Nuclear Energy
NRC's Workforce and Processes for New Reactor Licensing Are Generally in Place, but Uncertainties Remain as Industry Begins to Submit Applications Gao ID: GAO-07-1129 September 21, 2007Nearly three decades after the last order for a new nuclear power reactor in the United States, electric power companies plan to submit 20 applications in the next 18 months to the Nuclear Regulatory Commission (NRC) for licenses to build and operate new reactors. Since 1989, NRC has developed a new license review process that allows a power company to obtain a construction permit and an operating license through a single combined license (COL) based on one of a number of standard reactor designs. NRC expects its new process to enhance the efficiency and predictability of its reviews. GAO reviewed NRC's readiness to evaluate these applications by examining the steps NRC has taken to (1) prepare its workforce and manage its workload and (2) develop its regulatory framework and review process for new reactor activities. GAO reviewed NRC documents for new reactor workforce staffing and training, examined NRC's guidance for the review of license applications, interviewed NRC managers and representatives of nearly all of the COL applicants, and observed NRC's public meetings.
NRC has taken many steps to prepare its workforce for new reactor licensing reviews, but several key elements of its preparations are still underway. As a result, uncertainties remain about NRC's ability to manage its workload associated with the surge of applications. Specifically, NRC has increased its funding for new reactor activities, created the Office of New Reactors and reorganized several other offices, and hired a significant number of entry-level and midlevel professionals. To assist its staff in reviewing the applications, NRC also plans to contract out about one-third of its fiscal year 2008 workload. However, several elements of NRC's preparatory activities are still in progress, including hiring for some critical positions; developing key training courses; and developing computer-based tools intended to enhance consistency and coordination in reviewing like sections of COL applications. In addition, NRC has not fully developed criteria for setting priorities if the workload exceeds available staff and contractor resources. Finally, while the Office of New Reactors established a cross-divisional resource management board early in 2007 for coordinating certain office review activities, it has not clearly defined the extent of the board's responsibilities. NRC has significantly revised its regulatory framework and review process to prepare for licensing new reactors, but until NRC completes certain additional actions, it may not fully realize the anticipated benefits of the new process. NRC has revised, augmented, and clarified most rules, guidance, and inspection oversight criteria to provide for early resolution of issues, standardization, and predictability in the license review process. However, NRC has not yet completed several actions to implement this process. For example, NRC only recently modified its acceptance review process to include an evaluation of the application's technical sufficiency in addition to its completeness. NRC plans to complete new acceptance review guidance and tools reflecting this change by the end of September 2007. NRC also is refining its process for tracking requests to each applicant for more information but has not developed a coordinating mechanism to avoid unnecessarily requesting information from multiple applicants.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-07-1129, Nuclear Energy: NRC's Workforce and Processes for New Reactor Licensing Are Generally in Place, but Uncertainties Remain as Industry Begins to Submit Applications
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Licensing Are Generally in Place, but Uncertainties Remain as Industry
Begins to Submit Applications' which was released on September 28,
2007.
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
September 2007:
Nuclear Energy:
NRC's Workforce and Processes for New Reactor Licensing Are Generally
in Place, but Uncertainties Remain as Industry Begins to Submit
Applications:
Nuclear Energy:
GAO-07-1129:
GAO Highlights:
Highlights of GAO-07-1129, a report to congressional committees.
Why GAO Did This Study:
Nearly three decades after the last order for a new nuclear power
reactor in the United States, electric power companies plan to submit
20 applications in the next 18 months to the Nuclear Regulatory
Commission (NRC) for licenses to build and operate new reactors. Since
1989, NRC has developed a new license review process that allows a
power company to obtain a construction permit and an operating license
through a single combined license (COL) based on one of a number of
standard reactor designs. NRC expects its new process to enhance the
efficiency and predictability of its reviews. GAO reviewed NRC‘s
readiness to evaluate these applications by examining the steps NRC has
taken to (1) prepare its workforce and manage its workload and (2)
develop its regulatory framework and review process for new reactor
activities. GAO reviewed NRC documents for new reactor workforce
staffing and training, examined NRC‘s guidance for the review of
license applications, interviewed NRC managers and representatives of
nearly all of the COL applicants, and observed NRC‘s public meetings.
What GAO Found:
NRC has taken many steps to prepare its workforce for new reactor
licensing reviews, but several key elements of its preparations are
still underway. As a result, uncertainties remain about NRC‘s ability
to manage its workload associated with the surge of applications.
Specifically, NRC has increased its funding for new reactor activities,
created the Office of New Reactors and reorganized several other
offices, and hired a significant number of entry-level and midlevel
professionals. To assist its staff in reviewing the applications, NRC
also plans to contract out about one-third of its fiscal year 2008
workload. However, several elements of NRC‘s preparatory activities are
still in progress, including hiring for some critical positions;
developing key training courses; and developing computer-based tools
intended to enhance consistency and coordination in reviewing like
sections of COL applications. In addition, NRC has not fully developed
criteria for setting priorities if the workload exceeds available staff
and contractor resources. Finally, while the Office of New Reactors
established a cross-divisional resource management board early in 2007
for coordinating certain office review activities, it has not clearly
defined the extent of the board‘s responsibilities.
NRC has significantly revised its regulatory framework and review
process to prepare for licensing new reactors, but until NRC completes
certain additional actions, it may not fully realize the anticipated
benefits of the new process. NRC has revised, augmented, and clarified
most rules, guidance, and inspection oversight criteria to provide for
early resolution of issues, standardization, and predictability in the
license review process. However, NRC has not yet completed several
actions to implement this process. For example, NRC only recently
modified its acceptance review process to include an evaluation of the
application‘s technical sufficiency in addition to its completeness.
NRC plans to complete new acceptance review guidance and tools
reflecting this change by the end of September 2007. NRC also is
refining its process for tracking requests to each applicant for more
information but has not developed a coordinating mechanism to avoid
unnecessarily requesting information from multiple applicants.
Table: Anticipated COL Applications by Fiscal Year:
Expected submission date: First quarter, FY 2008; Number of
applications: 5;
Number of reactor units: 9.
Expected submission date: Second quarter, FY 2008; Number of
applications: 4;
Number of reactor units: 6.
Expected submission date: Third quarter, FY 2008; Number of
applications: 1;
Number of reactor units: 1.
Expected submission date: Fourth quarter, FY 2008 ; Number of
applications: 4;
Number of reactor units: 6.
Expected submission date: FY 2009;
Number of applications: 6;
Number of reactor units: 9.
Total;
Number of applications: 20
Number of reactor units: 31.
Source: NRC.
Note: Information as of September 10, 2007.
[End of table]
What GAO Recommends:
GAO is making recommendations to better ensure that NRC‘s workforce and
review processes efficiently and effectively facilitate the review of
new reactor license applications. In commenting on a draft of the
report, NRC agreed with GAO‘s recommendations.
To view the full product, including the scope and methodology, click on
GAO-07-1129. For more information, contact Mark Gaffigan at (202) 512-
3841 or gaffiganm@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
NRC Has Implemented Many Actions to Prepare Its Workforce for New
Reactor Licensing Reviews, but Several Key Elements Are Still Under
Way:
NRC Has Significantly Revised Its Overall Regulatory Framework and
Review Process, but Several Activities Are Still in Progress:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Scope and Methodology:
Appendix I: Major Components of NRC's New Reactor Licensing Framework:
Appendix II: Comments from the Nuclear Regulatory Commission:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: NRC Offices' Responsibilities for New Reactors:
Table 2: Computer-Based Tools to Assist NRO Reviewers:
Table 3: Key Project Management Components for New Reactor Licensing:
Table 4: Major Components of NRC's New Reactor Licensing Regulatory
Framework:
Figures:
Figure 1: The New Reactor Licensing Process under Part 52:
Figure 2: Reactor Designs Associated with the 20 Expected COL
Applications and the Estimated Schedule for Application Submission:
Figure 3: Major Aspects of the COL Review Process:
Abbreviations:
ABWR: Advanced Boiling Water Reactor:
AP1000: Advanced Passive 1000:
CIP: Construction Inspection Program:
COL: combined license:
DOE: Department of Energy:
ESBWR: Economic Simplified Boiling Water Reactor:
ESRP: Environmental Standard Review Plan:
FTE: full-time equivalent:
IMC: inspection manual chapter:
ITAAC: Inspections, Tests, Analyses, and Acceptance Criteria:
NRC: Nuclear Regulatory Commission:
NRO: Office of New Reactors:
RAI: request for information:
SRP: Standard Review Plan:
U.S. APWR: Advanced Pressurized Water Reactor:
U.S. EPR: Evolutionary Pressurized Water Reactor:
United States Government Accountability Office:
Washington, DC 20548:
September 21, 2007:
The Honorable Barbara Boxer:
Chairman:
The Honorable James M. Inhofe:
Ranking Member:
Committee on Environment and Public Works:
United States Senate:
The Honorable Thomas R. Carper:
Chairman:
The Honorable George V. Voinovich:
Ranking Member:
Subcommittee on Clean Air and Nuclear Safety:
Committee on Environment and Public Works:
United States Senate:
Nearly three decades after the last order was placed for a new civilian
nuclear power reactor in the United States, electric power companies
are again showing interest in nuclear power. This interest reflects the
nation's growing demand for electricity, which will require the
addition of substantial new generating capacity. It also has coincided
with ever-increasing U.S. dependence on foreign oil, higher natural gas
prices, and uncertainty about future restrictions on the carbon dioxide
emissions of coal-fired power plants. To reduce the nation's dependence
on crude oil, the Energy Policy Act of 2005 authorizes the Department
of Energy (DOE) to diversify the U.S. energy portfolio by, among other
things, providing financial incentives to stimulate investment in new
nuclear power reactor projects, which can cost more than $4 billion.
