ML17356A269

Construction Lessons Learned Report

ML17356A269
Person / Time
Site:	Watts Bar
Issue date:	12/20/2017
From:	William Jones NRC/RGN-II
To:	Catherine Haney NRC/RGN-II
Jones W
References
Download: ML17356A269 (32)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 December 20, 2017 MEMORANDUM TO: Catherine Haney, Regional Administrator FROM: William B. Jones, Director Division of Construction Oversight

SUBJECT:

WATTS BAR UNIT 2 CONSTRUCTION LESSONS LEARNED REPORT The Watts Bar 2 Construction Oversight Lessons Learned Working Group has completed the Watts Bar Unit 2 Construction Lessons Learned Review Report. The report, which is enclosed, will be made available to the public via the U.S. Nuclear Regulatory Commissions Agencywide Documents Access and Management System. Issuance of the report concludes the working groups actions under its charter.

Enclosure:

Watts Bar Unit 2 Construction Lessons Learned Report cc: V. McCree, EDO L. Dudes, RII J. Munday, RIl B. Holian, NRR F. Brown, NRC CONTACT: Tomy Nazario, R2/DCO Phone: 240-701-4174

C. Haney 2 Memorandum to Catherine Haney from William B. Jones

SUBJECT:

WATTS BAR UNIT 2 CONSTRUCTION LESSONS LEARNED REPORT PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE 0 SENSITIVE NON-SENSITIVE ADAMS APPLICABLE JSUNSI REVIEW COMPLETE ML#___________________

OFFICE tRIl: DCO/CIB3 RIl: DCC SIGNATURE %i,;;g.

NAME I T. Ntario WSJens DATE rZ/2c/

U.S.NRC United States Nuclear Regulatory Cummisson Protecting People and the Environment WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION LESSONS LEARNED October 31, 2017 Enclosure

Table of Contents Executive Summary . iii Acronyms iv I. Background 1 II. Scope and Methodology 4 Ill. Lessons Learned 5 IV. Recommendations 12 V. Attachment A-i

Executive Summary This report summarizes the Watts Bar Nuclear Plant Unit 2 (WBN2) Construction Lessons Learned project. The lessons learned project involved contributions from senior staff, interviews of staff involved with the reactivation of WBN2, and review of previous lessons learned efforts.

The lessons learned contained in this report highlight actions that contributed to the effectiveness of program implementation and enhancements for future activities, consistent with the U.S. Nuclear Regulatory Commissions (NRCs) Principles of Good Regulation (Independence, Openness, Efficiency, Clarity, and Reliability). This report also provides a comparison that will inform the development of prospective inspection programs and identify areas for followup.

This report groups the lessons learned into the areas of (1) planning, scheduling, and reporting, (2) inspection program staffing, (3) communications, and (4) construction to operations transition. Specific lessons and recommendations range from improvements to existing inspection program guidance to the use of tabletop exercises to identify potential gaps, strengths, and focus areas.

This report documents the following additional lessons and recommendations:

• The agencys ability to adapt to change throughout all phases of a project is key to the successful completion of inspection and licensing objectives.

• Early inspection program development by experienced and knowledgeable staff is valuable to the inspection effort.

• Staff training and selections for first time and one-of-a-kind projects are an essential element to regulatory oversight effectiveness.

• Stakeholder engagement during all phases of a project assist with keeping everyone informed and serve as a platform for open communication.

Although this report refers to a number of lessons and the corresponding recommendations as proposed, several recommendations have been implemented and the associated actions have been completed. In other cases, the lesson or the recommendation may not apply, in which case a justification is provided.

In summary, this report captures noteworthy lessons learned from the reactivation of WBN2.

The consideration and potential implementation of these lessons learned and recommendations will serve as a principal component to the development of future NRC programs. Moreover, these lessons will continue to support the NRCs commitment to continuous improvement.

