ML993190151
| ML993190151 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1999 |
| From: | Black S NRC/NRR/DLPM |
| To: | Marion A Nuclear Energy Institute |
| References | |
| Download: ML993190151 (10) | |
Text
October
==
29,
==
1999
==
Mr.
==
Alex
==
Marion
==
Director,
==
Programs,
==
Nuclear
==
Generation
==
Nuclear
==
Energy
==
Institute
==
1776
==
1Street,
==
NW
==
Suite
==
400
==
==
==
20006
==
SUBJECT:
==
RESPONSE
==
TO
==
FEEDBACK
==
REGARDING
==
==
OFFICE
==
LETTER
==
803,
==
REVISION
==
2
==
==Dear
==
Mr.
==
Marion:==
==
Thank
==
you
==
for
==
your
==
letter
==
dated
==
August
==
23,
==
1999,
==
addressing
==
industry
==
feedback
==
regarding
==
==
Office
==
Letter
==
(OL)
==
803,
==
Revision
==
2,
==
License
==
Amendment
==
Review
==
Procedures.
==
Our
==
responses
==
to
==
your
==
comments
==
are
==
attached
==
for
==
your
==
review.
==
As
==
you
==
know,
==
we
==
are
==
interested
==
in
==
addressing
==
industry
==
and
==
public
==
concerns
==
with
==
the
==
Nuclear
==
Regulatory
==
Commission's
==
(NRC)
==
processes
==
and
==
procedures.
==
These
==
processes
==
and
==
procedures
==
will
==
be
==
revised
==
as
==
necessary
==
consistent
==
with
==
the
==
goals
==
of
==
maintaining
==
safety,
==
reducing
==
unnecessary
==
regulatory
==
burden,
==
increasing
==
public
==
confidence,
==
and
==
increasing
==
efficiency
==
and
==
effectiveness.
==
Following
==
our
==
meeting
==
on
==
September
==
29,
==
1999,
==
the
==
staff
==
has
==
had
==
internal
==
discussions
==
on
==
the
==
planned
==
issuance
==
of
==
our
==
next
==
revision
==
to
==
Office
==
Letter
==
803.
==
We
==
are
==
evaluating
==
the
==
comments
==
received
==
from
==
the
==
Licensing
==
Action
==
Task
==
Force
==
(LATF)
==
as
==
well
==
as
==
internal
==
NRC
==
stakeholders.
==
Our
==
plan
==
remains
==
to
==
issue
==
the
==
revision
==
by
==
the
==
end
==
of
==
the
==
year.
==
We
==
may,
==
if
==
the
==
revision
==
is
==
nearly
==
complete,
==
provide
==
the
==
LATF
==
with
==
a
==
draft
==
version
==
of
==
the
==
Office
==
Letter
==
at
==
our
==
next
==
meeting.
==
We
==
are
==
not,
==
however,
==
currently
==
planning
==
to
==
ask
==
the
==
LATF
==
to
==
comment
==
on
==
the
==
draft
==
in
==
time
==
to
==
support
==
the
==
next
==
revision.
==
Our
==
preference
==
is
==
that
==
interested
==
stakeholders,
==
including
==
members
==
of
==
the
==
LATF,
==
forward
==
suggestions
==
or
==
comments
==
which
==
will
==
be
==
considered
==
in
==
subsequent
==
revisions.
==
If
==
you
==
have
==
any
==
questions
==
or
==
additional
==
concerns
==
about
==
this
==
issue
==
please
==
contact
==
me
==
at
==
(301)
==
415-1453/scb@nrc.gov
==
or
==
Larry
==
Burkhart
==
at
==
(301)
==
415-3053/ljb@nrc.gov.
==
Sincerely,
==
ORIGINAL
==
SIGNED
==
BY
==
Suzanne
==
Black,
==
Deputy
==
Director
==
Division
==
of
==
Licensing
==
t
==
!e*
==
j.
==
Office
==
of
==
Nuclear
==
Rea'10e-
==
tbn
==
Enclosure:
==
as
==
stated
==
DISTRIBUTION:
==
J.
==
Zwolinski
==
PUBLIC
==
==
File
==
Center
==
I
==
o
==
receive
==
a
==
copy
==
ot
==
thiS
==
document,
==
indicate
==
'T
==
in
==
the
==
box
==
OFFICE
==
PDIV-1/PM
==
C
==
PDIV-D/LA
==
C
==
DLPM/DD
==
fO'
==
0
==
NAME
==
LBurkh
==
WCJamerson
==
SBlack
==
DATE
==
/.
==
/Zl'
==
/9'9
==
1
==
f/'/9
==
9
==
j,
==
17--j
==
/99
==
DOCUMENT
==
NAME:
==
A:\ol803responserevl.wpd
==
OFFICIAL
==
RECORD
==
COPY
==
NRC
==
Response
==
to
==
NEI
==
Comments
==
on
==
==
Office
==
Letter
==
803,
==
Revision
==
2
==
"License
==
Amendment
==
Review
==
Procedures"
==
A.
==
Response
==
to
==
General
==
Comments
==
1.
==
Feedback
==
from
==
licensees
==
indicates
==
that,
==
in
==
general,
==
Revision
==
2
==
to
==
Office
==
Letter
==
(OL)
==
803
==
is
==
a
==
useful
==
document
==
that
==
provides
==
important
==
insights
==
into
==
the
==
license
==
amendment
==
review
==
process.
==
Project
==
Managers
==
(PMs)
==
appear
==
to
==
be
==
using
==
the
==
Office
==
Letter,
==
and
==
there
==
have
==
been
==
several
==
examples
==
of
==
submittals
==
being
==
clarified
==
through
==
early
==
telephone
==
communications.
==
Feedback
==
has
==
been
==
positive
==
on
==
PM's
==
(and
==
==
management's)
==
commitment
==
to
==
improve
==
the
==
efficiency
==
of
==
the
==
review/approval
==
process.
==
RESPONSE:
==
No
==
response
==
required.
==
2.
==
The
==
Office
==
Letter
==
should
==
be
==
expanded
==
to
==
include
==
guidance
==
on
==
the
==
processing
==
of
==
other
==
types
==
of
==
"licensing
==
actions"
==
(e.g.,
==
relief
==
requests,
==
exemption
==
requests,
==
topical
==
reports,
==
generic
==
communications,
==
etc.).
