January 24, 2017 COMSECY-17-0004

 

MEMORANDUM TO: Chairman Burns 

Commissioner Svinicki 

Commissioner Baran 

FROM: Victor M. McCree /RA/ 

 Executive Director for Operations 

SUBJECT: PROPOSED CLOSURE OF PROJECT AIM INTEGRATED 

IMPLEMENTATION PLAN TASK NO. 19 - LICENSING BUSINESS 

PROCESS IMPROVEMENT 

This memorandum documents operating reactor licensing process improvement activities and 

requests Commission approval to close Task No. 19 in the Project Aim Integrated 

Implementation Plan dated August 21, 2015.1 Task No. 19 implemented Recommendation III-2 

in SECY-15-0015,2 “Project Aim 2020 Report and Recommendations,” dated January 30, 2015, 

which was to “[i]mprove licensing by conducting a business process improvement [BPI] review 

of the operating reactor licensing process and make associated improvements to enhance the 

predictability, timeliness, and efficiency of the reviews, while ensuring and measuring the 

effectiveness and quality of the reviews.” This recommendation was approved by the 

Commission in a staff requirements memorandum (SRM) dated June 8, 2015.3 The 

Commission also approved the staff proposal to delegate decision-making about this activity (its 

timing, its scope, and the application of its results) to the Director of the Office of Nuclear 

Reactor Regulation (NRR) and indicated that the review should incorporate available lessons 

learned about how the backlog of licensing actions that existed at the time originated and how it 

was resolved. 

In proposing to close this task, the staff concludes that desired outcomes of the BPI review—

improving predictability, timeliness, and efficiency of licensing reviews—have been achieved 

without the need to expend the additional time and cost of a formal BPI. In reaching this 

conclusion, the staff considered its successful implementation of process improvements that 

restored licensing review performance within standards established in the Congressional 

Budget Justification (CBJ), as well as recently implemented, ongoing, and planned 

improvements to licensing processes, including enhanced performance monitoring and 

management oversight of these processes. 

CONTACT: Jennivine K. Rankin, NRR/DORL 

 (301) 415-1530 

 

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML15216A603. 

2 ADAMS Accession No. ML15023A558. 

3 ADAMS Accession No. ML15159A234. 

PLEASE RESPOND BY:

February 9, 2017

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 
The Commissioners - 2 - 

SECY-15-0015, Enclosure 1 (the Project AIM report) describes a significant number of licensing 

actions that remained under NRC staff review for greater than 1 year. The agency completed 

only 87 percent of its licensing action reviews within 1 year for fiscal year (FY) 2014, which did 

not meet CBJ metric that at least 95 percent of licensing actions be completed within 1 year. 

This metric and the other metrics discussed in this document are described in further detail in 

Enclosure 1. 

The reduction in licensing action performance was in large part caused by the redirection of staff 

resources to support Fukushima-related licensing actions in FY 2013. While the staff had 

anticipated that the submittal of a smaller number of routine licensing actions would support this 

redirection of staff resources, the total licensing actions submitted per year actually increased by 

nearly 50 percent from 2011 to 2013. When the inventory of licensing actions older than 1 year 

peaked at 112 licensing actions in November 2014, the agency recognized the need to exert 

additional efforts to complete these licensing actions and achieve consistency in program 

implementation. These efforts included reassignment of staff, greater use of contractor support, 

and reinforcement of management expectations. To communicate these efforts, in January 

2015 NRR management issued an “Expectations Memo”4 to its staff. The memo reinforced the 

guidance in existing office instructions and placed specific emphasis on several key items, 

including: 

• ensuring that workload management system dates reflect realistic schedules to support 

workload forecasting; 

• developing draft safety evaluations “with holes” correlating to requests for additional 

information (RAIs) prior to issuing the RAIs; 

• ensuring greater division management focus on RAIs, particularly second-round RAIs; 

and 

• initiating early division management engagement on differing views or potential denials. 

In addition, NRR created several office initiatives specifically targeting areas where staff could 

make improvements to enhance the licensing process. NRR formed working groups to review 

initiatives in regulatory decision-making, acceptance review procedures, license amendment 

review procedures, and technical and regulatory adequacy of licensing reviews. Enclosure 3 

provides a brief description and status of each of these initiatives as well as subsequently 

identified related initiatives. 