The Nuclear Energy Institute, which represents the nuclear power
industry, estimates that the industry has spent more than $2 billion
during the past 3 years in preparation for applying to the Nuclear
Regulatory Commission (NRC) for licenses to build and operate new
reactors.
In 1989, NRC promulgated 10 CFR Part 52, which establishes a new
combined license (COL) for electric power companies to obtain a license
to build and operate a new reactor.[Footnote 1] The COL is NRC's
response to the nuclear industry's concerns about the length and
complexity of NRC's former two-step process of issuing a construction
permit followed by an operating license. The COL process provides a one-
step approval process that authorizes a licensee to construct and
conditionally operate a nuclear power plant; as such, it is intended to
provide predictability and early resolution of issues in the review
process. In addition, as shown in figure 1, NRC established (1) the
design certification, which standardizes the design of a given reactor
for all power companies using it, with modifications limited to site-
specific needs, and (2) an early site permit, which allows a potential
applicant to resolve many preliminary siting issues before filing a COL
application. NRC also plans to issue new regulations addressing the
construction activities companies can conduct with NRC authorization
and oversight (through a limited work authorization).[Footnote 2]
Figure 1: The New Reactor Licensing Process under Part 52:
[See PDF for image]
Source: NRC.
[A] NRC's Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)
process is designed to verify that a new nuclear facility has been
constructed and will operate in conformance with the COL, NRC
regulations, and the Atomic Energy Act.
[End of figure]
As of September 2007, electric power companies had informed NRC of
their intent to submit 20 COL applications between October 2007 and
about April 2009--5 by December 2007 alone. As shown in figure 2, these
companies plan to use five reactor designs: General Electric's Advanced
Boiling Water Reactor (ABWR) and Economic Simplified Boiling Water
Reactor (ESBWR), Westinghouse's Advanced Passive 1000 (AP1000), AREVA's
Evolutionary Pressurized Water Reactor (U.S. EPR), and Mitsubishi Heavy
Industries' Advanced Pressurized Water Reactor (U.S. APWR).[Footnote 3]
NRC has certified two designs that the companies plan to use--ABWR in
1997 and AP1000 in 2006--and is currently reviewing the ESBWR
design.[Footnote 4] The U.S. EPR and U.S. APWR designs have not yet
been submitted to NRC for review, although at least one reactor using
each design is under construction in another country. Design
applications may total up to 15,000 pages, and reference to the
certified design will represent a large part of a COL application.
Figure 2: Reactor Designs Associated with the 20 Expected COL
Applications and the Estimated Schedule for Application Submission:
[See PDF for image]
Source: NRC and COL applicants.
[A] Westinghouse submitted its AP1000 application for final design
approval and standard design certification in March 2002.
Note: Excludes any limited work authorizations companies plan to file
allowing them to begin certain construction activities before receiving
a license. Information as of September 10, 2007.
[End of figure]
Under the COL process, NRC estimates that the first few applications
will require about 100,000 hours of staff review and identified around
2,500 associated NRC review activities related to each application's
detailed safety, environmental, operational, security, and financial
information, which may total several thousand pages. NRC anticipates
that for each application, the review process will take 42 months--
including 30 months for its staff review, followed by approximately 12
months for a public hearing.[Footnote 5] In June 2007, NRC approved
several actions to improve the use of its resources and further
streamline and increase the predictability of its review process. These
actions may decrease the overall duration of a given review, depending
on how they are implemented.
Since the enactment of the Energy Policy Act of 2005, NRC has
accelerated its efforts to build up its new reactor workforce and
develop the necessary processes for licensing new reactors. NRC
projects that its total workforce size needs to grow from about 3,100
employees to about 4,000 employees by 2010. NRC created the Office of
New Reactors (NRO) in October 2006 to lead the new reactor reviews and
anticipates that it will employ about 500 people and spend several
million dollars a month for contractor support to conduct these reviews
in 2008. In January 2007, we reported that NRC had been generally
effective in recruiting, developing, and retaining a critically skilled
workforce and had taken several actions to enhance its overall
workforce capacity; however, we identified several challenges that will
require a considerable level of flexibility, staff commitment, and
successful strategic human capital management for NRC to be able to
appropriately adapt to shifting human capital needs.[Footnote 6]
Accordingly, we recommended that NRC take actions to further address
its current and future needs for a critically skilled workforce, and
NRC agreed with our recommendations.
In this context, you asked us to review NRC's readiness to evaluate
applications for new reactor licenses. Specifically, we examined the
steps NRC has taken to (1) prepare its workforce to review new reactor
license applications and to manage its workload and (2) develop its
regulatory framework and key review processes for new reactor
activities.
To address these questions, among other things, we reviewed NRC
documents for new reactor workforce staffing and training, examined
NRC's regulations and guidance for its review of license applications,
observed internal NRC management meetings, and interviewed NRC managers
in NRO and the Offices of Nuclear Security and Incident Response,
Nuclear Regulatory Research, and General Counsel. We also obtained the
perspectives of the Advisory Committee on Reactor Safeguards, a
statutory body of scientists and engineers, and the Atomic Safety and
Licensing Board Panel. In addition, we held discussions with nearly all
of the announced COL applicants to obtain their views on the efficiency
and usefulness of the COL process and its implementation. Finally, we
observed several of NRC's public meetings on the new reactor licensing
process. We conducted our work from January 2007 through September 2007
in accordance with generally accepted government auditing standards. A
fuller discussion of our scope and methodology is presented at the end
of our report.
Results in Brief:
NRC has implemented many actions to prepare its workforce for new
reactor licensing reviews and manage its workload, but several key
elements of its preparations are still under way. Specifically, NRC has
increased its funding for new reactor activities, reorganized several
offices, created NRO, and hired a significant number of entry-level and
midlevel professionals. To assist its staff in reviewing the safety and
environmental portions of the applications, NRC plans to contract out
about $60 million in fiscal year 2008 through support agreements with
several DOE national laboratories and contracts with commercial
companies. NRC also has rolled out several new training courses and
developed some computer-based tools to assist staff in reviewing
multiple applications. To enhance its management and coordination of
the anticipated work required to review COL applications and design
certifications, NRC is using a project management approach to plan and
schedule its workload. NRC has made progress in these areas, but
several elements of NRC's activities to prepare its workforce are still
under way, as the following illustrates:
* As of August 2007, NRC had assigned about 350 staff to NRO, about 10
percent of its workforce. However, some critical positions are vacant,
and the office plans to grow to about 500 employees in 2008. NRC also
is still developing content for in-depth training on reactor designs
and providing training in other areas needed for reviewing new reactor
applications, and has not yet implemented certain key computer-based
tools to provide staff with easy access to commonly used information.
* NRC has developed plans for allocating resources for a design
certification application and an early site permit it is currently
reviewing, 20 COL applications, 2 additional design certification
applications, and a design certification amendment application--all of
which NRC expects to have in its review process over the next 18
months. However, NRC has not yet developed specific criteria to
prioritize the review of these applications if it needs to decide which
applications take precedence. Without criteria, NRC managers are likely
to find it more difficult to decide how to allocate resources across
several high-priority areas.
* NRC has developed a comprehensive project management approach that
includes guidance, a management tracking system, and a contracting
support strategy to prepare for COL application reviews. However, it
has not yet fully developed criteria for allocating staff and resources
to both licensing activities and implementing computer-based tools
intended to improve the staff's productivity. Consequently, NRC may
have to choose between allocating resources to licensing activities or
to further developing these tools.
* NRO established a cross-divisional resource management board early in
2007 for resolving resource allocation issues if major review
milestones are at risk of not being met. However, it has not clearly
defined the board's role, if any, in managing and setting priorities
for resource allocation. As a result, NRO may not be able to
efficiently manage the multiple activities associated with reviewing at
least 26 applications associated with its new reactor program. NRC
managers we spoke with recognize this problem and plan to address it.
NRC has significantly revised its regulatory framework and review
process to prepare for licensing new reactors. Specifically, NRC has
revised and augmented its rules, guidance, and oversight criteria for
licensing and constructing new reactors primarily to provide for early
resolution of issues, standardization, and predictability in the
licensing process. In making these changes, NRC has regularly
interacted with nuclear industry stakeholders to determine which parts
of an application's technical and operational content could be
standardized and to clarify guidance on certain technical matters.