==
RESPONSE:
==
Since
==
some
==
aspects
==
of
==
processing
==
other
==
licensing
==
actions
==
such
==
as
==
relief
==
and
==
exemption
==
requests
==
are
==
very
==
similar
==
to
==
processing
==
license
==
amendments,
==
guidance
==
will
==
be
==
included
==
to
==
recommend
==
that
==
the
==
==
utilize
==
applicable
==
sections
==
of
==
==
803
==
for
==
the
==
processing
==
of
==
exemption
==
requests,
==
relief
==
requests
==
and
==
other
==
licensing
==
action
==
requests.
==
As
==
an
==
example,
==
the
==
Request
==
for
==
Additional
==
Information
==
(RAI)
==
guidance
==
contained
==
in
==
==
803
==
can
==
and
==
should
==
be
==
applied
==
to
==
exemption
==
and
==
relief
==
requests.
==
In
==
addition,
==
the
==
staff
==
is
==
working
==
to
==
develop
==
general
==
guidance
==
for
==
the
==
various
==
types
==
of
==
licensing
==
actions
==
(OL
==
807,
==
"Control
==
of
==
Licensing
==
Basis
==
for
==
Operating
==
Reactors")
==
and
==
specific
==
process
==
standards
==
for
==
each
==
type
==
of
==
licensing
==
action
==
or
==
other
==
licensing
==
task
==
for
==
work
==
planning
==
purposes.
==
In
==
the
==
long
==
term,
==
the
==
staff
==
plans
==
to
==
have
==
improved
==
procedures
==
defined
==
for
==
all
==
of
==
its
==
routine
==
activities.
==
The
==
interactions
==
planned
==
between
==
the
==
staff
==
and
==
the
==
LATF
==
team
==
for
==
licensing
==
submittals
==
(other
==
than
==
Technical
==
Specifications)
==
may
==
be
==
a
==
forum
==
for
==
improving
==
some
==
of
==
our
==
current
==
practices.
==
3.
==
Minor
==
administrative
==
or
==
non-safety
==
changes
==
to
==
the
==
Technical
==
Specifications
==
(i.e.,
==
"cleanup"
==
changes)
==
receive
==
a
==
relatively
==
low
==
review
==
priority.
==
A
==
simplified
==
administrative
==
process
==
for
==
reviewing
==
"minor
==
Tech
==
Specification
==
changes"
==
should
==
be
==
incorporated
==
into
==
the
==
Office
==
Letter.
==
Minor
==
changes
==
need
==
not
==
be
==
subjected
==
to
==
the
==
same
==
degree
==
of
==
process
==
control
==
as
==
safety/risk-related
==
changes.
==
RESPONSE:
==
As
==
discussed
==
in
==
the
==
September
==
29,
==
1999,
==
LATF
==
meeting,
==
this
==
issue
==
is
==
unlikely
==
to
==
be
==
resolved
==
by
==
the
==
scheduled
==
issuance
==
date
==
of
==
Revision
==
3
==
to
==
==
803.
==
Appropriate
==
guidance
==
will
==
be
==
included
==
in
==
==
803
==
when
==
this
==
issue
==
is
==
resolved
==
and
==
a
==
policy
==
for
==
handling
==
these
==
types
==
of
==
changes
==
is
==
established.
==
4.
==
NEt
==
supports
==
the
==
scheduling
==
of
==
NRC
==
workshops
==
for
==
relatively
==
small
==
groups
==
of
==
licensees
==
where
==
attendees
==
can
==
discuss
==
issues
==
pertaining
==
to
==
submittal
==
quality.
==
The
==
NRC
==
staff
==
can
==
describe
==
the
==
criteria
==
used
==
to
==
determine
==
the
==
completeness
==
of
==
a
==
proposed
==
submittal,
==
and
==
licensee
==
staff
==
can
==
comment
==
on
==
the
==
quality
==
of
==
the
==
NRC
==
review
==
process.
==
The
==
cumulative
==
ENCLOSURE
==
effect
==
of
==
the
==
workshops
==
should
==
be
==
the
==
documentation
==
of
==
consistent
==
guidance
==
usable
==
by
==
the
==
entire
==
licensee
==
community,
==
perhaps
==
through
==
subsequent
==
revisions
==
of
==
==
803.
==
RESPONSE:
==
The
==
tentative
==
schedule
==
of
==
licensing
==
workshops
==
was
==
provided
==
at
==
the
==
last
==
LATF
==
meeting.
==
To
==
date
==
the
==
workshops
==
have
==
been
==
highly
==
successful
==
by
==
providing
==
an
==
informal
==
forum
==
for
==
the
==
exchange
==
of
==
information
==
and
==
ideas
==
between
==
the
==
industry
==
and
==
the
==
NRC.
==
Currently,
==
all
==
licensees
==
are
==
scheduled
==
to
==
attend
==
a
==
workshop
==
over
==
the
==
next
==
year.
==
Meeting
==
summaries
==
are
==
produced
==
for
==
every
==
workshop.
==
In
==
addition
==
to
==
discussions
==
at
==
the
==
workshops,
==
the
==
staff
==
will
==
place
==
additional
==
recommendations
==
regarding
==
the
==
content
==
of
==
license
==
amendment
==
submittals
==
into
==
the
==
next
==
revision
==
of
==
==
803.
==
5.
==
The
==
Office
==
Letter
==
should
==
include
==
guidance
==
on
==
electronic
==
transfer
==
of
==
information.
==
Some
==
==
typically
==
request
==
electronic
==
copies
==
of
==
licensees'
==
"no
==
significant
==
hazards
==
consideration"
==
(NSHC)
==
evaluations
==
to
==
expedite
==
the
==
publishing
==
of
==
proposed
==
amendments
==
in
==
the
==
Federal
==
Register.
==
==
should
==
also
==
be
==
encouraged
==
to
==
provide
==
electronic
==
copies
==
of
==
approved
==
amendments
==
to
==
licensees.
==
RESPONSE:
==
Currently,
==
hard
==
copies
==
of
==
documents
==
are
==
required
==
to
==
be
==
submitted
==
for
==
license
==
amendment,
==
relief,
==
exemption,
==
and
==
other
==
licensing
==
requests.
==
It
==
is
==
acknowledged
==
and
==
encouraged
==
that
==
==
use
==
electronic
==
copies
==
of
==
submittals,
==
voluntarily
==
forwarded
==
by
==
the
==
licensee,
==
to
==
facilitate
==
the
==
license
==
submittal
==
review
==
process.
==
For
==
example,
==
the
==
use
==
of
==
electronic
==
copies
==
of
==
amendment
==
requests
==
enables
==
the
==
efficient
==
and
==
timely
==
production
==
of
==
the
==
Federal
==
Register
==
notice
==
that
==
includes
==
the
==
no
==
significant
==
hazard
==
consideration
==
determination
==
(NSHCD).