NRR also placed significant focus on management oversight of ongoing licensing casework as 

well as performance restoration activities. In November 2014 NRR began holding leadership 

team workload management meetings twice a month and executive team workload 

management meetings once a month. The meetings focused on the progress of performance 

restoration activities, identification and resolution of licensing obstacles, and lessons learned 

from recent complex or challenging reviews. In FY 2015 NRR also implemented an internal 

goal of improving performance on the CBJ metric by at least 2 percent per year (e.g., increasing 

from 87 percent to 89 percent) until the metric was met. 

By the end of FY 2015, NRR had reduced the inventory of licensing actions older than 1 year 

significantly, to 32 licensing actions. Although this reduction resulted in only a small 

 

4 ADAMS Accession No. ML15309A433. 
The Commissioners - 3 - 

improvement in NRR’s performance in the CBJ metric (from 87 to 88 percent for FY 2015), this 

reduction demonstrated the value of activities that led to significantly improved performance in 

FY 2016. 

In FY 2016, NRR continued steps to improve existing processes to enhance the predictability, 

timeliness, and efficiency of licensing reviews. NRR performed a lessons-learned study on the 

difficult and unusually complex LaSalle license amendment involving the ultimate heat sink that 

far exceeded expected levels of effort and timeliness. During the same time period, the working 

groups for the aforementioned NRR initiatives completed and finalized their reports. The office 

used specific insights from these reports and the LaSalle lessons-learned study to issue a 

revised Expectations Memo5 in April 2016. The revised Expectations Memo further reinforced 

adherence to office procedures and provided additional guidance to improve efficiency of the 

licensing process regarding: 

• enhancing communications to ensure timely identification of issues that could warrant 

non-acceptance; 

• leveraging the license amendment denial process to hold licensees accountable in 

providing timely and complete responses to RAIs; 

• processing grouped or particularly complex submittals; and 

• evaluating the appropriateness of RAIs, including consideration of other tools (audits or 

public meetings) in lieu of second-round RAIs when those tools could support more 

efficient and timely resolution of outstanding technical issues. 

Additionally, NRR sent a letter6 to all operating power reactor licensees on August 22, 2016, to 

ensure they were aware of the revised expectations. By the end of FY 2016, NRR had reduced 

the number of licensing actions older than 1 year to 10 licensing actions. In doing so, the 

agency far exceeded its goal of a 2-percent improvement over the last year for the CBJ 

licensing action timeliness metric (improving 7 percent over what was achieved in FY 2015) and 

returned to standard on the CBJ metric ahead of the expected schedule. If the office can 

maintain this level of performance, the agency will meet the CBJ metric in FY 2017. 

Enclosure 2 provides additional information on the improvement in licensing action timeliness. 

Additionally, analysis by the staff indicates that the agency has gained efficiencies from the 

completed and ongoing process improvements. For example, from FY 2015 to FY 2016, NRR 

has reduced the average time it takes to complete a routine licensing action (actions requiring 

300 hours or less) by approximately 2 months. Routine licensing actions account for 

approximately 85 percent of the total licensing action inventory. Further, while the restoration of 

licensing performance can be partially attributed to the temporary reallocation of staff, NRR has 

continued to show performance increases following an overall reduction in staff and return of 

staff to other important work activities. 

 

5 ADAMS Accession No. ML16202A029. 

6 ADAMS Accession No. ML16225A003. 
The Commissioners - 4 - 

To support sustained high licensing performance, NRR established additional internal metrics 

for FY 2017: 

• Completion Effort: Percentage of actions completed within 125 percent of hours 

forecasted ≥ 90 percent 

• Completion Schedule: Percentage of actions completed within the schedule 

forecasted/requested + 1 month ≥ 90 percent 

• Acceptance Reviews: Percentage of acceptance reviews completed on time ≥ 95 

percent 

These metrics, as well as actions taken for their implementation, are described in detail in 

Enclosure 1. 

In addition, in October 2016 NRR deployed a newly developed workload management tool 

called Reactor Program System Licensing/Workload Management (RPS Licensing/WM). This 

enhanced platform offers more flexibility to the users, creates additional avenues for 

communication between the project management and technical staffs, and enhances the 

processing and managing of licensing activities. NRR developed RPS Licensing/WM to 

specifically incorporate tools for implementing some of the new guidance from the revised 

Expectations Memo and recent lessons learned from previous complex licensing actions. With 

this increased functionality, the system will be able to provide data to support additional 

indicators beyond those established for FY 2017, thus providing the NRR management team 

with a more informed picture of overall licensing performance. 

