the results of the audits, additional staff work may be required, including rulemaking. At the completion of the audits, the staff will report the results of its efforts / audits to the Commission, with recommendations for further actions. Resources for further actions are not budgeted at this time.
The conduct of the NRR DRP JTA by LANL is budgeted for $366,000 and approximately 0.6 FTE in FY 1998. The review of the JTA report will take approximately an additional 0.5 FTE over a four month period in FY 1999. The resources needed to implement any recommendations or actions will be determined as part of the implementation efforts.
The Office of the Chief Financial Officer is in the process of obtaining a contractor to provide consultation and implementation assistance to the NRC initiative to implement a Planning, Budgetine and Program Management process. A primary focus of this effoort is to provide assistanc in the area of program assessment and evaluation. Additional funds, to obtain assistance under this contract, will be needed to ascess NRR programs and activities (see.
milestone schedule item 3.) The OCFO will make funds available for this work.
Cost-Benefit Considerations The analysis of headquarters DRP positions under the JTA is expected to cost the NRC
$366,000 and approximately 0.6 FTE, and the review of the analysis is expected to cost an additional 0.5 FTE. The JTA and implementation of its recommendations is expected to improve the efficient use of headquarters licensing personnel.
The Consolidated Operating Plan for the Licensing Area reflects the continuation of the implementation of the ADP PIP, including developing the commitment management program l'
and conducting about 8 audits of licensees' commitment management programs. The continued implementation of the action items on the ADP PIP is expected to improve the effectiveness of the integration of the licensing and inspection programs, and the efficiency and effectiveness of licensing programs.
Lead Office Staff and Staff from Supporting Offices l
l The NRR individual managing the overall ADP Process Improvement Plan and all its action items, including the Millstone-Maine Yankee lessons leamed efforts for the licensing area is Cindi Carpenter, DRPW/NRR. These action items include the commitment management l
l FY 1998 Page 26 ExceIIence Plan l
l
l U. S. NuclearRegulatory Commission DRAFT Strategy 2 l
program, audits of the licensee's commitment management program, the NRR DRP JTA, and the NRR Office Letter on workload priorities. The lead project manager on the commitment maragement program is Jack Donohew, DRPW/NRR. The lead project manager on the audits l
of the licensee's commitment management program is Bill Reckley, DRPW/NRR. Jon Hopkins, j
DRPW/NRR is the lead project manager on the NRR DRP job task analysis.
i j
ADP/NRR has the lead for formalizing the licensing oversight function. Roy Zimmerman, NRR, has the lead for use of a contractor to assist the staff in assessing performance.
Staff assist from supporting offices include:
l NRR Labor-Management Partnership Committee National Treasury Employees Union
- Chief Financial Officar and Chief Information Officer i
i l
FY 1998 Page 27 Excellence Plan L__-__.--__-____-----_________-
U. S. Nuclear Regulatory Commission DRAFT Strategy 2 Figure 2a-Imorove Licensing Program Enhance NRC Effectiveness.
' Enhance NRC Effectiveness E
Enhance Efficient Use of NRC Resources Enhance Efficient Use of NRC
{ Associate Director for Projects Process Resources Improvement Plan) y
( (Licensing Oversight Function) j
(
o JL k
( Strategy Outputs } --> [ Program Outputs)
(Strategy Outputs) --> [ Program Outputs)
Updated, consolidated, Enhanced regulatory Documentation of Formal and continuing and ongoing Project oversight of the licensing licensing oversight oversight and evaluaten Management guidance program function within ADP of reactorlicensing (7/98) program
- Futy revised Project Consistency in licensing Manager Handbook program Documentation of
~3 avalletple on intamal duties and homepage (5/97C) improved staff responsibilities 3
i.
S
- Periodic changes to quellAcetions associated with O
Project Manager oversight function
.Handtmok Setter definition oflicensing within ADP (7/98) role
- I*
"* 8 Enhanced regulatory 8* *"**
decisions New and clartfled inspechon guklance Staff trained on licensing issues Promulgation of management expectations PM/PD Advisory Panel -
and charter established (6/96C)
Jk
~Jk JL M
' Strategy Developmental Regulatory Programs Strategy Developmental Regulatory Programs'l Activities and Activities Activities and Activities J
,m l Sately Assessment Team Maine Yankee independent Implementation of Reactor Assess need for consolidated implementation of Reactor e
Licensing Program and formaltred oversight of Licensing Program 2 Inspection (Tle to Strategy 3) licensing program (Tle to Strategy 3) a.
as Millstone specialinspecton impiomantetion of Reactor Develop licensing oversight e efforts and lessons loamed inspection Program functions and resource j
(Tio to Strategy 1) requirements within ADP
> Assess existing guidance, 8 processes and polices Develop and formatro clear j
duties and responsibilities to g Develop new and clarify effect implementation of g existing gueence, processes licensing oversight function and pohceu g
a. Establish PM/PD Advisory j Panoi and charter IIOTE: The Associate Director for Projects (ADP) Process improvement Plan (PIP) is an ongoing system for addressing improvements in the licensing process and currently includes over 150 separate items. The 6ctivities and outputs depicted are generica5f applicable to the individualitems. Figuras 2t (and 2c represent three of the more signincant activities include 1 on the ADP PIP.
j FY 1996 Page 28 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 2 Figure 2b-Improve Licensing Program I
Enhance NRC Effectiveness I
Enhance NRC Effectiveness Enhance Efficient Use of NRC Resources Enhance Efficient Use of NRC Resources 3
(Licensee Commitment Management L(NRC Commitment Management Program)>
f
(
Program Audits) j t
t (Strategy Outputa) -->- ( Application Outputa) ( Strategy Outputs )
4 (Program Outputs)
NRC endorsement of Enhanced regulatory interim guidance on ISTS Established process for industry guidance on decisions relocation (2/g7C) regulatory oversight of commitment licenses commitments management (96C)
Resolucon of related Interim guidance on irnportant to regulatory
.5 policy issues commitment management decisions c6 NRC audit procedure E
(incorporates results of pilot program)(4/98)
Consistency in treatment of O identification of 8 plants licensees' commitments to be audited (2/98C)
WISP operational to track made in licensing actions licensee commitments in Complebon of 8 audits licensing actions (5/98)
Final guidance on Recommendations to commitment management Commission (8/98)
(issued as Office Letter and incorporates public comments)(10/98)
Staff trained t
t t
^
r
,r r
Strategy Developmental Regulatory Programs Strategy Developmental Regulatory Programe g
Activities and Activities Activities and Activities a
Regulatory Review Group implemer.tation of Reactor Maine Yankee inds perwient miplementation of Reactor o
recommendation to review Licensing Program Safety Assessment Tehm Licensing Program m.
licensee commitment (Tie to Strategy 3) inspection (Tle to Strategy 3) as management program e
implementation of Reactor Millstone specialinspection implementation of Reactor j
Assess industry guidance on inspection Program efforts and lessons leamed inspection Program managing commitments to (Tle to StabN 1)
(Tle to Strategy 1) m NRC Modify the NRR Workload y
information and Scheduling Develop pilot study to audit Program (WISP) to track and h licensees'implementabon of report licensee ccomitments commitrnent management that are relied upon for j
program regulatory decisions (C) m Review results of audits and Develop interirn staff develop recommendabons commitment management guidance Conduct pilot program (C)
Solicit public comment on interim staff commitment management guidance (6/98)
Develop final staff commitment management guidance Develop staff training FY 1998 Page 29 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 2 l
Strategy 2c - Improve Licensing Program 3
Enhance NRC Effectheness E
Enhance Efficient Use of NRC Resources (Job Task Analysis) j
(
jk l
( Strategy Outputs)
> ( Program Outputs )
implementation of appropriate JTA Improved staff qualirscations recommendations Enhanced clarification of PM/LA/PD l
Revised (as appropriate) headquarters duties and responsibilities i
5 DRP position descriptions and elements
)
s and standards (1/99)
Consistency in headquarters DRP l
functions among divisions and Project j
in-place headquarters DRP training directorates requirements (10/99) 1 Updated management expectations for adequate job performance Basis for comparing actual to desired performance l
t
)
l Jk A
i'
\\
l I
e
( Strategy Developmental Activities )
Regulatory Programs and Activities l
Perform JTA with contractor assistance Enhanced implementation of project
- Issued JTA contract (97C) manager oversight
- Complete JTA (6/98) g
- Final contract on report (6/98)
(Tie to Strategy 7)
,sy Evaluate JTA recommendations and findings g
(TBD)
Develop headquarters DRP training g
requirements (rBD)
E' a
l l
FY 1998 Page 30 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 2 l.
l Figure 2d -Improve Licensing Program i
e*
r E
More Efficient Use of NRC Resources, (improve Planning and Budgeting Process) o g
(
(
(Strategy Outputs,
( Program Outputsj l
g FTE projection for future program activities input for licensing program budgets I
(Tie to Strategy 7) a3 Identification of resource shifts j
Rebaseline of current priorities Enhanced method of tracking programs Contractor developed plan for assessment of of office planned accomplishments selected NRR programs (budget vs. actual)
Selected staff trained in assessment Predictions of future accomplishments techniques based on allocated resources and linking to Strategic Plan / Performance Plan Selected imprcrements to NRR processes including self-assessment capabilities I
A A
J (Strategy Developmental Activities)
( Regulatory Activities and Programs) g 2{
Budget Process improvement Efiort Iicensing program planning process a.
(5/g7) inspection program planning process Reviewing process for prioritizing (Tle to strategy 1) e2 staffworkload f,
(Tie to Strategy 1)
Program plan and operating plan development 4
Selection of contractor to evaluate D
staff practices to meet performance j
goals (4/g8)
- e; I
FY 1996 Page 31 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 3 Strategy 3 Implement risk-informed regulation. Use risk insights to (a) enhance safety decision making, (b) make more efficient use of NRC resources, and (c) reduce burden on licensees.
Purpose The NRC established its regulatory requirements to ensure that nuclear facilities can be operated and nuclear materials can be used without undue risk to the health and safety of the public. These requirements are largely based on deterministic engineering criteria, involving the use of multiple barriers and application of a defense-in-depth philosophy. Beyond its deterministic criteria, for commercial power reactors, the NRC has additionally formulated guidance, consistent with the intent of the Safety Goal Policy Statement, that utilizes quantitative, probabilistic risk measures to supplement the traditional engineering approach to decision making. Also, the Commission has been using PRA in performing regulatory analyses for backfit of cost-beneficial safety improvements at operating reactors (as required by 10 CFR 50.109) for a number of years.
The application of PRA to nuclear regulatory activities has evolved with improvements in PRA techniques and data bases. PRA techniques can be used to derive valuable insights, perspectives, and general conclusions as a result of the integrated and comprehensive examination of the plant design and operation and a structured examination of plant and operator response to events. For a nuclear power plant, a plant-specific PRA can be used to derive plant-specific insights and conclusions, where appropriate. PRA studies are particularly useful in focusing designers, operators, and regulators on important aspects of design, operation, and maintenance.
The Commission has considered recent improvements in nuclear technology and accumulated experience with risk assessment methods, and concluded that increased use of these techniques as an integral part of the regulatory decision-making process is now justified.
Consequently, in its policy statement, "Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities"(60 FR 42622, August 16,1995), the Commission adopted the policy that the use of PRA should be encouraged and the scope of PRA applications in nuclear regulatory matters should be expanded to the extent supported by the state-of-the-art methods and data. The successful implementation of this effort will result in enhanced safety decision making, more effective and efficient use of NRC resources, and reduced burden on licensees.
Approach An Agency-wide plan was established in 1994 to provide the necessary interoffice framework for strengthening and increasing the use of PRA technology in agency regulatory activities. The plan, referred to as the PRA implementation Plan, integrated the efforts of NRR, NMSS, AEOD, and RES into a coherent approach to expand the use of PRA within the agency. The plan has generally focused on improving regulatory decision making through the use of risk insights, improving the quality and availability of data used in developing risk insights, developing consistent and technically adequate methods for conducting risk analysis, and providing the FY 1998 Page 32 Excellence Plan i
9 U. S. NuclearRegulatory Commission DRAFT Strategy 3 necessary training to the staff on PRA methods and statistics. The PRA implementation Plan has grown into a multi-office, integrated effort that tracks many of individual items with the overall goal of improved regulatory decision-making, more efficient use of agency resources in focusing efforts on the most safety-significant issues, and reduced industry burden in responding to less safety-significan' issues.
The efforts of this strategy capitalize on the PRA Implementation Plan, a plan that implements the Commission's PRA Policy Statement and establishes a foundation for risk-informed regulation. The Office of Research has the lead and is the central point of contact for the plan, however, RES, NRR, AEOD and NMSS are responsible for key tasks. This strategy focuses on those tasks in the PRA imp!ementation Plan that will improve NRC decision making capability and clarify regulatory guidance on the application of risk insights. This would include innovative ways for developing and using risk insights, the development of Regulatory Guides, and the development of a revised Standard Review Plan sections. The following specific tasks are considered part of this strategy:
1.1 Develop Standard Review Plans for risk-informed regulation 1.2 Pilot Application for Risk-informed Regulatory Initiatives 1.7 -
Regulatory Effectiveness Evaluation 2.1 Develop regulatory guides for risk-informed regulation 2.4 Methods development and demonstration 2.7 NEl initiative to conduct "whole plant" risk study 2.8 PRA Standards Development i
2.10 Safety Goal revision 3.4 Risk-based performance indicators 3.6 Staff Training 4.1 Validate-Risk Analysis Methodology developed to assess most likely failure modes and human performance in the use of industrial and medical radiation devices 4.2 Continue use of risk assessment of allowable radiation releases and doses associated with low-level radioactive waste and residual activity.
l 4.3 Develop guidance for the review of risk associated with waste repositories.
4.4 Risk assessment of material uses 4.5 Framework for use of PRA in regulating nuclear materials i
5.1 Regulation of High-Level Waste 5.2 Apply PRA to spent fuel storage facilities 5.3 Continue use of risk assessment in support of radioactive material transportation The staffs progress on these i+ ems furthc :n oken down into subactivities, is reported to the Commission every quarter. The mot,1.% cent progress report, SECY-98-012, was dated January 23,1998. The details of this plan will not be repeated in this document.
l Criteria for Measuring Success The application of the activities in the PRA implementation plan is broad, effecting nearly every aspect of the agency's interaction with its licensees. The criteria for measuring success and evaluation of the outcomes of the individual activities planned and accomplished under the PRA FY 1998 Page 33 ExceIIence Plan E-------________________________________________-.__
U. S. NuclearRegulatory Commission DRAFT Strategy 3
. implementation Plan, will be addressed as part of the Program Planning and Performance Measurement Process, as described in Section ill of this plan. Criteria relating to the outputs and outcomes of these activities will be included in the individual operating plans for the involved offices.
One key task associated with the PRA implementation plan, focuses on the identification of candidate issues for improving the regulatory process. PRA issues which can potentially change the regulatory process, will be evaluated and dispositioned under strategy 5.
Specifically, regulatory effectiveness issues raised by PRA Plan Task 1.7 link directly into the
' strategy 5 assessment process. In addition to closely linking to strategy 5, implementation of risk-informed-regulation under strategy 3 also links to:
- strategy 1 by providing PRA support to Senior Management Meetings,
- strategy 2 by identifying risk-significant licensee commitments which the staff relied upon to make regulatory decisions,
- strategy 4 by modifying 10 CFR Part 35 to be more risk-informed,
- strategy 5. by identifying issues that stem from the NEl Pilot Program (PRA Plan Task 2.7),
- strategy 6 by working expeditiously with industry to develop a national consensus standard for PRA scope and quality (PRA Plan Task 2.8),
- strategy 7 by identifying PRA training and core capability needs.
Utilizing the Excellence Plan to link the above strctegies will enhance the use of PRA technology in regulatory matters, and help focus staff resources on risk sensitive issues, consistent with the PRA Policy Statement.