III

ACRONYMS CFR Code of Federal Regulations ADAMS Agencywide Documents Access and Management System CIPIMS Construction Inspection Program Information Management System DCO Division of Construction Oversight IMC inspection manual chapter IP inspection procedure IP&S inspection plan and scheduling ITAAC inspections, tests, analyses, and acceptance criteria NGO nongovernmental organization NRC U.S. Nuclear Regulatory Commission NRO Office of New Reactors NRR Office of Nuclear Reactor Regulation OEDO Office of the Executive Director for Operations ORAl Operational Readiness Assessment Team RIl Region II ROP Reactor Oversight Process SRI senior resident inspector TVA Tennessee Valley Authority WBN1 Watts Bar Nuclear Plant Unit 1 WBN2 Watts Bat Nuclear Plant Unit 2 WRAG WBN2 Review and Assessment Group iv

I. BACKGROUND The reactivation of Watts Bar Nuclear Plant Unit 2 (WBN2) has a unique licensing history and regulatory framework. The Watts Bar site consists of two Westinghouse-designed pressurized-water reactors, owned and operated by the Tennessee Valley Authority (TVA).

TVA received a construction permit for Watts Bar Nuclear Plant Unit 1 (WBNJ) and WBN2 in 1973 under Title 10 of the Code of Federal Regulations(10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. In 1985, TVA stopped construction on WBN1 and WBN2 because of multiple construction quality issues. TVA completed WBN1 in 1995, but it has conducted very little work specific to WBN2 since 1985.

In 2007, TVA informed the U.S. Nuclear Regulatory Commission (NRC) of its plan to resume construction of WBN2. Shortly thereafter, the NRC staff submitted SECY-07-0096, Possible Reactivation of Construction and Licensing Activities for the Watts Bar Nuclear Plant Unit 2, dated June 7, 2007 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML071220492) to the NRC Commission. The SECY paper discussed the staffs approach for possible reactivation of licensing and construction inspection activities for WBN2.

The Commission approved the staffs recommendations for the licensing and inspection of WBN2 in Staff Requirements Memorandum (SRM)-SECY-07-0096, dated July 25, 2007 (ADAMS Accession No. ML072060688). In keeping with its approach, the NRC staff developed a site-specific inspection program contained within Inspection Manual Chapter (IMC) 2517, WBN2 Construction Inspection Program. This IMC delineates the policy for the conduct of inspections at WBN2 during construction and startup under the following IMCs:

• IMC 2512, Light Water Reactor Inspection ProgramConstruction Phase

• IMC 2513, Light Water Reactor Inspection ProgramPreoperational Testing and Operational Preparedness Phase

• IMC 2514, Startup Testing Inspections IMC 2517 also defines the roles and responsibilities for Region II (RIl) and NRC Headquarters.

The NRC reviewed all historical documentation to determine the status of the IMC 2512 inspection procedures (IPs) in effect at the time TVA stopped construction and to confirm that all issues and inspection requirements would be completed for WBN2. The NRC staff called this effort the reconstitution process. The staff documented the results of the reconstitution process in Inspection Report 05000391/2009602, dated April 30, 2009 (ADAMS Accession No. ML091210420), and used the results to identify areas that required additional inspections.

During the early stages of the NRCs oversight of WBN2, RIl coordinated and worked extensively with the WBN2 Special Projects Branch in the NRC Office of Nuclear Reactor Regulation (NRR). This coordination resulted in the establishment of an oversight group known as the WBN2 Review and Assessment Group (WRAG), which consisted of NRC senior managers from Rh and NRC Headquarters, the cognizant Rh branch chief, NRR senior project manager, and senior resident inspector. The senior managers in NRR and RIl construction organizations co-chaired the WRAG.

The WRAG proved to be a key process in integrating licensing and inspection activities with the licensees schedule and focused the NRCs management oversight on complying with the 1

Commissions directions in SRM-SECY-07-0096. The WRAG ensured an effective integration of licensing and inspection activities, which enabled NRC staff to be adequately prepared to support meetings and hearings.

To effectively manage the IMC 2517 inspection program, RIl developed a site-specific inspection plan and scheduling (IP&S) tool to complete the inspections required by IMC 2512, IMC 2513, and IMC 2514$ open temporary instructions (TIs); and open NRC generic communications such as generic letters and bulletins. The IP&S tool also facilitated the accounting, tracking, and completion of items that resulted from the reconstitution of the inspection program. The tool assisted with and provided sufficient flexibility for rescheduling inspections to accommodate applicant schedule changes.