While NRC has made progress in these areas, it has not yet completed
several actions to implement its review process. For instance, NRC has
only recently initiated modifications to its acceptance review process
to include both an evaluation of the application's completeness and its
technical sufficiency. NRC plans to publish additional acceptance
review guidance reflecting these modifications by the end of September
2007. Until this guidance is publicly available, it is unclear whether
applicants will need to submit additional information or revise their
applications. In addition, NRC is refining its processes to track its
requests for additional information to each applicant. In some
instances, applicants using the same reference reactor design may be
asked the same question, and one applicant may have already provided a
satisfactory answer. With a completed tracking process, the second
reviewer could access the previously submitted information to avoid
duplication.
We are recommending that NRC take four actions--three to better manage
its new reactor application workload and one to better ensure that its
processes more efficiently and effectively facilitate these reviews.
NRC agreed with our recommendations.
Background:
The Energy Reorganization Act of 1974 established NRC as an independent
agency, headed by a five-member Commission, to regulate the nation's
civilian use--commercial, industrial, academic, and medical--of nuclear
energy and materials, including nuclear power reactors and research and
test reactors. NRC's mission is to ensure that civilian users of
nuclear materials adequately (1) protect public health and safety; (2)
promote the common defense and security, including securing special
nuclear materials against radiological sabotage and theft or diversion;
and (3) protect the environment. NRC's budget authority grew from $626
million for fiscal year 2004 to $824.9 million in fiscal year 2007, and
NRC requested $916.6 million for fiscal year 2008. By law, NRC is
required to recover about 90 percent of its budget authority each
fiscal year, less certain specified amounts, through the fees it
charges licensees and applicants. NRC staff grew from 3,110 as of
September 2004 to 3,536 employees as of August 2007.
NRC's design-centered review approach is central to its streamlined COL
review process because it allows multiple applicants to reference a
particular design by including common information in their
applications. Specifically, NRC reviews standardized application
content for a reactor design at one site--known as the reference COL.
Companies using the same design can then refer to this reference COL
content in their applications to decrease NRC's need to conduct the
same level of review twice on the same application content. NRC expects
that this design-centered review approach will provide the applicant
with more certainty about the application process and improve its
efficiency in reviewing COL applications without compromising safety.
The design-centered review approach intends to leverage work NRC
conducts through its design certification process. During that process,
NRC examines any possible limits on operations and safety, resolves any
issues that arise, and uses a rule-making process to establish a
standardized reactor unit design that is not subject to major
modifications during the COL review process. However, if a COL
application does not reference a design certification, the applicant
will have to submit the required design information in its COL
application. Furthermore, NRC staff will review any design variations
the applicant makes to the reference COL.
For each application, NRC staff prepare the project's Environmental
Impact Statement and review other site-specific factors affecting
safety and security because these factors are not standard.
Accordingly, 10 CFR Part 52 requires that the COL application provide
data and assessments of these factors. Alternatively, an applicant may
opt to provide this information by applying for an early site permit,
which allows the applicant to evaluate the suitability of a given site
without going through the full COL application process. Once NRC issues
an early site permit, the applicant can reference the permit in its COL
application without resubmitting the site information.
NRC Has Implemented Many Actions to Prepare Its Workforce for New
Reactor Licensing Reviews, but Several Key Elements Are Still Under
Way:
In preparing for COL application reviews in the time frame since our
January 2007 report, NRC has continued its hiring and training efforts
and made substantial progress in implementing reviewer and management
tools. It also has developed a systematic project management approach-
-which includes models for planning and scheduling activities and
contractor support activities--so that it can apply sufficient
resources to several applications simultaneously. However, NRC has not
yet fully developed criteria for allocating resources across COL
applications, and it has not applied separate decision-making criteria
for allocating funding for licensing activities and for support
activities, such as developing computer-based review tools.
NRC Has Taken Steps to Increase Staffing, Training, and Reviewer Tools
to Support Its New Reactor Efforts, but Several Actions Are Not
Complete:
In response to the electric power industry's growing commitment to
building new reactors following the enactment of the Energy Policy Act
of 2005, NRC has significantly increased its hiring and funding for its
new reactor licensing program. NRC's overall budget requests for new
reactor licensing activities increased from nearly $50 million in
fiscal year 2006 to about $175 million for fiscal year 2008. To
understand what resources the agency would need, NRC staff developed
estimates for how many full-time equivalent (FTE) positions would be
needed to review various applications: about 120 FTEs for a design
certification, about 60 FTEs for a reference COL,[Footnote 7] and about
30 FTEs for a subsequent COL. NRC officials noted that the reference
COL staff-time estimate does not include any efficiencies gained
through applying the design-centered review approach.
To support its review of new reactor COL applications, NRC initially
reorganized the Office of Nuclear Reactor Regulation to create a
division solely responsible for new reactor licensing work and
substantially increased its size to more than 750 employees by hiring
of entry-and midlevel employees. In August 2006, NRC created NRO to
better prepare for new reactor licensing while ensuring that the Office
of Nuclear Reactor Regulation maintained appropriate focus on the
safety of the 104 currently operating reactors, and began phasing staff
into NRO, primarily from the Office of Nuclear Reactor Regulation, in
October 2006.[Footnote 8] NRO is expected to grow from 350 employees in
August 2007 to about 500 staff during fiscal year 2008.[Footnote 9] In
addition, NRC is increasing staff to five other offices with new
reactor responsibilities. FTEs for new reactor activities in these
offices will increase from 50 to about 90 FTEs in fiscal year 2008, as
hiring continues. For example, for new reactor work, the Office of
Nuclear Security and Incident Response plans to have four times as many
staff and the Office of the General Counsel two times as many staff;
the Atomic Safety and Licensing Board Panel plans to hire at least two
times as many staff, as well as more panelists committed to new reactor
work. The Advisory Committee on Reactor Safeguards and the Office of
Nuclear Regulatory Research FTE levels will also slightly increase.
Several of these offices also reorganized to assume their new
responsibilities. Table 1 identifies the new reactor responsibilities
of several NRC offices.
Table 1: NRC Offices' Responsibilities for New Reactors:
Office: New Reactors;
Responsibilities: Lead office responsible for siting, design
certification, licensing, and oversight for new nuclear power reactors,
including construction inspection.
Office: Nuclear Security and Incident Response;
Responsibilities: Conducts a security review and consults with the
Department of Homeland Security on its security review under a
memorandum of understanding and conducts an emergency preparedness
review in coordination with the Federal Emergency Management Agency.
Office: Nuclear Regulatory Research;
Responsibilities: Assists or leads on the development of regulatory
guidance. Supports NRO on new reactor design activities, including
developing technical expertise, experimental data, numerical simulation
analyses tools, and the knowledge bases needed for making reliable and
technically sound regulatory decisions.
Office: Atomic Safety and Licensing Board Panel;
Responsibilities: Comprised of independent judges who hear and address
concerns of individuals or entities that are directly affected by any
licensing or enforcement action involving a facility that produces or
uses nuclear materials. Conducts all licensing and other hearings as
directed by the Commission. Makes determinations on the standing and
admissibility of contentions to a given COL application during the
course of the review process and issues initial decision on whether to
issue a COL.
Office: General Counsel;
Responsibilities: Counsels on the licensing of new nuclear power
reactors under 10 CFR Parts 50 and 52, including issuance of initial
licenses, early site permits, and COLs and on design certification
activities; represents NRC staff in related adjudications and on
judicial review; and advises the Commission and NRC staff on
promulgating and amending NRC regulations and guidance documents.
Office: Advisory Committee on Reactor Safeguards;
Responsibilities: Reviews and makes recommendations to the Commission
on all new reactor applications to build or operate nuclear power
reactors and reviews NRC staff's Safety Evaluation Report. The
Committee reports directly to the Commission, which appoints its
members, and is independent of the NRC staff.
Source: NRC.
[End of table]
NRC has taken steps to expeditiously staff NRO in part because more
than half of the work for a 30-month COL review is conducted in the
first year. NRO reached its fiscal year 2007 staffing level by filling
its midlevel and higher positions, phasing in existing NRC employees,
and hiring new employees. Regarding fiscal year 2007, NRO managers
noted that (1) budget constraints had limited hiring until NRC's fiscal
year 2007 appropriation was enacted in February 2007 and (2) demanding
workloads made it difficult for NRC staff to develop vacancy
announcements and select and interview candidates. Some critical
vacancies remain, and NRO will need to grow by an additional 30 percent
to reach its fiscal year 2008 target. NRO managers expressed some
concern about whether NRO will have sufficient staff with expertise to
fill such critical vacancies as project management, structural
engineering, and digital instrumentation and control. Several managers
in NRO and other NRC offices also expressed concern about NRC's ability
to retain staff in the intermediate and longer term and provide
sufficient physical space for them.
Regarding training, NRC has taken several steps to build on its
existing curriculum so staff can be prepared to review new reactor
license applications. Specifically, for new reactor licensing training,
in early 2007 NRO adapted some of the Office of Nuclear Reactor
Regulation's training to contain technical and regulatory content for
new reactors. NRC also offers basic regulatory and technical overview
training across a range of areas. In 2008, NRC plans to launch several
new courses that will include both overview and detailed training on
new reactor designs. To the extent possible, NRO and other offices are
also using on-the-job training opportunities to ensure employees have
some exposure to the breadth and depth of new reactor work, including
shadowing and mentoring programs.