Stakeholderinvolvement Stakeholder involvement for various aspects of the implementation plan has been and will continue to be extensive. For example, to facilitate solicitation of public comments on Regulatory Guides and Standard Rev. w Plans for making risk-informed changes to the current licensing basis of nuclear power plants, workshops were recently held during the public comment period to explain the draft documents and answer questions. Public meetings and workshops will continue to be held on other regulatory activities to obtain input from industry and other members of the public where it is believed such workshops will facilitate stakeholder involvement. Also, the staff will conduct working meetings with personnel from professional associations, national laboratories, academic institutions, and industry on an as needed basis.
Schedule and Milestones The schedule and milestones for the PRA implementation Plan activities will be maintained in the staff's quarterly progress reports. The current quarterly report, SECY-97-234, provides the most recent schedule and milestones.
Resources The total resources currently budgeted for this work are $4 million and 25 FTE in FY 1998 and FY 1998 Page 34 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 3 FY 1999. The resources from among RES, NRR, NMSS, and AEOD required to implement the 18 specific PRA Plan Tasks discussed above, amount to approximately 25 FTE and $4 million each year for 5 years. Further, as described in SECY-97-234, these resources include, for example, the staff and contract funds in the PRA branches in RES, NRR, and AEOD as well as other selected staff throughout the Agency.
Cost-Benefit Considerations The staff considers the activities conducted under the PRA implementation Plan to be necessary to ensure the timely and integrated agency-wide use of PRA methods and technology. PRA methods have been applied successfully in numerous nuclear regulatory activities and have proven to be a valuable complement to deterministic engineering approaches. The increased use of PRA in nuclear regulatory activities has broad implications and could result in significant changes in many areas of the current regulatory framework, particularly in those areas that may be over-or under-regulated.
Lead Office Staff and Staff From Supporting Offices Lead office:
RES (Mark Cunningham)
Other offices:
NRR (Gary Holahan)
NMSS (Margaret Federline)
AEOD (Patrick Baranowsky) 1 i
I FY 1998 Page 35 Excellence Plan
l I
U. S. NuclearRegulatory Commission DRAFT Strategy 3 Figure 3a - Risk informed Regulation
( Enhance Safety Decisions )
s o
A (Strategy Outputs )
( Program Outputs )
Operator Licensing Set of Risk-Based Event Assessment Risk insights on Catalog (8/95C)
Performance indcators insights (ongoing)
Industry Trends (6/99)
Standards (3/97C)
(9/00)(Tle to strategy 1)
IPE-Generic issue Risk-Performance Closure of Accident Compilation of Operstmg closure (TBD)
Indicators (1/01)
Mangement (TBD)
Experience Data (ongoing)
Advanced Design Cert Risk insights on Tech Support (ongomg)
PSA Evaluation industrial & Medcal PRA Methods for (Ongoing)
Rad Devices (TBD) 2 Methods for Treatmg:
. Brachytherapy (TBD)
(Tle to strategy 4)
- Aging Effects (11/98)
. Teletherapy (TBD)
IPE Follow-up lasues 5
- Errors of Com (9/98)
(Tle to Strategy 4)
Resolved (12/99)
Risk insights on 0
- OrganPerf (TBD)
Allowable Red
- Fire Risk (9/98)
LLW and Residual Activity IPE/IPEEE Reviews Releases (TBD)
- Digital Sys (6/99)
Decision Criteria (2/08)
Completed (12/99)
Risk ;asights on National Consensus BTP on LLW Disposal Generic issues Industrial Gauges:
Resolved (ongoing)
.Cosium 137(9/98)
(Tle to Stratopy 6)
- Cobalt 60 (9/98)
PRA Methods for LP/ Shutdown insights Recommendation on Medical / Industrial Nuclear (10/98)
Risk insights on Yucca Safety Goals (3/98)
Risk (9/98)
Mt (TBD)
ASP Rev 3 Models PRA Framework for Sys& Comp 12/98 Risk insights on Dry I11'01I Nuclear Materials (TBD)
Initiating Evnts (3/98)
Cask Storage (TBD)
Hum Char (TBD)
Risk insights on Rad ASP insights (ongoing)
Mat Transpt (12/99)
+
+
( Regulatory Activities and Programs )
f Regulatory Activities and Program )
1.4 Operstmg Licensing 3.5 Compile Operating 1.5 Event Assessment 3.4 Application of Risk Exponence Data Based Perf Indicators j
1.9 Accident 1.6 Evaluate PRA Use a
Management 4.1 PRA Methods in Resolving Gis 4.1 Application of Risk Mtds En Development for Med to Indust & Med Rad 2
2.2 Technical Support and Red Devices 1.8 Adv Reactor Rev
- Devices, s.
as 2.4 PRA Methode 4.2 Develop Decision 1.10 EvalIPE insights 4.2 Application of Risk e
Development Criteria for for Follow-up issues Methods to LL Rad Waste Decommissioning
& Residual Activity 8
2.8 PRA Standards 2.5 IPE/IPEEE Rev Development 4.3 Develop 4.4 Application of Risk y
GuidanceFor the 2.6 Generic lasues Pg Methods to industrial 2.10 Safety Goal Review Of Risk Gauges p
Revision Associated With Waste 2.9 LP & Shutdown oy Repositories Benchmark Study 5.1 Application of Risk 3
3.2 Accident Sequence Methods to Hgh-Level e
Procursor (ASP) 4.4 Risk Assessment of 3.1 Risk-Based Trends Waste Repository j
Program Material Uses and Pattoms Analysis 5.2 Application of Risk 3.4 Risk-Based 4.5 Develop framework 3.2 ASP Program Methods to Spent Fuel Performance Indicators for use of PRA in Storage Facihty nuclear material 3.3 Industry Risk regulaten Trends 5.3 Application of Risk Methods to Radioactive Materials Transport FY 1998 Page 36 ExceIIence Plan l
l
(
l U. S. NuclearRegulatory Commission DRAFT Strategy 3
- Figure 3b - Risk Informed Regulation E
r o
Effective and Efficient j
Use of NRC Resources O
A
( Strategy Outputs
( Program Outputs)
Risk-informeri inspection Guidance (7/97C)
Senior Management Meeting Risk insights (Tie to Strategy 1)
(ongoing) (Tie to Strategy 1)
Revised Core inspection Procedures (ongoing)
Utilization of Sr Reactor Analyst (SRA)
(Tie to Strategy 1)
Expertise (ongoing)(Tie to Strategy 1)
SRA Qualification Program and Associated Maintenace Rule Baseline Inspections (7/98)
)
Jt Training (ongoing)
[
Identification of Regulatory Effectiveness 1
5 Maintenance Rule Baseline inspection Training issues (12/98)(Tie to Strategy 5) 0 (8/96C)
Modification of 10CFR52 for Use of Updated PRAs Beyond Design Certification (12/99)
Technical Staff Trained on PRA (P-105 Course)
(ongoing) (Tle to Strategy 2) l Technical Managers Trained on PRA (P-107 Course)(ongoing)(Tle to Strategies 1 and 2)
Resident inspectors Trained on PRA (P-111 Course)(ongoing)(Tle to Strategy 1) h A
E Regulatory Activities and Programs Regulatory Activities and Programs Em 2
1.3 Inspections
1.3 Instxuons:
a.
. Guidance on UseOf
. PRA Support of Senior Mangt d
IPE/IPEEEinsights meetings 3
- Senior Reactor Analyst (SRA)
. Senior Reactor Analyst (SRA)
E Qualification Program f
. Maintenance Rule inspection
. Maintenance Rule Tra,enmg o"
1.7 Regulatory Effectiveness h*
2.3 Support for NRR Standard Evaluation g
Reactor PRA Reviews 3g 3.6 Staff Training a:
1 FY 1998 Page 37 ExccIIence Plan I
i
U. S. NuclearRegulatory Commission DRAFT Strategy 3 l
l Figure 3C - Risk informed Regulation 1
( Reduce Unnecessary Conservatism)
E 3
j A
( Strategy Outputs )
( Program Outputs )
General SRP for Risk-Informed Decision Making (1/98C) in-Service Testing Pilot Application Changes (5/98)(Tie to Strategy 2)
SRP for in-Service Testing (3/98)
In-Service inspectionPilot Application SRP for in-Service Inspect (4/98)
Changes (TBD)(Tle to Strategy 2) e SRP for Technical Spec (3/98)
Technical Specification Pilot Application E
Changes (4/98)(Tie to Strategy 2)
Graded QA Inspection Guidance (10/98)
Graded QA Pilot Application Changes (1/987C)(Tie to Strategy 2)
General RG for Risk Informed Decision Making (1/98C)
NEl Pilot Application Changes (TBD)
(Tie to Strate;iles 2 and 5)
RG for in-Service Testing (3/98)
RG for in-Service inspection (4/98)
RG for Technical Spec (3/98)
RG for Graded Quality Assurance (3/98)
Risk informed regulation seminars (2/98C)
A A
(Regulatory Activities and Programs)
( Regulatory Activities and Programs)
I 1.1 Develop Standard-Review Plans 1.2 Motor-operated valve studies a-for Risk-Informed Regulations 1.2 In-ServiceTesting Pilot Study 1.3 Develop GQA j
inspectionGuidance 1.2 in-Ser.;ce inspection PilotStudy h
2.1 Develop Risk-Informed Regulatory 1.2 Technical Specircation Pilot Guides Program Seminar Training on Risk-informed 1.2 Graded Quality Assurance Pilot JI!
Regulations Program 3
I 2.7 NEl Pilot Program a:
FY 1998 Page 38 ExceIIence Plan
U. S. Nuclear Regulatory Commission DRAFT Strategy 4 Strategy 4 Improve the medical regulatory program by modifying 10 CFR Part 35 to be more risk-informed and performance-based.
Purpose The purpose of revising 10 CFR Part 35, Medical Use of Byproduct Material, is to develop specific improvements in NRC's regulations goveming the medical use of byproduct material.
The revision is intended to make Part 35 a more risk-informed, performance-based regulation that will:
focus the regulations on those medical procedures that pose the highest risk, a
from a radiation safety aspect, with a subsequent decrease in the oversight of low-risk activities; focus on Nse requirements that are essential for patient safety; a
initiate imp ovements in NRC's medical program, by implementing recommendations from intemal staff audits, other rulemaking activities, and results of analyses in medicalissues papers; incorporate regulatory requirements for new treatment modalities;
=
reference, as appropriate, available industry guidance and standards; and a
provide for capturing not only relevant safety-significant events, but also precursor events.
Approach.
NRC examined the issues surrounding its medical use program in detail during the last four years. The process started with NRC's 1993 intemal senior management review; continued with the 1990 independent extemal review by the National Academy of Sciences, Institute of Medicine; and culminated in NRC's Strategic Assessment and Rebaselining Project (SA). In particular, medical oversight was addressed in the SA Direction-Setting lasue Paper Number 7 (DSI 7), Materials / Medical Oversight. In SRM - COMSECY-96-057, the Commission directed the staff to submit a plan for revising Part 35, associated guidance documents, and, as necessary, the Commission's 1979 Medical Policy Statement.
The rulemaking process is being used to revise Part 35 into a risk-informed, more performance-based regulation in order to focus regulatory oversight on those activitiec that pose the highest risk. The review and development of the Part 35 revision is being conducted using a group approach. The Working and Steering Groups include representatives of the NRC, Organization of Agreement States, and the Conference of Radiation Control Program Directors. Within the NRC, members of the Working and Steering Groups represent NMSS, RES, OGC, OSP, OE, and Region i. In addition to developing the. rule text as part of the Working Group, the members are also overseeing the development of the associated documents in order to ensure consistency in the rulemaking package. For example, the guidance development team will be FY 1998 Page 39 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 4 chaired by the Region I member, and the environmental ass'essment, regulatory analysis, and submittal to the Office of Management and Budget will be developed by a contractor under the direction of an NMSS member.
The staff has developed rule language attematives, with specific rule text, for the major.
regulatory issues. In addition, altematives have been developed for revising the Medical Policy Statement. These attematives were discussed at: the Advisory Committee on the Medical Use of Isotopes (ACMUI) Meetings in September 1997 and March 1998; the All Agreement States Meeting in October 1997; and public meetings held in October 1997 in Philadelphia, PA and in t
November 1997 in Chicago, IL. The attematives were also available for comment on the Intemet and were discussed with numerous. medical groups. NUREG documents that summarize the comments at'all four public meetings are being prepared.
The proposed rule, associated documents, and recommendations for changes to the 1979 Medical Policy Statement are being developed using the Working and Steering Group approach. This process involves comprehensive reviews of past comments received on medical issues, medical standards of care, state medical regulations, industry standards, etc.
The final rule will also be developed using a Working and Steering Group approach. Prior to submission of the draft final documents to the Commission, they will be discussed with the ACMUI and Agreement States and made available to the public.
Criteria for Measuring Success 1.
Reduction in the regulatory requirements for those medical procedures that pose the lowest risk.
2.
Reduction in the number of exemption requests by medical licensees.
3.
Reduction in the information collection burden for both NRC and medical licansees.
4.
Expected reduction in costs for both medical licensees and NRC (to be determined by regulatory analysis).
5.
Improvement in radiation safety for the public, workers, and patients.
6.
Increased flexibility for medical licensees because of performance-based requirements.
7.
Improved program for " capturing" safety significant events, including precursor events.
Stakeholder involvement The program for revising Part 35 and the associated guidance documents provides more opportunity for input from potentially affected parties (the medical community and the public) than is provided by the typical notice and comment rulemaking process. Early public input was solicited through several different mechanisms: requesting public input through Federal Register notices; holding open meetings of the govemment grcups developing the revised rule FY 1998 Page 40 Excellence Plan
4 U. S. NuclearRegulatory Commission DRAFT Strategy 4 language; meeting with medical professional societies and boards; putting background documents, options for the more significant regulatory issues associated with the rulemaking, and attematives for revising the 1979 Medical Policy Statement on the Intemet; and convening public workshops. Participants from the broad spectrum ofinterests that msy be affected by the rulemaking were invited to attend the public workshops in Philadelphia, PA and Chicago, IL, held in October and November 1997. The public was also welcome to attend these workshops, as well as the Part 35 Workshop that was held in conjunction with the All Agreement States Meeting in October 1997 and the ACMUI meetings in September 1997 and March 1998.
in addition, as noted above in " Approach," the rulemaking process is using a working group, l
steering group, and guidance consolidation team that includes not only members from the NRC headquarters offices, but also members from the regional licensing and inspection staff that are in frequent contact with NRC's medicallicensees. Representatives of two Agreement States and a non-Agreement State are members of the groups developing the rule and guidance. The Agreement State representative on the working group is also a member of the Conference of l
Radiation Control Directors' Suggested State Regulation Committee on Medical Regulation, i
which is working toward parallel development of suggested state regulations. State participation in the process will enhance development of corresponding rules in State regulations and will provide an early opportunity for State input. In addition, it will allow the State staff to assess the potentialimpacts of NRC draft language on the regulation of non-Atomic Energy Act materials used in medical diagnosis, treatment, or research in the States.
The meetings of the groups developing the rule text and the associated guidance are noted in the NRC meeting announcements and are open to the public.
Staff put the Working Group's draft proposed rule on the intemet in January 1998 for public -
comment. This provides the public an opportunity to comment on a "strawman" draft proposed text while the staff and contractor continue to develop the guidance documents and the other rulemaking documents associated with the rulemaking, and to finalize the proposed rule prior to forwarding it through the concurrence process.
Af*er Commission approval of the proposed rule language and associated documents, they will l
be pHished in the Federal Reaister for public comment for 75 days. The NRC staff plans to l
hold'
'e public meetings during the formal comment period to facilitate public comment.
Development of the final rule, associated documents, and final guidance will also be done using a govemment steering and working group, which will hold open meetings. In addition, staff plans to continue making draft documents available on the Intemet and to discuss the draft final documents with the ACMUI and the Agreement States before submitting them to the Commission.
Schedule and Milestones i
The overall schedule provided to the Commission in SECY-96-131 calls for staff to provide a pwposed rule, associated documents (e.g.,the regulatory analysis, environmental impact l
.FY 1998 Page 41 Excellence Plan l
l l
J
i I
U. S. NudearRegulatory Commission DRAFT Strategy 4 statement, and finding of no significant environmental impact), and the Office of Management and Budget clearance package to the Commission in May 1998. At the same time, staff will also provide the Commission with draft guidance documents and :ts recommendations on the need for any changes to the 1979 Medical Policy Statement. Following Commission approval, the proposed rule and draft documents would be published for a 75 day public comment period.
