ML22179A081
| ML22179A081 | |
| Person / Time | |
|---|---|
| Issue date: | 05/18/2022 |
| From: | Matt Bartlett NRC/NMSS/DFM/FFLB |
| To: | |
| Bartlett M 3014157154 | |
| Shared Package | |
| ML22179A081 | List: |
| References | |
| Download: ML22179A081 (6) | |
Text
Fuel Cycle Smarter Licensing May 18, 2022 Status Update
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 NRC staff has completed incorporation of the smarter licensing Near- and Mid-Term recommendations into the guidance and procedures tracked in the Division Instructions (DIs) entitled: LIC-FM Licensing Overview (ML22130A659), LIC-FM Acceptance Review Process, LIC-FM Requests for Additional Information (RAIs), and LIC-FM Safety Evaluation Reports (SERs). In addition, work on the Mid-Term recommendations to develop job-aids, templates, and training have also been completed. Work on the Long-Term recommendations will be processed as resources and priorities allow. The LIC-FM-1 was made publicly available on May 12, 2022. The other DIs identified above are under review for public release.
The enclosure below provides a summary of the smarter licensing recommendations and a crosswalk to the section in each DI where the recommendation is implemented.
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 updates at the Fuel Facilities Stakeholder Meeting, 05/17-18/2022, see ML22175A185.
- 2. The Near- and Mid-term recommendations have been incorporated into the following DIs:
- LIC-FM-1 Licensing Overview.
- LIC-FM-2 Acceptance Review Process (Draft),
- LIC-FM-3 Requests for Additional Information (Draft), and
- LIC-FM-4 Safety Evaluation Reports (Draft)
- 3. The status of the various Near-, Mid-, and Long-term recommendations are summarized in the table below.
NEXT STEPS Finalize the remaining DIs and make them publicly available.
Points of
Contact:
Matthew Bartlett, Smarter Licensing Project Manager, NMSS/DFM, 301-415-7154 Jake Zimmerman, Branch Chief, NMSS/DFM, 301-415-1220
Summary of Smarter Licensing Recommendations with Status and Cross Reference to the Division Instructions Recommendation DESCRIPTION Task LIC-FM-1 LIC-FM-2 LIC-FM-3 LIC-FM-4 Status Finish Date Make Division 16 Make internal guidance publicly available. Instructions Ongoing End 2022 (DIs) Public NT-0 Ensure Smarter Licensing (SL) revisions to the DIs are discussed Training on 19 Completed 2022 during training DIs Harmonize, incorporate good practices, and combine, where 32 appropriate, the staff review procedures and instructions within the Develop DI Completed Spring 2022 Division of Fuel Management (DFM).
2.4, 5) 2.3.4 2.11.4, a) 2.3.7 Establish schedule and estimate date of completion of technical review 2.11.4, b) 2.3.9 1 Add to DIs 2.8 Completed Spring 2022 with input from licensee. 2.11.5, b)(3) 2.3.10 2.12.2 (first 2.11.1(e)(2) paragraph) 2.3.9 Share metrics and estimated hours needed for the completing the 2.12.2 (first 2 Add to DIs 2.3.10 2.8 Completed Spring 2022 technical review with the licensee. paragraph) 2.11.1(e)(2) 2.4 (introduction, second Update status of the review as it progresses, including using of routine sentence)
NT-1 3 status calls between the U.S. Nuclear Regulatory Commission (NRC) Add to DIs Completed Spring 2022 2.4 (second and the applicant.