==
Due
==
to
==
planned,
==
improved
==
electronic
==
information
==
processing
==
capability,
==
the
==
NRC
==
is
==
encouraging
==
the
==
increased
==
use
==
of
==
electronic
==
media
==
for
==
all
==
correspondence.
==
The
==
NRC
==
is
==
currently
==
piloting
==
an
==
Electronic
==
Information
==
Exchange
==
(EIE)
==
process
==
with
==
the
==
Atomic
==
Safety
==
Licensing
==
Board
==
Panel
==
(ASLBP)
==
and
==
the
==
participants
==
in
==
the
==
relicensing
==
hearing
==
before
==
it.
==
The
==
process
==
uses
==
Digital
==
certificate
==
and
==
a
==
Digital
==
signature
==
to
==
assure
==
verification
==
and
==
validation.
==
The
==
NRC
==
provides
==
the
==
participants
==
the
==
capability
==
to
==
digitally
==
sign
==
the
==
submittals
==
at
==
no
==
charge
==
to
==
the
==
licensee
==
or
==
participants.
==
This
==
is
==
the
==
same
==
system
==
that
==
will
==
be
==
implemented
==
on
==
a
==
full
==
scale
==
for
==
all
==
submittals
==
to
==
the
==
agency.
==
The
==
next
==
step
==
in
==
the
==
process
==
of
==
implementing
==
==
capability
==
is
==
to
==
issue
==
a
==
Regulatory
==
Issues
==
Summary
==
in
==
November
==
that
==
will
==
allow
==
Part
==
50
==
submittals
==
in
==
electronic
==
form
==
if
==
accompanied
==
by
==
one
==
hard
==
copy.
==
The
==
Regulatory
==
Issues
==
Summary
==
will
==
grant
==
a
==
blanket
==
exception
==
to
==
allow
==
for
==
the
==
submittal
==
of
==
the
==
one
==
hard
==
copy
==
with
==
the
==
electronic
==
submittal.
==
In
==
the
==
summer
==
of
==
2000,
==
a
==
rule
==
will
==
be
==
published
==
allowing
==
all
==
NRC
==
trading
==
partners
==
to
==
submit
==
electronically
==
in
==
lieu
==
of
==
any
==
hard
==
copy.
==
Guidance
==
addressing
==
the
==
use
==
of
==
electronic
==
media
==
will
==
be
==
included
==
in
==
the
==
next
==
revision
==
of
==
the
==
Office
==
Letter
==
to
==
the
==
greatest
==
extent
==
possible.
==
6.
==
The
==
Office
==
Letter
==
does
==
not
==
address
==
changes
==
to
==
the
==
Technical
==
Specification
==
Bases.
==
Guidance
==
for
==
processing
==
Bases
==
changes
==
may
==
be
==
useful,
==
especially
==
for
==
plants
==
with
==
non
==
standard
==
Technical
==
Specifications.
==
The
==
Bases
==
are
==
an
==
important
==
source
==
of
==
information,
==
and
==
both
==
licensees
==
and
==
NRC
==
staff
==
should
==
maintain
==
consistent,
==
up-to-date
==
versions.
==
RESPONSE:
==
This
==
issue
==
is
==
being
==
tracked
==
and
==
addressed
==
by
==
the
==
LATF
==
and
==
may
==
not
==
be
==
resolved
==
by
==
the
==
date
==
of
==
issuance
==
of
==
Revision
==
3
==
of
==
==
803.
==
At
==
the
==
September
==
29,
==
1999,
==
LATF
==
meeting,
==
NEI
==
stated
==
that
==
they
==
would
==
forward
==
a
==
recommendation
==
for
==
handling
==
TS
==
Bases
==
changes.
==
Guidance
==
will
==
be
==
included
==
in
==
Revision
==
3
==
of
==
==
803,
==
if
==
available
==
and
==
as
==
appropriate.
==
7.
==
When
==
possible,
==
references
==
to
==
internal
==
NRC
==
memoranda
==
should
==
be
==
avoided.
==
Relevant
==
portions
==
of
==
a
==
memo
==
should
==
be
==
incorporated
==
into
==
the
==
body
==
of
==
the
==
Office
==
Letter,
==
or
==
the
==
memo
==
should
==
be
==
attached
==
to
==
the
==
Office
==
Letter.
==
RESPONSE:
==
The
==
staff
==
is
==
reviewing
==
the
==
information
==
contained
==
in
==
the
==
internal
==
memoranda
==
and
==
will
==
incorporate
==
portions
==
that
==
are
==
relevant
==
and
==
necessary.
==
Internal
==
memoranda
==
may
==
be
==
placed
==
in
==
the
==
public
==
domain,
==
if
==
deemed
==
appropriate.
==
This
==
will
==
allow
==
the
==
public
==
to
==
review
==
these
==
memoranda
==
without
==
including
==
the
==
entire
==
text
==
in
==
==
803.
==
8.
==
Additional
==
guidance
==
is
==
recommended
==
throughout
==
the
==
Office
==
Letter
==
to
==
assist
==
the
==
==
in
==
contractor
==
management
==
and
==
oversight.
==
RESPONSE:
==
Contractor
==
management
==
is
==
an
==
infrequent
==
responsibility
==
of
==
the
==
==
and
==
is
==
rarely
==
an
==
issue
==
in
==
processing
==
license
==
amendments.
==
In
==
general,
==
contractors
==
are
==
utilized
==
during
==
reviews
==
of
==
relief
==
requests,
==
topical
==
reports,
==
and
==
as
==
technical
==
support
==
in
==
some
==
other
==
staff
==
activities.
==
In
==
these
==
cases,
==
contractors
==
are
==
supervised
==
by
==
the
==
cognizant
==
technical
==
branch.
==
The
==
staff
==
will
==
review
==
the
==
issue
==
of
==
contractor
==
management
==
as
==
it
==
prepares
==
guidance
==
for
==
other
==
review
==
activities.
==
B.
==
Comments
==
on
==
the
==
Office
==
Letter
==
1.
==
Section
==
C,
==
"Preparationof
==
the
==
Safety
==
Evaluation,"
==
states
==
that
==
projectmanagers
==
are
==
responsible
==
for
==
determining,"with
==
assistancefrom
==
technical
==
branch
==
personnel,who
==
will
==
perform
==
the
==
safety
==
review
==
(the
==
==
or
==
technicalbranch
==
staff)."