The staff expects to provide a final rule, associated documents, and final guidance documents for Commission approvalin May 1999.
Resources The resource projections associated with revising Part 35 and associated documents were provided to the Commission in SECY-97-115. The total resources currently budgeted for this work are approximately $189 K and 6.0 FTE in FY 1998; $110K and 5.1 FTE in FY 1999, depicted as follows:
FY 1998 FY 1999 FY 2000 OfDsa
NMSS 39 3.0 60 3.0 0
0.3 RES 150 1.9 50 1.0 OGC*
O 0.3-0.6 0
0.3-0.6 OSP 0
0.5 0
0.5
- OGC effort includes the facilitation support for the public meetings from the Special Counsel for Public Liaison.
COMSECY-96-057, " Materials / Medical Oversight (DSI 7), noted that this rulemaking and associated guidance development is a very high priority for the Commission, and the
' Commission is prepared to provide, as necessary, additional resources required to complete the rulemaking on schedule. Therefore, NMSS management is closely monitoring the resources required for this rulemaking.
Cost-Benefit Considerations Revision of Part 35 into a risk-informed, performance-based regulation is expected to result in reduced costs and increased benefits for both NRC and its medical licensees because the proposed revision would focus the regulations on those medical procedures that pose the highest risk, with a subsequent decrease in the oversight of low-risk activities.
The program for revising Part 35 includes a complete regulatory analysis that will examine the costs and benefits of the attematives considered during the rulemaking. This will ensure that any proposed changes to the regulatory burden on medical licensees are based on adequate information about the extent of these burdens and the resulting benefits. The regulatory FY 1998 Page 42 ExceIIence Plan
)
t U.1 NuclearRegulatory Commission DRAFT Strategy 4 l
analysis will also ensure that the regulatory burdens imposed are needed, justified, and the minimum necessary to achieve regulatory objectives. The regulatory analysis will include an assessment of: direct costs or savings to licensees, the NRC, and State govemment agencies; I
and conformance with formal positions adopted by national and intemational standards and medical organizations.
l Lead Office Staff and Staff from Supporting Offices Steering Group:
Working Group:
Sam Jones, NMSS 1
Penny Lanzisera, Region i i
Donald Cool, NMSS, Cathy Ha..ey, NMSS, Marjorie Rothschild, OGC j
Chairperson Chairperson and Project David Walter, State of i
Tom Hill, State of Georgia Manager Alabama Jim Lieberman, OE Lloyd Bolling, OSP Barry Siegel, M.D., Medical Paul Lohaus, OSP Joe DelMedico, OE Consultant Stuart Treby, OGC Diane Flack, NMSS Cheryl Trottier, RES Marcia Howard, State of Ohio Guidance Consolidatiori Team:
Penny Lanzisera, Region I, Chairperson Robert Gattone, Region 111 Andrea Jones, Region ll l
Robert Reid, State of Ohio i
FY 1998 Page 43 ExceIIence Plan
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p U. S. NuclearRegulatory Commission DRAFT Strategy 5 l
Strategy 5 -
Develop a process and identify candidate hsues for improving the effectiveness and efficiency of rules, standards, regulatory guidance, and their application.
I W
' Purpose l
The purpose of this strategy is to develop and implement a process to identify effectiveness and l
efficiency issues related to rules, standards, regulatory guidance, and their application that could be improved through changes to the regulatory framework. The process is intended to identify those rules, standards, and regulatory guidance where the objectives of clarity, coherence, logical basis, consistency, reliabikty, technical soundness, and effectiveness are not
_ being met. The process will also identify unnecessary regulatory requirements and where processes can be streamlined for batter efficiency (as stated in the NRC Strategic Plan). This is an assessment activity based on information available within the Nuclear Reguistary Commission and augmented by input from internal and extemal stakeholder. The candidate issues will be derived from the review of informadon from many sources to identify significant effectiveness and efficiency issues.
l
- The staff has incorporated into its normal busi'.1ess practice several activities that result in periodic reviews of regulations and regulatory products within the existing regulatory framework.
The genesis of these activities can be traced back to focused effo-ts such as the Marginal to Safety Programs, the Regulatory Review Group effott, and the CRGR's special reports, each of j
which identified such issues. In many cases, the results of these one-time efforts were captured in on-going action plans or tracking systems such as the PRA implementation Plan or l,
Generic issues Prioritization and Resolution Process described in the periodic NUREG-0933, "A l
Priontization of Generic Safety issues."
l Besides the periodic review of existing programs, candidate issues have historically been identified in a variety of ways, including lessons from everits, petitions for rulemaking, and staff l
initiatives. However, at the present time an integrated and systematic process within the NRC does not exist to proactively identify candidate issues for improvement of the regulatory i
. framework on a continuing basis. Strategy 5 is to improve the current approaches and identify.
j potential improvements to the regulatory framework in a more systematic and proactive i
- manner, i
i l
- The list of candidate effectiveness and efficiency issues identified through systematic application of this process will be periodically forwarded to the Deputy Executive Director for l
Regulatory Effectiveness (DEDE) and program offices for their consideration and appropriate action. Where appropriate, the resulting improvement initiatives will be presented to the Program Review Committee (PRC) and the Executive Council (EC) for endorsement or revision.
l FY 1998 Page 45 Excellence Plan l
U. S. NuclearRegulatory Commission DRAFT ^
Strategy 5 Approach / Process The Office for Analysis and Evaluation of Operational Data (Excellence P an) l
- (AEOD) has been assigned the
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strategy 5:
f significant participation by the candidate issues l
Office of Nuclear Regulatory j
(AEOD) j o
u Research (RES). Since regulatory issues from throughout the agency
' Effectiveness.
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Generic Applicability h
r well as knowledge of the available 8
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I information and data sources are k-k important elements of this strategy. To the extent possible,
,e AEOD will make use of existing e
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sources and programs. In j
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s addition, a systematic review will be undertaken of sources of Figure 5.1 Strategy 5 information not accessible through review of operating and licensing experience databases. These will include (1) probabilistic risk assessments (PRAs) conducted by the NRC, by U.S. industry, and by foreign entities and'(2) results of research programs, engineering analyses, and tests conducted by the NRC, U.S.
industry, and foreign entities.
In addition to the participation of RES, AEOD will work in concert with the Office of Nuclear Reactor Regulation (NRR), the Office of Nuclear Material Safety and Safeguards (NMSS), the Office of Enforcement (OE), the Office of Investigations (01), and the Agency Allegation Advisor to evaluate information contained in their existing databases and other information sources maintained by these ofices. Issues will also be solicited from the nuclear power industry, public, and internal stakeholder.
The process for developing a list of candidate effectiveness and efficiency issues will consist of three major phases -issue identification, issue analysis, and issue proposal. Intemal and extemal stakeholder input will be solicited throughout the process. Figure 5.1 shows the major components and flow of Strategy 5. Figure 5.2 shows more detail on the sources used to identify the issues.
Figu os 5.1 and 5.2, represent the current thinking of ways to identify and analyze issues from well established sources. It is a holistic view of the various sources of information that would yield issues. There may exist other sources that have not been listed but that will be reviewed FY 1998 -
Page 46 Excellence Plan
U. S. NuciearRegulatory Commission DRAFT Strategy 5
\\
as the Strategy 6 process matures. All the sources for issue identification will not be reviewed in detail initially. Instead, due to resource limitations, it will be necessary to exercise judgement and experience to single out those issues which merit further analysis to determine whether action to improve agency programs is warranted. The process will be iterative and will be modified as new ways to categorize and assess issues are identified. However, the basic process in Figure 5.1 is not expected to change as far as having the three separate phases of the strategy -issue identification, issue analysis, and issue proposal.
ISSUE IDENTIFICATION
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AEOD. These reviews will include the following k cnes> /
cnes3 databases: Sequence Coding i
and Search System, Accident Fieme 5.2 informason sowoes for strenesy 5
. Precursor Program, Nuclear Materials Events Data, Significant Events Data, Allegations Data, and Equipment Performance and information Exchange data. The review of each database will be peiformed to identify the I
problems and issues that keep recurring. AEOD will also review its Technical and Reliability FY 1998 Page 47 Excellence Pian
U. S. NuclearRegulatory Commission DRAFT Strategy 5 Studies to identify findings and issues from individual studies.
Licensina and insoection Information AEOD will be responsible for the licensing and inspection information assessments with support from RES, NRR, NMSS,01, and OE. This assessment will include review of enforcement actions and investigation reports to identify recurring problems. Reactor licensee inspection experience will be obtained by reviewing the plant issues matrix system database. The Senior Management Meeting template will be reviewed to see if recurring licensing and inspection issues can be identified. The exemption database will be reviewed to identify those rules with frequent exemptions. Generic Communications will be reviewed to identify recurring issues. Where compiled, licensee responses and the adequacy of licensee corrective actions will be reviewed.
Enaineerina. Scientific information Sources RES will be responsible for identifying issues from various engineering and scientific sources. Periodic information will be captured from such programs as Reactor Aging Research, Human and Organizational Factors Research, and Thermal-Hydraulic / Severe Accident Research. A normal part of the completion of a research project is an evaluation of the usefulness of the results. These research programs may identify technical advances in related disciplines, such as uses of advanced computational technologies, that have potential for significant contributions to other activities.
Risk Information RES will be responsible for identifying issues from various programs related to risk.- Information related to risk estimation and sisk management may be brought out by the follow up activities to completed projects such as NUREG-1150. Additional information will continue to arise out of the PRA implementation Plan (DSI-12) including those initiatives included in Strategy 3 of the Regulatory Excellence Plan (e.g., results of the IPE and IPEEE reviews; the NEl sponsored plant risk assessments). National as well as intemational health effects studies will be considered. Finally, the results of efforts to bring risk insights more effectively into the Senior Management Meeting process will also be considered.
Regulatory Initiatives AEOD and RES will jointly conduct review of previous and current regulatory initiatives to identify issues. This will include on-going efforts to identify requirements where a more performance-based approach would be preferable. This assessment will take into account the efforts to more effectively utilize industry initiatives (DSI-13) as described in Strategy 6 of the Excellence Plan. The effectiveness of selected rules such as those identified in the PRA implementation Plan will also be assessed Extemal/intamal Stakeholder input RES will be responsible for obtaining extemal stakeholder input. The public will be given the opportunity to submit issues through several mechanisms. A Federal Register notice will be published soliciting issues. During 1998, a special workshop will be held to introduce the Plan for Regulatory Excellence including all strategies but with emphasis on Strategies 6 (DSI-13), 3 (DSI-12), 5 and, in addition, the initiative to achieve more performance-based regulation. RES and AEOD will utilize this workshop to solicit industry input. AEOD will place this strategy on the Intemet to solicit issues and comments on the process from the public, and will establish a means to periodically obtain input and provide FY 1998 Page 48 ExceIIence Plan
^
U. S. NuclearRegulatory Commission DRAFT Strategy 5 feedback on the results of the assessments. AEOD, with the assistance of RES, will also solicit i
issues from other offices and will place this strategy on the agency Intemet to solicit issues and comments on the process from the staff.
l It is expected that the sources described above will surface many potential issues. Judgement l
will be required to arrive at the most significant issues. As potential issues for further detailed l-ana!ysis are identified, they will be screened to determine whether they have previously been or j-are currently being addressed in an NRC program. Specifically, the Generic issue Prioritization and Resolution program (NUREG 0933), the Rulemaking Activity Plan and Generic Letters and Regulatory Guidance recently issued or under development will be reviewed. The screening will also consider the degree to which the issue is applicable to a broad or narrow range of licensees and a preliminary judgement regarding whether the issue is likely to involve enhanced safety or greater flexibility or burden relief to licensees or whether it more likely involves greater efficiency or effectiveness of NRC programs or procedures. The possibility that the issue would be related to a need to develop a more performance oriented approach to regulation will also be considered. The screened issues will be grouped and categorized to enable additional more efficient assessments.
Nominated issues Nominated issues are topics identified by senior management and the Commission. These issues will not be subject to the initial screening process since they are already judged important by senior management, in the January 14,1998, Staff Requirements -
- SECY-97-225 - Enhancing NRC Effectiveness and Efficiency, staff was requested to include the need for an improved program to assure licensee control and accountability of radioactive devices and sealed sources as a candidate in strategy 5. As a result, this will be considered a nominated issue, however the staff's actions in this area will be consistent with the Commission's response to SECY-97-273,"lMPROVING NRC'S CONTROL OVER, AND LICENSEES' ACCOUNTABILITY FOR, GENERALLY AND SPECIFICALLY LICENSED DEVICES."
Regulatory Effectiveness issues originally identified in the PRA Implementation Plan (ltem 1.7) will now be addressed under this strategy. These nominated issues are the effectiveness of station blackout and anticipated transient without scram rules, and Unresolved Safety issue A-45, decay heat removal. These issues are further discussed in the issue analysis, milestone, and resource sections below.
ISSUE ANALYSIS For each issue identified through the process described above, issue analysis will be conducted to assess the issues' regulatory effectiveness and efficiency. Regulatory effectiveness means a regulatory framework for ensuring public health and safety that is clear, coherent, logical, consistent, reliable, and technically sound. Efficiency means a regulatory framework that is cost effective for both the NRC and its licensees. This phase will identify the issues that have a broad, potentially excessive impact on a large number of stakeholder, and determine the resources spent on these issues. Data will be collected on the resources spent by the staff and FY 1998 Page 49 ExceIIence Plan l
U. S. NuclearRegulatory Commission DRAFT Strategy 5 the industry on the important issues.
For issues related to power reactors, the analysis will build upon the process that the staff currently employs to prioritize generic safety issues which are documented in NUREG-0933.
This process will require modification to address issues of burden reduction. The analysis of the risk and safety significance of reactor related issues will include consideration of whether the issue affects prevention or mitigation, the relationship to the defense in depth principle or whether the issue involves a potential for common mode failure. To the extent practical quantitative estimates of the risk significance such as changes in core damage frequency or probability of a significant release of radioactivity will be developed. These will be based on existing sources such as NUREG 1150, the Accident Sequence Precursor program, IPE and IPEEE results, and emerging sources of risk information such as the NEl full plant PRA's.
When it is impractical to develop meaningful quantitative information regarding risk, qualitative perspectives will be developed.
The generic safety issue prioritization process is the staff's customary activity to provide analytical insights for issue prioritization for power reactors. This process will be used to the degree applicable for decision making to support Strategy 5. The objective of the process is to assign a priority ranking (high, medium, low, or drop) for each issue. In addition to the impact /value analysis which explicitly considers risk reduction potential and costs, other pertinent factors will also be considered, such as availability of manpower and material resources, time needed for resolution, conflicts in resource allocation and scheduling, and budget constraints. Systematic peer review and stakeholder review of each evaluation will assure the completeness and accuracy of the analysis. The decision making will also be guided by a decision matrix similar to that which has been adopted in the regulatory analysis guidelines. The process is also structured for use in situations where significant cost reductions may be possible without a substantial change in public risk. NRR currently implements a variant of this concept in the Technical Specifications improvement program as part of the Cost l
Beneficial Licensing Action Program. As guidance becomes available to the staff and reactor i
licensees through R.G.1.174, "Using Probabilistic Assessment in Risk-Informed Decisions On Plant-Specific Changes To The Current Licensing Basis" (when approved by the Commission),
i the staff will be able to improve the decision making on small but positive changes to risk. The l
effectiveness issues identified in the PRA implementation plan will be evaluated using these approaches.
For issues involving material licensees, quantitative information will be developed to the extent practical. However, in most cases for such issues, it will be necessary to rely on qualitative insights.
An important part of the analysis phase will be to relate the issues to the NRC regulations and activities. The issues will be evaluated to determine how they are linked to specific regulations, standards, guidance, programs, and processes. Identification of correct linkages will require significant, extensive analysis, and interpretive effort. Part of this step will be the development of assessment criteria to include, among other considerations, the timeliness to implement FY 1998 Page 50 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 5 i
regulations, clarity and consistency of the regulations and guidance, and assessing if existing regulations are meeting their intended purpose. This step will also focus on whether there might be potential benefits from a more performance oriented approach to regulation.