In parallel with the previously described actions, NRR also considered methods to better predict 

workload and any consequential resource challenges. NRR issued Regulatory Issue Summary 

(RIS) 2015-16,7 “Planned Licensing Action Submittals for All Power Reactor Licensees,” dated 

November 25, 2015. The NRC issued RIS 2015-16, Revision 1 on January 15, 2016,8 providing 

additional guidance and information for licensee’s responses. Collectively, RIS 2015-16 

requested all power reactor licensees to submit information on planned licensing actions for the 

following two calendar years as well as information on any planned power uprates. NRR has 

compiled the industry’s responses into a managed data repository. To preserve data repository 

accuracy, the project managers systematically update the repository through information 

received from their routine communications with licensees. This managed data repository is 

then used to forecast licensing workload, identify future resource needs, and seek ways to 

mitigate any impacts to licensing schedules, including revised work prioritization and resource 

reallocation. While this data is useful for workload planning, the industry has stated that they 

can only forecast with reliability 1 year in advance (2 years for major licensing actions). Thus, 

the data has limitations for detailed, long-term budgeting and planning. 

 

7 ADAMS Accession No. ML15266A509. 

8 ADAMS Accession No. ML16013A156. 
The Commissioners - 5 - 

NRR continues to proactively seek additional improvement opportunities to enhance current 

performance, ensure quality, and monitor the effectiveness of implemented changes. For 

FY 2017, these activities include: 

• creating additional office-level, sub-element monitoring measures (such as number of 

licensing actions with second-round RAIs) to further identify where attention should be 

focused to address impediments to the licensing review process; 

• continuing efforts on the regulatory decision-making initiative and technical and 

regulatory adequacy initiative (see Enclosure 3); and 

• conducting periodic audits of RAIs issued since issuance of the 2016 Expectations 

Memo to validate whether staff is meeting expectations (see Enclosure 3). 

 

In summary, NRR has performed thorough evaluations of its licensing process and has 

implemented substantial process improvements including enhanced performance monitoring 

and management oversight of these processes. In performing these assessments, the staff 

utilized BPI-like approaches, such as forming working groups targeting areas where staff could 

make improvements, and identified the types of improvements that likely would have resulted 

from a formal BPI review, such as revising pertinent guidance documents, enhancing tracking 

systems, and enhancing performance monitoring. These improvements have proven to be 

effective in restoring licensing performance and enhancing the predictability, timeliness, and 

efficiency of the licensing reviews. Additionally, with the enhanced capabilities of RPS 

Licensing/WM, additional performance monitoring and trending analysis, and the standing 

workload management meetings with the NRR leadership and executive teams, NRR is wellpoised to reassess, on an ongoing basis, the need for a more extensive look into the licensing 

process based on actual performance. Furthermore, these process improvements and 

enhancements will allow NRR to manage its inventory of licensing actions and predict licensing 

process performance, even if resources were redirected away from licensing casework as 

occurred following the Fukushima event. The staff will continue self-assessments and process 

improvements through NRR’s ongoing workload management process. 

As such, the staff concludes that that the desired outcomes of improving predictability, 

timeliness, and efficiency of licensing reviews as described in Task No. 19 in the Project Aim 

Integrated Implementation Plan, have been achieved and requests Commission approval to 

close this task. 

SECY, please track. 

Enclosures: 

1. Licensing Performance Metrics 

2. Licensing Timeliness Charts 

3. Summary of NRR Initiatives 

cc: SECY 

 OGC 

 OCA 

 OPA 

 CFO
The Commissioners - 6 - 

SUBJECT: PROPOSED CLOSURE OF PROJECT AIM INTEGRATED IMPLEMENTATION 

PLAN TASK NO. 19 - LICENSING BUSINESS PROCESS IMPROVEMENT 

DATED: JANUARY 24, 2017 

DISTRIBUTION: SRM-S15-0015-19 

RidsNrrDorl RidsNrrMailCenter RidsEdoMailCenter 

RidsNrrOd RidsOgcMailCenter JRankin 

JBurkhardt TClark, OEDO TBloomer, OEDO 

ADAMS Accession No.: ML16340A115 *via email 

OFFICE NRR/DORL/LPL3-1/PM NRR/DORL/LPL4-1/LA QTE* NRR/DORL/D* 

NAME JRankin JBurkhardt CHsu ABoland (EBenner for)