==
It
==
seems
==
more
==
appropriate
==
to
==
make
==
this
==
guidance
==
part
==
of
==
Section
==
A,
==
"Preparationof
==
the
==
Work
==
Plan."
==
RESPONSE:
==
The
==
possible
==
relocation
==
of
==
this
==
responsibility
==
will
==
be
==
considered.
==
2.
==
Section
==
D,
==
"Review
==
and
==
Concurrenceof
==
the
==
Amendment
==
Package,"states:
==
"The
==
Office
==
of
==
the
==
General
==
Counsel
==
(OGC)
==
shall
==
review
==
all
==
amendment
==
packages
==
for
==
legal
==
adequacy
==
and
==
defensibility,
==
unless
==
a
==
memorandum
==
of
==
agreement
==
is
==
developed
==
stating
==
that
==
specific
==
amendments
==
do
==
not
==
require
==
==
concurrence."
==
(Also
==
see
==
footnote
==
4
==
on
==
page
==
5.3
==
of
==
the
==
attachment
==
to
==
the
==
Office
==
Letter.)
==
==
review
==
of
==
amendment
==
packages
==
should
==
be
==
the
==
exception,
==
not
==
the
==
rule.
==
To
==
improve
==
administrative
==
efficiency,
==
Project
==
Directors
==
and
==
==
in
==
the
==
==
Division
==
of
==
Licensing
==
Project
==
Management
==
should
==
play
==
a
==
role
==
in
==
determining
==
when
==
==
input
==
is
==
needed.
==
Criteria
==
for
==
obtaining
==
==
review
==
should
==
reside
==
in
==
an
==
internal
==
NRC
==
memorandum
==
of
==
understanding
==
between
==
the
==
General
==
Counsel
==
and
==
the
==
==
Office
==
Director.
==
Written
==
guidance
==
is
==
needed
==
on
==
the
==
role
==
of
==
==
in
==
the
==
amendment
==
process.
==
RESPONSE:
==
It
==
is
==
the
==
current
==
policy
==
that
==
all
==
amendment,
==
relief,
==
and
==
exemption
==
requests
==
be
==
reviewed
==
by
==
OGG.
==
Any
==
change,
==
if
==
desired,
==
to
==
this
==
policy
==
will
==
require
==
detailed
==
review
==
and
==
negotiation
==
by
==
==
and
==
OGC.
==
The
==
staff
==
will
==
pursue
==
this
==
issue;
==
however,
==
it
==
is
==
unlikely
==
that
==
a
==
change
==
as
==
recommended
==
above
==
will
==
be
==
included
==
in
==
the
==
next
==
revision
==
of
==
the
==
Office
==
Letter.
==
C.
==
Comments
==
on
==
the
==
"Guide
==
for
==
Processing
==
License
==
Amendments"
==
1.
==
Section
==
2.0,
==
"Work
==
Planning,"describes
==
the
==
steps
==
that
==
should
==
be
==
addressedby
==
==
in
==
developing
==
an
==
amendment
==
review
==
work
==
plan.
==
Although
==
this
==
section
==
contains
==
timeliness
==
goals
==
for
==
the
==
overall
==
process,
==
NRC
==
should
==
consider
==
adding
==
individual
==
timeliness
==
expectations
==
for
==
the
==
key
==
administrative
==
steps
==
necessary
==
to
==
process
==
a
==
proposed
==
license
==
amendment,
==
for
==
example,
==
Federal
==
Register
==
notifications.
==
RESPONSE:
==
We
==
expect
==
that
==
the
==
work
==
planning
==
initiative
==
within
==
==
will
==
address
==
the
==
scheduling
==
of
==
sub-tasks.
==
In
==
general
==
the
==
proposed
==
approach
==
is
==
to
==
estimate
==
the
==
resource
==
requirements
==
(staff-hours)
==
of
==
a
==
sub-task
==
and
==
assign
==
the
==
sub-task
==
to
==
the
==
appropriate
==
organization
==
or
==
individual.
==
The
==
availability
==
of
==
resources
==
would
==
normally
==
determine
==
the
==
expected
==
completion
==
date
==
(unless
==
priority
==
or
==
other
==
circumstances
==
dictate
==
that
==
other
==
work
==
assignments
==
be
==
deferred
==
to
==
complete
==
an
==
incoming
==
task).
==
2.
==
Section
==
2.3,
==
"Searchfor
==
PrecedentLicensing
==
Actions,"
==
describes
==
the
==
use
==
of
==
precedent
==
in
==
the
==
review
==
process.
==
This
==
section
==
of
==
the
==
Office
==
Letter
==
should
==
emphasize
==
the
==
importance
==
of
==
==
communication
==
with
==
the
==
appropriate
==
technical
==
branch(es)
==
early
==
in
==
the
==
review
==
phase.
==
Early
==
agreement
==
on
==
use
==
of
==
precedent
==
between
==
the
==
==
and
==
technical
==
reviewers
==
will
==
help
==
expedite
==
the
==
review
==
process.
==
See
==
Enclosure
==
2
==
for
==
additional
==
comments
==
on
==
the
==
use
==
of
==
precedent.
==
RESPONSE:
==
The
==
staff
==
is
==
not
==
aware
==
of
==
a
==
problem
==
in
==
this
==
area
==
but
==
will
==
consider
==
adding
==
additional
==
emphasis
==
on
==
early
==
communication
==
between
==
==
and
==
technical
==
branches
==
3.
==
Section
==
2.4,
==
"Developa
==
Work
==
Plan,"
==
states:
==
==
give
==
special
==
attention
==
to
==
those
==
reviews
==
that
==
involve
==
multiple
==
==
[technicalbranches]
==
or
==
==
reviewers.
==
The
==
work
==
plans
==
for
==
such
==
amendment
==
requestsneed
==
to
==
ensure
==
that
==
the
==
scope
==
and
==
schedule
==
for
==
each
==
reviewer
==
are
==
well-defined
==
and
==
understood."
==
One
==
of
==
the
==
main
==
objectives
==
of
==
==
803
==
is
==
the
==
consistent
==
and
==
timely
==
processing
==
of
==
license
==
amendments.
==
A
==
work
==
plan,
==
as
==
described
==
above,
==
is
==
necessary
==
to
==
accomplish
==
this
==
objective.
==
For
==
example,
==
the
==
work
==
plan
==
should
==
consolidate
==
==
from
==
different
==
technical
==
branches
==
into
==
a
==
single
==
set
==
of
==
RAis.