ISSUE PROPOSAL i
The final phase of Strategy 5 will be to propose a list of issues with well-documented evidence supporting whether an issue is either no longer warranted or has significant effectiveness and l
efficiency problems. This phase in the process will provide a well-founded basis derived from the analyses and screening that were utilized to obtain the most important issues. Throughout l
the Strategy 5 process, the program office who would be impacted by the identified issues will be kept informed on the issue's progress. The candidate list is the final product of the strategy l
which will be submitted to the DEDE and the program offices for their consideration as l
improvement initiatives. The prioritization and response to these candidate issues will be based l
on safety impact, the potential for improving the agency's ability to meet its goals, resource impact to the licensees and the NRC, impact on quality of agency work, and public confidence in the NRC.
The DEDE will then integrate these improvement initiatives along with the input from the l
program offices for presentation to the PRC, identifying those issues which appear to be most l
appropriate for resolution through routine agency programs (e.g. generic issue resolution or rulemaking), those which appear to be appropriate for new excellence programs strategies, and those which may be dropped. The PRC will provide recommendations to the EC on the response to these improvement initiates. The EC will then select the assessment and l
improvement initiatives that will be described in detail in the periodic update of the NRC l
Excellence Plan.
Criteria for Measuring Success The Strategy 5 process will nominate four well-founded issues which will be considered by agency management for further evaluation by September 30,1998. In the longer term, the measurement of success wiil be the number of changes due to Strategy 5 to the regulatory framework that will increase safety, reduce regulatory burden, or produce NRC resource savings.
l Stakeholder involvement i
in coordination with RES and the other Excellence Plan strategies, AEOD will involve both intemal and extemal stakeholder and solicit their input in the development process and in the selection of candidate issues. Meetings will be conducted with the other offices to describe the process development. The development plan will be made available to the industry through use of the Intemet, public presentations, the federal register, and meetings with industry
{
groups. Meetings with the public will be integrated with meetings held for Strategy 6," increase Effectiveness and Efficiency of the Regulatory Process." Once processed, the list of candidate l
FY 1998 Page 51 Excellence Plan l
U. S. NuclearRegulatory Commission DRAFT Strategy 5 issues will be made publicly available.
Schedule and Milestones Strategy 5 is both the development and the implementation of a process. Work on the conceptual development process began November 1997. Public presentation on the process development to the extemal stakeholder will be coordinated with Strategy 6. AEOD and RES will make presentations to the other offices and will place the process on the local area network for employee comments. Intemal and external stakeholder' comments will be incorporated into the development process. A test run will be completed by June 30,1998, and the first set of candidate issues will be completed by September 30,1998. Although the program will be operational by September 30,' 1998, we intend to continue the program's enhancement and refinement. The effectiveness review of the PRA implementation Plan issues will be completed by the second quarter of 1999. The important milestones are as follows:
Milestones Begin Conceptual Development Process November 1,1997 Effectiveness / Efficiency May 30,1998 Review Questions and Metrics Developed Meetings with public and industry Coordinated with to introduce concepts and solicit issues Strategy 6 Test Run of Process Development Complete June 30,1998 Revision of Detailed implementation Plan July 31,1998 based on Test Run lessons learned First set of candidate issues completed September 30,1998 Complete ascessment of PRA Implementation Plan Second Quarter 1999 effectiveness issues Resources The total resources currently budgeted for this work are $200 K and 4.0 FTE in FY 1998 and 5 FTE in FY 1999. Development and application of the systematic process will require 2 AEOD FTE,2 RES FTE, and $200K for FY 1998. After establishing the program, it is estimated that the program will require 2 AEOD FTE and 2 RES FTE to maintain the same level of support.
An additional 1 FTE throughout the rest of the agency may be required to implement this plan in FY 1999. The $200K budgeted for FY 1998 will be used for expert help in assessing information sources. Additional funds needed to support the work in the future will be FY 1998 Page 52 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 5 determined as part of the implementation efforts.
Resources to perform the assessment of PRA implementation Plan Regulatory Effectiveness issues are included in the agency's FY 1998 operating plans. Assessment of these issues will I
require 0.75 RES FTE and 0.2 AEOD FTE. Technical assistsnce of $100K for this effort will be transferred from NRR to RES. These resources have been budgeted as part of the PRA implementation plan.
l Cost-Benefit Considerations The benefit of this program is the identification of potentialimprovements in the effectiveness and efficiency of the regulatory process. This encompasses potential savings of resources for i
both the NRC and the nuclear industry. Without such a program, ineffective and inefficient I
rules, standards, regulatory guidance, programs, and processes may not be identified for
{
correction in a timely manner. The five FTE estimated for this effort are a small percentage of the overall resources expended to improve and implement the regulatory framework.
j l
Lead Office Staff and Staff From Support Offices Jack Rosenthal, AEOD George Lanik, AEOD i
Jose Ibarra, AEOD j
William Hutchinson, Ol Nader Mamish, OE Joe Murphy, RES Paul Norian, RES Prasad Kadambi, RES Sid Feld, RES John Flack, RES Ed Baker, Agency Allegations Official Fred Combs, NMSS l
l t
FY 1998 Page 53 Excellence Plan l
4
U. S. Nuclear Rergulatory Commission DRAFT Strategy 6 Strategy 6 I
increase effectiveness and efficiency of the regulatory process by expediting evaluation of industry initiatives and promoting more rapid adoption of consensus standards I
Purpose The purpose of this strategy is to leverage stakeholder work on standards and initiatives to improve the efficiency of the NRC and the ability of licensees to meet regulatory requirements in a more efficient and effective manner. This strategy recognizes the importance of NRC interaction with industry groups, professional societies, and technical institutes to' develop new l
codes, standards, and guides and will lead to an improved process for NRC participation in the development and endorsement of consensus standards. A review of past experience and practices in this area revealed the need for improvement. The development of this strategy will also lead to an improved process with clear decision criteria for handling industry initiatives that would be used as substitutes for regulatory action.
Approach The major activities undertaken as part of this strategy will be: (1) to define and implement
. process and decision criteria that would be used by the NRC staff to evaluate industry initiatives that would be substitutes for regulatory action and (2) to increase the involvement of licensees and others in our regulatory development process by encouraging industry to develop codes, standards, and guides that can be endorsed by the NRC and carried out by the industry. These activities are under the scope of Direction Setting issue (DSI) -13, Role of Industry.
The first major step in implementing this strategy will be for the NRC to hold stakeholder meetings to discuss the process and decision criteria to be used for evaluating industry, initiatives and to discuss areas for improvement in the standards development process.
Following these meetings, the staff will develop recommendations subject to Commission approval, followed by procedures intended to improve NRC effectiveness and efficiency in these areas. This is expected to include a procedure that will define the process to review and evaluate the initiative and the general decision criteria to be used to determine if a proposed industry initiative should be reviewed by the NRC or if the NRC should participate in the initiative. A separate procedure is also anticipated to describe specific staff activities associated with participation in the development and endorsement of standards. This procedure will address activities such as maintaining the staff standards committee membership roster, establishing criteria for staff participation on standards development organizations (SDO) committees, incorporating provisions for standards involvement in individual NRC staff elements and standards, establishing a process to define development of
" informed staff votes," and early formulation of staff positions. In order to ensure timely update of regulations and regulatory guides that endorse standards, databases for referenced standards will be established along with a procedure to periodically monitor the need for updating the reference.
FY 1998 Page 54 ExceIIence Plan
. U. S. Nuciaar Regulatory Commission DRAFT Strategy 6 Criteria for Measuring Success 1.
The completion of the initial acceptance review within six months of receipt cf a written proposal for an industry initiative.
2.
A reduction of 10 to 20 percent in the average time to endorse standards in regulations, regulatory guides, or by other appropriate means.
3.
Full implementation of the provisions of Public Law 104-113, " National Technology j
Transfer and Advancement Act of 1995"(P.L.104-113) and OMB Circular A-119,
" Federal Participation in the Development and Use of Voluntary Consensus Standards,"
1 (A-119).
1 Stakeholderinvolvement Stakeholder meetings as discussed above are planned for mid 1998. These meetings will be integrated with the meetings to introduce the public end industry to the regulatory excellence program and several other excellence strategies including Strategy #3 regarding the use of probabilistic risk assessment and Strategy #5 regarding the identification of candidate issues for improving the regulatory framework.
The stakeholder meetings will address issues related to the development of standards by SDOs and the endorsement of those standards by the NRC. Issues to be discussed will include: 1) l the standards development process, including the importance of the SDO identifying the safety.
significance of new standards and revisions, the impact of proposed standards on licensee and I
2 the regulatory process, and the NRC process for developing regulatory positions; 2) the NRC endorsement process, including the impact of the Administrative Procedures Act; 3) P.L.104-113 and A-119, as these govemment-wide provisions affect NRC participation in the l
development and use of consensus standards and the development of ballot positions by NRC j
l staff; 4) the Federal Advisory Committee Act (FACA) as it regulates formation and operation of advisory committees by federal agencies; and 5) 10 CFR 50.55a, " Codes and Standards," with regard to its 120-month update provision and other backfit considerations.
Following the initial stakeholder meetings, the staff proposes to have periodic meetings, perhaps semiannually, with key SDos. These meetings would provide the opportunity for the staff and SDOs to discuss specific technical needs that could be addressed by standards development and specific issues associated with the standards development and endorsement processes. Information gained from the periodic meetings would be used to implement or improve the ongoing process.
l FY 1998 Page 55 ExceIIence Plan I
l
U. S. NuclearRegulatory Commission DRAFT Strategy 6 Schedule and Milestones SECY responding to SRM (DSl-13) submitted to Commission 11/97 Commission approves recommendations on industry initiatives, and TBD codes and standards Announce stakeholder meeting Within 1 month of Commission approval Hold stakeholder meeting Within 6 months of Commission approval Provide SECY that (1) summarizes the cominents received from Within 4 months of stakeholder, (2) provides staff's recommendations regarding the Stakeholder meeting process and decision criteria to be used for industry initiatives, and (3) provides staffs recommendations regarding whether the endorsement process for codes and standards can be improved Commission decision on recommendations TBD Develop procedures / Management Directives to implement Within 3 months of Commission decision Commission decision implement procedures / Management Directives Within 6 months of Commission decision Resources The resource estimate to implement the Commission directive for Strategy 6 has near and long-term components. Near term resources regarding industry initiatives and codes and standards are those needed to conduct stakeholder meetings, report findings and recommendations to the Commission, and develop procedures and Management Directives. It is estimated that 3 to 6 staff-months (0.5 FTE) of effort following Commission approval of SECY-97-303, "The Role of Industry (DSI-13) and Use of Industry initiatives", dated December 30,1997, will be needed to complete these near term Strategy 6 activities in FY 1998 and FY 1999. These near-term
- resource requirements have been budgeted by RES.
Long-term resource estimates regarding industry initiatives are unknown because the extent of future work in this area is not known. Emerging activities in this area and the availability of resources will be handled as part of the program planning, budgeting, and performance management process.
It is estimated that the resources required to implement the long-term standards component of this strategy could range 13 - 19 FTEs
FY 1998 Page 56 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 6 While other options will be discussed with stakeholder and may be recommerrded to the Commission, this estimate is based on a specific option that required increased staff participation to provide for early development of regulatory positions on individual standards under development. At present, it is estimated that 10 FTEs are being used for this purpose.
The additional resources anticipated to implement this portion of the strategy have not been budgeted because the approach is still under development and subject to Commission -
approval. The additional resources needed to implement this activity will be determined as part of the implementation efforts.
Cost-Benefit Considerations Conducting regulatory activities in a manner that is consistent or complementary with industry initiatives may save NRC resources and improve understanding of emerging regulations. The future costs and benefits associated with industry initiatives that would be substitutes for regulatory action are case-by-case dependent and would be difficult to determine. Optimizing expertise in the development of standards hr.s historically saved the NRC a significant amount of resources. For example, the NRC relies on many industry standards that control some of the most important aspects of nuclear safety.
The general benefits to be accrued from this strategy are increased effectiveness and efficiency of the tsgulatory process, including a more consistent approach to industry initiatives, and compliance with P.L. 104-113 and A-119. Additional benefits from this strategy are improved communication with and understanding of NRC activities by NRC stakeholder.
Lead Office Staff and Staff from Supporting Offices A task force (composed of a steering group and team) was established to respond to the SRM on DSI-13. Currently the staff plans call for the task force to continue to be responsible for the near-term effort which includes stakeholder meetings and the subsequent SECY that will summarize the meetings and propose updated options on industry initiatives and codes and standards activities. Preparation of the associated procedures and Management Directives will be done by the office most directly involved in the related activity. For example, NRR would have lead responsibility for the procedures and Management Directive related to industry initiatives that would be substitutes for regulatory action, and RES would have the lead responsibility for the procedures and Management Directive related to codes and standards.
Offices represented and individuals participating on the task force are:
Steering Group RES Chairman John Craig NRR David Matthews NMSS John Surmeier OGC Stuart Treby FY 1998 Page 57 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 6 Team RES Team Leader Joel Page RES Key Staff Gilbert Millman NRR Key Staff John Tappert NMSS Key Staff Cynthia Jones AEOD Key Staff Earl Brown OGC Key Staff Geary Mizuno The long-term effort to implement the procedures / Management Directives for industry initiatives and codes and standards activities will include staff from RES, NRR, NMSS, AEOD, OGC and the Regions. The applicable program office will be responsible for implementation of the procedures / Management Directive for industry initiatives. RES will be responsible for implementation of the procedures / Management Directive for standards.
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U. S. Nuclear Regulatory Commission DRAFT Strategy 7 Strategy 7 Assess core capability needs by comparing requirements to current availability. Improve core competencies through recruitment, training, and development of staff and/or identification and acquisition of contractor services.
Purpose This activity will assess the availabihty of knowledge, skills, and abilities (KSAs) within the NRC, identify whether there are any gaps in those KSAs that may effect the ability of the NRC to fulfill its mission, and develop strategies to deal with those gaps. The minimum KSAs to support effective implementation of the NRC regulatory responsibilities can also be referred to as the core competencies necessary in order to satisfy core capability requirements.
The present budgetary practices and our approach to human resources management has been useful in meeting our near term needs but may not be effective in projecting longer term needs, integrating overall agency needs, and taking into consideration significant intemal and extemal
' factors that may impact the ability of the agency to maintain a correct balance of KSAs. Intemal factors include the agency's attrition profile and downsizing goals impacted by workload and trends in govemmental streamlining initiatives. Extemal factors include the labor market for experienced professionals, the workload as projected by the activity of the nuclear industry, and the declining university enrollment in nuclear engineering studies and other fields related to nuclear safety.
This effort is necessitated by changes in the environment in which the NRC operates.
Changing mission requirements, such as those that may result from anticipated changes in the type and activities of licensees and Commission action on DSis will change the mix of technical expertise and skills the staff will need The national goal of a smaller Federal workforce and budget reductions will limit the agency's ability to hire to meet new demands and put increased pressure on justifying the basis for our requests. The current trend of moderate to low attrition rates will also limit hiring and may be expected to exacerbate potential skills imbalances.
A key goal of this effort is to position the staff for the kinds of changes described above. This in tum requires approaching the availability and development of staff competency on a highly flexible, agency-wide basis. The agency needs to be able to identify and deploy staff rapidly and efficiently to meet changing requirements and priorities. Acurate information about requirements and available competencies is essential.
Approach implementation of this strategy will occur in three distinct phases.