The NRC staff reviewed inspection activities, particularly near the completion of construction, on a nearly daily basis to establish when, where, and what type of inspection resources were needed. The NRC assigned additional resident inspectors to the site, and regional inspectors remained on site for weeks to several months during construction, preoperational testing, and startup testing. As an example, the agency used the former WBN1 senior resident inspector to assist in the development of other inspectors and with WBN2 operational knowledge transfer.

This helped maintain project continuity and train other inspectors during the preoperational and startup periods. Additionally, the continued use of rotational resident inspector positions helped maintain adequate levels of staffing at the site. The NRC regional offices, the NRC Technical Training Center (TTC), and NRC Headquarters provided support during the construction period and through startup testing. IMC 2517 governs the qualifications for individuals performing these different types of inspections.

As the project neared completion, the WRAG provided frequent communication on the status of WBN2 and eliminated the need for the generic readiness IP 94300, Status of Plant Readiness for an Operating License, 90-day status report, and subsequent status report updates. The NRC issued IP 94302, Status of WBN2 Readiness for an Operating License, specific to WBN2, which provided a list of open items to be tracked and resolved following issuance of the operating license (ADAMS Accession No. ML15288A305). IP 94302 provided updated guidance to support reporting the status of WBN2 readiness for an operating license. This guidance allowed for a detailed understanding of the outstanding and completed inspections, the type (discipline), and the inspectors needed to accomplish the remaining work. The NRC made the list of open items available to the publicly (via ADAMS) and provided the basis for RIls assessment of WBN2 readiness for an operating license.

Consistent with the NRCs value of openness, the agency held numerous public meetings through standing weekly teleconferences, WRAG updates, end-of-cycle meetings, nongovernmental organization (NGO) interactions, and informational meetings. These meetings took place in the NRC Headquarters and RIl offices and in the vicinity of Watts Bar.

The NRC held an informational public meeting on March 26, 2015, at a high school in Athens, TN, as construction activities were ending. At the meeting, NRC senior management met with the public, TVA, and other stakeholders concerning WBN2 and discussed the status of the WBN2 construction project, including major milestones and potential challenges that could impact the project schedule. During this meeting, the RIl Regional Administrator and the NRR Office Director addressed the operating license process. The NRC also held a meeting with NGOs earlier that same day.

The NRC developed a detailed transition plan (ADAMS Accession No. ML15096A204) in April 2015 to support the transition of WBN2 from construction and testing under IMC 2517 to 2

the Reactor Oversight Process (ROP). This transition plan ensured the use of a deliberate approach to transition each individual ROP cornerstone. It also assigned responsibilities resolving any relevant open issues to ensure that each cornerstone was ready for NRC monitoring using the ROP before final transition (i.e., performance indicators and inspections).

The ROP and IMC 2517 provided the guidance for the inspection and assessment of the licensees performance through preoperational and startup testing and into full-power operations. The RH construction organization continued to participate in WBN2 briefings until the followup items identified in the IP-94302 letter were closed. The Division of Reactor Projects assumed the lead oversight responsibility following issuance of the operating license and established a communication protocol that included a standardized form of upcoming activities, challenges, and resource needs. The Division shared this communication protocol within Ru and with the cognizant headquarters offices, including the Office of the Executive Director for Operations fOEDO). OEDO also used this tool to update the Commission on ongoing activities at WBN2.

On May 26, 2015, the Commission issued SRM-SECY-15-0068, Watts Bar Nuclear Plant, Unit 2Review Status and Authority of the Director of the Office of Nuclear Reactor Regulation for Operating License Issuance (ADAMS Accession No. ML15146A213). The Commission approved the staffs recommendation to grant the NRR Office Director the authority to issue WBN2 a full-power operating license. On October 22, 2015, the NRC issued the operating license (ADAMS Accession No. ML15251A587). After issuance of the operating license, the NRC disbanded the WRAG, and NRC oversight of WBN2 transitioned to the ROP for operating reactors.

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II. SCOPE AND METHODOLOGY On March 8,2017, the NRC Rh staff conducted and documented an initial lessons learned effort in a memorandum from William B. Jones, Director, Division of Construction Oversight (DCO) in RH to Chris Miller, Director, Division of Inspection and Regional Support (DIRS) in NRR. Rh staff issued the WBN2 lessons learned memorandum to capture the staffs initial insights into the implementation of the WBN2 oversight program. The staff identified four general areas into which the lessons were categorized: organization, construction inspection, testing, and transition. The associated items provided an outline of the types of issues the staff and management addressed to accomplish the inspection and assessment of WBN2 during construction and transition to commercial operation. The attachment to this report includes the specific items identified in the memorandum.