The in-depth and on-the-job training opportunities made available to
staff have been somewhat limited to date. For example, the
implementation of some technical training courses was delayed because
some reactor design features need further clarification, and NRC's
budget was constrained until February 2007, when its fiscal year 2007
appropriation was enacted. It is unclear whether employees working on
some new reactor activities will be able to take these courses before
their work group's design certification or COL applications arrive. In
addition, some NRC staff conducting new reactor licensing work will not
have related practical experience because they have not participated in
early site permit, design certification, or preapplication activities.
NRC is in the process of putting new tools into place to support
reviewers as they conduct their work. These tools are designed to
enhance productivity and ensure a more consistent and coordinated
application review process by providing easily accessible pointers to
key reviewer guidance and other information. Some tools are also
intended to provide a means to document and share knowledge and lessons
learned. (See table 2.)
Table 2: Computer-Based Tools to Assist NRO Reviewers:
NRO reviewer tools: "The Wizard"; (SharePoint platform)[A];
Intent: Designed to make certain information more readily available to
staff to facilitate more effective review. This information includes
safety standard review plan sections; regulatory guide content; design
center information; and relevant codes and standards. The platform may
also be populated with topic-specific and general lessons learned,
insights, technical tips, and advice;
Status: The Wizard is available but does not contain full content.
NRO reviewer tools: Environmental Assessment Reactor Review Team Home;
Intent: Makes available environmental review plan sections, regulatory
guide content, templates and communication tools, archived public
comments, and requests for information through a Web portal to
facilitate NRC staff review. As an information access site, it can be
used for tracking progress, records management, documenting lessons
learned, and communications among staff across multiple work teams;
Status: This Web portal is in place.
NRO reviewer tools: Safety Evaluation Report templates, by each reactor
design type; (SharePoint platform);
Intent: Facilitates timely drafting of Safety Evaluation Reports by
using draft templates for generic formatting for all safety review
sections and to leverage work done during design certification reviews.
Design-specific matrixes will also be developed to identify which areas
of review remain open and need to be reviewed during the COL
application;
Status: Most templates are being completed for staff use between August
2007 and March 2008.
NRO reviewer tools: Request for Additional Information (RAI) system;
(SharePoint platform);
Intent: Designed to electronically categorize, track, and communicate
NRC's requests for information and applicants' responses to them across
both individual and multiple applications. Specifically, the system is
intended to support (1) NRC staff in generating, reviewing, and issuing
RAIs; (2) licensees in responding to RAIs; and (3) staff and licensees
in tracking RAIs;
Status: NRC expects the system will be in place by March 2008.
Source: NRC.
[A] SharePoint is a Microsoft Office server tool designed to facilitate
collaboration, provide content management features, implement business
processes, and supply access to information essential to organizational
goals and processes.
[End of table]
The development or completion of such computer-based tools as the RAI
system has been delayed until fiscal year 2008 because NRC management
gave higher priority to such activities as developing limited work
authorization guidance, publishing a proposed rule for assessing
aircraft impact characteristics not included in design basis, and
completing licensing work already in process. As a result, staff
reviews may not be as timely and consistent until these computer-based
tools are available, and NRC may not benefit from intended productivity
efficiencies.
NRC Is Implementing a Project Management Approach for Its New Reactor
Licensing Program but Needs to Make Further Enhancements:
As part of its workforce preparation, NRC is using a project management
approach to conduct and coordinate COL reviews so it can apply
sufficient resources to several applications simultaneously. With this
approach, NRC intends to enhance its overall ability to ensure
priorities are appropriate, eliminate uneven workload, and allow
managers to appropriately assess progress. As table 3 shows, the
project management approach includes four components intended to
communicate the processes, procedures, and tools to complete new
reactor licensing projects. They include (1) a Licensing Program Plan
manual, (2) general and application-specific models and templates--
whose estimates NRO took several steps to refine in 2007, (3) a
Microsoft Project tool, and (4) a contracting support strategy. In
addition, from June through September 2007, NRO provided information to
staff involved in new reactor activities to familiarize them with this
approach.
Table 3: Key Project Management Components for New Reactor Licensing:
Component: Licensing Program Plan manual;
Intent: Provides practices, procedures, and governance tools for the
management of safety and environmental reviews. The manual includes
definitions of organizational roles and responsibilities; a risk
management framework; workflow, reporting, analysis, and controls
measures; communication tools within NRO; and training outlines
tailored by staff and management responsibilities.
Component: Resource schedules and templates for design certifications,
reference COLs, subsequent COLs, and early site permits;
Intent: Provide NRC's planning estimates, assumptions, and prebaseline
plans for conducting each type of review. Templates consist of work
task data, resource data reflecting what type of resource and how much,
and time needed to accomplish the work. NRO has developed generic
models for each type of application and will develop specific models
for each slightly before, or as they receive them. The information is
maintained through NRC's Enterprise Project Management Environment.
Component: Enterprise Project Management Environment, also known as the
Microsoft Project tool;
Intent: Provides intranet access to NRC's management system tracking
schedule information. NRO intends to use the tool during the COL review
process to plan and re-plan work, track status against project and
schedule baselines, help manage resources, generate reports to track
progress, and facilitate communication.
Component: Contracting support strategy;
Intent: Provides support from (1) a blend of four or five commercial
contractors organized by NRC's design centers and supporting DOE
laboratories and (2) the U.S. Army Corps of Engineers for additional
environmental support and the U.S. Geological Survey for the seismology
review.
Source: NRC.
[End of table]
Because it plans to rely on contractors to perform about one-third of
its overall review work, NRC issued a request for proposals, developed
a contracting toolkit for staff that includes generic templates to
facilitate drafting of statements of work, and took steps to enter into
or revise interagency agreements with several DOE
laboratories.[Footnote 10] NRC plans to obligate about $60 million to
contractors in fiscal year 2008 to assist reviewers on both the safety
and environmental portions of the COL applications. In addition, in
fiscal year 2007 NRO used contractors to document its overall project
management approach and conduct a program assessment and gap analysis
for identifying additional process improvements, among other things.
While NRO managers, COL applicants, and reactor designers are generally
optimistic about the overall readiness of NRO's staff to review COL
applications, NRC faces the following challenges:
* Developing decision criteria for addressing competing priorities. NRC
has developed plans for allocating resources for a design certification
application and an early site permit it is currently reviewing, 20 COL
applications, 2 additional design certification applications, and a
design certification amendment application--all of which NRC expects to
have in its review process over the next 18 months. However, NRC has
not yet ranked initial COL application factors for making resource
allocations and schedule decisions if licensing work exceeds NRC's new
reactor budget. These factors include the quality and completeness of
the application itself, the extent to which the COL application
references an early site permit or design certification, evidence of
the applicant's financial commitment to build a reactor in the near
term, and other factors.[Footnote 11] In commenting on recommendations
in our draft report, NRO officials said that NRC will develop these
criteria by the end of 2007.
* Maximizing the use of the Microsoft Project tool. In June 2007, NRO
began using the Microsoft Project tool to schedule certain internal
activities and work related to design certification and early site
permit applications already under review. To effectively schedule
tasks, the Microsoft Project tool needs several layers of NRC staff to
regularly estimate and note their progress on each task. Entering this
information into the system is a new practice that officials
acknowledged will require some adjustment. Even with this tool, it will
be a complex undertaking for staff and managers to regularly update and
monitor entries, evaluate them for a range of user needs, and review
reports generated to assess progress. While NRC has dedicated
scheduling and project management resources to coordinate and direct
activities, it is too soon to tell whether they are sufficient.
Accordingly, understanding workflow, evaluating reports, and
continually assessing resource utilization will take some time to
become established practice. Most COL applicants generally supported
NRC's use of the Microsoft Project tool and noted that it could promote
more accountability for adhering to established schedules than has
historically been the case.
* Managing the increased reliance on contractors. NRO plans to use
contracts to support at least one-third of the COL application review
process--for fiscal year 2008, NRO's budget request is about the same
for contractor support as it is for staff salaries and
benefits.[Footnote 12] NRC's efforts to implement its contractor
support strategy are still under way. For example, NRO staff and
managers initially defined particular work they expected contractors to
conduct in fiscal year 2008. Specifically, NRO plans to use more than
200 task orders for a broad range of skills under at least 10 umbrella
contracts or interagency agreements.[Footnote 13] Contractors are to
support about 50 percent of the site-specific and environmental review
work, as they did to review early site permit applications. As of early
September 2007, NRO staff had completed most initial statements of
technical work to be included in each task order, and NRC had awarded
three of four commercial contracts and entered into three of seven
interagency agreements planned for fiscal year 2008. NRC plans to have
the remaining contracts and agreements in place by the beginning of
October 2007.
