ML16215A410

Non-Power Production and Utilization Facility Construction Inspection Program Presentation

ML16215A410
Person / Time
Site:	SHINE Medical Technologies
Issue date:	05/26/2016
From:	NRC/NRR/DPR/PRLB
To:
Lynch S, NRR/DPR, 301-415-1524
Shared Package
ML16215A398	List: ML16215A408 ML16215A409 ML16215A410
References
Download: ML16215A410 (47)

Text

Non-Power Production and Utilization Facility (NPUF) Construction Inspection Program (CIP)

U.S. Nuclear Regulatory Commission May 26, 2016

Construction Inspection Program Overview Carl Weber Office of New Reactors

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Background===

• Generic CIP to cover NPUFs

- Not all aspects will apply to every facility

• Sample based

• Focus on safety related systems, structures, and components (SSCs)

• Quality Assurance Program commitments

- Corrective Action Program 3

Licensing and Oversight Responsibility Construction Inspection Manual Chapter:

Region II QA Inspections SSC Inspections Operational Readiness Inspection report from Region II stating CIP complete Operation Inspection Manual Chapter:

NRR Startup Testing Licensing Actions: NRR Issue Operating License Issue Construction Permit Oversight Inspections 4

Inspection Manual Chapter (IMC) 2550

• NPUF-CIP: Single IMC

- Facility Specific Assessment and Review Group (FSARG)

- Inspection Report format

- Enforcement (Traditional)

- Overall Inspection Strategy

- Assessment

• Transition to Operations.

• Qualification and Training for Inspectors addressed in IMC 1245 5

Inspection Procedures (IPs)

• Facility Construction

- IP 69020, Inspections Of Structures, Systems And Components During Construction Of Non-Power Production and Utilization Facilities

• Quality of Construction

- IP 69021, Inspections Of Quality Assurance Program Implementation During Construction Of Non-Power Production and Utilization Facilities

• Operational Readiness

- IP 69022, Inspections Of Operational Readiness During Construction Of Non-Power Production and Utilization Facilities 6

Facility Construction Inspection Procedure Structures, systems and components (SSC) inspection procedure Sample selection will be based on safety significance (QL-1 systems)

Potential inspection areas:

- Foundations and buildings

- Structural concrete

- Structural steel and supports

- Piping systems

- Piping restraints and supports

- Mechanical components

- Electrical cable

- Electrical systems and components

- Ventilation and confinement systems

- I&C systems

- Nuclear welding

- Structural welding

- Fire protection systems Inspections include applicable aspects of QA Program implementation 7

Quality of Construction Inspection Procedure

• Quality Assurance (QA) Implementation IP

• Consists of 3 parts

- One Time QA Implementation Inspection.

- Periodic QA Inspections (at least annually):

• Corrective Action Program (CAP) Review.

• Design Control, Nonconformance Control, Audits.

• Other Criteria (as needed).

- Reactive Inspections (e.g., problem areas identified during SSC inspections, adverse trends, etc.)

• ANSI 15.8 requirements 8

Operational Readiness Inspection Procedure

• Operational Readiness Assessment Inspection

- One time inspection

- Conducted after licensee submits operating license application and near the end of construction activities

- Covers status of CIP completion, and may include programs needed for operations

• Inspection supports decision on operating license application determination 9

Construction Oversight and Inspections William Gloersen Region II

Oversight and Inspections:

Communication

• Establish and maintain frequent communications with NRC

• Establish point of contact for NRC RII construction project manager

• Conduct weekly teleconferences with the following participants:

- NRC licensing (HQ) and construction project management staff (RII)

- SHINE licensing and construction project management staff 11

Oversight and Inspections:

Communication Consider developing a construction status briefing sheet to facilitate the teleconference with the following information:

- Construction status and schedule

• Major milestones

• Major activities in the past week

• Major activities planned

- NRC inspection schedule

• Inspections completed

• Inspections planned

- Licensing Status

• Key licensing actions

- Meetings

• SHINE drop-in visits to NRC HQ or RII

• NRC management visits to SHINE

• Public meetings 12

Oversight and Inspections Establish and maintain a restricted access electronic reading room for use by both NRC inspection and licensing staff Types of information provided in the electronic reading room

- Licensing Documents

• Construction Authorization

• Quality Assurance Plan

• Safety Analysis Report

- Inspection Documents

• Construction Schedules

• Project Procedures

• Condition Reports

• Non-conformance Reports

• Engineering documents and drawings

• Construction photographs 13

Observations

• Develop strong partnerships with proven vendors

• Maintain critical oversight of work planning packages

• Perform intrusive and strategic inspections to confirm work is performed correctly prior to major undertakings and prior to NRC inspections 14