In June 2017, RIl established an interoffice working group made up of senior staff from NRR and the Rh inspection office to further assess the lessons learned from WBN2. The working group transmitted its charter via memorandum dated June 26, 2017 (ADAMS Accession No. ML17192A031). The working group focused on aspects of the WBN2 reactivation, including the transition from construction to operations. The working group used the March 8, 2017, lessons learned memorandum as a basis for this report.

On August 910, 2017, the working group met to discuss WBN2 lessons learned. The group reviewed several documents, combined lessons learned from previous efforts, and identified lessons learned that could be retained and disseminated in a manner that would maximize their benefits and usefulness to the staff.Section III of this report describes the following four general lesson learned areas:

• Lesson Area 1: Planning, Scheduling, and Reporting

• Lesson Area 2: Inspection Program Staffing

• Lesson Area 3: Communications

• Lesson Area 4: Construction to Operations Transition The working group developed specific lessons under each general lesson area. Some lessons have overlapping themes.Section IV of this report further discusses the specific recommendations and applicability to existing processes such as those covered under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants. This report consolidates all the lessons gathered through interviews and other similar efforts, including the March 8, 2017, memorandum.

The following individuals contributed to this Watts Bar Plant Unit 2 Construction Lessons Learned report:

• Tomy Nazario, NRC Rh

• James Baptist, NRC RhI

• Christopher Even, NRC RIl

• Jason Eargle, NRC RII

• Stephen Campbell, NRC NRR

• Phil OBryan, NRC NRO 4

III. LESSONS LEARNED Lesson Area 1: Planning, Scheduling, and Reporting 1 .a Because of the plants unique nature and licensing basis, the NRC developed project-specific procedures and processes for WBN2. For example, the staff developed and issued IMC 2517, WBN2 Construction Inspection Program, and IP 37002, Construction Refurbishment ProcessWatts Bar Unit 2. During the development of the IMC and IP, the program office engaged experienced regional inspectors to compile guidance that was mote directly applicable to and specifically designed for the inspectors.

The regional inspectors involved in the IMC and IP development had direct involvement in the restart of the Browns Ferry Nuclear Power Plant and Watts Bar during the 1 980s and 1990s. The authors of the WBN2-specific documents understood the unique history of Watts Bar and had first-hand knowledge of the licensing basis, technology, and the material condition of the plant. They also had an indepth understanding of the inspection program used for WBN1 and how to develop a program that supported the Commissions approach that employed the current licensing basis for Unit 1 as the reference basis for the review and licensing of Unit 2, as stated in SRM-SECY-07-0096.

In summary, the participation of experts and knowledgeable staff in the development of the inspection program proved valuable, as evidenced by site-specific tailored guidance and procedures that required minimal future revisions.

Lesson: For first-of-a-kind or unique projects, the engagement of experienced experts and knowledgeable staff during the development of guidance documents proved valuable and resulted in final guidance that was tailored to the unique licensing basis of Wafts Bar.

1 .b During the early stages of the WBN2 project, the regional construction organization was initially set up to mirror the current operating reactor oversight organizational structure, which distributed the responsibilities to a project management division (Division of Reactor Projects) and an inspection support division (Division of Reactor Safety). This division of responsibilities introduced additional approval layers and independent tracking of open items. It also resulted in inspection planning, scheduling, and reporting challenges. Initially, there were varied methods of coordinating inspections because inspection assignments were independently assigned, scheduled, and tracked among different work groups. This inspection planning methodology required resident and project staff to routinely validate project schedule information to ensure that inspections were scheduled accordingly. Moreover, the documentation and reporting of inspections varied, requiring added review efforts by the project managers.

A centralized project management approach was instituted with a single management chain of command at the project level to address some of the unique inspection planning challenges. This approach assigned all inspection items to the project management branch responsible for project oversight, so that a single point of contact collectively assigned, scheduled, and tracked inspection items instead of multiple sources and work groups. In summary, this approach resulted in a one stop shop for inspection assignments, which contributed to a more structured environment, improved status updates, and provided a consistent quality of inspection reports.

