Nuclear Energy: NRC's Workforce and Processes for New Reactor
Licensing Are Generally in Place, but Uncertainties Remain as
Industry Begins to Submit Applications (21-SEP-07, GAO-07-1129).
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.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-1129
ACCNO: A76813
TITLE: Nuclear Energy: NRC's Workforce and Processes for New
Reactor Licensing Are Generally in Place, but Uncertainties
Remain as Industry Begins to Submit Applications
DATE: 09/21/2007
SUBJECT: Construction industry
Employees
Evaluation criteria
Independent regulatory commissions
Licenses
Nuclear energy
Nuclear powerplant construction
Nuclear reactors
Program evaluation
Program management
Standards evaluation
Strategic planning
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GAO-07-1129
* [1]Results in Brief
* [2]Background
* [3]NRC Has Implemented Many Actions to Prepare Its Workforce fo
* [4]NRC Has Taken Steps to Increase Staffing, Training, and Revi
* [5]NRC Is Implementing a Project Management Approach for Its Ne
* [6]NRC Has Significantly Revised Its Overall Regulatory Framewo
* [7]NRC Has Revised Most Key Regulations and Guidance with Consi
* [8]While NRC Has Taken Steps to Advance the Design-centered Rev
* [9]Conclusions
* [10]Recommendations for Executive Action
* [11]Agency Comments
* [12]Scope and Methodology
* [13]GAO Contact
* [14]Staff Acknowledgments
* [15]GAO's Mission
* [16]Obtaining Copies of GAO Reports and Testimony
* [17]Order by Mail or Phone
* [18]To Report Fraud, Waste, and Abuse in Federal Programs
* [19]Congressional Relations
* [20]Public Affairs
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
GAO-07-1129
Contents
Letter 1
Results in Brief 6
Background 8
NRC Has Implemented Many Actions to Prepare Its Workforce for New Reactor
Licensing Reviews, but Several Key Elements Are Still Under Way 9
NRC Has Significantly Revised Its Overall Regulatory Framework and Review
Process, but Several Activities Are Still in Progress 18
Conclusions 27
Recommendations for Executive Action 28
Agency Comments 28
Scope and Methodology 28
Appendix I Major Components of NRC's New Reactor Licensing Framework 31
Appendix II Comments from the Nuclear Regulatory Commission 35
Appendix III GAO Contact and Staff Acknowledgments 36
Tables
Table 1: NRC Offices' Responsibilities for New Reactors 11
Table 2: Computer-Based Tools to Assist NRO Reviewers 13
Table 3: Key Project Management Components for New Reactor Licensing 14
Table 4: Major Components of NRC's New Reactor Licensing Regulatory
Framework 18
Figures
Figure 1: The New Reactor Licensing Process under Part 52 2
Figure 2: Reactor Designs Associated with the 20 Expected COL Applications
and the Estimated Schedule for Application Submission 4
Figure 3: Major Aspects of the COL Review Process 22
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
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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.^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).^2
^154 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.
^2Such activities as site clearing, excavation, road building,
transmission line routing, and erecting construction-related support
buildings or service facilities do not require NRC authorization.
Figure 1: The New Reactor Licensing Process under Part 52
^aNRC'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.
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).^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.^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.
^3This 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.
^4NRC also certified the Combustion Engineering/Westinghouse System 80+ in
1997 and Westinghouse's Advanced Passive 600 in 1999.
Figure 2: Reactor Designs Associated with the 20 Expected COL Applications
and the Estimated Schedule for Application Submission
^aWestinghouse 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.
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.^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.^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.
^5The 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.
^6GAO, Human Capital: Retirements and Anticipated New Reactor Applications
Will Challenge NRC's Workforce, [21]GAO-07-105 (Washington, D.C.: Jan. 17,
2007).
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:
o 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.
o 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.
o 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.
o 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,^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.^8 NRO is expected
to grow from 350 employees in August 2007 to about 500 staff during fiscal
year 2008.^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.
^7NRC 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.
^8NRC 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.
^9In 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.
Table 1: NRC Offices' Responsibilities for New Reactors
Source: NRC.
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
Source: NRC.
^aSharePoint 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.
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
Source: NRC.
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.^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:
o 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.^11 In commenting on recommendations
in our draft report, NRO officials said that NRC will develop
these criteria by the end of 2007.
o 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.
o 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.^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.^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.
o 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.
o Clarifying the Resource Management Board's role.^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.
^10During 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.
^11Commissioners 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.
^12According 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.
^13As 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.
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.
^14In July 2007, NRO renamed the Change Management Board to the Resource
Management Board.
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
Source: NRC.
^a72 Fed. Reg. 49351 (Aug. 28, 2007).
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.^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
o 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;^16 and
o 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.
^15Participants 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.
^16NuStart 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.
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
^aOnly 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.
^bNRC currently is considering internally recommended changes to its
hearing process.
^cSome draft Environmental Impact Statement activities also occur in phase
1.
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.^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:
o 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.^18
o 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.
^17While 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.
^18NRC officials told us that the acceptance review assessment also will
inform how it develops the review schedule for each application.
o 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.
o Completing revisions to the hearing process. NRC is revising its
policy for conducting hearings on both the contested and
uncontested portions of applications.
o 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.
o 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:
o Fully develop and implement criteria for setting
priorities to allocate resources across applications
by January 2008.
o 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.
o Clarify the responsibilities of NRO's Resource
Management Board in facilitating the coordination and
communication of resource allocation decisions.
o 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 [22]http://www.gao.gov .
If you or your staffs have any questions about this report, please
contact me at (202) 512-3841 or [email protected]. 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.
Mark E. Gaffigan
Acting Director, Natural Resources and Environment
Appendix I: Major Components of NRC's New Reactor Licensing Framework
Source: NRC.
Appendix II: Comments from the Nuclear Regulatory Commission
Appendix III: GAO Contact and Staff Acknowledgments
GAO Contact
Mark E. Gaffigan, (202) 512-3841 or [23][email protected]
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.
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Highlights of [31]GAO-07-1129 , a report to congressional committees
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
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.
[32]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.
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.
Anticipated COL Applications by Fiscal Year
Source: NRC.
Note: Information as of September 10, 2007.
References
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31. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1129
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