==
The
==
work
==
plan
==
should
==
screen
==
out
==
duplicate
==
questions
==
from
==
different
==
branches,
==
screen
==
out
==
questions
==
solely
==
informational
==
in
==
nature,
==
eliminate
==
questions
==
that
==
are
==
not
==
relevant
==
to
==
the
==
proposed
==
amendment
==
and
==
minimize
==
the
==
number
==
of
==
technical
==
reviewers.
==
==
work
==
planning
==
should
==
establish
==
appropriate
==
constraints
==
on
==
the
==
scope
==
of
==
Branch
==
reviews.
==
The
==
Office
==
Letter
==
should
==
contain
==
supplemental
==
guidance
==
or
==
refer
==
to
==
internal
==
work
==
planning
==
procedures
==
to
==
assist
==
==
in
==
defining
==
the
==
appropriate
==
technical
==
review
==
scope.
==
-5
==
RESPONSE:
==
The
==
work
==
planning
==
initiative
==
may
==
resolve
==
some
==
of
==
these
==
concerns.
==
The
==
staff
==
needs,
==
however,
==
to
==
maintain
==
enough
==
flexibility
==
in
==
its
==
guidance
==
to
==
address
==
the
==
wide
==
variety
==
of
==
issues
==
that
==
arise
==
during
==
reviews.
==
For
==
example,
==
some
==
licensees
==
would
==
prefer
==
that
==
==
not
==
be
==
consolidated
==
but
==
that
==
an
==
==
from
==
each
==
branch
==
be
==
sent
==
when
==
ready.
==
Regarding
==
additional
==
guidance
==
on
==
determining
==
the
==
scope
==
of
==
technical
==
reviews,
==
the
==
Office
==
Letter
==
is
==
primarily
==
a
==
process
==
control
==
document.
==
Although
==
it
==
specifies
==
that
==
the
==
staff
==
should
==
establish
==
the
==
appropriate
==
scope
==
and
==
depth
==
of
==
reviews,
==
the
==
wide
==
variety
==
of
==
technical
==
and
==
regulatory
==
issues
==
cannot
==
be
==
captured
==
in
==
the
==
Office
==
Letter
==
(i.e.,
==
the
==
Office
==
Letter
==
cannot
==
serve
==
the
==
function
==
of
==
an
==
updated
==
standard
==
review
==
plan).
==
Given
==
its
==
importance
==
to
==
the
==
process
==
and
==
in
==
light
==
of
==
your
==
comments,
==
the
==
staff
==
will
==
consider
==
adding
==
emphasis
==
to
==
the
==
issue
==
of
==
scope
==
and
==
depth
==
of
==
technical
==
reviews.
==
4.
==
Section
==
2.4.1,
==
"Scope
==
and
==
Depth
==
of
==
Review,"
==
states:
==
'A
==
memorandum
==
to
==
the
==
staff...
==
dated
==
October30,
==
1998,
==
provides
==
guidance
==
for
==
the
==
review
==
of
==
applicationsclassified
==
as
==
risk-informed
==
licensing
==
actions."
==
The
==
role
==
of
==
the
==
==
[Probabilistic
==
Safety
==
Assessment]
==
Branch
==
of
==
the
==
==
Division
==
of
==
Systems
==
Safety
==
&
==
Analysis
==
(DSSA)
==
in
==
the
==
review
==
of
==
proposed
==
license
==
amendments,
==
whether
==
"risk-informed"
==
or
==
"deterministic,"
==
has
==
become
==
an
==
important
==
issue.
==
The
==
Office
==
Letter
==
should
==
be
==
revised
==
to
==
include
==
additional
==
guidance
==
on
==
"groundrules"
==
for
==
the
==
role
==
of
==
the
==
==
Branch
==
in
==
establishing
==
the
==
scope
==
and
==
duration
==
of
==
the
==
overall
==
NRC
==
staff
==
review.
==
Additional
==
guidance
==
is
==
needed
==
to
==
specify
==
how
==
the
==
staff
==
will
==
accept
==
the
==
"burden
==
of
==
proof"
==
when
==
deciding
==
to
==
undertake
==
a
==
risk-informed
==
review
==
of
==
a
==
purely
==
deterministic
==
submittal.
==
The
==
outcome
==
should
==
be
==
an
==
objective,
==
scrutable,
==
decision-making
==
process
==
subject
==
to
==
response
==
and
==
rebuttal
==
from
==
the
==
licensee.
==
The
==
==
should
==
be
==
a
==
part
==
of
==
the
==
process
==
and
==
should
==
be
==
able
==
to
==
explain
==
the
==
staff's
==
decision
==
to
==
the
==
licensee.
==
RESPONSE:
==
The
==
staff
==
has
==
recently
==
prepared
==
a
==
Commission
==
Paper
==
on
==
this
==
issue.
==
We
==
plan
==
to
==
add
==
additional
==
guidance
==
to
==
the
==
Office
==
Letter
==
regarding
==
this
==
subject.
==
5.
==
Section
==
2.4.3,
==
"LicensingAction
==
Timeliness
==
Goals,"
==
specifies
==
timeliness
==
goals
==
to
==
be
==
used
==
as
==
performance
==
measures
==
to
==
monitor
==
the
==
efficiency
==
and
==
effectiveness
==
of
==
NRC
==
staff
==
completion
==
of
==
licensing
==
actions.
==
The
==
Office
==
Letter
==
should
==
make
==
clear
==
that
==
timeliness
==
goals
==
should
==
never
==
be
==
used
==
as
==
a
==
basis
==
for
==
denying
==
a
==
proposed
==
amendment
==
or
==
for
==
encouraging
==
a
==
licensee
==
to
==
withdraw
==
a
==
proposed
==
amendment.
==
NRC
==
management
==
oversight
==
will
==
help
==
ensure
==
the
==
integrity
==
of
==
the
==
timeliness
==
goals.
==
RESPONSE:
==
The
==
staff
==
agrees
==
that
==
the
==
timeliness
==
goals
==
should
==
not
==
be
==
routinely
==
used
==
as
==
a
==
basis
==
for
==
denying
==
a
==
licensing
==
action
==
request.
==
The
==
staff
==
will,
==
however,
==
consider
==
denying
==
amendment
==
requests
==
if
==
a
==
licensee
==
is
==
being
==
unresponsive
==
to
==
requests
==
for
==
information.
==
The
==
denial
==
would
==
make
==
clear
==
that
==
the
==
rationale
==
was
==
a
==
lack
==
of
==
information
==
and
==
not
==
the
==
technical
==
merits
==
of
==
the
==
amendment
==
application.