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The centralized project management approach instituted an environment of clear expectations and development of detailed roles and responsibilities with sufficient authority, all of which contributed to project success.

Lesson: A centralized project management structure with single management chain of command, institution of clear expectations, and development of detailed roles and responsibilities with sufficient authority were key to project success.

1 .c As discussed in Section I of this report, the NRC initiated a review of all historical documentation to determine the status of all open items and confirm that all issues had been addressed and inspection requirements would be completed for WBN2. This effort was known as the reconstitution effort. During the reconstitution effort (20082009) for WBN2, the retention of applicable documentation (in accordance with agency guidance) for open items was important to establishing a comprehensive basis for the resumption of discontinued projects. These open items included legacy items, generic communications, allegations, corrective action programs, special programs, and unresolved items. In some cases, the thorough and detailed documentation of these historical open items provided the staff a comprehensive basis during the reconstitution effort.

Lesson: Retention of thorough and detailed documentation associated with open items was important to establishing a comprehensive basis for the resumption of discontinued projects.

I .d In addition to reviewing the documentation of open items during the reconstitution effort, the staff reviewed IFs to determine whether inspection objectives had been satisfied.

The staff reviewed historical inspection reports (pre-2008) to determine whether IP samples had been completed. If inspection sample information was limited or incomplete, the staff made conservative decisions and determined those to be incomplete samples that required further inspection. Examples of such limited or incomplete information included (1) a specific unit identifier for components was not listed, (2) sufficient detail to provide the basis for completion of IF steps and substeps was lacking, (3) the intent of the top level steps could not be satisfied as documented in the historical inspection reports, and (4) only partial inspections of WBN2 were performed for some systems common to or shared with WBN1.

As the staff developed the WBN2 inspection program (post-2008), the staff implemented a detailed recording and accounting of IP steps and substeps in publicly available inspection reports. This effort proved beneficial and valuable because of the ability to accurately track inspection completion in spite of project delays.

Lesson: Progress of the inspection program (including IP samples) should be thoroughly documented and accounted for to ensure completion. The documentation and status of top-level and lower level inspection steps should contain sufficient detail such that they can be reconstituted if the need arises.

1 .e Typically, large-scale construction projects rely on complex schedules. The NRC project management staff and resident inspectors initiated several compensatory measures to gather real-time site activity information and validate schedule information. This information was then matched up with inspection objectives and schedule site visits. It was recognized early on that remotely synchronizing inspection schedules with 6

construction schedules required additional onsite corroboration because the higher level construction schedules did not reflect specific field work inspection activities. The resident staff was routinely relied upon to validate and corroborate schedule information, causing additional administrative burden on the inspectors. It is important to note that while the NRC was and continues to be focused on the nuclear safety of construction projects versus construction schedules, efficiently managing and planning inspection resources is consistent with one of the five Principles of Good Regulation (Efficiency).

For WBN2, onsite NRC representatives continuously evaluated, monitored, corroborated, and modified inspection schedule changes that could affect NRC resources.

Lesson: Use onsite NRC project management to continuously evaluate, monitor, corroborate, and modify inspection schedules in order to minimize impacts to NRC resources and support the agencys oversight responsibilities.

Lesson Area 2: Inspection Program Staffing 2.a A main component of inspection program implementation was the continuity of staffing on the project and the use of experienced personnel. During the development of the inspection program, the NRC used experienced individuals who participated in construction inspection programs in the 1980s and 1990s. Experiences and insights provided by these team members greatly contributed to the establishment of a viable program and to the completion of the inspection program. The ability to retain key, experienced personnel during different phases of the project provided continuity and stability to the oversight of WBN2 construction.

It is important to note that during the WBN2 project, the NRC underwent several changes and transitions in staffing at the management level both in Rh and NRC Headquarters. Consequently, a contributor to the successful completion of the inspection program was that key staff remained on the project as attrition or staffing changes took place.

Throughout the WBN2 project, a number of individuals supported inspections on a rotational basis, which allowed the agency to develop and train staff who would later be assigned to 10 CFR Part 52 (Advanced Passive (AP) 1000) projects. Given the complexity and duration of large-scale projects, it is important to develop and conduct detailed tabletop exercises for project staffing strategies. These strategies should include the use of individuals with extensive relevant experience, the evaluation of training programs, and the involvement of stakeholders.