DATE 12/5/16 12/5/16 12/9/16 1/4/17 

OFFICE OGC* NRR/D CFO EDO 

NAME AGhosh WDean MWylie VMcCree 

DATE 1/4/17 1/9/17 1/13/17 1/24/17 

OFFICIAL RECORD COPY 
Enclosure 1 

Licensing Performance Metrics 

Existing Timeliness Metric from the Congressional Budget Justification (CBJ): 

• Percentage of Licensing Actions Completed in 1 Year or Less ≥ 95 percent 

In fiscal year (FY) 2014, performance on this metric fell to 87 percent, which focused 

attention in the Office of Nuclear Reactor Regulation (NRR) on licensing process 

performance. For FY 2015, NRR implemented an internal goal of improving 

performance on the CBJ metric by at least 2 percent per year until the metric was met. 

NRR was able to restore performance on this metric by the end of FY 2016 and 

anticipates meeting the metric for FY 2017. Additionally, the metric for FY 2017 starts 

when an application is determined to be acceptable. 

Additional Internal Metrics Implemented for FY 2017: 

• Completion Effort: Percentage of actions completed within 125 percent of hours 

forecasted ≥ 90 percent 

The purpose of this metric is to ensure that licensing actions are completed in 

accordance with resource estimates that are developed at the beginning of the staff’s 

review of the licensing action. To improve the validity of this metric, NRR provided 

additional guidance to the staff on estimating the hours it takes to complete a licensing 

action. These project estimates are used in two ways. First, the staff communicates 

with the licensee to increase transparency in the level of staff resources needed to 

complete a given review. Second, the staff actively monitors the actual hours expended 

as compared to the projected hours. NRR uses this information to measure the 

progress of the review and identify difficulties in the licensing review. Internal processes 

enable estimates to be updated, where appropriate, if significant safety issues 

necessitate additional staff effort. 

• Completion Schedule: Percentage of actions completed within the schedule 

forecasted/requested + 1 month ≥ 90 percent 

The CBJ metric reflects an overall timeliness goal for completion of licensing actions, but 

does not account for the many licensing actions that are requested on an expedited 

schedule by applicants. These licensing actions are typically of higher priority to the 

applicant because they typically are indicative of situations that may impede a plant 

startup or necessitate a plant shutdown if not resolved. The staff developed this metric 

to better assess its performance on these higher priority licensing actions and 

demonstrate predictability to licensees requesting expedited schedules. 

• Acceptance Reviews: Percentage of acceptance reviews completed on time 

≥ 95 percent 

Acceptance reviews are performed to ensure that an application is of acceptable quality 

before the staff begins its detailed technical review. The staff determined that the review 

duration considered for the CBJ metric should start at the time an application is 

determined to be acceptable for detailed review, and this is reflected in the 2017 CBJ 

metric. In 2016 the staff identified that acceptance reviews were taking longer than 
- 2 - 

expected. If this continued, given the revised 2017 CBJ metric, it could be perceived as 

the staff was allowing itself more time to review licensing actions. To address this 

possible perception, NRR identified the need to more closely monitor performance in this 

area and developed this performance metric. As of October 2016, the staff has 

substantially improved performance in this area with all current acceptance reviews on 

track to be completed within the timeliness goals contained within the applicable 

procedure (NRR Office Instruction LIC-109, “Acceptance Review Procedures”).1 

Additionally, NRR created additional office-level, sub-element monitoring measures (such as 

number of licensing actions with second-round requests for additional information), to further 

identify where attention should be focused to address impediments to an efficient and effective 

licensing review process. 

 

1 Agencywide Documents Access and Management System Accession No. ML091810088. 
Enclosure 2 

Licensing Action Timeliness Charts 

This chart above shows the evolution of the licensing action inventory over time. The accident 

at Fukushima Dai-Ichi occurred in March 2011. Number of licensing actions older than 1 year 

began to increase in September 2012 as staff resources were diverted to Fukushima-related 

activities and peaked in November 2014. At that point, the Office of Nuclear Reactor Regulation 

initiated many office strategies that reduced the number of licensing actions older than 1 year to 

below pre-Fukushima levels. 

This chart shows the 10-year history for licensing action timeliness.