==
This
==
will
==
be
==
made
==
clear
==
in
==
the
==
next
==
revision.
==
6.
==
Section
==
3.0,
==
"PublicNotification."
==
Section
==
3
==
should
==
include
==
guidance
==
on
==
hybrid
==
hearing
==
procedures
==
for
==
expansion
==
of
==
spent
==
fuel
==
storage
==
capacity
==
(10
==
CFR
==
2.1107
==
requires
==
particular
==
wording
==
in
==
the
==
Federal
==
Register
==
notice).
==
Section
==
3
==
should
==
also
==
include
==
guidance
==
on
==
environmental
==
assessments.
==
Processing
==
can
==
be
==
delayed
==
if
==
==
are
==
not
==
aware
==
of
==
special
==
administrative
==
steps
==
associated
==
with
==
certain
==
amendments
==
(such
==
as
==
spent
==
fuel
==
pool
==
expansions).
==
RESPONSE:
==
The
==
staff
==
agrees
==
and
==
more
==
guidance
==
will
==
be
==
included
==
in
==
the
==
next
==
revision.
==
7.
==
Section
==
3.1,
==
"Normal(30-day)
==
Public
==
Notification,"
==
states:
==
"ProjectManagers
==
are
==
expected
==
to
==
prepare
==
the
==
notice
==
as
==
soon
==
as
==
convenient
==
following
==
receipt
==
of
==
an
==
incoming
==
amendment
==
request.
==
It
==
is
==
not
==
clear
==
whether
==
this
==
occurs
==
before
==
or
==
after
==
the
==
initial
==
acceptance
==
review.
==
In
==
any
==
case,
==
a
==
target
==
time
==
period
==
(e.g.,
==
one
==
week)
==
should
==
be
==
specified
==
for
==
preparation
==
of
==
public
==
notification
==
to
==
ensure
==
prompt
==
initiation
==
of
==
the
==
review
==
process.
==
RESPONSE:
==
The
==
evaluation
==
and
==
issuance
==
of
==
a
==
notice
==
comes
==
after
==
the
==
acceptance
==
review.
==
In
==
general,
==
it
==
is
==
best
==
to
==
issue
==
the
==
FR
==
notice
==
as
==
soon
==
as
==
practicable
==
after
==
receipt
==
of
==
the
==
license
==
amendment
==
request
==
and
==
the
==
latest
==
that
==
the
==
notice
==
should
==
be
==
published
==
is
==
30
==
days
==
prior
==
to
==
the
==
desired
==
amendment
==
issuance
==
date.
==
This
==
will
==
be
==
emphasized
==
more
==
clearly
==
in
==
the
==
next
==
revision.
==
8.
==
Section
==
3.
==
1,
==
"Normal(30-day)
==
Public
==
Notification,"
==
states:
==
"All
==
applicationsand
==
supplements
==
to
==
an
==
applicationshould
==
be
==
sent
==
under
==
O&A
==
(50.30).
==
[Oath
==
&
==
Affirmation]
==
It
==
would
==
be
==
helpful
==
if
==
the
==
Office
==
Letter
==
included
==
examples
==
of
==
when
==
an
==
O&A
==
is,
==
or
==
is
==
not,
==
required.
==
RESPONSE:
==
More
==
detailed
==
information
==
will
==
be
==
included
==
in
==
the
==
next
==
revision
==
of
==
the
==
OL.
==
9.
==
Section
==
4.1.1,
==
"ProjectManager
==
Review,
==
"discusses
==
project
==
manager
==
(PM)
==
feedback
==
on
==
submittal
==
quality
==
as
==
input
==
to
==
the
==
plant
==
issues
==
matrix
==
(PIM).
==
It
==
is
==
important
==
for
==
==
to
==
put
==
negative
==
input
==
on
==
a
==
single
==
submittal
==
in
==
the
==
context
==
of
==
all
==
submittals.
==
Similarly,
==
balanced
==
input
==
should
==
be
==
made
==
for
==
all
==
types
==
of
==
licensee
==
submittals,
==
not
==
just
==
proposed
==
license
==
amendments.
==
If
==
only
==
negative
==
feedback
==
reaches
==
the
==
PIM,
==
a
==
single
==
sub-par
==
submittal
==
could
==
outweigh
==
numerous
==
quality
==
submittals.
==
This
==
could
==
adversely
==
and
==
erroneously
==
impact
==
the
==
plant
==
performance
==
review
==
(PPR).
==
RESPONSE:
==
==
entries
==
are
==
event-specific
==
evaluations
==
and
==
not
==
an
==
overall
==
performance
==
evaluation.
==
==
entries
==
made
==
by
==
the
==
==
addressing
==
licensing
==
performance
==
should
==
include
==
both
==
good
==
and
==
bad
==
performance.
==
Additional
==
guidance
==
will
==
be
==
included
==
in
==
the
==
next
==
revision.
==
10.
==
Section
==
4.1.2,
==
"TechnicalStaff
==
Review,"
==
discusses
==
technical
==
branch
==
(TB)
==
input
==
to
==
the
==
==
regardinglicensee
==
performance.
==
RESPONSE:
==
==
entries
==
are
==
made
==
by
==
the
==
PM,
==
with
==
possible
==
insights
==
from
==
a
==
technical
==
r3viewer
==
or
==
==
manager.
==
The
==
==
staff
==
would
==
not
==
be
==
expected
==
to
==
prepare
==
a
==
==
entry
==
without
==
interacting
==
with
==
the
==
PM.
==
Please
==
see
==
response
==
above.
==
11.
==
The
==
second
==
sub-bullet
==
of
==
Section
==
4.2,
==
"Use
==
of
==
PrecedentSafety
==
Evaluations,"
==
states:
==
"ensurethat
==
the
==
precedent
==
meets
==
current
==
expectations
==
for
==
format,
==
findings,
==
internalNRR
==
guidance
==
for
==
the
==
item,
==
==
guidance
==
to
==
industry,and
==
technical
==
content.
==
The
==
discussion
==
of
==
what
==
constitutes
==
appropriate
==
precedent
==
should
==
be
==
expanded.
==
More
==
explicit
==
guidelines
==
will
==
help
==
licensees
==
and
==
the
==
NRC
==
staff
==
cite
==
precedent
==
safety
==
evaluations
==
with
==
greater
==
confidence.