* Allocating funding for developing reviewer and management tools. In
fiscal year 2008, NRC will have hundreds of licensing activities under
way and other internal activities to support the review of COL
applications and certification of reactor designs. Evaluating the
importance of completing activities that support the reviews--such as
ensuring the smooth operation of the Microsoft Project tool, revising
computer-based reviewer tools for enhancing productivity, delivering
contractor training, increasing information technology support, or
revising remaining guidance--may not be as important as completing
priority licensing priorities. However, NRC has not developed criteria
to determine how it will allocate resources between licensing
activities and developing reviewer and management tools.
* Clarifying the Resource Management Board's role.[Footnote 14] In May
2007, NRO's management team formed a board of deputy division directors
that meets weekly. The board is responsible for developing decision-
making processes if certain milestones are in danger of not being met,
and NRO therefore has to significantly shift resources. While NRO
expects the board to recommend actions to mitigate the impact on
overall scheduling if such changes are required, it is unclear whether
the board will have any role in generally setting priorities and
directing resource allocation. Without such clarification, NRO may miss
opportunities for more effectively managing multiple activities
associated with reviewing as many as 20 applications, certifying
designs, granting early site permits, and reviewing applications for
limited work authorizations. NRC managers recognize this problem and
plan to address it.
According to NRO officials, some efforts are still under way and the
effectiveness of others cannot be determined until the application
review begins. Consequently, NRO plans to periodically assess the
project management approach's effectiveness.
NRC Has Significantly Revised Its Overall Regulatory Framework and
Review Process, but Several Activities Are Still in Progress:
In redesigning its regulatory framework to better resolve issues early
and promote standardization and predictability in the licensing
process, NRC reached out to stakeholders, particularly those who would
be seeking certification for designs or applying for licenses. Industry
stakeholders generally consider NRC's design-centered review approach
and revised framework to be an improvement over NRC's prior process.
However, NRC has not explained to applicants how it plans to implement
its revised processes for accepting (docketing) a COL application,
requesting additional information, or conducting hearings. These
uncertainties may limit expected efficiencies and predictability
regarding the total time a COL applicant needs to obtain a license.
NRC Has Revised Most Key Regulations and Guidance with Considerable
Involvement of Stakeholders:
During the past 4 years, NRC has taken several steps to significantly
revise and augment its primary regulatory framework to prepare for
licensing and construction of new reactors. This framework consists of
NRC's 10 CFR Part 52 rule; guidance to aid licensees in developing COL
application content, such as the Regulatory Guide 1.206; safety and
environmental standard review plans that guide reviewers in evaluating
applications; and criteria to guide inspectors examining operational
programs and construction activities. The framework also includes
ancillary rules and guidance related to security, limited work
authorization, and fitness for duty. (See table 4 and app. I for more
information about the framework's major components and remaining work.)
Table 4: Major Components of NRC's New Reactor Licensing Regulatory
Framework:
Framework component and purpose: 10 CFR Part 52 rule making governs the
issuance of standard design certifications, early site permits, and
COLs for nuclear power plants;
Status: Complete: Check;
Incomplete: [Empty];
Work remaining: NRC's final rule was published in the Federal Register
in August 2007, with an effective date of September 27, 2007.[A].
Framework component and purpose: Regulatory Guide 1.206 provides
guidance to applicants on how to comply with requirements laid out in
10 CFR Part 52 when submitting applications;
Status: Complete: Check;
Status: Incomplete: [Empty];
Work remaining: [Empty].
Framework component and purpose: High-priority regulatory guide updates
provide guidance to applicants on implementing specific parts of NRC's
new reactor licensing regulations;
Status: Complete: Check;
Status: Incomplete: [Empty];
Work remaining: [Empty].
Framework component and purpose: Safety Standard Review Plan provides
guidance for NRC staff to conduct safety reviews for nuclear power
plants;
Status: Complete: Check;
Status: Incomplete: [Empty];
Work remaining: [Empty].
Framework component and purpose: Environmental Standard Review Plan
provides guidance for NRC staff to conduct environmental reviews of
nuclear power plants;
Status: Complete: [Empty];
Status: Incomplete: Check;
Work remaining: NRC is awaiting public comments through September 2007
and has not yet determined when the revision of the guidance will be
completed.
Framework component and purpose: Limited Work Authorization rule making
allows holders of early site permits and COL applicants to conduct
certain preconstruction activities without a COL;
Status: Complete: [Empty];
Status: Incomplete: Check;
Work remaining: NRC approved the rule in April 2007 and issued
additional requirements for staff to complete.
Framework component and purpose: Construction Inspection Program (CIP)
is a series of inspections aimed at validating the acceptability of the
construction programs, processes, and products for new nuclear
facilities;
Status: Complete: [Empty];
Status: Incomplete: Check;
Work remaining: CIP framework is largely in place;
NRC plans to increase CIP staff as needed through 2014. In June 2007,
NRC announced plans to enhance its Vendor Inspection Program.
Framework component and purpose: Inspections, Tests, Analyses, and
Acceptance Criteria (ITAAC) enable NRC to determine whether a new
nuclear facility has been constructed and will operate in conformance
with the COL, NRC regulations, and the Atomic Energy Act;
Status: Complete: [Empty];
Status: Incomplete: Check;
Work remaining: Once a COL is issued, the licensee builds the reactor
facility and documents completion of the ITAAC. Before the facility can
begin operations, NRC must verify that all ITAAC have been met. To
support this determination, the NRC is developing the closeout
verification process that will work in coordination with its CIP. NRC
plans to issue draft guidance about this process by the end of 2008.
Framework component and purpose: Physical Protection rule making
governs security requirements for physical protection of nuclear power
plants;
Status: Complete: [Empty];
Status: Incomplete: Check;
Work remaining: NRC plans to issue the draft final rule in 2008.
Framework component and purpose: Aircraft Impact Assessment rule making
will amend Part 52 by establishing assessment requirements for security
measures that reactor designers incorporate early in the design
process;
Status: Complete: [Empty];
Status: Incomplete: Check;
Work remaining: NRC has shared information with reactor and plant
designers and plans to issue a proposed rule for public comment in
September 2007 or later.
Framework component and purpose: Fitness for Duty rule making governs
drug and alcohol testing programs and establishes requirements for
managing worker fatigue at operating nuclear power plants;
Status: Complete: [Empty];
Status: Incomplete: Check;
Work remaining: In July 2007, NRC modified its April 2007 final rule;
NRC expects to issue a final rule in early 2008. The Commission
directed staff to engage industry and other stakeholders to complete
associated regulatory guidance.
Source: NRC.
[A] 72 Fed. Reg. 49351 (Aug. 28, 2007).
[End of table]
In revising and augmenting this regulatory framework, NRC took steps to
convey key changes and solicit feedback through public meetings and
formal interactions with stakeholders to help resolve issues
early.[Footnote 15] NRC also solicited information from potential
applicants for planning purposes. In addition, NRC frequently reached
out to applicants and reactor designers during 2006 and 2007 regarding
new reactor licensing by:
* supporting the formation and activities of design-centered working
groups for COL applicants and design certification applicants to help
standardize COL application content and format and clarify NRC's
expectations for the level of detail in COL applications;[Footnote 16]
and:
* holding several public meetings related to specific technical areas--
such as digital instrumentation and control, probabilistic risk
assessment, and seismic analyses--and operational program areas,
including quality assurance, reactor component manufacturer
inspections, training, and emergency planning.
NRC accelerated some schedules to have key components of the regulatory
framework in place before applications are submitted. Both applicants
and NRC acknowledge that the accelerated, overlapping time frames for
power companies to prepare their COL applications while NRC revises its
regulatory framework have neither been ideal nor fully avoidable.
Specifically, NRC did not promulgate its Part 52 rule until August 28,
2007, 4 months after originally planned. NRC is still in the process of
completing some rules and guidance related to both licensing and
construction activities. Applicants expressed some concern that NRC's
review of applications, in some areas, could change as long as these
components remain incomplete. For example, in September 2006, NRC
proposed a rule to update physical protection requirements, which
officials told us is not due out in final form until 2008. In addition,
its limited work authorization rule, while substantially complete, will
not be available in final form before October 2007, and NRC is in the
process of developing associated guidance. NRC has not yet told
applicants how it will apply resources to limited work authorization
applications or how this will affect individual COL application review
schedules. Also, because NRC only recently solicited public comments to
further update its environmental guidance, applicants may have more
difficulty developing specific COL content for unresolved issues.
Furthermore, NRC is continuing to develop several components of the
Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) process,
such as the final closeout review for ensuring all criteria are met.
Finally, NRC has just begun its multiyear process of staffing its
Construction Inspection Program; efforts to date have primarily
included conducting a range of quality assurance inspections
activities.
While NRC Has Taken Steps to Advance the Design-centered Review
Approach, Some Aspects of the Implementation Process Are Not Yet
Complete:
NRC and applicants have taken steps to advance how the design-centered
review approach will be implemented during 2008 and 2009 to facilitate
NRC's review of applications for at least 20 COLs, 3 design
certifications, 1 design certification amendment, and 1 early site
permit, as well as 1 or more limited work authorizations. Figure 3
presents a simplified diagram of the COL application review process,
including estimated time frames associated with each aspect of the
review; major preapplication activities and postlicensing activities
associated with the completion and verification of ITAAC after the
Commission grants the COL; and information about the construction time
period should an applicant choose to build a plant.