Phase 1 will consist of an assessment of the availability of current competencies residing in the technical staff. The Office of Human Resources (HR), with stakeholder input from the program FY 1998 Page 60 Excellence Plan
I*
I U. S. NuclearRegulatory Commission '
DRAFT Strategy 7 offices, will develop, test, and implement a methodology to gather and maintain skills availability in a manner that is consistent and usaLa agency-wide. The information will be stored as part l
of an evolving Human Resources information System (HRIS). Maintaining this database will be an ongoing effort. The focus of this effort will be on cataloging the KSAs of the technical staff within the offices of NRR, NMSS, RES, AEOD, the regions, and the technical staff supporting the EDO and Commissioners; The information will be collected by requesting each technical staff member to fill out a questionnaire sent by e-mail. The results of the responses will be compiled and submitted to the managers of the staff persons for review and verification.
l Phase 2 will develop core technical capability requirements based on the strategic planning l
horizon, extrapolated where feasible to a maximum 10 year planning frame. Core capability l
requirements will be derived from strategic and pe;1ormance planning, benchmarks derived l
both intemally and extemally, and based on a strategic analysis of other intemal and extemal factors. The product will consist of a compilation of core capabilities necessary to fulfill the L
mission in each of the strategic arenas in the Strategic Plan. These core capability l
requirements will also need to be updated in the course of regular updates of the strategic plan.
Phase 3 consists of the development of strategies to prevent or close gaps between required core technical capabilities and available competencies. The completion of phases 1 and 2 will provide a basis for determining which combination of staff, contractor, or laboratory maources would best address specific capability requirements, and for developing action plans to address gaps between available competencies and core capability requirements, including developing the needed competencies within the staff. Actions to ensure that core capability requirements are met would be embedded in the regular planning process and incorporated in performance, budjet, and operating plans.
Criteria for Measuring Success 1.
Delivery of skills assessment methodology on schedule, 2.
Validation and acceptance of results of implementation of methodology.
Stakeholder involvement Office / region representatives will participate in the development of the methodology for identifying and recording staff competencies.
. Staff members will be individually involved in the collection of the KSA information, and they will be given the opportunity to review the final results of their individual coding. Briefings will be held with individual work groups with special expertise to discuss the formulation of core capability requirements.
FY 1998 Page 61 ExceIIence Plan II l
U. S. Nuclear Regulatory Commission DRAFT Strategy 7 Schedule and Milestones Phase 1 - Skills Availability Assessment May 1998 Develop methodology, including templates for gathering, synthesizing, storing and retrieving skills data.
June 1998 initial implementation of methodology in selected areas in AEOD, NMSS, NRR and RES.
July 1998 Assess the validity and utility of collected skills data.
August,1998 Evaluate and, as appropriate, revise methodology.
September 1998 Establish schedule for full assessmc.nt of agency technical skills September 1998 Incorporate skills assessment activity in FY 1999 operating plans Phase 2 - Core Canability Requirements identification April 1998 Develop and issue methodology, including criteria for determining that a capability is core, and for selecting a core competency source (e.g. DOE lab, university, other contractor, in-house staff).
September 1998 On basis of updated strategic, performance, and budget planning guidance, identify technical competency requirements over budget I
planning period, and longer-range horizon as feasible.
l 1
determine which competencies are core.
determine competency source (lab, contractor, in-house staff).
incorporate results in budget and operating plans.
Phase 3 - Development and implementation of Streiecies to Remedy Comoetency Ge_r=
October,1998 Identify gaps between available in-house skills and core in-house competency requirements December 1998 Incorporate approaches formulated for addressing competency and ongoing gaps in updates of Program and Organization Operating Plans, including:
FY 1996 Page 62 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 7 assessment of skills decrements from anticipated attrition l
an assessment of anticipated increments to staff skills and competencies vis-6-vis core capability requirements achievable through training over planning horizons estimates of potential FTE and $ costs of training Resources The total resources currently budgeted for this work are approximately $256 K and 1.0 FTE in FY 1998. The activities for phase 1 will primarily be bome by HR. The development of the methodology willlikely require several staff weeks of effort and the possible use of a contractor.
The implementation of supporting IT applications will require approximately 1 FTE and $265 K in FY 1998. These costs have been budgeted. HR will have the lead responsibility for this phase of the effort.
Individual technical staff members will expend approximately one hour filling out a questionnaire.
The activities for phase 2 will primarily be bome by program offices in the form of an increment to the overall planning effort. HR will expend several weeks in the development and coordination of the methodology for identifying core capability requirements; program offices will expend in the aggregate a comparable number of staff weeks of effort in assisting in the development of the methodology.
The resource costs of phase 3 activities, such as specialized training, needed to close any skills gaps will be identified and re-programmed in the regular budgeting process.
Cost-Benefit Considerations Costs As noted above, the principal costs of Phase 1 this effort will consist of:
FTE required to develop skills availability methodology and gather, analyze, and report skills availability data.
funding for IT software applications and hardware needed to record the data and e
maintain its currency.
Benefits Accurate, up-to-date information on the availability of competent staff for technical program FY 1998 Page 63 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 7 needs will:
o facilitate more accurate targeting of technical training to fill and maintain the core competency needs of the agency; support cost effective choices among staffing attematives (hire, train, retrain, e
outsource);
e help position the agency for change.
Lead Office Staff and Staff from Supporting Offices Methodology development - HR Compilation of Phase 1 results - HR Development of core capability requirements - Program Offices Development of strategies to close core competency gaps - HR, with Program Office support FY 1998 Page 64 ExceIIence Plan
.o U. S. Nuclear Regulatory Commission DRAFT Strategy 7 Figure 7 - Assess Core Capability Needs and Improve Core Competencies e
E Enhanced NRC Effectiveness j
More Efficient Use of NRC Resources L
g J
A Strategy outputs]
( Program Outputs)
Skilled resources identified agencywide for High quality hires g
technical programmatic requirements a3 Trained staff Skills availability database a
O Efficient training and retraining for Core capability requirements database agencywide requirements (Tie to Strategies 1 and 2)
Revised staffing plans identification of competency gaps A
A (Strategy Developmental Activities)
> ( Regulatory Activities and Programs)
E E
Identify and test database formats for incorporate into office Operating Plans
- ['
documenting and tracking staff skills and resources and milestones for identifying core competencies (g/g8) core capability requirements and assessing staff technical skills (7/98) 2 Develop methodologies for skills
{
assessment and identifying core capability identify and document s+aff skills (TBD)
E requirements (4/g8)
{
identify and document core capability p
Develop recruitment and training strategies requirements (TBD) to fill gaps in required skills (Or: going) oj Assess gaps in required skills for g
Develop career transition strategies for non.
training snd retraining (TBD) fungible staff overages (TBD) e et implement recruiting and training activities to close gaps (Ongoing) l Implement career transition plans for non-fungible staff overages (Ongoing) i FY 1998 Page 65 ExceIIenco Plan i
U. S. Nuclear Regulatory Commission DRAFT Strategy B Strategy 8 Evaluate headquarters and regional support to determine if it achieves its intended goals in an efficient and effective manner and make recommendations for improvement.
Purpose As the environment in' which the NRC operates continues to change through advances in information technology, reorganization, program changes, and continued budget pressures, it is essential for NRC to continue to improve the way that it conducts its business, including its support functions, with the goal of assuring that the agency is both effective and efficient. This project will assess NRC headquarters and regional support activities to determine whether and how improved efficiency and effectiveness can be achieved. The project will include an assessment of the current utilization of headquarters and regional support resources, determining whether current activities achieve their desired purpose in an efficient and effective manner, whether they should be continued, modified, or sunset, and whether their processes should be redesigned. If redesigned, the assessment will also describe how the process should be redesigned including the use of information technology to improve performance. The results of the assessment will be compared with benchmarks and best practices in both public and private sectors. Recommendations will be made based on findings.
Approach A contractor with substantial experience in performing such evaluations will be used to conduct the assessment defined above. We expect the contractor to be the one that is being negotiated for agency-wide support of the Planning, Budgeting and Performance Management process.
In addition to the contractor assessment to implement this strategy, some NRC support organizations are conducting self-assessments as part of their normal planning, budgeting and performance management activities. Such self-assessments are being performed in various areas to (1) identify the most effective and efficient means of meeting the needs of their customers; (2) assure that services are of appropriate timeliness and quality; and (3) identify specific costs in dollars and FTE of delivering these services.
Criteria for Measuring Success To be determined.'
Stakeholder involvement To be determined.
FY 1996 Page 66 ExceIIence Plan l
U. S. NuclearRegulatory Commission DRAFT Strategy 6 Schedule The contractor assessment is expected to be conducted during FY 1999. The specific schedule is dependent on the performance of the contractor that will conduct a similar review of NRR programs starting in FY 1998 and the availability of funds and NRC staff.
Resources The resources for the contractor assessment during FY 1999 have not yet been estimated.
Lead Staff To be determined.
l I
FY 1998 Page 67 Excellence Plan
U. S. Nuclear Regulatory Commission DRAFT Strategy 8 Figure 8 - Evaluate Headquarters and Regional Support Programs Enhanced NRC Effectiveness 3
More EfRelent Use of NRC Resources f
L J
A
( Strategy Outputs)
(Program Outputs )
Assessment reports (TBD)
Identification of more effective and efficient means of for support functions S
Identincation of costs (FTE and $)
to mect the NRC's needs i
for desvery of certain support 3
services Delivery of support services in an o
appropriately timely and quality manner Training of staff Potential organizational changes
[
A A
Ea 2
n.
j
( Strategy Developmental Activities)
( Regulatory Programs and Activities )
e s
Contractor acquisillon (TBD)
Headquarters and regionalsupport 5
octivises.
Assessment critorie d=:':;zent (TBD) i b
2 Identlncetion of best practices (TBD) 5
?
a:
l l
FY 1998 Page 68 Excellence Plan
o 1
U. S. NuclearRegulatory Commission DRAFT Strategy 9
\\
l Strategy 9 Assess tne effectiveness, including integration and data sharing, of information systems supporting NRC's major business areas.
Purpose The purpose of this project is to assess the baseline measures of how well NRC application systems in each of NRC's eleven business areas are supporting the information goal in the NRC Performance Plan: Ensure that accurate information is available as needed to achieve the agency's strategic goals. This will enable effective targets to be set for improvement above the baseline, and will allow the development of appropriate strategies for improving application systems in specific business areas.
OClO has worked with the IT Council and program offices to develop an " Enterprise Model" for the agency which describes NRC's major functions and processes in eleven business areas.
Al; of the agency's information systems were mapped to the business areas by function and all systems were categorized as " primary" or " supplemental " The Enterprise Model is a key I
element of the Information Technology architecture that the agency is mandated to develop under the Clinger-Cohen Act of 1996 (formerly known as the Information Technology Management Reform Act). The Act defines an IT architecture as "an integrated framework for evolving or maintaining existing information technology to achieve the agency's strategic goals and information resources management goals." The development of this framework includes a systematic assessment of the way application systems are being used to support the agency's business functions, and development of strategies to improve information delivery to the agency's key business areas.
Approach Application systems will be assessed in three elements:
(1)
Level of satisfaction with the accuracy and availability of information to meet user needs in NRC's primary systems in each business area; (2)
Percent of high-level data entities' in the agency's primary systems that are entered once for all systems to access; and (3)
The cost, technical health, and ability of application systems to effectively support performance plan output measures in specific business areas.
The first two elements listed above are performance indicators for the information goal (Goal l
Vill.A.2) in NRC's Performance Plan. This project will assess the baseline measures for these l
High level data entities are the categories of things about which NRC maintains information,
- such as reportable events, employees, licensees, and nuclear power reactors.
[
FY 1998 Page 69 ExceIIence Plan
l U. S. Nuclear Regulatory Commission DRAFT Strategy 9 two indicators. To set a baseline for the first performance indicator, OClO will utilize a survey.
The staff will acquire the services of an industry leader in IT performance measurement who will provide standard survey instruments and benchmark our user satisfaction against that of users in other govemment agencies and in the private sector. This indicator will be a valuable tool to help the spor' sors of primary systems to identify areas for improvement, both in the quality of data being entered into agency systems, and in the usefulness of the data that is being maintained. In FY 1998 as a prelude to using this indicator in FY 1999, we will validate the list of primary systems, decide on the population to survey (managers in business areas, users of systems), develop and pre-test the survey instrument, execute the survey to establish a baseline, and establish a target for improvement in FY 1999.
To set a baseline for the second performance indicator, OClO will conduct a study on data sharing for the agency's high level data entities. High level data entities are the people, places, events, and things about which the NRC maintains information. There are about 100 of these (for example, licensees, employees, reportable events, reactors). This indicator is important becuse a low level of data sharing is typically associated with high level of data redundancy.
Redundant data results in excess data entry and maintenance costs, data reconciliation costs, and, more important, a higher rate of errors and inconsistencies. In FY 1998 as a prelude to using this indicator in FY 1999, the staff will identify data entities in NRC's primary systems, determine the criteria for systems meeting the measure (e.g., single database and controlled l
replication), calculate the baseline of compliant systems, and establish a target for improvement in FY 1999.
The third element of this project is to assess the cost, technical heaith, and ability of application systems to effectively support performance plan output measures for two of the eleven business areas in the Enterprise Model and to develop goals and strategies for making improvements. An evaluation of the " technical health" or " adequacy" of an application system is determined by how technically sound it is - does it use standard technologies, what platform (s) does it use, how well documented is it, how flexible is it to meet new requirements, how good is the vendor support, how maintainable, etc. The goals and strategies developed will be comprehensive, encompassing the entire business area rather than a single system or small group of systems. A prototype study of the Financial Management business area was begun in FY 1997 and will be available in draft in the early 1998. After review of the prototype, the approach will be applied to two other business areas in FY 1998:
Inspection / Enforcement / Investigation and Human Resources Management.
Critoria for Measuring Success This project is primarily an assessment of the baseline condition of how well NRC information systems are supporting the Agency's information goal based on the following criteria:
(1)
Level of satisfaction with the accuracy and availability of information to meet user needs in NRC's primary systems; (2)
Percent of high-level data entities in the agency's primary systems that are entered once FY 1998 Page 70 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 9 for all systems to access, and (3)
The cost, technical health, and ability of application systems to effectively support performance plan output measures in major business areas based on evaluations made by knowledgeable NRC staff and/or contractors.
l The measure of the success for this effort will then be whether these three criteria can be reliably obtained. For element 1, validity will be judged on the ability to use a tested and proven survey instrument. For element 2, validity will be demonstrated by multiple analysts reaching the same assessment as to whether a data entity is shared, based on the same input. For element 3, validity will be based on gaining a two thirds majority vote of the IT Business Council that the results of the evaluations were credible.
Stakeholder involvement The stakeholder for this project are all offices that sponsor or use agency application systems.
Users of application systems will be involved in the first element of the project through their participation in the survey. Stakeholder offices will be involved in the second element through review of draft information on data sharing for the systems that they sponsor. Stakeholder 4
offices will be involved in the third element through participation in rating the technical health and ability to support performance plan outputs for the systems they sponsor and review of
' draft materials conceming the evaluations of applications supporting business areas in which they have a stake. The IT Business Council will also be involved to assist in assuring that the evaluation methodology is credible.
Schedule and Milestones Elements 1 and 2 will be completed in FY 1998. The survey will be repeated annually or as required and will focus on verifying planned improvements from new systems efforts. For instance, we should see an improvement in the rating of inspection systems when RPS is implemented. The survey will measure user satisfaction before and after RPS implementation to assess the impact of RPS. Element 3 will be completed in FY 1998 and if there is agreement that the studies completed in FY 1998 are of sufficient value, the approach will be continued for the rest of the business areas. The schedule for completing the remaining eight business areas will be determined based on the actual cost of completing the first three areas and the available resources. Current estimates and budgets provide for completing two more business areas in FY 1999.
EY_1998 Element 1 Q1 Validate the existing list of primary systems in the NRC Enterprise Model Q2 Obtain assistance of an industry leader in IT performance measurement Q3 Develop and pre-test a survey instrument to measure satisfaction with accuracy and availability of information Q3 Execute the survey to establish a baseline Q4 Establish a target for improvement in FY 1999 FY 1998 Page 71 ExceIIence Plan
t
(
U. S. Nuclear Regulatory Commist. ion DRAFT Strategy 9 FY 1998 Element 2 Q2 Identify data entities in the primary systems 1
Q3 Determine criteria for measuring data sharing Q4 Calculate the baseline of compliant systems and establish a target for improvement in FY 1999 FY 1998 Element 3 l
Q2 Establish cost and technical health of the Human Resources Management l
business area i
Q4 Establish cost and technical health of the Compliance business area Resources l
)
Total resources currently budgeted for this work are $100K and 0.7 FTE in FY 1998. Elements 1 and 2 are estimated to require about 0.5 OClO FTE in FY 1998. In addition, about $50K will i
be required for survey design, execution and analysis. Element 3 is estimated to require about l
0.2 OCD FTE and $100K in FY 1998 for two business areas. Resources are budgeted within OClO for these efforts. Small amounts of stakeholder FTE will be required to complete the survey, assess the technical health of application systems, and review the studies.
