NRR Office Instruction LIC-500 “Topical Report Process”

Update PlanUpdate PlanPresented at the public meeting with the industry

May 2, 2012

Andy Hon PE Topical Reports Process Project Manager

NRR/DRP/PLPB

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Agenda• Purpose:

– Communicate process improvement on vendor/owner group topical reports (TR) reviews as followup to last year’s public meeting.

• Outcome:– Brief stakeholders on progress with Office Instruction

LIC-500 Revision-5• Process:

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• Process:– Present the identified improvement needs and work

done in LIC-500 update:1. Prioritization and performance measures2. Approved Version usage reinforcement.3. Implementing NRR-NRO interface improvement

recommendations.4. Other administrative and editorial improvements

5/17/2011

Topical Report Review Process Summary• Staff attends vendor/owners group pre-submittal meeting.

• V/OG submits the TR.

• OCFO determines fee waiver, if requested, based on tech branch’s input.

• DPR/PLPB PM opens the TAC, coordinates with the tech branch and the V/OG to review.

• Tech branch and PLPB:– determines Acceptance for Reviews and expected completion

date, based on internal priority and resources,

– coordinates NRO peer reviews.

• Requests for Additional Information (RAI) and response.

• Tech Branch prepares and PM issues the draft and final Safety Evaluation (SE) in ~two years (historical).

• V/OG submits Approved version (-A) of the TR for closure.3

Significant Change #1: Prioritization and Metric

• Declining review resources available to review TRs while submittals continue to increase.

• Briefed LT on 11/12/2010 the need to apply priority to the whole TR review cycle and changed the 2-year metric to reflect the budget (20/year for FY11-12), due to resource limitations Additional cuts in FY 13 to support Fukushimalimitations. Additional cuts in FY-13 to support Fukushima Lesson’s Learned actions.

• At the recent LATF, industry (including vendors) is aware that we recently removed topical reports from our SES performance plans in part to lower the number of performance metrics and reflect limited resources, thus the need to prioritize.

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Topical Report Reviews VS. Resources (est.)

43 43

55

43

53

66

60

40

50

60

70# Topical Report Reviews Completed# TAC open backlogBudget FTEActual FTE charged Contract Budget $ X 100K

5

2724

27

43

14 15

2018

1317 15 14 16 18

$13.4

$7.6

$12.2 $10.5

$1.00

10

20

30

40

FY-07 FY-08 FY-09 FY-10 FY-11

Significant Change #1: Prioritization and Metric(Cont.)

Prioritization

• Drafted an expanded priority score card and coordinated with NRR division TAs for tech branch inputs in March 2011.

• Met with the stakeholders on 7/28/2011for industry’s i t f t t idinputs on factors to consider.

• Updated draft score card with feedbacks received.

• Use this public meeting to inform the stakeholders the priority score card to be used

• Will update the metric, score card and Acceptance for Review Letter in LIC-500 (e.g. no longer committing completion dates).

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Proposed Prioritization Factors for the Score Card

• TR’s Classification: – Generic Safety Issue (6)

– Emerging issue resolution, (3)

– New safety technology (2),

– Revision to outdated TRs (2)( )

– Standard TR (1)

• TR Application Scope (potential)– Industry wide (3)

– Entire group (2)

– Only partial group (1)

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Proposed Prioritization Factors for the Score Card• TR Implementation Certainty

– Industry wide implementation (3)

– Entire group who sponsored the TR (2)

– Letter of intent by US plant licensee to docket (1)

• Tie to an actual licensing action or renewal date (3)

• Review Progress (mainly for mid priority current reviews)

– Accepted for Review (0.3) , RAI issued (0.5)

– RAI responded (1.2), SE drafted (2.0).

• NRR Management discretion adjustment (↑ or ↓) for border line mid-high priority TRs. (-3 to +3).

• Total score is the sum of the above. (0 – 22)

• Applicable only to specific technical division/branch for priority decisions.

• PM will coordinate with each stakeholder to finalize the list by the end of June 2012.

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Draft Score Card to Update LIC500- Rev-5

Examples of Current Backlog p gPartial List with scores

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Significant Change #1: Prioritization and Metric(Cont.)

Proposed list for inactive low priority backlog

Purpose:

• Establish a meaningful backlog list with realistic milestones for high priority TR reviews.

• Avoid charging time/contract dollar to frequently interrupted low priority TR reviews without results.interrupted low priority TR reviews without results.

• Better resources justification and management for both parties.

Implementation:

• PM will maintain a centralized inactive list and update it (moving to active TAC list), as needed.

• PM will coordinate with each stakeholder to finalize this list by the end of June 2012.

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Significant Change #2: Approved Version “-A” Reinforcement

• “-A” is intended to be a compilation of all existing docketed documents related to the topical report approval.

• It should have incorporated the limitations and conditions of the SE without adding unreviewed new information.

• It provides the application licensees and NRC licensingIt provides the application licensees and NRC licensing action reviewers a complete and self-contained info package to minimize misunderstandings and omissions.

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Significant Change #2: Approved Version Reinforcement (cont)

Issues:

• Some vendors/OGs are slow in submitting the “-A” TR and some TBs treat its review as low priority work. Vendor/OG sometimes add/omit important info. Recent example is a TSTF referencing a “-A” that did not properly incorporate the conditions outlined in the SE and was not accepted.

• LIC-500 does not explicitly require the staff to review the submitted “-A” for accuracy/completeness by certain date.

• Licensees currently submit LARs referencing either approved “-A” or just the SE.

Need to reinforce only staff approved “-A” TR be referenced

• Clarify final staff review of the “-A” via LIC-500.

• Reinforce the referencing only staff accepted “-A” in LARs by DORL PMs’ acceptance for review for SE>3 months. 12

Significant Change #3: NRO Interface Improvement(05/17/2011 LT Approved Recommendations)

• Update LIC-500 to add guidance on dual applicability topical report reviews to include:

– PM checklist, such as that used for TR pre-submittal meeting participation.

Other office’s review/concurrence that is built into the– Other office s review/concurrence that is built into the project management closure plan -schedule/resource loaded.

– Joint Office OI with NRO (proposed).

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#4 Other administrative and Editorial Improvements

• Updating organizations and contacts.

• Updating boiler plate letters for Plain Writing Act of 2010 and MD 3.57 “Correspondence Management” implementation.

• Capturing updates on metric priorities NRO interface• Capturing updates on metric, priorities, NRO interface and “-A” protocol.

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Summary• Purpose:

– Communicated process improvement on vendor/owner group topical reports reviews to followup last year’s public meeting.

• Outcome:– Briefed stakeholders on progress with LIC-500

Revision-5• Process:

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• Process:– Presented the identified improvement needs and work

done in LIC-500 update:1. Prioritization and performance measures.2. Approved Version usage reinforcement.3. Implementing NRR-NRO interface improvement

recommendations.4. Other administrative and editorial improvements

5/17/2011

Backup Slides

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Topical Report Review Purpose Summary

• TR deals with a specific safety-related subject regarding a nuclear power plant that requires a safety evaluation by the NRC staff.

• The TR is expected to be used by multiple licensees in a number of requests for licensing actions.

• Consistent with the criteria in LIC-109, “Acceptance pReview Procedures,” the TR contains complete and detailed information on the specific subject presented. Conceptual or incomplete preliminary information will not be reviewed.

• NRC approval of the report will increase the efficiency of the review.

• LIC-500 is the process for applications that reference the report.

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