Figure 3: Major Aspects of the COL Review Process:
[See PDF for image]
Sources: NRC and Art Explosion (photographs).
[A] Only the COL application safety review process is illustrated here.
Early site permit, design certification, and limited work authorization
activities also may affect timelines and the scope of some activities.
[B] NRC currently is considering internally recommended changes to its
hearing process.
[C] Some draft Environmental Impact Statement activities also occur in
phase 1.
[End of figure]
NRC officials expect to develop schedule estimates for each application
after it is received, conduct an estimated 60-day initial review of
technical sufficiency and completeness as a basis for docketing an
application; and if the application is found acceptable, develop an
estimated schedule for completing the review. The COL review process
includes three primary areas of review: the safety/technical review,
which results in a Safety Evaluation Report; the environmental review,
which results in an Environmental Impact Statement; and the
adjudicatory review, which results in hearing findings/orders.
Throughout the safety and environmental reviews, NRC typically develops
several hundred requests for additional information that range in
length and complexity to ascertain the sufficiency of the information
the applicant has provided so that NRC can develop its findings. NRC
officials estimated that the safety review will take 30 months, the
environmental review 24 months. Prehearing activities take place
concurrently with the staff's reviews, while the hearing on any
contested issues and on the uncontested portion of the application
takes about 12 months once NRC staff have completed their safety and
environmental review documents.
COL applicants and reactor designers told us they support NRC's design-
centered review approach. They expect that standard applications will
enable NRC staff, to the maximum extent practical, to use a "one issue,
one review, one position" strategy. They said this approach is feasible
if applicants and NRC staff implement it as intended, in accordance
with guidance set out in NRC's Regulatory Guide 1.206 and Standard
Review Plan. Most applicants and managers stated that they plan to be
thorough, timely, and disciplined in implementing the process for
reviewing COL applications. However, they also expected that some
processes and procedures will be clarified during the implementation
process. Furthermore, several COL and design applicants jointly
developed detailed matrixes to identify all reference COL application
parts that are identical to the design and all subsequent COL
application parts that are identical to the reference COL. These parts
are incorporated by reference, other parts are clearly identified as
including some similar content, and the remaining parts are clearly
identified as site specific. Also, the Nuclear Energy Institute and
applicants developed standard templates for certain parts of the
application content--for example, some operational programs--and NRC
agreed to their use.[Footnote 17]
While NRC has substantially defined its COL review process, it is not
yet clear how the agency will implement a few key components. For
example, NRC is revising the acceptance review process and the conduct
of hearings in response to an internal task force's recommendations.
Consequently, uncertainties remain about how these processes will be
implemented, which may make it more difficult for applicants to know
what information they must provide and how NRC will review their
applications:
* Clarifying recent acceptance review process changes. In June 2007, 3
months before it expected to receive the first COL applications, NRC
announced it would expand its acceptance review process to include not
only an evaluation of the application's completeness but also its
technical sufficiency. NRC also increased the allotted amount of time
for this review from 30 to 60 days. The intent of the new process is to
enable NRC to identify areas of potential concern early in the process
and discuss them with the applicant. NRC expects that applicants will
submit high-quality, complete applications for docketing. By the end of
September 2007, NRC plans to publicly release associated internal
guidance that its staff will use for deciding whether to accept, delay,
or reject docketing.[Footnote 18]
* Better managing the request for additional information process. Such
requests to assess technical sufficiency during the review process have
been a central component of prior safety and environmental reviews, yet
a few steps remain to better ensure efficiency. NRC is still developing
its process for tracking requests for additional information from
applicants. However, NRC cannot yet coordinate these requests to
multiple applicants who are using the same reactor design, which may
lead to unnecessary duplication of effort. For example, in some
instances, applicants using the same reference reactor design may be
asked the same question, and one applicant may have already provided a
satisfactory answer. If NRC's tracking system were in place, the second
reviewer could have access to the previously submitted information,
thereby avoiding another request for information and improving the
efficiency of the review. Several COL applicants also expressed concern
that duplicative or unnecessarily detailed requests for information may
result because many of the reviews will be conducted simultaneously by
multiple reviewers. Until the revised process is available to staff and
communicated to stakeholders, it is unclear whether NRC will gain
intended efficiencies in applying the design-centered review approach
to its request for information process.
* Addressing ITAAC process implementation concerns early. Some NRC
staff and COL applicants said they would benefit from further
discussion about how NRC will (1) oversee the applicant's
implementation of ITAAC for the construction and operation of the new
nuclear reactor units and (2) determine that an ITAAC is complete. In
addition, applicants will need to inform NRC about certain procurement
and construction activities, such as the acquisition of major parts.
* Completing revisions to the hearing process. NRC is revising its
policy for conducting hearings on both the contested and uncontested
portions of applications.
- In June 2007, NRC issued a proposed policy statement that would allow
the Atomic Safety and Licensing Board Panel to consolidate hearings on
contentions related to the standardized portions of multiple
applications.
- The process for hearings for the uncontested portion of the COL
proceeding may change. The Commission plans to seek legislative
authority from the Congress to eliminate the statutory requirement to
conduct a hearing even if no one has requested it in order to conserve
resources. If a hearing must be held, however, the Commission has taken
steps to assume responsibility for conducting the uncontested portion
of hearings. Currently, the Atomic Safety and Licensing Board Panel is
responsible for conducting all of NRC's hearings, not just those
associated with new reactor applications. NRC assumes that it would
save considerable staff and Panel resources if the Commission takes the
responsibility for this portion of the hearings because it could
conduct a different style of hearing.
Beyond the changing processes and unresolved technical issues that
remain--such as evaluating applicants' use of digital instrumentation
and controls, NRC faces some general constraints because of the short
or overlapping time frames between the preparation of its regulatory
framework and process and the submission of applications starting in
October 2007. For instance, for the environmental component of NRC's
review, NRC would prefer to have about 22 months of preapplication
discussions with the applicants to allow staff to plan its work more
effectively and identify potential areas of concern. However, these
discussions are at the applicant's discretion; none of the fiscal year
2008 applications will begin with this lead time, and some may have had
as little as 2 months. Also, while NRC has scheduled considerable
resources to conduct design certification reviews concurrently with its
COL reviews, applicants have announced plans to use two new reactor
designs that have not been submitted to NRC for certification, a
reactor designer is amending its previously certified design, and
another designer may also revise its design. These additional changes
likely will tax NRC's resources and stafftime.
Conclusions:
NRC has made major strides in developing its new licensing process for
nuclear reactors to improve timeliness and provide more predictability
and consistency during reviews. Nevertheless, NRC will face a daunting
task in implementing this new process while at the same time facing a
surge in applications over the next 18 months.
We recognize that NRC cannot prepare for all contingencies in its
review of license applications under this new process, but we also find
that NRC could be better positioned to manage the process if it further
refined the criteria and processes it has already put into place.
First, while NRC has identified factors for staff to consider in
developing the fiscal year 2008 budget proposal for new reactor
activities, it has not made plans to use these factors in making
resource allocations and schedule decisions. As a result, NRC may find
it difficult to set priorities as it begins to review applications
early next year. Second, NRC has not implemented some reviewer and
management support tools that are intended to facilitate efficiency and
productivity, and may not devote sufficient resources to their
completion in the future. Third, NRO established the Resource
Management Board to recommend actions when the office is at risk of
missing major milestones. However, NRO has not specified the extent to
which the board is responsible for generally setting priorities or
allocating resources, which is likely to be much more challenging once
applications are submitted. NRC managers plan to clarify the board's
responsibilities. Finally, the design-centered approach is premised, in
part, on streamlining the review process through standardization.
However, NRC has not worked out a process for coordinating multiple,
similar requests for additional information, which could facilitate
greater efficiencies.
Recommendations for Executive Action:
To better ensure that its workforce is prepared to review new reactor
applications and its review processes more efficiently and effectively
facilitate reviews, we recommend that NRC take the following four
actions:
* Fully develop and implement criteria for setting priorities to
allocate resources across applications by January 2008.
* Provide the resources for implementing reviewer and management tools
needed to ensure that the most important tools will be available as
soon as is practicable, but no later than March 2008.
* Clarify the responsibilities of NRO's Resource Management Board in
facilitating the coordination and communication of resource allocation
decisions.
* Enhance the process for requesting additional information by (1)
providing more specific guidance to staff on the development and
resolution of requests for additional information within and across
design centers and (2) explaining forthcoming workflow and electronic
process revisions to COL applicants in a timely manner.
Agency Comments:
We provided NRC with a draft of this report for its review and comment.
In written comments, NRC agreed with our recommendations. (See app.
II.) In addition, NRC provided comments to improve the report's
technical accuracy, which we have incorporated as appropriate.