Lesson: Project staffing within the organization should be commensurate with the level of activity at the site to provide flexibility, continuity, and assurance that the NRC is equipped to handle attrition and transition events, such as project delays, turnover of personnel, or reprioritization of agency activities.

2.b During the WBN2 project, some targeted work activities for inspection occurred outside of normal working hours (dayshift Monday through Friday). Because of the large number of construction and testing activities during different phases of the project, both regional and resident inspectors exercised a large degree of flexibility to successfully cover and inspect around-the-clock work activities. Typically, resident inspectors were expected to covet backshift and weekend work activities, as stated in Regional Office 7

Instruction 2251, Staff Guidance for the Division of Reactor Projects, and IMC 2515, Light Water Reactor Inspection Program-Operations Phase. However, resident guidance and expectations on how to provide backshift and weekend coverage did not include or apply to inspectors who were not part of the resident program.

Lesson: Clearly establish and manage expectations and guidance for onsite inspection presence during construction and testing such that resources are evenly distributed and equitably assigned during backshift and weekend hours.

2.c Resident offices at operating sites and construction sites are composed of a senior resident inspector (SRI) who performs supervisory duties, resident inspector(s), and an administrative assistant. Historically, SRIs are solicited for informal input during the selection of their staff; however, they are not directly involved in the selection process.

Inspection staff turnover at Watts Bar and specific inspection skill needs changed throughout the project. The NRC recruited high-performing individuals in an effort to meet short-term and long-term staffing needs. During the selection process, key personnel, including the SRI, were consulted and asked for their input on specific skill needs. The regional inspection organization found it to be beneficial to engage site supervisory staff (i.e., the SRI) and RIl leadership during the selection of candidates for projects such as WBN2 that required unique skill sets and experience.

Lesson: Engage site supervisory staff (i.e., the SRI) and regional leadership during the selection of candidates for projects that require unique skill sets and experience.

2.d The NRC trained and qualified inspectors to perform WBN2-specific inspections in support of the WBN2 project. IMC 2517 governs the qualifications for individuals performing inspections at WBN2, including testing activities, whereas IMC 1252, Construction Inspector Training and Qualification Program, dated April 25, 2011 (ADAMS Accession No. ML110470606), governs the construction inspector qualification program for AP1000 sites under construction (10 CFR Part 52). It is important to note that IMC 2517 contains qualification guidance for inspections of testing, and IMC 1252 also requires the Preoperational and Startup Testing Inspection course (with a focus on inspections, tests, analyses, and acceptance criteria (ITAAC)); however, the IMC 1252-specific course was never developed and IMC 1252 was superseded in August 2017 by IMC 1245, Qualification Program for New and Operating Reactor Programs, Appendix C-i 5, Construction Inspector Technical Proficiency Training and Qualification Journal.

Given the industrys proposals to build numerous plants with new reactor designs, the agency trained and qualified most construction inspectors under IMC 1252 during the same time the WBN2 project was taking place. The inspection needs at that time resulted in a limited number of qualified and experienced individuals available to inspect testing activities at WBN2. Even though the regional inspection office started out with a limited number of qualified testing inspectors, the efforts to conduct just-in-time training and increase the number of qualified testing inspectors contributed to the successful completion of key and targeted testing inspections.

Lesson: Proactive regional training enhancements during the testing phases of WBN2 contributed to the successful completion of key and targeted testing inspections.

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Lesson Area 3: Communications 3.a Effective communications during the project were important because of the unique nature and complex licensing history of WBN2. Stakeholder involvement at all levels included NRC Headquarters, Rh, the public, other government agency representatives, NGOs, the Commission, and the licensees organization.

During the early stages of the project, an oversight group (the WRAG) consisting of senior personnel from Rh and NRC Headquarters was established. The WRAGs scope of activities included the following:

• oversight for overall project planning among the NRC offices

• communication of licensing and technical issues to stakeholders

• conduct of periodic meetings with the applicant to discuss progress of the reactivation effort and identify ways to enhance NRC oversight of the project

• oversight for the established WBN2 Reactivation Communication Plan to ensure that key stakeholders were informed of the review status

• coordination and oversight of the applicants preoperational and startup testing As the WRAG increased its oversight role, added benefits were noted throughout the project, such as the WRAGs ability to coordinate and prioritize resources. The WRAG continuously evaluated the project for change, including redirection and curtailment of specific inspection and licensing activities as a result of changes in project scope, schedule, and objectives. The WRAG also contributed to periodic internal and external meetings, the development of the communication plan, and effective communications through different phases of the project.

