ML21322A318
| ML21322A318 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/2021 |
| From: | Matt Bartlett Division of Fuel Management |
| To: | |
| References | |
| Download: ML21322A318 (5) | |
Text
Tracking the Smarter Licensing Recommendations Smarter Inspection Enhancement Project Status as of 10/30/2021
Background:
The NRC charter for building a smarter fuel cycle licensing program is dated April 26, 2019, (ADAMS Accession No. ML19115A016). On April 30, 2020 (ADAMS Accession No. ML20099F354), the NRC smarter licensing working group issued a report that included recommendations for addressing the collected suggestions from both internal and external stakeholders.
Division management endorsed the implementation of the recommendations and directed the staff to develop an action plan (AP) dated July 10, 20220 (ADAMS Accession No. ML20184A267). The AP grouped the implementation of the recommendations into three general categories: Near-term actions, Mid-term actions, and Long-term actions.
The current focus of the smarter licensing team is to incorporate the Near-Term recommendations into the guidance and procedures tracked in the Division Instructions (DIs) entitled: LIC-FM Licensing Overview, LIC-FM Acceptance Review Process, LIC-FM Requests for Additional Information (RAIs), and LIC-FM Safety Evaluation Reports (SERs). Work on the Mid-Term recommendations to develop job-aids, templates, and training have started and will increase as the NRC staff transition for DI development to implementation. Work on the Long-Term recommendations will be processed as resources and priorities allow.
Objective:
To provide a status update on the staffs ongoing efforts to revise and implement approved smarter licensing recommendations, which consist of Near-, Mid-, and Long-Term recommendations.
ACCOMPLISHMENTS 1.
Provided Status Update at the Fuel Facilities Stakeholder Meeting, March 2021, see ML21120A058 2.
Provided Status Update at the Public Meeting, June 2021, see ML21200A120 3.
The Near-Term recommendations have been incorporated into the following DIs which are in the final stages of concurrence:
LIC-FM-1 Licensing Overview (Draft),
LIC-FM-2 Acceptance Review Process (Draft),
LIC-FM-3 Requests for Additional Information (Draft), and LIC-FM-4 Safety Evaluation Reports (Draft) 4.
Implementing recommendations as summarized in the table below.
NEXT STEPS 1.
Finalize the DIs and make them publicly available.
2.
Conduct NRC staff training on the Near-Term recommendations in the finalized DIs.
3.
Develop job-aids and templates for implementations of the Mid-Term recommendations.
Points of
Contact:
Matthew Bartlett, Smarter Licensing Project Manager, NMSS/DFM, 301-415-7154 Jake Zimmerman, Branch Chief, NMSS/DFM, 301-415-1220
2 Tracking Implementation for the Smarter Licensing Recommendations Recommendation DESCRIPTION Task Status Finish Date NT-0 16 Make internal guidance publicly available.
Make DIs Public Future 2022 19 Ensure Smarter Licensing (SL) revisions to the Division Instructions (DI)s are discussed during training Training on DIs Future 2022 32 Harmonize, incorporate good practices, and combine, where appropriate, the staff review procedures and instructions within DFM.
Develop Division Instructions (DI)
Ongoing End of 2021 NT-1 1
Estimate completion date based on the established schedule and share with licensee DI, LIC-FM-1, 2,
& 3 Ongoing End of 2021 2
Estimate the hours needed for the review and share with the licensee.
DI, LIC-FM-1, 2,
& 3 Ongoing End of 2021 3
Establish regular and periodic status calls with the licensee.
DI, LIC-FM-1 Ongoing End of 2021 6
Ensure that milestone schedule includes the entirety of the review including areas beyond the technical review (e.g., environmental, external agencies)
DI, LIC-FM-1, 2,
& 3 Ongoing End of 2021 29 (P1)
Improve early alignment between the NRC staff and the applicant on the scope and content of the submittal/review.
DI, LIC-FM-1 & 2 Ongoing End of 2021 29 (P2)
Seek early alignment with the review team on the scope and details of the review.
DI, LIC-FM-1 & 2 Ongoing End of 2021 NT-2 4
For new, large, unique, or complex actions, consider holding meetings with the applicant during the pre-application phase or during the acceptance review.
DI, LIC-FM-1 & 2 Ongoing End of 2021 7
(P2) 7a - Coordinate site visits at the appropriate time and include non-technical staff who support the review (e.g., Office of General Counsel).
7b - Consider holding meetings or site visits early in the process, during pre-application or acceptance.
DI, LIC-FM-1 & 2 Ongoing End of 2021 27 (P1)
Hold early team meetings to align on the scope of the review and identify any unique review considerations.
DI, LIC-FM-1 & 2 Ongoing End of 2021 NT-3 5
Allow for flexibility within the review metrics to improve efficiency in the review.
DI, LIC-FM-1 & 2 Ongoing End of 2021 10 (P2)
Evaluate the tracking of Requests for Additional Information (RAI) in Web-Based Licensing (WBL) and ensure they can be tracked to completion.
DI, LIC-FM-1 Ongoing End of 2021 17 Make sure WBL tracks Nuclear Energy Innovation and Modernization Act metrics.
DI, LIC-FM-1 Ongoing End of 2021 28 Allow PMs to improve the review efficiencies by allowing flexibility within the review metrics.
