ML19275H067
| ML19275H067 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/2019 |
| From: | Joseph Holonich NRC/NRR/DLP/PLPB |
| To: | |
| Holonich J, NRR/DLP/PLPB, 415-7297 | |
| References | |
| Download: ML19275H067 (12) | |
Text
TR Modernization Process Update Topical Report Transformation Working Group Joe Holonich Jason Drake Josh Kaizer Ngola Otto Rich Stattel On Yee October 23, 2019
Purpose 2
Bottom line: the implementation of an integrated, combination of approaches to improve the timeliness of topical report (TR) reviews.
Purpose:
Provide an overview of options, courses of action, and recommended path forward for TR process transformation.
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Background===
3 Topical Reports in licensing Not required Single staff review of a safety-related topic Low priority Most are new technology, methodology, or process Industry concerns about timeliness of reviews Budgeted resources for TR historically did not cover need TR Transformation Working Group established
Current TR Process Observations 4
Same review regardless of TR complexity New topic or TR revision Large or small TR Variations in TR Vendor submissions can vary in quality Staff resources required to complete the review Multiple rounds of RAIs are often needed to complete the SE
List of Options 5
Option Brief Description Status Quo No change in current process Simplified and Limited SE Standard form (3-4 pages) or reduced SE documentation Modified Reviews Accept or deny; Prepare draft SE with open items for vendor to address with RAIs in only minimal circumstances Tiger team reviews Perform on-site audit and prepare draft SE with open items Submittal documentation Not require RAIs for all information from vendors Administrative process Editing and administrative processes add time Eliminate -A version End review when final SE is issued Dedicate Branches Pre-assign dedicated staff to TR Review Branch
Timelines for Current and Proposed Topical Reviews 6
Analysis of Options 7
Option Potential Time to SE Pros Cons Recommend Implementation Period Status Quo
- Varies, lengthy
- Known process
- Does achieve reviews
- Concerns about timeliness
- Need to husband scarce resources
- One size fits all Keep N/A Simplified and Limited SE 3-12 months
- Reduce review time
- Focus resources on risk significant TRs
- Submit smaller changes which get reviewed faster
- TR update process
- Distinction based in TR complexity
- Difficult to establish the reduced scope.
- Difficult to project appropriate SE
- Challenging to limit staff hours Yes, pilot Short term Modified Review 12 Months
- Vendor burden
- Keeps schedule
- External pressures to continue work
- Staff and vendor want TR Yes, pilot Short term
Analysis of Options (cont.)
8 Option Potential Time to SE Pros Cons Recommend Implementation Period Tiger team reviews 12 Months
- Draft SE complete
- RAIs if needed
- Shorter reviews
- Not all TRs
- Need right TR and staff
- Billing for travel Yes, Pilot Short Term Submittal documentation Varies
- Reduce RAIs
- Significant time savings
- Potential confusion
- Information tracking Yes Short Term Administrative process Varies
- Improve timeliness
- Accurate budget
- AA staff overloaded
- Priorities shift
- Focus for cuts Yes Short term Eliminate -A version None
- Some resource savings
- Time savings
- TRs could be changed
- Review time not shortened No N/A Dedicated TR Branches None
- Establishes special teams
- Avoids competing priorities
- TR workload may not justify No N/A
Recommended Combination of Options -
Short Term 9
Simplified SE no new regulatory finding confirming previous NRC finding is still applicable.
minimal documentation (e.g., a few sentences) 3 - 6 months to complete review Limited SE new regulatory finding finding is of very limited scope and requires minimal assessment.
some documentation (e.g., a few pages) 6 - 9 months to complete review Normal SE: Current process Reduced documentation Administrative processes: Document processing and editing Establish a flow diagram and associated guidance in LIC-500 to enable to appropriate SE for each review.
Path Forward 10 Simplified SE Pilot
- Digital I&C TR change (October 2019)
- Second TR is being considered for pilot Reduced SE Pilot Submittal in October 2019 Tiger Team review ongoing
- March - Review began
- September - Final Draft SE Activity Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep LIC-500 Update #1 OGC Rule Pilot Simplified SE Public Workshop Pilot Reduced SE Admin Process Discussion LIC-500 Update #2
- Write New Procedure
-LT Review
- Training (if needed)
-Implmentation FY 2020
Simplified SE Standard Form Concept 11
Simplified SE Standard Form Concept (cont.)
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