==
RESPONSE:
==
The
==
staff
==
intended
==
the
==
phrase
==
to
==
simply
==
caution
==
against
==
the
==
use
==
of
==
a
==
precedent
==
evaluation
==
without
==
considering
==
the
==
possibility
==
that
==
the
==
NRC
==
technical
==
position
==
or
==
preferred
==
safety
==
evaluation
==
content
==
might
==
have
==
changed
==
in
==
the
==
period
==
between
==
applications
==
(sometimes
==
years).
==
The
==
staff
==
will
==
consider
==
adding
==
some
==
clarification
==
to
==
the
==
Office
==
Letter.
==
See
==
subsequent
==
response
==
for
==
more
==
detailed
==
discussion
==
of
==
precedents.
==
12.
==
Section
==
4.3,
==
"Requestsfor
==
Additional
==
Information,"
==
contains
==
guidance
==
on
==
the
==
content
==
and
==
timing
==
of
==
RAIs.
==
==
guidance
==
should
==
apply
==
to
==
all
==
NRC
==
requests,
==
not
==
just
==
proposed
==
license
==
amendments.
==
RESPONSE:
==
As
==
discussed
==
in
==
A.2
==
above,
==
additional
==
information
==
will
==
be
==
included
==
to
==
ensure
==
adherence
==
to
==
==
guidance
==
for
==
other
==
licensing
==
actionrequests,
==
such
==
as
==
exemption
==
and
==
relief
==
requests.
==
This
==
section
==
should
==
state
==
that
==
the
==
number
==
and
==
nature
==
of
==
RAls
==
are
==
not
==
indicators
==
of
==
the
==
quality
==
of
==
staff
==
review.
==
The
==
long-term
==
objective
==
is
==
to
==
improve
==
the
==
communication
==
of
==
mutual
==
expectations
==
such
==
that
==
the
==
need
==
for
==
==
decreases
==
over
==
time.
==
A
==
goal
==
of
==
"zero
==
RAls"
==
is
==
reasonable
==
and
==
achievable.
==
RESPONSE:
==
The
==
number
==
of
==
RAIs,
==
by
==
itself,
==
does
==
not
==
necessarily
==
indicate
==
the
==
quality
==
of
==
a
==
licensee's
==
submittal.
==
The
==
need
==
for
==
clear
==
communications
==
will
==
be
==
emphasized
==
so
==
that
==
unneeded
==
==
will
==
not
==
be
==
issued.
==
If
==
the
==
first
==
paragraph
==
of
==
Section
==
4.3
==
were
==
reformatted
==
as
==
a
==
list,
==
it
==
would
==
better
==
emphasize
==
the
==
importance
==
of
==
ensuring
==
that
==
each
==
==
question
==
is
==
warranted.
==
RESPONSE:
==
Suggested
==
format
==
will
==
be
==
considered.
==
With
==
respect
==
to
==
item
==
1
==
on
==
page
==
4.3,
==
technical
==
branch
==
reviewers
==
should
==
be
==
sure
==
to
==
include
==
the
==
regulatory
==
basis
==
for
==
their
==
questions
==
so
==
the
==
==
can
==
include
==
it
==
in
==
==
telecons
==
and
==
letters
==
to
==
licensees.
==
RESPONSE:
==
Clearer
==
guidance
==
will
==
be
==
included
==
in
==
the
==
next
==
revision
==
and
==
additional
==
staff
==
training
==
will
==
be
==
provided,
==
as
==
needed.
==
The
==
staff
==
is
==
considering
==
reactions
==
from
==
various
==
internal
==
and
==
external
==
stakeholders
==
regarding
==
the
==
format
==
of
==
RAIs.
==
Although
==
RESPONSE:
==
Clearer
==
guidance
==
will
==
be
==
included
==
in
==
the
==
next
==
revision
==
and
==
additional
==
staff
==
training
==
will
==
be
==
provided,
==
as
==
needed.
==
The
==
staff
==
is
==
considering
==
reactions
==
from
==
various
==
internal
==
and
==
external
==
stakeholders
==
regarding
==
the
==
format
==
of
==
RAls.
==
Although
==
the
==
importance
==
of
==
having
==
a
==
nexus
==
between
==
==
questions
==
and
==
our
==
regulatory
==
finding
==
will
==
continue
==
to
==
be
==
emphasized
==
in
==
the
==
Office
==
Letter,
==
it
==
is
==
not
==
certain
==
that
==
the
==
guidance
==
will
==
require
==
an
==
explicit
==
reference
==
to
==
a
==
regulatory
==
requirement
==
for
==
each
==
question.
==
The
==
staff
==
is
==
attempting
==
to
==
balance
==
the
==
various
==
factors
==
(burden,
==
efficiency,
==
etc.)
==
in
==
developing
==
the
==
specific
==
guidance.
==
With
==
respect
==
to
==
item
==
3
==
regarding
==
communications
==
prior
==
to
==
issuing
==
an
==
==
(page
==
4.3)
==
and
==
item
==
6
==
regarding
==
communications
==
after
==
issuing
==
an
==
==
(page
==
4.4),
==
a
==
PM/TB/Licensee
==
conference
==
call
==
would
==
be
==
useful
==
in
==
both
==
cases.
==
Technical
==
branch
==
participation
==
in
==
conference
==
calls
==
will
==
help
==
assure
==
that
==
technical
==
questions
==
are
==
clearly
==
communicated
==
and
==
understood
==
by
==
all
==
parties.
==
The
==
conversation
==
may
==
obviate
==
the
==
need
==
for
==
at
==
least
==
some
==
of
==
the
==
questions.
==
RESPONSE:
==
Clearer
==
guidance
==
will
==
be
==
included
==
in
==
the
==
next
==
revision.
==
==
should
==
not
==
be
==
used
==
as
==
general
==
information
==
requests,
==
or
==
as
==
a
==
means
==
to
==
encourage
==
commitments
==
from
==
licensees.
==
RESPONSE:
==
This
==
will
==
be
==
emphasized
==
clearly
==
in
==
the
==
new
==
Office
==
Letter.
==
The
==
staff
==
would,
==
however,
==
caution
==
against
==
making
==
communication
==
protocols
==
too
==
rigid
==
in
==
terms
==
of
==
the
==
questions
==
that
==
can
==
be
==
asked
==
during
==
conference
==
calls.
==
Licensees
==
should
==
understand
==
that
==
a
==
few
==
general
==
questions
==
during
==
a
==
conference
==
call
==
may
==
be
==
the
==
most
==
efficient
==
and
==
cost-effective
==
way
==
for
==
a
==
reviewer
==
to
==
complete
==
an
==
evaluation.