paragraph) 2.4.1, a) 2.11.4, a)
Coordinate and share with the applicant the review milestones/schedule 2.11.4, b) 2.3.9 including milestones for actions/areas to be completed by supporting 6 organizations (e.g., NRC offices, external contributors, centers of Add to DIs 2.11.5, b)(1) 2.3.10 2.8 Completed Spring 2022 excellence). 2.12.2 (first 2.11.1(e)(2) paragraph)
Improve, and incorporate into review guidance, the early processing, 2.11 (introduction) 2.3.5 29 alignment, and documentation of the expected focus, scope, and level Add to DIs 2.12.1, c) Completed Spring 2022 of detail of reviews and sharing this information with the applicant. 2.15.1 2.3.9 Meeting with the applicant during the acceptance review phase to better 2.3.6 2.4.3, c)(3) 4 understand the unique aspects of the applicants request and identify Add to DIs 2.7.3 (introduction) Completed End of 2021 complexities or unique aspects of the review. 2.4.3, c)(4) 2.7.3(a) 2.4 (5th paragraph) 2.4.3, e) (second NT-2 Holding site visit during the pre-application or acceptance review paragraph) 2.3.6 7b Add to DIs Completed End of 2021 phases that include all expected reviewers. 2.4.4 (introduction) 2.7.3(a) 2.4.4, a) 2.15.1, c)
Apply a holistic approach in gaining early alignment on the expected 2.4.4 (introduction) 27 scope of the review and need for management approval to modify the Add to DIs 2.4.4, a) 2.3.9 Completed End of 2021 scope, if needed. 2.15.1 1
Enclosure
Recommendation DESCRIPTION Task LIC-FM-1 LIC-FM-2 LIC-FM-3 LIC-FM-4 Status Finish Date 2.2, item 2) second 2.3.2 paragraph 2.5.1 2.6.3, second 2.5.3 Encourage combining multiple steps (e.g., acceptance and approval 5 Add to DIs paragraph 2.7.1(a) Completed End of 2021 letters) for simple applications.
2.11.5, a)(1) 2.11 2.11.5, a)(2) (introduction) 2.11.5, c)
NT-3 Develop an automated tool to track licensing actions in accordance 2.11.4, c) 17 Add to DIs Completed End of 2021 with the Nuclear Energy Innovation and Modernization Act (NEIMA). 2.14 2.2, item 2) second paragraph 2.3.2 Revise guidance and associated metrics to allow combining review 2.6.3 (second 2.5.1 28 steps for expected short-duration and straight-forward license Add to DIs paragraph) 2.11.5, 2.7.1(a) Completed End of 2021 application reviews. a)(1) 2.11 2.11.5, a)(2) (introduction) 2.11.5, c)
Hold a site visit, especially for major license amendments, license 2.4.4 (introduction) 7a renewals, and new applications, at the draft Request for Additional Add to DIs 2.4.4, a) 2.7.3 Completed Spring 2022 Information (RAI) phase involving the pertinent reviewers. 2.11.5, a)(4) 8 Ensure the RAIs have a documented regulatory basis. Add to DIs 2.4.1 Completed Spring 2022 2.3.3, d)(3) 2.7.1, b) 9a - Provide and discuss draft RAIs to the applicant to confirm 2.9.4 2.7.2, a) understanding of request and anticipated level of effort needed to Add to DIs 2.13.1 Completed Spring 2022 develop the response. 2.9.1, a) 2.13.2 9 2.10.1, a)
Appendix C, Item (2) 2.7.1, b) 9b - Also hold a call with the applicant to discuss their draft RAI Add to DIs 2.7.2, b) Completed Spring 2022 responses.
Appendix C, Item (3) 2.3.3, d)(1) 2.3.3, d)(2)
Establish RAI timeliness metric considerations for application reviews in 10 Add to DIs 2.3.3, d)(3) Completed Spring 2022 which RAIs are developed in a phased manner.