27 28 28 30

42 54

96 93

75

112

93

69 70

32

26 22

14 10

0

20

40

60

80

100

120 Licensing Actions >12 Months

97.6% 96.9%

94.6% 94%

93%

90.3%

95.8% 95%

87%

88%

95%

80%

82%

84%

86%

88%

90%

92%

94%

96%

98%

100%

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

1-Year Licensing Action Timeliness
Enclosure 3 

Summary of the Office of Nuclear Reactor Regulation Initiatives 

As a result of the large number of licensing actions older than 1 year as of fiscal year (FY) 2014, 

the Office of Nuclear Reactor Regulation (NRR) created office initiatives targeting areas where 

the agency could make improvements to enhance the licensing process. Specifically, NRR 

formed working groups targeting acceptance review procedures, license amendment review 

procedures, regulatory decision-making, technical and regulatory adequacy of licensing reviews, 

and quality reviews on requests for additional information (RAIs). A summary and status of 

each initiative are provided below. 

I. Conduct Effective Acceptance Reviews 

Background: NRR performs acceptance reviews of incoming licensing actions in 

accordance with Office Instruction LIC-109, “Acceptance Review Procedures.” The 

purpose of this instruction is to determine whether the applicant has provided the 

necessary information (including sufficient scope and depth) to allow the U.S. Nuclear 

Regulatory Commission (NRC) staff to perform an efficient safety review. When the 

application lacks critical information necessary for the staff to complete its review, the 

staff spends an excessive amount of time requesting the information and waiting for the 

applicant to respond. By identifying the insufficient information early in the process, the 

NRC and the licensee both benefit by not expending resources on an insufficient 

application, and the licensee benefits as the NRC has provided an early decision that 

enables resubmission following necessary correction. 

Objective of Initiative: Evaluate if LIC-109 is performing its intended function of adding 

efficiencies to the review process, and modify or eliminate accordingly. 

Result: The working group determined that LIC-109 has value when consistently applied. 

The instruction was written to provide guidelines to the staff for evaluating the 

completeness or the minimum, sufficient information in the application. When the staff 

applies the acceptance review process correctly (i.e., only accepting complete 

applications), the number of RAIs should be reduced. In turn, the resources necessary 

for the actual review and the timeframe for that review are reduced. 

Status of Initiative: NRR is revising LIC-109 to ensure that both NRC staff and applicants 

understand what constitutes the minimum and sufficient information for a complete 

application. The revision also enhances the instruction to ensure a common 

understanding of the criteria supporting denial or rejection of an application. NRR 

estimates it will issue revised LIC-109 in January 2017. Furthermore, NRR is developing 

staff training to conduct in conjunction with LIC-101 training, discussed in Section II 

below, at a future date. 

II. Reinforce Our Licensing Procedures 

Background: NRR performs licensing reviews in accordance with NRR Office Instruction 

LIC-101, “License Amendment Review Procedures.” In FY 2013 through FY 2015 NRR 
- 2 - 

was challenged with a deferral of licensing work resulting from the reprioritization and 

shifting of resources to address lessons learned from the accident at Fukushima DaiIchi. On June 17, 2014, the NRC staff briefed the Commission on strategic 

considerations associated with the Operating Reactors Business Line, including the 

status and challenges facing the licensing program. On June 30, 2014,1 the 

Commission issued a staff requirements memorandum that led the staff to develop new 

mechanisms to restore licensing performance, specifically with respect to timeliness and 

the number of licensing actions. 

Objective of Initiative: Review and evaluate the existing LIC-101 process with the goal of 

reinforcing current expectations and best practices. In conducting this initiative, the 

working group was to identify and evaluate opportunities and processes to implement 

efficiencies and effectiveness in conducting licensing reviews. 

Result: The working group conducted interviews with NRR staff members and analyzed 

performance data. The working group provided a list of recommendations to the NRR 

management team. Examples of recommendations included drafting safety evaluations 

prior to issuing RAIs to focus the scope of RAIs, improvements to the workload 

management system to remind staff of upcoming milestones, better communication if 

schedules cannot be met, and additional tools for staff to ensure proper technical 

branches are involved in the review. NRR management used these recommendations 

to inform the revised Expectations Memo dated April 18, 2016. 