==
Hopefully,
==
both
==
staff
==
and
==
licensees
==
can
==
work
==
to
==
reach
==
the
==
appropriate
==
level
==
of
==
questions
==
to
==
meet
==
the
==
needs
==
and
==
efficient
==
use
==
of
==
resources
==
of
==
both
==
parties.
==
13.
==
Section
==
4.4,
==
"RegulatoryCommitments,
==
"discusses
==
the
==
potentialfor
==
escalation
==
of
==
commitments
==
into
==
license
==
conditions.
==
The
==
NRC
==
should
==
discontinue
==
the
==
practice
==
of
==
escalating
==
commitments
==
into
==
license
==
conditions.
==
If
==
a
==
licensee
==
has
==
submitted
==
a
==
license
==
amendment
==
application
==
under
==
oath
==
and
==
affirmation,
==
and
==
the
==
NRC
==
staff
==
has
==
approved
==
the
==
amendment,
==
associated
==
commitments
==
should
==
be
==
managed
==
through
==
a
==
formal
==
commitment-management
==
program.
==
If
==
commitments
==
are
==
not
==
being
==
satisfied,
==
the
==
NRC
==
has
==
sufficient
==
authority
==
to
==
take
==
enforcement
==
action
==
when
==
warranted.
==
RESPONSE:
==
The
==
staff
==
intended
==
the
==
guidance
==
to
==
reflect
==
the
==
general
==
hierarchy
==
of
==
the
==
licensing
==
bases
==
that
==
has
==
been
==
discussed
==
between
==
industry
==
and
==
NRC
==
on
==
several
==
occasions
==
(see
==
SECY
==
98-224).
==
The
==
Office
==
Letter
==
states
==
that
==
the
==
staff
==
should
==
not
==
routinely
==
make
==
commitments
==
into
==
license
==
conditions.
==
However,
==
it
==
is
==
possible
==
that
==
a
==
licensee
==
might
==
make
==
a
==
commitment
==
in
==
an
==
application
==
that
==
the
==
staff
==
believes
==
should
==
be
==
escalated
==
into
==
a
==
regulatory
==
requirement
==
(e.g.,
==
a
==
license
==
condition).
==
The
==
guidance
==
to
==
be
==
included
==
in
==
==
807
==
will
==
clarify
==
this
==
issue.
==
14.
==
Section
==
4.5,
==
"Safety
==
Evaluation
==
Format,"
==
discusses
==
various
==
technicaland
==
format
==
considerationsassociated
==
with
==
NRC
==
staff
==
safety
==
evaluation
==
reports
==
(SERs).
==
Section
==
4.5
==
does
==
not
==
disci
==
ss
==
differences
==
between
==
licensee
==
submittals
==
and
==
NRC
==
staff
==
SERs.
==
The
==
Office
==
Letter
==
should
==
include
==
guidance
==
for
==
citing
==
the
==
differences,
==
including
==
the
==
reasons
==
for
==
the
==
differences.
==
This
==
would
==
allow
==
all
==
parties
==
to
==
verify
==
that
==
the
==
==
satisfies
==
the
==
==
rule
==
(10
==
CFR
==
50.109).
==
RESPONSE:
==
The
==
staff
==
will
==
add
==
guidance
==
in
==
this
==
area
==
15.
==
Section
==
5.0,
==
"Review
==
and
==
Concurrence,"
==
discusses
==
the
==
process
==
by
==
which
==
the
==
quality
==
and
==
consistency
==
of
==
an
==
amendment
==
package
==
is
==
verified.
==
The
==
discussion
==
in
==
this
==
section
==
should
==
include
==
Tech
==
Spec
==
Bases
==
changes.
==
If
==
Bases
==
changes
==
are
==
part
==
of
==
an
==
amendment
==
package,
==
the
==
NRC's
==
==
and
==
transmittal
==
letter
==
should
==
explicitly
==
state
==
that
==
the
==
Bases
==
changes
==
are
==
part
==
of
==
the
==
NRC
==
staff's
==
approval.
==
Otherwise
==
licensees
==
are
==
left
==
to
==
assume
==
that
==
proposed
==
Bases
==
changes
==
have
==
been
==
approved
==
by
==
the
==
NRC
==
staff's
==
review.
==
RESPONSE:
==
As
==
previously
==
discussed,
==
the
==
staff
==
and
==
LATF
==
plan
==
to
==
refine
==
guidance
==
for
==
the
==
NRC
==
and
==
licensees
==
regarding
==
Bases
==
changes.
==
16.
==
Section
==
5.0,
==
"Review
==
and
==
Concurrence,"discusses
==
the
==
attributes
==
of
==
a
==
completed
==
amendment
==
package.
==
If
==
final
==
NRC
==
concurrence
==
cannot
==
be
==
reached
==
to
==
approve
==
the
==
amendment
==
package,
==
the
==
licensee
==
should
==
have
==
the
==
opportunity
==
to
==
communicate
==
with
==
cognizant
==
NRC
==
staff
==
to
==
provide
==
additional
==
clarification
==
or
==
information
==
in
==
support
==
of
==
the
==
proposed
==
amendment.
==
Any
==
meeting
==
or
==
conference
==
call
==
should
==
occur
==
before
==
NRC
==
takes
==
final
==
written
==
action.
==
RESPONSE:
==
This
==
is
==
the
==
general
==
practice.
==
The
==
staff
==
will
==
consider
==
adding
==
additional
==
guidance
==
to
==
the
==
OL.
==
General
==
Comments
==
on
==
Enclosure
==
2
==
-
==
Use
==
of
==
Precedents
==
The
==
staff
==
is
==
not
==
aware
==
of
==
general
==
issues
==
regarding
==
the
==
inclusion
==
or
==
exclusion
==
of
==
reviews
==
in
==
terms
==
of
==
our
==
use
==
of
==
precedents.
==
In
==
general,
==
if
==
a
==
reviewer
==
believes
==
that
==
a
==
review
==
(in
==
whole
==
or
==
in
==
part)
==
is
==
relevant,
==
we
==
want
==
to
==
encourage
==
the
==
use
==
of
==
the
==
review
==
as
==
a
==
precedent.
==
We
==
do
==
not
==
foresee
==
adding
==
significant
==
guidance
==
in
==
this
==
area.
==
We
==
will
==
consider
==
some
==
of
==
the
==
suggestions
==
in
==
Enclosure
==
2
==
such
==
as
==
improving
==
our
==
documentation
==
regarding
==
the
==
use
==
of
==
precedent
==
reviews.