Scope and Methodology:
To examine the steps NRC has taken to prepare its workforce to review
new reactor license applications and manage its workload, we obtained
information about its workforce preparation by reviewing NRC documents,
conducting semi-structured interviews with several managers directly
responsible for the planning and implementation of new reactor
licensing activities, and observing internal NRC meetings. More
specifically, we reviewed strategy and commission papers, licensing
program planning documents and briefings, and a range of documents
regarding reorganization, staffing, training, hiring, contracting, and
project scheduling. We supplemented this information through interviews
with NRC managers in NRO; the offices of Nuclear Security and Incident
Response, Nuclear Regulatory Research, General Counsel, and Human
Resources; the Advisory Committee on Reactor Safeguards; and the Atomic
Safety and Licensing Board Panel. We also observed several NRO-specific
internal management meetings and employee training sessions, and NRO
staff demonstrated their Microsoft Project tool and associated
scheduling models and templates. We updated NRC workforce data
presented in our January 2007 report entitled Human Capital:
Retirements and Anticipated New Reactor Applications Will Challenge
NRC's Workforce. We also obtained budget data from NRC's Office of the
Chief Financial Officer and determined that these data were
sufficiently reliable for the purposes of this report.
To examine the steps NRC has taken to develop its regulatory framework
and key processes, we reviewed various NRC reports, meeting transcripts
and minutes, and strategy and commission papers and supplemented this
information with interviews with cognizant NRC managers. We conducted
semi-structured interviews with representatives from 2 nuclear power
consortia and 16 of the 17 electric power companies that have announced
plans to file a COL application, as well as 2 reactor design companies.
We also interviewed officials of the Nuclear Energy Institute; the
Union of Concerned Scientists; the Institute of Nuclear Power
Operations; Winston and Strawn, LLP; and the Georgia Public Service
Commission. In addition, we observed several of NRC's design-centered
working group and public meetings focused on new reactor licensing
activities, and attended conferences held on new reactor licensing.
As agreed with your offices, unless you publicly announce the contents
of this report, we plan no further distribution until 30 days from the
report date. At that time, we will send copies to appropriate
congressional committees, the Chairman of NRC, the Director of the
Office of Management and Budget, and other interested parties. We will
also make copies available to others upon request. In addition, the
report will be available at no charge on the GAO Web site at
[hyperlink, http://www.gao.gov].
If you or your staffs have any questions about this report, please
contact me at (202) 512-3841 or gaffiganm@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made major contributions
to this report are listed in appendix III.
Signed by:
Mark E. Gaffigan:
Acting Director, Natural Resources and Environment:
[End of section]
Appendix I: Major Components of NRC's New Reactor Licensing Framework:
Table 5:
Framework component: 10 CFR Part 52 rule making: Governs the issuance
of standard design certifications, early site permits, and combined
licenses (COL) for nuclear power plants. The final rule amends or makes
conforming changes to 10 CFR Parts 1, 2, 10, 19, 20, 21, 25, 26, 50,
51, 52, 54, 55, 72, 73, 75, 95, 140, 170, and 171;
Key NRC actions/ status:
* In April 1989, NRC promulgated 10 CFR Part 52 to reform its licensing
process for new nuclear power plants;
* In December 1998, NRC issued SECY-98-282, "Part 52 Rulemaking Plan,"
to update 10 CFR Part 52 based on its experience in using the standard
design certification process;
* In March 2006, NRC published a revised proposed rule to update Part
52 for public comment;
* In October 2006, NRC staff forwarded draft final rule to the
Commission for consideration;
* In April 2007, the Commission made the rule final, pending certain
revisions;
* On May 22, 2007, NRC posted the draft final rule on its Web site
while the Office of Management and Budget completed its review;
* On August 28, 2007, the final rule was published in the Federal
Register.
Framework component: Development of Regulatory Guide 1.206, "Combined
License Applications for Nuclear Power Plants" Describes and makes
available to the public (1) data that NRC staff need in reviewing
applications for permits and licenses, (2) methods that NRC staff
consider acceptable for use in implementing specific parts of the
agency's regulations, and (3) techniques that NRC staff use in
evaluating specific problems or postulated accidents;
Key NRC actions/ status:
* In September 2006, NRC staff posted Draft Guide 1145, the precursor
to Regulatory Guide 1.206, on its Web site for public comment;
* In April 2007, NRC posted completed sections of Regulatory Guide
1.206 for preliminary use;
* In June 2007, NRC issued final guide in total.
Framework component: Update of high-priority regulatory guides:
Provides guidance to applicants on implementing specific parts of the
regulations, techniques used by the NRC staff in evaluating specific
problems or postulated accidents, and data the staff will need to
review permit or license applications;
Key NRC actions/status:
* In July 2006, NRC staff identified about 30 high-priority regulatory
guides to update by March 2007;
* Public comment period for the high- priority regulatory guides ended
in December 2006;
* In March 2007, NRC staff completed publishing these guides for new
reactor licensing activities.
Framework component: Update of Safety Standard Review Plan (SRP),
"Standard Review Plan for the Review of Safety Analysis Reports for
Nuclear Power Plants," NUREG 0800: Provides guidance to NRC staff for
evaluating whether an applicant or licensee complies with 10 CFR Parts
50 and 52. SRP's principal purpose is to ensure the quality and
uniformity of staff safety reviews;
Key NRC actions/status:
* In August 2004, NRC staff began issuing updates to SRP sections. The
staff also made public its reprioritized schedule for updating SRP
sections starting in April 2005 to support new reactor licensing;
* In January 2006, NRC accelerated the issuance schedule to March 2007;
* In March 2007, NRC issued all SRP chapters, except chapter 19 on
probabilistic risk assessment;
* In June 2007, NRC issued the probabilistic risk assessment chapter.
Framework component: Update of Environmental Standard Review Plan
(ESRP), "Standard Review Plans for Environmental Reviews for Nuclear
Power Plants," NUREG 1555: Provides guidance to NRC staff for
conducting environmental reviews of nuclear power plant license
applications;
Key NRC actions/status:
* NRC last updated ESRP in 1999;
* In 2006, NRC staff prioritized ESRP sections and began to update
them;
* Draft Revision 1 revises one or more sections of nearly all chapters;
* In August 2007, NRC convened a public meeting to obtain comments on
draft revisions and is accepting comments through mid-September 2007.
Framework component: Limited Work Authorization rule making: Revises
(1) the scope of activities for which a construction permit, COL, or
limited work authorization is necessary; (2) the scope of construction
activities that may be performed under a limited work authorization;
and (3) the review and approval process for limited work authorization
requests;
Key NRC actions/status:
* In March 2006, NRC published a proposed rule that would substantially
amend Part 52, but not Part 50;
* In response to public comments, NRC prepared a supplemental proposed
rule intended to reduce the time between an applicant's decision to
proceed with a COL application and the start of commercial operation;
* In October 2006, NRC published the supplemental proposed rule;
* In February 2007, NRC staff submitted a draft final rule to the
Commission for review;
* In April 2007, the Commission approved the rule and issued additional
requirements for NRC staff to complete;
* The rule was submitted to the Office of Management and Budget for
clearance review on August 30, 2007.
Framework component: Construction Inspection Program (CIP): Has several
components and is designed for NRC to develop a level of confidence in
the licensee's programmatic controls. CIP will involve a combination of
differently directed inspections, all of which are aimed at validating
the acceptability of the construction programs, processes, and
products. The components include four inspection manual chapters (IMC),
periodic assessment, and vendor oversight activities;
Key NRC actions/ status:
* In 2001, NRC renewed prior efforts to update the CIP by incorporating
lessons learned into the revised framework. The team includes regional
and headquarters licensing and inspection staff;
* In April 2003, NRC issued IMC-2501, "Early Site Permit.";
* In June 2005, NRC issued IMC-2502, "Pre-Combined License (Pre-COL)
Phase," on quality assurance, engineering, and environmental
protection;
* In April 2006, NRC issued IMC-2503, "Inspections, Tests, Analyses,
and Acceptance Criteria (ITAAC)," for inspecting construction
activities and supporting completion of the ITAAC;
* In April 2006, NRC issued IMC-2504, "Non-ITAAC Inspections," for
inspecting programmatic areas;
* In June 2007, NRC published information about how it plans to enhance
its Vendor Inspection Program, including developing program guidance
and increasing audit and inspection activities.
Framework component: Inspections, Tests, Analyses, and Acceptance
Criteria: Specifies that a COL application must identify the
inspections, tests, and analyses (including those that apply to
emergency planning) that the licensee will perform to provide NRC with
data to determine whether the applicant has met NRC's acceptance
criteria and the reactor has been constructed and will operate in
conformance with the COL, NRC regulations, and the Atomic Energy Act;
Key NRC actions/status:
* In 2001, to update the inspection program, NRC formed the
Construction Inspection Team, which includes staff from each region,
new reactor licensing, and inspection program management;
* In October 2005, NRC staff issued "Review of Operational Programs in
a Combined License Application and Generic Emergency Planning
Inspections, Tests, Analyses, and Acceptance Criteria." The Commission
then provided policy direction on license conditions for operational
programs in a COL application and the use of emergency planning/
emergency preparedness ITAAC;
* In April 2006, NRC issued IMC-2503, "Inspections, Tests, Analyses,
and Acceptance Criteria," and IMC-2504, "Non-ITAAC Inspections," which
describe the programs for inspecting construction activities;
* In January 2007, NRC solicited stakeholder input from public
meetings;
* In March 2007, NRC staff presented to the Commission its plan for
selecting ITAAC for inspection and closing these ITAAC;
* In May 2007, the Commission approved the staff's approach for
verifying the closure of licensees' ITAAC through a sample-based
inspection program;
* In July 2007, the Advisory Committee on Reactor Safeguards concurred
with the approach and proposed threshold values;
* NRC continues to develop inspection procedures; work processes and
procedures to support the closure of ITAAC and the implementation of
the enforcement process; and a methodology for assessing licensee
performance. NRC plans to prioritize activities to ensure that products
will be ready to support inspector training and inspections.