Observations

• Develop a robust corrective action program

- Identify, classify, and track conditions adverse to quality

- Ensure proper implementation and closure of corrective actions are completed

- Consider a Management Review Committee

• Safety Culture

- Keep the terms simple and usable for the construction staff

- Encourage staff to have a questioning attitude

- Demonstrate importance daily and reward behaviors

• SHINE Management Oversight

- Challenge the status quo

- Be seen in the field and model the correct behaviors and priorities - seek to understand 15

Construction Lessons Learned:

New Reactors Phil OBryan Office of New Reactors

Discussion Topics

• Design Control Lessons Learned

• Construction Lessons Learned

• Corrective Action Program Lessons Learned 17

Design Control Lessons Learned

• Unclear Licensing Basis

- New aspect of design that wasnt originally described or addressed in Construction Permit

- Misapplication of Codes/Standards in licensing basis

• Lack of awareness of licensing basis commitments

- Use of standard methodologies not in licensing basis

- Misinterpretation of Codes/Standards

- Use of wrong revision of Codes/Standards

- Incorrect, or lack of, vendor specifications

- Field changes poorly researched 18

Construction Lessons Learned

• Poor vendor quality, not identified by receipt inspection

• Poor Work Packages/Procedures

• Constructability & Field engineering

• Poor Supervision/QC oversight 19

Corrective Action Program (CAP)

Lessons Learned

• Safety Conscience Work Environment and workers new to nuclear industry

• Use of multiple CAPs/QAPs

• Use-as-is justifications

• Use of CAP to reconcile deviations and licensing basis 20

Construction Lessons Learned:

Fuel Cycle Facilities David Tiktinsky Office of Nuclear Material Safety and Safeguards

Topics

• Commitments in licensing documents

• Change process

• QA programs

• NRC observations 22

Commitments Made in Licensing Documents

• Clear commitments in licensing documents (e.g. codes, standard and exceptions)

- NRC inspects against licensing commitments

- Interpretations of code requirements

- Clear language

- Deviations and exceptions from codes and standards

- Descriptions versus commitments 23

Change Process During Construction

• Change requirements used for evaluating changes to site, structures, processes, systems, components, etc. (for ISA summary)

• Change process for license application

- NRC reviews and inspects process and results

- Reassess criteria based on actual experience 24

NRC Observations

• Design control

• Vendor oversight

• Inspection 25

Design Control Inspection Findings

• Translating design requirements (including codes and standards) into design and construction documents and properly implementing design documents

• Initiating, performing, verifying and documenting design changes and evaluating the impact of those changes on the design bases 26

Design Control Corrective Actions

• Training

• Surveillance activities at vendors

• Documentation of code deviations

• Procedure revisions 27

Supplier and Vendor Inspection Findings

• Compliance of inspection procedures with respect to ASME codes

• Oversight of vendors QA activities

• Documentation of weld repair procedures

• QA examinations of repair welds not performed as required by procurement specifications

• Vendor welder qualification program

• Inadequate documentation of weld repair/rework activities 28

Supplier and Vendor Corrective Actions

• Training related to preparing technical justifications

• Revised procedures to provide project personnel instructions on handling supplier issued non-conformance reports

• Additional oversight of vendors QA

• Clarification of procurement specifications 29

Lessons Learned from Industry Representative*

• Accepted Industry Practice does not necessarily affect the NRCs Position

• Emphasis on survey of the supply chain not realistic, unless accounted for when developing procurement strategy for how to establish a supply chain for a CGI

• The completeness of the evaluation, survey results, test results and the final acceptance records are important for CGI as any other nuclear component

• Presented by Rodney Whitney, MOX Services at NRC vendor oversight workshop in August 2012.

30

Challenges to Quality Construction (Industry)

• Ensuring vendors and construction contractors are implementing quality assurance requirements

• All organizations should be trained on and use similar corrective action programs

• Designing and redesigning as construction continues impacts inspection resources and scheduling

• Design control and verifications

- Does the field design match the approved design?