)
Cost-Benefit Considerations l
The resources being spent on this effort are a small percentage of the overall resources being spent by the NRC on its applications systems. The NRC expects to obligate about $12-15
{
million annually on its application systems. The resources being spent on this project are about l
1% of this amount. Benefits are expected to include:
l I
1.
Providing data that will measure indicators of the accuracy and availability of information l
in NRC application systems and set targets for improvement as required by GPRA.
2.
Cost and technical health studies enabling the development of specific goals and strategies for future investment and improvements in the various applications.
3.
Improving retum on investment, avoiding duplication, and increasing integration of application systems.
These benefits are expected to be substantial but can not be accurately quantified because of their dependency on the as-is conditions being sought by this assessment.
l FY 1993 Page 72 Excellence Plan
U. S. NuclearRegulatoiy Commission DRAFT Strategy 9 Lead Office Staff and Staff from Supporting Offices Lead Office:
Project Manager: Jesse Cloud, OClO Other OCIO participants: Lew Clayman, Marianne Bernero, and Louise Lovell '
Key Participating Offices:
HR (Cost and Technical Health Study of Application Systems Supporting the Human Resources Management Business area)
NRR, NMSS,01, OE, AEOD, RES, and Regions (Cost and Technical Health Study of Application Systems Supporting the inspection / Investigation / Enforcement Business Area)
Other:
IT Council l
I FY 1998 Page 73 Excellence Plan
l U. S. Nuclear Regulatory Commission DRAFT Strategy 9 Figure 9 - Assess the effectiveness, including integration and data sharing, of information systems supporting NRC's major business areas r
3
[
Enhanced NRC Effectiveness o
J!
More Efficient Use of MRC Roseuroes L
)
A
( Strategy Outputs ]
( Program Outputs)
Survey of user satisfaction with Baseline and FY 1999 target information in primary IT measures of performance to assist in systems; establish targets for achieving the performance goal for improvement information (Villa 2)
Study on data sharing in primary Setting baselines and improvement
.3 systems; establish targets for targets will allow NRC to:
S improvement y
- Improve accuracy and availability For 2 of 11 major business of information in NRC application areas the assessment of cost, systems technical health, and confort; ance to performance
- Improve return on investment, plan goals; establish goals and avoiding duplication, and increasing strategies for improvement integraten of application systems.
JL JL (Strategy Developmental Activities)
( Regulatory Programs & Activities)
Validats list of primary systems in 11 major business areas:
2 the NRC Enterprise Model(1Q/98) a.
. Licensing / Approval as Obtain assistance of an industry
-Inspection / Investigation /
3 leader in IT performance Enforcement 2:
measurement (2Q/98)
-Identification and assessment of E
safety concerns y
Develop, pre-lost,and execute a
- Rulemak p
surveyinstrument (3Q/98)
- External a o
- Financial management Determine criteria for measuring
- Human resources management
.3 dets sharing and conduct study to
-Information management 5'
determine extent of data sharing in
- Faceties property management a:
the NRC business areas (3Q/98)
Estab8sh cost and technical heetth of the applications systems for Human Resources Management (2Q/D8) and inspection /
Inysstiposon/ Enforcer.ient basiness areas (4Q/98)
FY 1998 Page 74 ExceIIence Plan l
l 1
U. S. NuclearRegulatory Commission DRAFT Strategy 10 Strategy 10 Improve the effectiveness of information systems, including the information systems supporting financial management (STARFIRE).
i Purpose There are over 10 financial and mixed financial / administrative systems in use in the agency.
The use of different software and hardware is characteristic of their independent development.
These systems are used for a variety of purposes ranging from budget planning to contract / project management. When financial data is required for these systems, it is either manually re-entered from source documentation or accounting system reports, or downloaded, periodically, from off-line automated accounting joumals.
Historically, financial and mixed financial / administrative systems development within the NRC were not developed with an agency-wide approach nor integration capabilities. The numerous systems in the agency evolvsd over the years es requirements were identified, usually-independent of each other. There was a general perception that needs were very different and, therefore, independent systems were developed. Furthermore, appropriate technology was not available to integrate them cost effectively. The current situation, whereby maay separate, independently operating systems are in use that provide management information, is the result of insufficient systems planning and cooniination. The Office of inspector General report, Improvements Needed in Agency Oversight ofInformation Resources Management Activities, highlights this problem.
The current financial systems do not meet all of NRC's current financial and resource needs.
The agency's informational needs have changed in the part few years because of recent legislation on financial management and performance measurement. The Office of the inspector General has also noted financial system deficiencies in the annual audit of the financial statements. It would be difficult and costly to modify the current systems to provide I
the data required in today's environment.
I 1
The existing financial systems have the following shortcomings: (1) lack of integration of financial data with other functional areas, (2) frequency of re-entry of the same data into multiple source and summary applications, (3) an inordinate number of incompatible technologies used to support the current structure, and (4) a general state of aging technology l
l across the full spectrum of hardware, software, and communications which are costly to l
l-maintain.
Approach 1
l An agency-wide financial management system, referred to as STARFIRE, is under development to improve the efficiency and effectiveness of agency wide financial and resource management and to establish a single authoritative source for financial and resource i
i FY 1998 Page 75 ExceIIence Plan j
i l
l 5
U. S. NuclearRegulatory Commission DRAFT Strategy 10 i
information to support the mission of the agency, provide for adequate management reporting, l
and support decision-making necessary to carry out program and fiduciaq responsibilities.
In order to manage the development of this effort a project management structure has been put in place consisting of a business team and a technical team that report to an overall project manager. The project manager reports to a steering committee consisting of a CIO, CFO, and
- EDO advocate. The business team will focus on overall project planning and allocating and directing staff and resources. The technical team will be responsible for the project's day-to-day technical activities.
STARFIRE is being developed using the agency Systems Development and Life-Cycle Management (SDLCM) Methodology which includes the following phases:
Phase 1 - Define initial Proiect Requirements Phase one involves creating the blueprint for the System after understanding the "needs" of the offices and the agency, the decision to retain and modify existing systems, and the availability of existing systems and components that meet those "needs."
During phase 1, the project team produced:
A project charter which is a management document that identifies the high-level goals and objectives, background, scope, and high-level approach for development of the System.
A project action plan which contains the overall plan for performing and managing the project from start to finish. It contains the project management and software development plans and is updated at defined milestones during the project's life cycle.
- A project definition and analysis document which includes the scoping of the project, the requirements analysis, and analysis of attematives.
Cost ' estimates for the total System broken down by phases 2-5.
Phase 2 - Acouire Suncort Resources 1.
- The technology, staff, training, and any other resources necessary to complete the project will be acquired.
Phase 3 - Desion the Solution l
l The functional, data, and communication / network requirements will be determined; the user interface requirements will be documented; and integration plans will be prepared.
FY 1998 Page 76 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 10 l
l Phase 4 - Enaineer the Solution The plans developed in phase 3 will be converted into computer coding for the operation of the system.
Phase 5 - Deolovment of System l
The system will be placed into production. Partial deployment may take place as components are completed.
i l
Criteria for Measuring Success Once implemented, this agency-wide financial management system will:
Record financial events and summarize information to support the mission of the agency, provides for adequate management reporting, support decision making necessary to carry out fiduciary responsibilities, and support the preparation of auditable financial statements.
Ensure that financial and related program performance data is accessible and available on a reliable, consistent, and timely basis.
Provide for full integration of user requirements at all levels of management and elimination of multiple financial and manpower tracking systems and redundant data entry.
Improve the capability, timeliness, and user-friendliness over existing systems.
Comply fully with all Govemment-wide laws, regulations, and guidance.
Specific criteria have not yet been developed to measure the degree of accomplishment of these attributes. Criteria under consideration involve the retirement of a number of legacy systems, cost savings, improvement of the agency's prompt payment percentage, and timely compliance with new laws. Specific criteria will be developed during phase 3.
Stakeholder involvement in addition to the STARFIRE project team, represented through multi-office representation (including the regions), the team has established office points of contact for the current and future phases of STARFIRE. During Phase 1, the team met with office representatives to i
collect system and process information. Facilitated sessions were conducted with key l
personnel associated with specific agency business processes to determine agency-wide requirements. Interviews were conducted with office directors to provide information on STARFIRE development and collect additionalinformation. Program office branch and section FY 1998 Page 77 ExceIIence Plan I
l l
[
4 U. S. NuclearRegulatory Commission DRAFT Strategy 10 chiefs were also consulted to share system development information and collect additional information to ensure that data the offices require are considered in the development of the l
syrtem. As the project progresses through the different phases, team composition will be reestablished to meet optimum input and coordination for development, and office involvement will continue as necessary to ensure system utility is maximized and the needs of the customers are addressed.
Schedule and Milestones Phase 1 - Define initial Project Requirements STARFIRE Action Plan provided to the Commission January 1998 Phase 2-Acquire Support Resources TBD Phase 3 - Design the Solution TBD Phase 4 - Engineer the Solution TBD Phase 5 - Initial Deployment of System June 1999 Resources Funding of $7 million has been approved for this project, $5.7 million in FY 1998 and $2.3 million in FY 1999. In addition, a team of 6 people will be working on this effort for the duration of the project plus specific experts within the agency for each of the modules. Staff resources have not been specifically budgeted and will be reprogrammed within the agency as needed.
Cost-Benefit Considerations Significant benefits in cost and efficiency are anticipated following deployment of this system. A detailed cost-benefit analysis was provided as part of the CPIC process in January 1998. CPIC cost estimates show that the system will pay for itself in less than 5 years.
Lead Office Staff and Staff From Supporting Offices Lead Office: OCFO with close coordination with OClO and OEDO Steering Committee:
Current Phase i Team Members:
CIO Advocate-Amold Levin Les Bamett, NRR Ray Gustave, RES CFO Advocate-James Turdici Rickie Esall, OCFO Marty Kerlin, Region lli EDO Advocate-James Blaha Abe Eiss, NMSS Jeff Lankford, Region 11 Ron Thompson, ADM Project Manager / Business Manager John Bird, OCFO Technical Manager George Mathews, OClO Office representatives will be assigned to the team full-time as required.
Contractor Support: CISSCO FY 1998 Page 78 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 10 l
Figure 10 -Improve information Systems Supporting Resource Management (Starfire) r 3
e g
Enhance NRC Effectiveness l
Enhance Efficient Use of NRC a
O Resources
(
j A
j (Strategy Outputs )
( Program Outputs }
STARFIRE application modules:
Numerous outputs of activities I
Core listed below 3
-LCDS s
Portarmance measures 9
- Payrog o
- Procurement
- Travel i
1
- dudget formulation
- Data warehouse Hot line support i
STARFIRE Hardware Suite STARFIRE Training JL JL l-l i
Strategy Developmental)
[ Regulatory Programs and]
m Activities J
( Activities J
Capital Planning and Investment CORE Financial System l
control analysis
-Office management support i
e
- Generalledger l
2 Phased project plan:
- Budget execution a.
, Requirements Document
- Reporting l
l 4
- Project Charter Funds Control
- Project Action Plan Cost Accounting Fee Biuing g
Contractual activities Budget Formulation Travel management Best practaces evaluation Payroll / Personnel l
D Automated Procurement j
Relevant laws and guidance:
Performance Measurement
- Chief Financial Officers Act a
1990 E
- GPRA of 1993
- FederalFinancialMgmt improvement Act of 1996
- OMB Cir. A-127 r
3 Note: Initial deployment of the system is scheduled for June 1999. Schedules for intermediate steps are being finalized as part of the ongoing contractual negotiations.
L J
FY 1996 Page 79 ExceIIence Plan
U. S. Nuclear Regulatory Commission DRAFT Strategy 11 Strategy 11 Improve information systems supporting document and records management (ADAMS)
Purpose NRC's regulatory functions require the preparation, review, receipt, and distribution of m s.sive amounts of documented information. Today, the NRC operates in a predominately paper-based environment, expending significant resources to reproduce, catalog, and microfilm documents. These present document management practices significantly limit the ability to efficiently and quickly integ~ ate, share, and disseminate information. Furthermore, the agency's document locator system, NUDOCS, will be increasingly expensive to maintain because it is no longer supported by the vendor, and will require a costly fix for the year 2000 problem.
The primary objective of the Agency wide Document Access and Management System (ADAMO) is to provide the NRC with a single document management capability that meets current and future document storage and retrieval needs. A secondary objective is to provide
- the NRC with the ability to perform its document management processes more efficiently and effectively by managing its documents electronically rather than in a paper based mode.
ADAMS is an enterprise system that provides cradle-to-grave document management. The system will support electronic document creation or capture, workflow management, distribution, and search and retrieval by both NRC s'aff and the public. ADAMS will replace NUDOCS - an aging l microfiche-based, legacy document indexing system that has limited text search capabilities, runs on a Data General minicomputer and relies heavily on customized software. Over time, ADAMS also will replace numerous other agency document and text management systems.
ADAMS also will be a centralized e!ectronic document repository that will be acceptable to the National Archives and Records Administration (NARA) as NRC's official record keeping system.
It will help NRC comply with provisions of the Paperwork Reduction Act and the Electronic Freedom of Information Act. ADAMS will make documents more readily available to the public, and will reduce the time that it takes for NRC staff to respond to public, licensee, and congressional requests.
As a major element of NRC's information technology infrastructure, ADAMS will provide the functionality needed to support other agency applications, such as LIONS and STARFIRE. It will reside on NRC's local area network and primarily consist of an integrated suite of off-the-shelf software.
Approach The ADAMS project was submitted to OMB as a major project in its Capital Asset Plan. NRC conducted an Capital Planning and Investment Control (CPIC) cost-benefit analysis for this FY 1998 Page 80 Exwl:ence Plan m
U. S. NuclearRegulatory Commission DRAFT Strategy 11 project, identifying the project objective, assumptions, attematives, a cost comparison, benefit comparison, risk comparison, sensitivity analysis, and sponsor recommendation. Detailed functional requirements have been identified and a conceptual design developed to simplify document and records management processes and take advantage of current and emerging technology available in off-the-shelf products. These requirements, including an assessment of several pilot projects, formed the basis of the CPIC analysis. A robust automated document management capability with a fully integrated software package was selected that would allow the agency to maintain and retire its official records electronically and to discontinue most of the existing paper-based record keeping systems.~ A project structure has been put in place consisting of technical and business teams to support ADAMS detailed design, integration, implementation, and pionning activities.
Criteria for Measuring Success
- 1. The NRC will survey the level of user satisfaction with the accuracy w! availability of information in agency documents in FY 1998 to establish a baseline measure. The specific increase will be determined after the baseline has been established. Performance will be measured six months after ADAMS is fully deployed and employees have been trained to use it.
- 2. All other application systems developed in a client server environment that are capable of interface or integration with ADAMS will be able to access ADAMS for its documents.
- 3. By the end of FY 2000,50% of all extemally generated pages will be received in an electronic format in lieu of a paper copy format.
Stakeholder involvement i
To date, stakeholder involvement has focused primarily on NRC users and the public, with PDR l
librarians representing the public's interest in information retrieval and dissemination. 'n order to gather NRC users and the public's requirements, a series of focus groups were held with a -
cross-section of headquarters and regional staff that centered around the major document management processes that ADAMS will automate. This process resulted in a detailed I
description of ADAMS functional requirements.
The ADAMS project team is coordinating with staff working on agency application projects such
- as LIONS and STARFIRE, that are dependent on ADAMS. During the months of November l
l and December 1997 focus groups, with a cross-section of staff, are being established on i
l~
electronic submission of regulatory documents, end-user training, and various aspects of l
document management. Feedback from these sessions will be used to make adjustments in both the training and implementation process. Also in December a one-day ADAMS planning conference will be held with the regions, followed by visits to each region in January. In March 1998,50 users across the agency will participate in a Rapid Application Development process to refine ADAMS capabilities using ADAMS software and infrastructure upgrades.