DI, LIC-FM-1 & 2 Ongoing End of 2021 Completed In Process Projected
Tracking Implementation for the Smarter Licensing Recommendations-Continued 3
Recommendation DESCRIPTION Task Status Finish Date NT-4 7
(P1)
Hold meetings with the licensee to support resolution of the RAI process.
Make the guidance publicly available for RAIs.
DI, LIC-FM-1, 2,
& 3 Ongoing End of 2021 8
Ensure the RAIs have a documented regulatory basis.
DI, LIC-FM-3 Ongoing End of 2021 9
9a - Develop and provide draft RAIs to the applicant and consider a call or site visit to discuss them.
9b - Also hold a call with the applicant to discuss their draft RAI responses.
DI, LIC-FM-2 & 3 Ongoing End of 2021 10 (P1) 10a - Allow staffs RAIs to be developed and issued in a staggered or phased manner on complex requests.
10b - Ensure the timeline for RAIS is considered in the metrics.
DI, LIC-FM-3 Ongoing End of 2021 11 Clarify that calls to discuss draft RAIs do not always need to be public meetings, if they are only for clarification.
DI, LIC-FM-3 Ongoing End of 2021 12 Ensure the draft safety evaluation report (SER) is developed and provided to the project manager (PM) along with the RAIs.
DI, LIC-FM-1 and LIC-FM-3 Ongoing End of 2021 13 (P1)
Have a transition plan for when reviewers leave and are replaced.
DI, LIC-FM-1 and LIC-FM-3 Ongoing End of 2021 22 Develop a way to electronically track RAIs such as a dashboard.
DI, LIC-FM-3 Ongoing End of 2021 Completed In Process Projected
Tracking Implementation for the Smarter Licensing Recommendations-Continued 4
Recommendation DESCRIPTION Task Status Finish Date MT-1 15 Allow for an adjustable review scope and schedule based on risk during the assignment and alignment meeting. Also, develop job-aids that describes how the assignment and alignment meting should identify scope and incorporates the risk tool.
LIC-FM-1, 2, & 3 job-aids, &
training Ongoing End of 2021 18 Ensure the assignment and alignment meeting has the appropriate scope and identifies the individual needed to support the review.
LIC-FM-1 & 2, job-aids, &
training Ongoing End of 2021 21 Update the guidance and training to ensure staff document the scope and focus of licensing reviews in the SERs.
LIC-FM-1 & 4, job-aids, &
training Ongoing End of 2021 25 (P1)
Facilitate inspector involvement early in the licensing review process.
LIC-FM-1,& 3, job-aids, &
training Ongoing End of 2021 27 (P2)
Provide appropriate training and job aids on the need to consider a holistic approach to gain early alignment on the expected scope of the review.
Provide for the ability to modify the scope of the review, with management approval, if needed.
LIC-FM-1 & 2, job-aids, &
training Ongoing End of 2021 29 Ensure staff are appropriately trained on the procedures for reaching early alignment between the NRC staff and the applicant on the scope of the review.
LIC-FM-2, job-aids, & training Ongoing End of 2021 30 Develop a template for creating roadmaps and job-aids that describe the process for conducting technical reviews for various types of facilities and licensing actions.
Creat a roadmap for licensing actions and templates Future 2022 31 RISK Tool - Consistent with #15, 29, 30, develop processes and technical job aids to support risk-informed reviews and decision making as resources are available.
LIC-FM-1 & 2, Expand the risk tool Future 2023 Completed In Process Projected
Tracking Implementation for the Smarter Licensing Recommendations-Continued 5
Recommendation DESCRIPTION Task Status Finish Date LT-1 13 (P2)
Develop formalized guidance on management turnover and keep briefing books up to date.
(monitor what IG group comes up with and make sure meets the need).
IG working group updates Ongoing To Be Determined LT-2 14 Develop a process to capture and use lessons learned on major licensing actions in future reviews.
LIC-FM-1, job-aids, & training Ongoing To Be Determined 23 Consistent with LT-2-14, update guidance for license renewals taking into consideration lessons learned (e.g., update NUREG-1520).
Update NUREG-1520 Future To Be Determined LT-3 20 Develop a standard review plan for reviews of greater than critical mass licensees/applicants.
Develop SRP Ongoing To Be Determined LT-4 24 Create a roadmap for each type of license and major activity that identifies the appropriate regulations, guidance, procedures, job aids, etc.
that should be used.
Develop roadmap for templates Future To Be Determined 25 (P2)
Develop a central repository and common profiling of licensing basis documents as part of the road map described in LT-4-24.
Make roadmap easily accessible to staff Future To Be Determined LT-5 26 Review lessons learned and self-assessments drawn from previous large-scope applications to proactively prepare for new types of applications (e.g., new technologies).
LIC-FM-1, Guidance for new types of facilities Future To Be Determined Additional Acronyms:
Division Instruction (DI),
Standard Review Plan (SRP),
Inspector General (IG),
Near-Term (NT),
Mid-Term (MT),
Long-Term (LT)
LIC-FM-1: "Overview of the Licensing and Certification Process of NRC-Regulated Activities" LIC-FM-2: "Acceptance Review Process" LIC-FM-3: "Request for Additional Information" LIC-FM-4: "Safety Evaluation Report" Completed In Process Projected