Lesson: The WRAG proved to be a key component of the WBN2 oversight effort.

The WRAG closely integrated project priorities and focused the NRCs management oversight.

3.b The NRC held numerous public meetings through recurring weekly teleconferences, WRAG updates, end-of-cycle meetings, NGO interactions, and informational meetings.

These meetings took place at the NRC Headquarters office and the RIl office and in the vicinity of Watts Bar. Between 2015 and 2016, the NRC developed an internal communications plan for the transition of the plant from construction to operations. The transition communication plan outlined the NRCs criteria for determining readiness for WBN2 to startup. The plan also contained key messages and specific actions during the phases of the transition. The NRC developed another communication plan in 2010 on the Notice of Violation associated with molded case circuit breakers. Even though multiple communication plans existed throughout the project, one integrated and comprehensive communication plan may have been easier to update and maintain.

Also, the development of a communications plan during the early stages of the project may have further enhanced communications at all levels.

Lesson: The use of several detailed communication plans for WBN2 proved valuable; however, the development of one integrated and comprehensive 9

communication plan would be easier to update and enhance communications at all levels.

Lesson Area 4: Construction to Operations Transition 4.a NRC inspectors witness, first hand, equipment assembly and subsequent testing during construction and component testing of the plant. This afforded inspectors the opportunity to gain unique insights into the equipment history of targeted safety-related components, such as safety injection pumps. Construction IPs for WBN2 provided limited guidance on how to inspect component testing activities. IMC 2517 governs preoperational and startup testing inspections; however, the guidance did not incorporate component testing.

Lesson: Inspections of construction component testing should be incorporated into the inspection program and should be used to inform preoperational and startup testing inspections.

4.b The NRC staff performed an Operational Readiness Assessment Team (ORAT) inspection in accordance with IMC 2514. Before issuance of the operating license at WBN2, IMC 2514 identified the requirement to perform the ORAT inspection in accordance with IP 93806, Operational Readiness Assessment Team Inspections, to assist the NRCs determination for plant startup readiness.

In June 2015, WA informed the NRC of its Declaration of Readiness for WBN2 Operational Readiness Assessment Team Inspection (ADAMS Accession No. ML15156A848). WAs letter briefly described the manner in which it had or will fulfill ORAT inspection-specific prerequisites. ORAT inspections typically coincided with the construction window after system completion and turnover to operations but before plant startup. This allowed inspectors to sample safety-related systems with issued operational procedures and, in some cases, partial or full implementation of those procedures.

Both IMC 2514 and IP 93806 allowed for the ORAT inspections to be tailored to the individual plant circumstances. The NRC staff performed the ORAT inspection with a number of safety-related systems incomplete and still within the custody of the projects construction organization. Because of the timing of the inspection and the limited time between construction completion and turnover of all systems, several site procedures were not fully issued or implemented.

On July 27, 2015, the NRC staff completed the ORAT inspection and concluded that TVA adequately demonstrated the readiness of the facility and staff to safely start up and conduct power operations at WBN2. The staff performed a number of inspections to support plant operations, after the turnover of the safety-related systems to the operations organization but before the systems were relied upon. This approach supported the NRCs determination for plant startup readiness and allowed the NRC to inspect the implementation of safety-significant activities.

Lesson: Perform a detailed assessment of the licensees readiness for an ORAT inspection immediately before the inspection to validate that the licensees operational programs and safety-related systems have met the ORAT prerequisites.

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4.c Following the issuance of the operating license on October 22, 2015 (ADAMS Accession No. ML15251A587), WBN2 transitioned into the ROP. The NRC monitored plant performance by focusing on seven cornerstones as part of the ROP. These cornerstones were assessed by a combination of objective performance indicators reported by the licensee and the NRC inspectors findings. ROP cornerstones became monitorable and transitioned from the NRCs WBN2 construction assessment process (IMC 2517) to the ROP (IMC 0305, Operating Reactor Assessment Program, and IMC 0609, Significance Determination Process), as construction activities finalized and the plants operations organizations took operational control.