FY 1998 Page 81 ExceIIence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 11 Previously, NRC participated with other private and public sector members of the Nuclear Information Records Management Association in a series of meetings and conferences on electronic information exchange (EIE). Once ADAMS is established internally, the NRC will engage its licensees in some forum, perhaps a series of workshops, to support optiona!
electronic submittal of regulatory documents.
Schedule and Milestones Develop conceptual design Completed Develop functional requirements Completed Conduct prototyper for proof-of-concept Completed Prepare CPIC analysis Completed Implement development laboratory Completed Complete design and engineering Q1/1999 Complete headquarters deployment Q2/1999 Complete regional deployment Q3/1999 Begin receipt of external electronic submissions Q3/1999 Complete conversion of existing document index Q4/1999 data Resources Resources to conduct this effort have been budgeted for FY 1998 and FY 1999. Costs incurred through the end of FY 97 were $3.46 million for requirements analysis, conceptual design, conducting pilots for proof-of-concept, acquisition of hardware for the development lab, and development / integration activities. Budget allocations are $9.024 million for FY 98 and $3.8 million for FY 99, with ADAMS being deployed Agency wide by October 1999.
Cost-Benefit Considerations A cost-benefit analysis was developed for the Capital Planning and Investment Control (CPIC) process. Assumptions for this analysis were: (1) the agency will develop and implement agency-wide document management rules that everyone will be required to follow, covering such items as standardized author-generated document descriptions and protocols for document routing and concurrence; (2) the agency will develop and implement regulations and resolve issues necessary to obtain submissions from extemal sources in an agency-specific electronic format. The cost estimates included in the analysis were based on the assumption i
that beginning in FY 2000,70% of all extemally generated pages will be received in an electronic format that requires no additional processing by the NRC; and (3) ADAMS will be a "this day-forward" system. It will start collecting newly created and received documents from the day that it becomes operational. Offices will have to budget for any existing documents they decide to convert.
A seven year life cycle (FY 1998 - FY 2004) was used that showed an estimated 569 FTE FY 1998 Page 82 Excellence Plan
. = _ - _ _ _
U. S. NuclearRegulatory Commission DRAFT Strategy 11 savings over the seven year period. Ninety-five percent of the estimated FTE savings come from reductions in the time administrative / clerical, technical / professional, and managers /
supervisors spend in managing, maintaining, and retrieving documents from local paper-based files. These savings are actually costs-avoided, and represent small fractions of time of many individuals. The cost of developing and implementing ADAMS over this period was estimated at $9.8 million higher than the status quo. Although ADAMS annual costs are projected ultimately to be lower than the status quo, the lower costs are not fully realized until FY 2002 when savings in costs of contractor support and space associated with records storage kick in.
l Eight other non-quantifiable benefits were also included in the cost-benefit analysis, including: a more effective approach to address common agency document management and workflow management needs; increased integrity of information; improved search capability resulting in quicker access to documents; streamlined document management; ability to reuse document text; more efficient document workflow processes; streamlined records management; and ability
)
of the agency to comply with federal laws and regulations.
Lead Office Staff and Staff from Supporting Offices ADAMS Coordinating Committee Proiect Manaoement Lynn Scattolini, OClO Lynn Scattolini, OClO-ovemil Arnold Levin, OClO Tom Kellam, OCIO - scheduling James Schaeffer, OClO Asclic t;cn Development and Integration IT Infrastructure Dan Graser, OClO - lead Mike Williams, OClO -lead I
Wil Madison, OClO Carol Agostino, OClO Beth DeWoody, OClO Dawn Oliver, OClO l
Matt Schmit, OClO Bill Szyperski, OClO John Sckzolas, OClO Rashida Alam, OClO Debbie Fling, OClO Information Manaaement Wayne Davis, OCIO - lead L
Focus groups established for: document creation; document intake, capture, and processing; records management; and information dissemination, staffed by the following individuals:
Kim Basile, OClO John Harris, OCIO Linda Schneider, OClO 1
Jeffrey Main, OClO Mike Collins, OCIO Jeff Bartlett, OClO Donnie Grimsley, OClO Regional participant, TBD FY 1998 Page 83 ExccIIence Plan I
U. S. NudearRegulatory Commission DRAFT Strategy 11 End-User Training Focus Group:
Beth DeWoody,0010 - lead Elizabeth Shelburne, OClO Kim Basile, OClO Carolyn Bassin, OHR Cynthia Dekle, OClO EDO representative (s) (TBD)
Electronic Submission of Regulatory Documents Focus Group:
- John Sckozlas, OClO - lead Brenda Shelton, OClO NMSS. NRR, OCFO, SECY, ASLBP (TBD) l FY 1998 Page 84 ExceIIence Plan
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U. S. NuclearRegulatory Commission DRAFT Strategy 12 Strategy 12 Improve the effectiveness of information systems supporting the reactor inspection and licensing programs (Reactor Program System - RPS).
Purpose The Reactor Program System (RPS) is being developed to fulfill program requirements which i
have evolved over the past several years. The initial problems to be fixed were highlighted in 1995 with both the staff's and GAO's findings relative to the difficulty in retrieving and analyzing information contained in inspection program documents, primarily inspection reports.
RPS is expected to satisfy increasing and critical requirements for improved information management and analytical capabilities associated with reactor oversight. The NRC needs a system that collects information once, at the source, and integrates information for both inspections and licensing in one location which can be correlated and analyzed against facility characteristics. RPS will provide this capability along with an integrated methodology for planning, scheduling, conducting, reporting and analyzing inspection, licensing and regulatory activitics. The system will also provide an analytical capability that will permit the linking, trending and analysis of plant performance information on an ongoing basis, so that plant performance characteristics can be better monitored. This will include automating relationships and searches so that inspection findings, event follow-up, and cause codes can be compared with facility characteristics and other program information to more effectively compare plant performance with similar plants.
The information includes inspection, licensing, plant performance assessment, events and emergency issues tracking, safety issues management, allegations management and other regulatory activities. RPS will provide information that is consistent, reliable, and readily accessible to about 1300 staff in NRC headquarters and regional offices. When completed, the RPS will replace 10 existing legacy systems serving NRR programs in headquarters and the regions, and provide data and a seamless interface to 5 other systems. RPS is designed to fit within the Agency's current client server and local area network infrastructure and be accessible via agency workstations using commercial-off-the-shelf software.
RPS is being designed and developed in a modular approach tailored to fit the regulatory programs it will support. At the same time, an enterprise approach has been taken with a global view of the entire RPS system so that the overall design, process model, data model and associated tables and naming conventions are in place and fit within the overall agency enterprise design.
RPS is expected to satisfy increasing and critical requirements for improving information management and analytical capabilities associated with reactor oversight. The system is expected to support a number of Agency program business areas including compliance management, licensing, and th3 identification and assessment of safety concems.
FY 1998 Page 86 Excellonce Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 12 Approach An interoffice team with representatives from NRR, IRM, and the regions was established to develop this system. A Capital Planning and investment Controf ' 'P]C) analysis was developed for this project identifying the project objective, asr 1, attematives, cost comparison, benefit comparison, risk comparison, sensitivity anesis.and sponsor recommendation. The CPIC was presented to the Commission in May 1997 and the development and deployment of RPS in headquarters and the regions was approved using a fully integrated client server environment including the incorporation of safety issues tracking and fullinterface to the enforcement action tracking system. The RPS project has been submitted to OMB as a major project for the NRC.
Criteria for Measuring Success Level of satisfaction with accuracy and availability of information in RPS. This will be measured using the same survey which will be used for Strategy 9.
Number of current older systems replaced by RPS and associated savings and other benefits. The current goal is the replacement of 10 older legacy systems. Progress on their replacement should be commensurate with the implementation schedule of the various RPS Components.
Levels of " single entry" and sharing of information, and commensurate reductions in the maintenance of duplicative data. This measure will be based on the percent of data elements entered once and shared throughout the entire RPS spectrum, compared to all data elements in the database.
Stakeholderinvolvement During the requirements development process, more than 150 individuals in the regions and headquarters were interviewed to develop the requirements for the inspection Planning (IP) and Automated Inspection Report System (AIRS) modules. A working group with members from each region, NRR, and IRM was established to provide continual input into the development 1
process. A rapid prototype development procedure was utilized so that the team could review the contractor's progress on a frequent basis. The group reviewed the " current" prototype approximately every three months during the development process. Training and Beta tests will be conducted in each region before the system is implemented.
Schedule and Milestones Primary system design, development and deployment milestones follow:
1 Overall System Conceptualization and Design Completed Requirements Determination, Design and Engineering for e
inspection Planning and Reporting Completed CPIC Analysis Completed FY 1998 Page 87 ExceIIence Plan p
1 L
d U. S. NuclearRegulatory Commission DRAFT Strategy 12 Development and Integration of Inspection Planning and Reporting Modules Completed Deployment of inspection Planning and Reporting Q2/1998 Deployment of Automated Inspection Reporting Q4/1998 Note: At this point RPS will be operational in the Regions.
Requirements Determination, Design and Engineering for Q3/1998 Licensing and Other Planning Complete Development of Licensing and Other Planning Q3/1999 Components Deployment of Licensing and Other Planning Modules Q4/1999 Complete Development and Deployment of any Remaining Q1/2001 Parts including Interfaces with other Agency Systems
' Preliminary testing of the AIRS module has indicated that certain technical issues pertaining to connectivity and rich text functionality need to be resolved prior to implementation. A testing of possible attemative solutions is underway. This testing may impact the schedule for AIRS deployment.
Resources The total resources currently budgeted for this work are $1.6 million and 3.5 FTE in FY 1998 and $1.2 million and 3.5 FTE in FY 1999, depicted as follows:
$ in millions FY 1997 FY 1998 FY 1999 FY 2000' FY 2001 TOTAL Full acquisition:
1.1 0.7 0.4 0.4 0.1 2.7 Total, sum of stages 1.1 0.7 0.4 0.4 0.1 2.7 (excludes maintenance)
Maintenance:
0.1 0.2 0.4 0.4 0.4 1.5 (Planning and some developmental activities took place prior to FY 1997. CPIC analysis conducted in FY 1997 cost approximately $35,000.)
FTE-FY1997 FY1998 FY1999 FY2000 FY2001 Total NRR 3.0 3.0 3.0 2.5 2.0 13.5 CJO
.5
.5
.5
.5
.5 2.5 FY 1996 Page66 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 12 Cost-Benefit Considerations A 7 year life cycle (FY 1998 - FY 2004) was used to cost altematives of full implementation of RPS as compared to the status quo. Estimated undiscounted dollar costs and FTEs for completion of RPS is $5,042K and 102.8 FTE. The estimated cost to maintain the status quo was $7,566K and 212.9 FTE. The estimated cost savings are primarily (about 67%) mainframe operations, maintenance and timesharing costs with another 20% being data entry / data quality-related. Over half the estimated FTEs saved (" costs avoided" rather'han staff reductions) are associated with manual inspection and licensing analysis activities with 27% being associated with data entry / data quality activities.
The basic assumption used by NRR's CPIC for RPS was that the use of the Safety Information Network (SINET) on the NIH mainframe by other NRC organizations would continue through the end of FY 2000. To realize the total estimated cost savings of an RPS altemative which allows NRR to discontinue the use of SINET, all other NRC use of SINET and the need to maintain it at NIH must be discontinued by the end of FY 2000.
In addition to the dollar and FTE savings, other benefits that have not been quantified are expected in the fobowing areas:
1.
More consistent data from single source entry.
2.
More efficient sharing of information 3.
Better analysis capabilities for licensing and inspection documents 4.
Faster and more efficient reporting capabilities 5.
More flexible ad hoc reporting 6.
More accurate and timely fee data 7.
Better data integrity 8.
Better integration of licensing and inspection information 9.
Better information for decision making by management Lead Office Staff and Staff From Supporting Offices Frank Gillespie, NRR Larry Yandell, Region IV Les Bamett, NRR John Pellet, Region IV Mike MacWilliams, NRR - RPS Project Manager Mike Kaltman, NRR - AIRS Project Manager Bill Usilton, IRM Technical Manager Conchita See, NRR Beverly Jones, NRR Tu Tran, IRM Janet Lanning, Region I Steve Vias, Region 11 Nick Shah, Region lli l
Mary McCormick-Barger, Region Ill FY 1998 Page 89 ExceIIence Plan l
l L_-_________
U. S. NuclearRegulatory Commission DRAFT Strategy 12 l
Figure 12 - Improve the Effectiveness of Information Systems Supporting the Reactorinspection and Licensing Programs (Reactor Program System - RPS) r m
j Enhanced NRC Effsethreaees More Efnelent Uso of NRC Reseastees y
(
)
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( strategy Outputo)
( Program Outputs) sofhrere module Enhanced consistency, 2
deployment:
retsbety, and accessabaty of 1
-inspection planning regulatoryinfonnation 3
module (3#98) o
-inspecton reporting Factor and more efileient module (04/93) sharing of regulatory
- Lk Tri% and other information planning module (Q4/9g)
- deployment complete improved accuracy and (Q1#01)
Integrity of date system usage guldence (ongohg) staff treining (ongoing)
A A
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E
,Activinos
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Concept development Reactor 5:;::!: program
)
Capital pionning and Reector Econsing program Investment controlanalysis p.
Reactor enforcement program
- j Formation of staff advisory II group e
sone.ro d hard re
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senchmark one vandation of g
appucations FY 1998 Page 90 ExceIIence Plan
U. S. Nuclear Regulatory Commission DRAFT Strategy 13 Strategy 13
)
i Assess the NRC organizational culture and make recommendations for improvement.
1 The Office of the Inspector General (OIG) has an initiative in this area to assess NRC saftey culture independently of this strategy. As directed by the Commission, the activity on strategy
- 13 will be held in abeyance pending review of the results of the OIG initiative. If after 1 year from the Commission approval of the Excellence Plan the results of the OIG initiative do not dovetail with the staff's objectives, the staff maypropose to the Commission to proceed with the plans describedin this strategy.
Purpose L
All organizations have particular cultural traits which help its members define how they are expected to behave. It is recognized that in order to make significant and long lasting improvements in the effectiveness and efficiency of NRC activities, fundamental changes in our work environment that cross organizational and functional boundaries may be necessary. This was a significant theme developed in several workshops held in July 1997 with a cross section of NRC staff. Issues discussed in this context included staff empowerment, communications between management and staff, organizational inconsistency and parochialism, and j
acceptance of differing views. Addressing issues of this type will be necessary in order to make i
significant improvements in agency activities. There was a consensus among workshop i
participants that it would be appropriate to conduct periodically a cultural survey of NRC employees and managers in order to identify areas for improvement and to initiate a baseline for comparison measurement.
Approach Organizational culture is simply the generally accepted way people work and behave on a daily basis within an organization. It consists of their commonly accepted beliefs, values, and norms of behavior. Experience within many different types of organizations has found that organizational culture is best developed over a period of time, growing from the behavior of key managers and stakeholder, who generally model the cultural behavior for employees and mangers through their actions. Organizational members may reinterpret these behaviors in terms of everyday activities, however if the behavior of employees deviate too far from the 1
cultural norms reenforced by key managers and stakeholder, organizational or cultural dissonance may occur. Such dissonance may cause disruption to the status quo making it difficult for the organization to carry out its work in the most productive and effective manner.
Defining these cultural traits can be a difficult process, and improving or changing them can be even more difficult. In order to provide an unbiased assessment of NRC's organizational culture HR will conduct a three-phase project.
i FY 1998 Page 91 ExceIIence Plan I
U. S. NuclearRegulatory Commission DRAFT Strategy 13 Phase I - Conduct Survev.
HR will develop an inter-agency agreement with the Office of Personnel Management to utilize i
the OPM Organizational Assessment Survey (OAS) among all NRC employees. The OAS l
instrument, based on a comprehensive literature review and rigorous development, has been utilized by a number of Federal agencies. The OAS has been fully validated and has shown to provide reliable data. Specific questions related to NRC will be included in the instrument, thus providing NRC information unique to this agency. The survey will measure the organizational conditions such as: the percentage of NRC staff that perceive the NRC workforce as motivated, ethical, and supporting cultural diversity (as stipulated in the FY1999 Performance Plan);
whether there are conflicting goals or a shared vision; whether problems are seen as an opportunity for improvement or are hidden or rationalized; whether good performance is properly recognized and rewarded; whether the focus is on short term or long term improvement; and whether decisions are made using objective data or seemingly arbitrary.