31

Vendor-Related Lessons Learned/Recommendations (Industry)

• Know your suppliers (and your suppliers supplier) fabrication and CGD processes

• Demand objective evidence that suppliers and sub-suppliers have appropriate QA programs & CGD Processes in-place to assure implementation is effective

• Otherwise you may see or get:

- Procedures not workable or developed but not followed

- Implementing procedures dont consistently address requirements

- Incapable of identifying critical characteristics

- Lack of experience with nuclear regulations and QA requirements

- Control of sub-suppliers by prime suppliers is poor 32

Vendor-Related Lessons Learned/Recommendations (Industry)

• Allow vendor flexibility in sampling plans due to their knowledge of particular circumstance of their supply chain knowledge

- Allow vendors to propose alternatives for your acceptance

- Experience has shown that QL-1 (IROFS) vendors vary dramatically in their knowledge of standard sampling plans and implementation of sampling plan methodology

- Example: Destructive/Non-destructive testing of raw materials 33

Vendor-Related Lessons Learned/Recommendations (Industry)

• Vendor Communication with project CGD group is very important.

- Placing CGD personnel in the vendor shop can be very beneficial.

- Train Subcontract Technical Representatives to understand project CGD positions, since they are the first line of technical oversight of the vendor.

- Understand foreign company quirks.

34

Vendor-Related Lessons Learned/Recommendations (Industry)

• Aggressive management and oversight of CGD programs is prudent

- Review all vendor Commercial Grade Dedication plans and procedures initially.

- Reviews may be stopped or lessened when confidence is gained with vendors program

• CGD acceptance process needs to be closely coordinated with receipt inspection capabilities 35

NRC Enforcement Program Tom Marenchin Office of Enforcement

Purpose of Enforcement Program:

Support NRC Mission

• Enforcement Action Should Be Used:

- As a deterrent to emphasize the importance of compliance with requirements, and

- To encourage prompt identification and prompt, comprehensive correction of violations 37

Enforcement Tools

• Formal Mechanisms (legally binding)

- Minor violation

- Non-cited violation (NCV)

- Notice of violation

- Civil penalty

- Order

- Demand for Information

• Administrative Actions (not legally binding)

- Notice of Deviation (failure to satisfy non-binding requirement)

- Notice of Nonconformance (contractor failure)

- Confirmatory Action Letter (licensee agreement to take specified actions) 38

NRC Enforcement Process

• Identify

• Assess

• Disposition 39

Identifying Noncompliances

• What requirement was violated?

• How was the requirement violated?

• When did the noncompliance occur?

• How long did it exist?

• Who identified it and when?

• What is significance

• What is the root cause? (if known)

• Corrective actions?

40

Significance

• NRC consider four issues:

- Actual safety consequences

- Potential safety consequences

- Potential for impacting the NRCs ability to perform its regulatory function

- Any willful aspects of the violation 41

Traditional Enforcement

• Each violation assigned a Severity Level (SL)

- SL I, II, III, IV, with SL I being the most significant and SL IV being the least significant on risk

- Enforcement Policy Provides violation examples for each of the four SLs

• Section 6.5 - Facility Construction (10 CFR Part 50 and 52 Licensees and Fuel Cycle Facilities)

- SL may be increased if violation determined to be willful 42

Notice of Violation (NOV)

• A written notice setting forth one or more violations of a legally binding requirement

• NOV states:

- When violation occurred (date)

- Who violated requirement

- Time and/or number of times violation occurred

- Brief description of the violation (i.e., what actually happened resulting in the violation)

• A civil penalty may be issued in conjunction with NOV 43

Escalated Enforcement

• SL I, II, III violations Civil Penalties

• NOVs to individuals

• Orders to modify, suspend, or revoke NRC licensees or the authority to engage in NRC-licensed activities

• Orders to impose civil penalties 44

Enforcement Panel

• All proposed escalated enforcement reviewed by enforcement panel

• Panel participants include OE, regional staff, headquarters staff, and, if needed, OGC

• Panel considers:

- Facts of the violation and requirements

- SL and violations examples in Policy

- Whether Identification Credit is warranted

- Whether Enforcement Discretion is appropriate

- Whether a CP is appropriate

- Whether to hold a PEC 45

Predecisional Enforcement Conference (PEC)

• Held if needed by NRC or requested by licensee

• Normally open to public

• Purpose - to obtain information to assist enforcement decision:

- Facts, Root Causes, Missed Opportunities

- Corrective Actions taken or planned

- Significance 46

References

• NRC Enforcement Policy http://www.nrc.gov (select Electronic Reading Room, then Document Collections, then Enforcement Docs, then Enforcement Policy)

• NRC Enforcement Manual http://www.nrc.gov (select Electronic Reading Room, then Document Collections, then Enforcement Docs, then Enforcement Guidance, then Enforcement Manual)

• Issued Escalated Enforcement Actions http://www.nrc.gov/about-nrc/regulatory/enforcement/current.html 47