Framework component: 10 CFR Part 73 rule making on physical protection:
Governs requirements for physical protection of nuclear power plants.
The rule is intended to codify orders issued in response to September
11, 2001, and fulfill certain provisions in the Energy Policy Act of
2005 by (1) enhancing requirements for access controls, event
reporting, security personnel training, safety and security activity
coordination, contingency planning and radiological sabotage protection
and (2) adding requirements related to background checks for firearms
users and authorization for enhanced weapons;
Key NRC actions/status:
* In October 2006, NRC published a proposed rule to codify several
physical protection orders into sections 73.55 and 73.56. The public
comment period closed in March 2007;
* Since July 2007, NRC has held public meetings on draft guidance
related to this rule making, and has provided specific sections of the
draft guidance to further inform stakeholders and the public;
* NRC expects to post the draft final rule for 10 CFR Part 73 on its
Web site in 2008.
Framework component: Aircraft Impact Assessment rule making: Requires
reactor unit designers to perform a rigorous assessment of design
features that could provide additional inherent protection to avoid or
mitigate the effects of an aircraft impact while reducing or
eliminating the need for operator actions, where practicable;
Key NRC actions/status:
* In April 2007, the Commission directed NRC staff to include aircraft
impact assessment requirements in 10 CFR Part 52;
* Since April 2007, NRC has discussed plans for assessing aircraft
impact characteristics not included in design basis with reactor and
plant designers who have submitted applications;
* NRC plans to publish a proposed rule for public comment in September
2007 or later.
Framework component: 10 CFR Part 26 rule making on fitness for duty:
Governs drug and alcohol testing programs and establishes requirements
for managing worker fatigue at operating nuclear power plants;
Key NRC actions/status:
* In April 2005, NRC staff presented its proposal to amend the fitness
for duty rule;
* In August 2005, NRC published the proposed rule in the Federal
Register. The public comment period ended in December 2005;
* In March 2006, NRC held a public meeting on the public comments to
the proposed rule;
* In October 2006, NRC posted the draft final rule on its Web site;
* In April 2007, the Commission approved the final rule and directed
staff to continue to engage stakeholders in complete associated
regulatory guidance;
* In July 2007, NRC modified the approved rule. NRC expects to issue a
final rule in early 2008.
Source: NRC.
[End of table]
[End of section]
Appendix II: Comments from the Nuclear Regulatory Commission:
United States:
Nuclear Regulatory Commission:
Washington, D.C. 20555-0001:
September 14, 2007:
Mr. Mark Gaffigan:
Acting Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Gaffigan:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am
responding to your e-mail dated August 29, 2007, requesting NRC review
and comment on your proposed report entitled, "Nuclear Energy: NRC's
Workforce and Processes for New Reactor Licensing Are Generally in
Place, but Uncertainties Remain as Industry Begins to Submit
Applications" (GAO-07-1129). I appreciate the time and effort that you
and your staff have invested in reviewing this important topic and the
care that you have taken to ensure that your report is constructive and
accurate.
Overall, the NRC considers the draft report to be comprehensive, fair,
and balanced. The report accurately identifies the accomplishments as
well as the challenges that the agency faces in preparing its workforce
for new reactor licensing reviews. Specifically, the report discusses
the NRC's ability to manage its workload associated with the
anticipated 20 new reactor applications in the next 18 months.
Ultimately, the NRC believes the report's findings, conclusions, and
recommendations to be very helpful.
The agency continues to aggressively take steps to address these
challenges. The Office of New Reactors (NRO) continues to be proactive
in hiring staff with the appropriate skill sets and providing key
training to staff members. In addition, NRO continues to develop tools
that will enhance consistency and coordination, as well as, increase
efficiency in reviewing combined license (COL) applications.
The enclosure provides some minor comments for your consideration. We
plan to implement your recommendations. Should you have questions about
these comments, please contact Ms. Melinda Malloy at (301) 415-1785.
Sincerely,
Signed by:
Luis A. Reyes:
Executive Director for Operations:
Enclosure:
NRC's Comments on Draft GAO-07-1129:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Mark E. Gaffigan, (202) 512-3841 or gaffiganm@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Richard Cheston, Assistant
Director; Amanda Leissoo; Sarah J. Lynch; Amanda Miller; Omari Norman;
Carol Herrnstadt Shulman; Julie E. Silvers; and Elizabeth Wood made key
contributions to this report.
[End of section]
Footnotes:
[1] 54 Fed. Reg. 15386 (Apr. 18, 1989). While NRC has revised its
regulatory process, the technical bases for its decisions to make
findings have generally remained the same.
[2] Such activities as site clearing, excavation, road building,
transmission line routing, and erecting construction-related support
buildings or service facilities do not require NRC authorization.
[3] This report focuses on NRC's readiness to license new light water
reactor designs. It does not address NRC's readiness to license new
advanced reactor designs, such as liquid metal-cooled reactors and high-
temperature gas-cooled reactors because they are significantly
different from light water reactors.
[4] NRC also certified the Combustion Engineering/Westinghouse System
80+ in 1997 and Westinghouse's Advanced Passive 600 in 1999.
[5] The evidentiary hearing portion of the adjudicative process occurs
near the end of the licensing process. However, prehearing activities,
which include decisions on standing, contention admissibility, and
procedural motions, begin when NRC dockets the application and continue
during the staff's review.
[6] GAO, Human Capital: Retirements and Anticipated New Reactor
Applications Will Challenge NRC's Workforce, GAO-07-105 (Washington,
D.C.: Jan. 17, 2007).
[7] NRC estimates that its review of a reference COL would cost
applicants about $26 million, assuming $258 per hour for reviewer time.
The Nuclear Energy Institute estimates that COL applicants would spend
about $100 million for preparing the application, paying NRC licensing
fees, responding to NRC during the review process, and overhead. A
reactor designer estimates that preparing a design certification
application costs $200 million.
[8] NRC management balanced grade levels, positions, and preferences in
assigning staff to the Office of Nuclear Reactor Regulation or to NRO.
The Office of Nuclear Reactor Regulation had about 530 employees as of
August 2007. Half of the staff for both offices have been at NRC for 5
years or less.
[9] In August 2007, NRO reorganized its Division of New Reactor
Licensing, which is responsible for the overall management of license
application review activities. NRO's largest division, it includes more
support for organizational effectiveness and productivity, contract
management, and project management.
[10] During 2007, NRC resolved two identified conflicts of interest
with using DOE laboratories to support NRO. NRC managers said they
faced these conflicts mainly because relatively few companies and
individuals with specialized skills do not have links to a potential
applicant or reactor designer. NRC management is considering whether to
use two other DOE laboratories with identified conflicts of interest.
[11] Commissioners indicated and NRC staff confirmed that these factors
apply when allocating resources during budget execution only and should
not be applied in preparing budget requests. These factors include 11
for COL applications, 2 for design certifications, and 3 for early site
permits.
[12] According to NRC officials, a contractor's FTE of work costs about
double that of an NRC permanent staff's FTE of work. Cumulatively,
proposed agreement and contract ceilings from fiscal year 2007 through
fiscal year 2012 total more than $300 million, including nearly $25
million in support from the U.S. Army Corps of Engineers and the U.S.
Geological Survey.
[13] As of early September 2007, NRC had committed about $7 million in
fiscal year 2007 funds for five DOE laboratories to perform
preparedness, preapplication, and licensing work and about $2 million
for commercial contractors to perform preparedness activities.
[14] In July 2007, NRO renamed the Change Management Board to the
Resource Management Board.
[15] Participants at the public meetings of the design-centered working
group we observed primarily represented NRC, COL applicants, reactor
designers, or the Nuclear Energy Institute. Similarly, public comments
on the proposed rule for Part 52 were mainly provided by industry
stakeholders. The Department of Homeland Security and the Environmental
Protection Agency also commented.
[16] NuStart and UniStar--two nuclear energy consortia composed of
electric power companies and reactor design companies--have supported
the design-centered working group's standardization efforts.
[17] While most COL applicants said that 65 percent to 80 percent of
their application's content will be standardized, this percentage does
not equate to the amount of time or resources NRC will need to review
the application. According to the applicants, the 20 percent of content
that is not standardized represents site-specific safety and
environmental analyses that require far more than 20 percent of both
COL applicants' and NRC's time and resources to complete.
[18] NRC officials told us that the acceptance review assessment also
will inform how it develops the review schedule for each application.
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