This will establish the as-is condition related to employee perceptions of NRC culture and working conditions.
Phase 2 - Focus Grouns.
Following the survey, further validation of the results as they apply to NRC will be conducted through a series of focus group meetings. Fifteen percent of agency employees will be invited to participate in this phase. Focus groups will be conducted jointly by OPM and our current organizational development contractor, Resolution Dynamics, Inc. Focus groups will explore the results of the OAS.
The result of Phase 1 and 2 will provide the NRC with data related to employee perceptions of our organizational culture, a benchmark comparison of NRC data with data on best practices from other govemmental and private entities.
Phase 3 - Action Plannina.
Following the survey and focus group sessions, and the review of agency benchmark information, the NRC, through its contractors, will identify several of the most significant issues and develop action plans targeted for improvement. The issues will be selected by the EC based on input from management and the NTEU.
Criteria for Measuring Success
- 1. Survey results indicate perception of employees and managers of NRC culture, values, and norms at current time. This will not be measured in quantitative terms, rather qualitative measures must be used by agency management.
- 2. Survey results compared with other Federal agencies used as a benchmark for assessing NRC and establishing goals for improvement. This measurement will be found useful as a FY 1998 Page 92 Excellence Plan
U. S. NuclearRegulatory Commission DRAFT Strategy 13 means of comparison and as a measure of progress in future assessments.
- 3. Survey questionnaire return to be at a statistically acceptable rate of return for the number of individuals surveyed.
- 4. 80% of the recommendations proposed by HR to be accepted by DEDM.
Stakeholder involvement All employees of the agency are stakeholder. All agency employees will be sent the survey questionnaire and approximately 5% of the staff will be asked to participate in focus groups.
The results of the survey questionnaire will be made available for staff review. Staff will be given the opportunity to provide feedback comments on the survey or its results directly to management or through their union representatives.
- The results of the OlG Safety Culture Suivey will be considered in scheduling the survey and in determining recommendations resulting from the data. The NTEU will be involved and kept informed throughout this process.
Schedule and Milestones Milestones are listed below; schedule to be determined pending completion of the OlG safety l
culture audit.
- 1. Interagency agreement with OPM to conduct survey.
- 2. Prepare draft survey for r? view by Partnership, Committees, EC.
i
- 3. Partnership Review completed.
- 4. Survey printed and distributed.
- 5. Results tabulated. Report submitted by OPM.
- 6. Focus Groups selected.
- 7. Focus groups complete meeting with contractors.
- 8. OPM prepare focus group report and final survey report.
l
- 9. Submit final report to Commission.
i
- 10. Prepare plan for dealing with issues.
- 11. Prepare report to Commission on goals for improvement and specific action items to be implemented.
Resources l
l The total resources estimated for this work are $50 K and 1.5 FTE in FY 1998. Approximately
$50K will be needed in FY 1998 to cover cost of contracts and has not been budgeted.
Approximately 1 FTE to be utilized by HR and approximately.5 FTE to be utilized by other Offices. These resources can be absorbed.
FY 1996 Page 93 Excellence Plan
9 U. S. NuclearRegulatory Commission DRAFT Strategy 13 Cost-Benefit Considerations The initial cost of developing this strategy as described above will be approximately $50K and 1.5 FTE in FY1998. The expenditure in this activity is a relatively small percentage of our overall personnel costs. We project specific dollar cost benefits and non-cost benefds to result from completion of this activity. Identifying human resource issues which are helping and hindering performance of the agency mission will be reflected in this activity. Clearly identifying issues and arriving at realistic recommendations for improvement, then implementing improvement projects should help improve job satisfaction, reduce sick leave usage, and promote efficiency and effectiveness of employee contributions. For example, it is estimated that a 1% raise in employee productivity equals approximately $2.6 million in salary and overhead expenditures. In terms of dollars specific cost-benefit figures cannot be determined at this time since the results of the survey are not available, but it is expected to be substantial in terms of increased efficiency and productivity of the staff.
Cost Considerations Assumptions:
Estimate 1 FTE NRC effort in HR
$100,000 Estimate.5 FTE other NRC staff outside of HR
$50,000 Estimate contract funding for survey development, distribution, focus group follow-up
$50,000 Total estimated cost
$200,000 Total estimated cost per employee
$46.75 Comparison costs Estimated cost if purchased through private sector contract
$109.25 per employee.
Estimated cost if accomplished totally in-house
$131.35 per employee.
Lead Office Staff and Staff from Supporting Offices Lead Office: HR FY 1998 Page 94 ExceIIence Plan
\\
~
U. S. NuclearRegulatory Commission DRAFT Strategic Plan NRC's Strategic Plan in the Strategic Arena of Excellence The following excerpt frorn the NRC Strategic Plan for FY 1997 - FY 2002 is provided for reference.
Excellence i
i Goal: Carry out the NRC regulatory program efficiently and effectively.
Striving for regulatory excellence in all NRC functions is both desirable and necessary to maintain an effective and efficient regulatory framework in today's changing environment. _ The NRC can improve its l
intemal performance by ensuring that its people and processes function with a goal of excellence. As used in this context, excellence includes both regulatory effectiveness and efficiency, and applies to all NRC functions. Regulatory effectiveness denotes a regulatory framework for ensuring public health and safety that is clear, coherent, logical, consistent, reliable, and technically sound. Efficiency connotes a regulatory framework which is cost effective for both the NRC and its licensees. As stated in the NRC's Principles of Good Regulation, the Amencen taxpayer. the rate-paying consumer, and licensees are all entitled to the best possible management and administration of regulatory activities. Where several effective attematives are available, the option which minimizes the use of the resources should be adopted.
l' The performance goals for measuring results toward meeting the general goal are:
Implement the agency's plan for regulatory excellence l
Evaluate and implement needed improvements for five major NRC l
processes by July 1,1999 A major factor or assumption affecting our strategy to achieve our goal of excellence is as follows:
The Administration, the Congress, and the Public will continue to expect cost-effective programs j
throughout the Govemment.
Strategy We will make regulatory excellence the comerstone for all of our strategies and activities.
We will proactively examine our programs and performance in order to improve the way we do our work through a comprehensive, systematic, agency-wide approach to program assessment and improvement.
We will implement changes to improve the ehectiveness and efficiency of our reguls. tory programs and our management and support activities.
We will make our improvements in a continuous, systematic, and open manner with the support and input of our intemal and extemal stakeholder.
We will provide training and development to our staff to enable us to achieve excellence in our l
organizational and individual performance.
' We will eliminate unnecessary regulatory requirements and policy statements, and streamline our processes, including using information technology to help improve efficiency.
FY 1998 Page 95 ExceIIence Plan l
L
h I
1
s
-w Response to lasues from Staff Requirements - SECY-97-225 -
Enhancing NRC Effectiveness and Efficiency item a:
l' Clearly identify the role and value added by the Regulatory Effectiveness Organization in building on existing initiatives. Any new responsibilities and roles for RES, AEOD, 01, and OE which are specifically focused on enhancing NRC effectiveness and efficiency should be identified.
I
Response
l The focal point for the coordination, development, and promotion of the Excellence Plan will rest with the Deputy Executive Director for Regulatory Effectiveness (DEDE). The Regulatory Effectiveness Organization, which includes the offices of AEOD, RES,01, OE, and the staff that reports directly to the DEDE, will be responsible for developing, collecting, and synthesizing i
candidate issues for assessment or improvement; conducting workshops with the public and industry for the purpose of describing ongoing efforts and soliciting candidate issues for improvement; and promoting employee awareness of the program and results. The f
implementation of the individual Excellence Plan strategies will be the responsibility of the offices designated as involved in each strategy. The Regulatory Effectiveness Organization l-has lead responsibilities for the implementation of the following strategies:
1 Strategy 3 - Enhance safety decision making, make more efficient use of NRC resources and reduce burden on licensees through use of PRA insights.
l Strategy 5 - Develop a process and identify candidate issues for improving the effectiveness and efficiency of rules, standards, regulatory guidance and their i
application.
Strategy 6 - Increase effectiveness and efficiency of the regulatory process by expediting evaluation of industry initiatives and promoting more rapid adoption of consensus standards l
The Regulatory Effectiveness Organization will support the implementation of the other strategies but will not play a special role in them beyond the coordination and presentation of
- these strategies in the Excellence Plan. The responsibilities and roles of the Regulatory g
Effectiveness Organization which are specifically focused on enhancing NRC effectiveness and efficiency are discussed in more detail on page 7 of the FY 1998 NRC Excellence Plan.
Item b:
Defer action on strategy 13, assessing the NRC culture, in view of the IG's initiative in this area.
If, at the end of a year, the results of the IG initiative do not dovetail with the staff's objectives, the staff may propose to the Commission to proceed with its own study.
[
l
p
Response
As requested by the Commission, the staff activities pertaining to Strategy 13, assessing the NRC organization culture, will be deferred in view of the IG's initiative in this area.
Item c:
Mount a more inclusive effort for the materials program. Specifically, the need ivr an improved progmm to assure licensee control and accountability of radioactive devices and sealed p
sources should be included as a candidate in strategy 5.
Response
The need for an improved program to assure licensee control and accountability of radioactive devices and sealed sources will be included as a candidate issue under strategy 5. This issue and others developed as part of this strategy (affecting both materials and reactor issues) will be evaluated and prioritized to determine whether they rise to the level of inclusion in the Excellence Plan as an independent strategy or should be pursued in another manner. Further, j
the scope of strategy 5 will be expanded to more broadly include materials issues in FY 1999 when resources can be made available for this effort. Note that the staffs actions in this area may be modified to be consistent with the Commission's response to SECY-97-273, "lMPROVING NRC'S CONTROL OVER, AND LICENSEES' ACCOUNTABILITY FOR, GENERALLY AND SPECIFICALLY LICENSED DEVICES" item d:
Consider incorporating efficiency improvements in the agency-wide events assessment and review of operational data function, and other outstanding candidate efficiency imp <ovements discussed in SECY-95-154, in the Regulatory Excellence Plan
Response
SECY-95-154 identified seven major candidate efficiency improvements in the following areas:
Safety Research Agreement State Program and Interface with States Events Assessment and Review of Operational Data Incident Response Maintenance of Staff Expertise Interoffice Administrative / support Overlap Training and Development in an SRM dated August 30,1995, in response to SECY-95-154, the Commission disapproved tM specific recommendations provided and stated that the candidate efficiency improvements should be considered as part of the strategic assessment and rebaselining initiative that was upcoming at that time. Activities in most of these areas were undertaken to address efficiency improvements. The areas of Safety Research and Agreement State Program and Interface 2
3 with States were addressed as part of DSI-22 and DSI-4 respectively. The areas of Maintenance of Staff Expertise and Training and Development were addressed in DSI-18, Staffing and Core Capabilities, and are also reflected in Excellence Plan strategy 7 on core competencies and core capabilities. The efficiency recommendations in the area of Intero'fice Administrative / Support Overlap are being considered as part of Excellence Plan strategy 8.
The efficiency recommendations identified in SECY-95-154 for incident response were considered and, where appropriate, have either been implemented, or are being implemented.
Further, based on recent interaction with the Commission, AEOD will conduct a broad self-assessment of the incident response function in order to identify what initiatives could improve the efficiency and effectiveness of the incident response program and facilities. It is anticipated that this self-assessment will be conducted by a team composed of experienced NRC incident response program members, including representatives from a region, the reactor safetv team, the protective measures team and the incident Response Division of AEOD. THs self-assessment will also utilize contractor support available thmugh the OCFO to provide team training, coaching, and facilitation in arriving at conclusions and recommendations. Input will also be solicited from extemal stakeholder such as the States (e.g., The Council af Radiation Control Program Directors) and Utilities (e.g., NEI). It is anticipated that the self-assessment will be completed by the end of September 1998.
The efficiency recommendations identified in SECY-95-154 in the area of Events Assessment and Review of Operational Data have been addressed and where appropriate implemented.
However, in response to the SRM and the continuing need to find resources for high priority tasks, an interoffice assessment group representing AEOD, NRR, NMSS and OSP has been formed to address the related issues raised in the " Strategic Assessment Phase I Final Report."
These issues included: what the appropriate level and balance of operating experience review should be among offices; how events assessment and review can be more efficient and effective; how the level of collection and review of operating experience should respond to changes in the NRC inspection program, risk and performance considerations, and licensee self-assessment; what the appropriate level of reliance on industry review of operating experience should be; and what the appropriate level of oversight of the agency's overall operating experience review and feedback should be to ensure responsiveness to changing intemal and external factors. The group will also consider the questions raised in SECY 154, including: what the future environment for events assessment and review will be; what operational data should be reviewed and analyzed; what is the appropriate level of redundancy, diversity, and independence of operating experience review; whether events assessment functions can be consolidated; what is the usefulness, necessity, and value of current office events assessment and review functions; and whether selected activities can be terminated.
The results of this assessment will be reported separately to the Commission by November 30, 1998, along with appropriate recommendations including whether any resultant actions should be addressed in a future update of the Excellence Plan.
Item e:
Discuss how and when it will integrate the initiatives outlined in SECY-97-225 into the routine agency phnning process, and when the Commission can expect to " sunset" this effort as a separate aanagement activity.
3
Response
As indicated in Figure 2 from the Commission paper, the Excellence Plan is intended to be updated periodically through Program Review Committee (PRC) and Executive Council (EC) l review of candidate assessment and improvement issues to determine whether these issues warrant consideration as Excellence Plan strategies. In the absence of the selection of new excellence plan strategies as part of this periodic update process, the Excellence Plan will not be revised and maintained as a formal document. Impacting the decision to maintain the Excellence Plan will be whether the key principles incorporated into the Excellence Plan strategies, such as stakeholder involvement, criteria for measuring success, and clear cost / benefit considerations becomo integrated into the more routine agency improvement activities. When the decision is made to " sunset" the maintenance and revision of the Excellence Plan, the activities shown enclosed in a dashed line in Figure 2 in the Commission paper can cease to exist and the ongoing efforts of the planning, budgeting, and performance management process, supplemented by input from strategy 5, will ensure a continued, comprehensive, and systematic approach to program assessment and improvement.
4
Attichm:nt 3 RESOURCE ESTIMATES ASSOCIATED WITH EXCELLENCE PLAN STRATEGIES r
Strategy FY 1998 FY 1999
$K FTE
$K FTE
- 1. Evaluate the reactor inspection program 689 11.45 0.76
- 2. Evaluate the licensing support &
366 3.7 2.6 regulatory oversight of the operating reactors program
- 3. Enhance safety decision making through 4,000 25.0 4,000 25.0 the use of PRA insights
- 4. Improve the medical regulatory program 189 6.0 110 5.1
- 5. Develop a process & identify issues far 200 4.0 5.0 improving the effectiveness & efficiency of rules, standards, and regulatory guidance
- 6. Increase effectiveness & efficiency of the 10.5' 10.5' regulatory process by expediting evaluation of industry initiatives and promoting more rapid adoption of consensus standards
- 7. Assess core capability needs and improve 265 1.0 core competencies
- 8. Evaluate headquarters and regional To be determined support j
- 9. Assess the effectiveness of information 150 0.7 s,vstems supporting NRC major business areas
- 10. Improve information systems supporting 5,700 6.0 2,300 6.0 resource management (STARFIRE) i
- 11. Improve information systems supporting 9,024 3,800 j
document & records management (ADAMS)
- 12. Improve information systems supporting 1,600 3.5 1,200 3.5 the reactor inspection & licensing programs (RPS)
- 13. Assess the NRC organizational culture Deferred
'This estimate could range higher as determined by the implementation efforts.
___--______--_ _ -