2.3.3, d)(6)
NT-4 2.13 2.3.3, d)(3) 2.7.1, b)
Ensuring clarification calls with the applicant to support clarity and 2.7.2, a) 11 understanding of RAIs is not disincentivized by the meeting notice Add to DIs Completed Spring 2022 metrics. 2.9.1, a) 2.10.1, a)
Appendix C, Item (2) 2.3.2, a)(2) 2.3.2, c)
Use the tools (e.g., job aids and templates) available to the NRC staff 2.18.5, a) 2.1.4.2 12 Add to DIs 2.4.2, d) Completed Spring 2022 to minimize the potential for multiple rounds of RAIs. 2.18.5, b) 2.1.4.2(1) 2.4.2, d)(1) 2.4.2, e) Appendix B 2.4.2, d)
Ensure the continuity of the quality, effectiveness, and efficiency of the 2.18.3, c) 2.4.2, d)(1) 2.1.4.2 13a Add to DIs Completed Spring 2022 licensing review process during NRC staff turnover. 2.18.5, b) 2.4.2, e) 2.1.4.2(1) 2.14 2
Use an electronic interface with applicants, including in support of 22 review planning and implementation, Add to DIs 2.7.1, c) Completed Spring 2022 such as for the RAI phase.
3
Recommendation DESCRIPTION Task LIC-FM-1 LIC-FM-2 LIC-FM-3 LIC-FM-4 Status Finish Date Incorporate into review guidance the use of integrated, multi- 2.3.5 15 Add to DIs 2.18.3, a) 2.4.3, a) Completed Spring 2022 disciplined, review teams. 2.3.9 Ensure internal work requests identify appropriate NRC staff and that 18 resource estimates are consistent with scope, focus, and level of detail Add to DIs 2.15.1 2.3.9 Completed Spring 2022 of each review area.
2.4.3, f), second Provide guidance to ensure the Safety Evaluation Report (SER) paragraph 21 documents the scope and focus of NRC staff reviews of licensing Add to DIs 2.1 Completed Spring 2022 2.18.5, b) (second actions.
paragraph) 2.1.3.5 25a Facilitate inspector involvement early in the licensing review process. Add to DIs 2.11.3, e) 2.4.2 (introduction) 2.13.4 Completed Spring 2022 2.13.5 MT-1 Implement Near-Term (NT)2-27 and incorporate into appropriate 2.18.2, a) 27 Add to DIs 2.8 (introduction) Completed Spring 2022 training and job aids. 2.18.2, b)
Implement NT1-29 and incorporate into appropriate training and job 2.18.2, a) 29 Add to DIs 2.8 (introduction) Completed Spring 2022 aids. 2.18.2, b)
Create a Develop a template for creating roadmaps and job-aids that describe roadmap for 30 the process for conducting technical reviews for various types of licensing Future To Be Determined facilities and licensing actions. actions and templates Develop job aid to support review considering risk factors and impacts (i.e., risk considerations associated within specific phases of a review, 31 including schedule risk and Add to DIs 2.3.9 Completed Spring 2022 review/decision-making risks).
Develop formalized guidance on management turnover and keep IG working LT-1 13b briefing books up to date. (monitor what Inspector General (IG) group Ongoing To Be Determined group updates comes up with and make sure meets the need).
Develop a process to capture and use lessons learned on major 14 LIC-FM-1 2.24 Completed Spring 2022 licensing actions in future reviews.
LT-2 Consistent with LT-2-14, update guidance for license renewals taking Update 23 Future To Be Determined into consideration lessons learned (e.g., update NUREG-1520). NUREG-1520 Develop a standard review plan for reviews of greater than critical LT-3 20 Develop SRP Ongoing To Be Determined mass licensees/applicants.
Create a roadmap for each type of license and major activity that Develop 24 identifies the appropriate regulations, guidance, procedures, job aids, roadmap for Future To Be Determined etc. that should be used. templates LT-4 Make roadmap Develop a central repository and common profiling of licensing basis easily 25b Future To Be Determined documents as part of the road map described in Long-Term (LT)-4-24. accessible to staff LIC-FM-1, Institutionalize post-review lessons learned activities of new or complex Guidance for LT-5 26 applications to improve guidance and inform future new and novel 2.24.1 Future To Be Determined new types of application reviews.
facilities 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" 4
ML22179A081; ML22179A081 OFFICE NMSS/DFM/FFLB NMSS/DFM/MSB NAME MBartlett MB TBoyce TB DATE Jun 28, 2022 Jul 1, 2022