Status of Initiative: NRR is revising LIC-101 to incorporate procedural changes 

introduced in the revised Expectations Memo, as well as recommendations from the 

LIC-101 working group. NRR estimates it will issue revised LIC-101 by the end of 

January 2017. Furthermore, the office is developing staff training to conduct in 

conjunction with LIC-109 training at a future date. 

III. Improve Regulatory Decision-Making 

Background: NRR did not have a formal process to efficiently resolve or elevate 

technical or regulatory issues to management when there may be staff disagreement on 

the correct path forward. As a result, there has been instances when the office did not 

resolve issues in a timely fashion and this adversely impacted the efficiency of 

processing some licensing actions. 

Objective of Initiative: Improve the process of making regulatory decisions when 

branches or staff within a branch reaches an impasse. Also, provide a better process for 

determining when staff should elevate issues to higher levels of management to ensure 

timeliness of management support. 

Result: NRR developed the Timely Elevation and Resolution Process (TERP) and 

documented it in NRR Office Instruction LIC-507 in FY 2016. TERP can improve 

resource efficiency by enhancing regulatory decision-making while maintaining staff 

involvement. The office instruction defines the process by which NRR staff and 

 

1 Agencywide Documents Access and Management System Accession No. ML14181B402. 
- 3 - 

supervisors will elevate impasses to the attention of higher levels of management for 

resolution. 

Status of Initiative: Draft LIC-507 was available for staff use through December 2016. 

NRR staff has used TERP once during the trial period. The process was successful as 

staff resolved the impasse in a timely manner. In 2017 the staff will review and adjust 

the office instruction with lessons learned from the trial period and issue the formal office 

instruction by spring of 2017. 

IV. Evaluate the Technical and Regulatory Adequacy of Licensing Reviews 

Background: This initiative is part of NRR’s overall effort to implement improvements that 

will enhance predictability, timeliness, effectiveness, and efficiency of reviews. In certain 

instances, there is not a clear set of essential information of specific acceptance criteria 

identified for making regulatory decisions. As a result, similar reviews completed by 

different technical reviewers are inconsistent in the information requested of the licensee 

and in the final regulatory conclusions. 

Objective of Initiative: Clearly articulate what constitutes “reasonable assurance” as it 

pertains to licensing reviews. This is consistent with management expectations that the 

NRC staff focus technical reviews on matters in a risk-informed manner, such that those 

aspects most pertinent in making a safety determination are considered and not those 

aspects that have little-or-no contribution to the safety significance of the issue. 

Result: The working group considered the goals for the initiative and feedback from 

facilitated focus groups and others. The working group recommended the selective 

development and use of structured multilevel guidance developed using maturity 

model/framework concepts for large, routine reviews. The working group has labeled 

this multilevel guidance “enhanced review guidance.” For a particular type of review, the 

enhanced review guidance is intended to be a comprehensive review aid that compiles 

all criteria and references needed to complete a review, including an explicit list of all 

information that is necessary and sufficient to make a regulatory finding. In part because 

of the amount of effort needed to develop enhanced review guidance, the working group 

has limited its recommendation to large routine reviews, review areas where NRR may 

lose expertise, or review areas that have a history of inconsistent regulatory 

decision-making. These are considered to be the types of activities where leveraging 

this enhanced review guidance will garner the most efficiency and also serve as a 

knowledge management tool. 

Status of Initiative: NRR is in process of completing several pilots of the enhanced 

review guidance, with the goal of completing four by the end of FY 2017 before 

expanding the initiative more broadly. 
- 4 - 

V. Review Quality of Requests for Additional Information 

Background: The NRC staff has placed increased emphasis on RAIs. The January 15, 

2015, and April 18, 2016, Expectations Memos direct that draft safety evaluations be 

written “with holes” correlating to RAIs before issuing RAIs, and that management 

increase attention when multiple rounds of RAIs are proposed. NRR established this 

initiative in the beginning of FY 2017 to validate the effectiveness of the recent changes 

in the RAI process. 

Objective of Initiative: A periodic review of RAIs issued since the April 18, 2016, 

Expectations Memo to validate whether the staff is meeting expectations in process 

adherence, quality, and timeliness. The results will be evaluated for improvement 

opportunities within the RAI process and used to better inform office-level, sub-element 

monitoring measures. 

Status of Initiative: The NRR staff is in the process of conducting this review. 

Preliminary results from the first review effort will be provided to the NRR executive team 

in February 2017.