The NRC developed IMC 2517 (as discussed above in Section I) and used the traditional enforcement process to assess findings identified throughout the construction phase because of the unique nature of WBN2. During the transition of cornerstones from construction to operations, the inspectors noted that the assessment guidance for dispositioning findings differed under the construction assessment process and the ROP. In some cases under IMC 2517, assessment guidance was limited and did not fully address findings associated with operational programs, whereas the ROP may have been more applicable to disposition these types of findings. Nonetheless, inspectors used the applicable guidance and successfully evaluated findings during the transition process.

Lesson: Phase the transition from construction to operations inspections and assessment programs (including enforcement) to reflect the licensees operational transition and ensure applicable NRC processes are being used.

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IV. RECOMMENDATIONS Recommendations are primarily based on how the lessons learned may apply to current and future 10 CFR Part 52 reactor construction projects. The NRC considered plants to be constructed, restarted, or licensed under 10 CFR Part 50 as part of the lessons learned evaluation. These lessons learned may also be applicable to future NRC-regulated construction projects of different types.

WBN2 Lesson Learned Applicability to 10 CFR Part 50 and Recommendations 10 CFR Part 52

1. Planning, Scheduling, and Reporting 1 .a For first-of-a-kind or unique 10 CFR Part 50: Continue to use guidance contained in projects, the engagement of Future JO CFR Part 50 projects would IMC 0040, specifically, Sections 06.04, experienced experts and have to be evaluated on a case-by-case Regional and Office Comments, and 06.05, knowledgeable staff during the basis to determine whether this lesson and Comment Resolution.

development of guidance recommendation could be applied.

documents proved valuable and Existing guidance (i.e., IMC 0040, It is important to note that IMC 0040 outlines resulted in final guidance that was Preparing, Revising and Issuing regional comment participation during the draft tailored to the unique licensing Documents for the NRC Inspection process. This guidance serves well for the basis of Watts Bar. Manual) may be applicable to future revision of existing inspection manual projects and thus govern corresponding documents; however, for unique or inspection programs. first-of-a-kind projects, the working group recommends that experienced and 10 CFR Part 52: knowledgeable personnel (including those in During the early development of the the region) become involved at the earliest 10 CFR Part 52 inspection program, stages of guidance development.

experienced and knowledgeable staff (including regional inspectors) participated Also, for unique or first-of-a-kind efforts, use in the development of the program through tabletop exercises in which key personnel working groups and review and discuss simulated scenarios. The tabletop concurrence of draft documents. exercises can be used to assess inspection program guidance documents and procedures before issuance.

1 .b A centralized project JO CFR Part 50: Evaluate consolidation of resources and management structure with single Future 10 CFR Part 50 projects would simplified management reporting structure management chain of command, have to be evaluated on a case-by-case (one division reporting structure vs.

institution of clear expectations, basis to determine whether this lesson and 12

WBN2 Lesson Learned Applicability to 10 CFR Part 50 and Recommendations 10 CFR_Part_52 and development of detailed roles recommendation could be applied. two divisions already in place via the DCO and responsibilities with sufficient Organizational structure and management merger).

authority were key to project structure may be dependent upon available success. resources at the time. Establish clear roles and responsibilities that support the inspection program and ensure an 10 CFR Part 52: organizational structure that allows for work The NRC has implemented aspects of this assignments to be equitably distributed.

recommendation for the 10 CFR Part 52 inspection program. Consider centralizing project management responsibilities and clearly defining project Examples include the following: management roles and responsibilities at the beginning of a project.

• Reorganized the construction divisions in Ru, which merged two divisions into one division, also known as the DCC merger (this introduced a single management chain of command for the project oversight group and inspection group).

• Designated a senior construction program manager with sufficient scheduling authority and responsible for the planning, scheduling, and tracking of inspection assignments.

• Developed a Construction Inspection Program Information Management System (CIPIMS) with the ability to plan, schedule, and generate consistent inspection reports.

• Conducted periodic internal meetinqs to discuss inspection 13

WBN2 Lesson Learned Applicability to 10 CFR Part 50 and Recommendations 10 CFR_Part_52 planning, project assessment, and expectations.

1 .c Retention of thorough and Ensure retention of inspection open items Evaluate the need for retention of documents detailed documentation associated and allegation-related material for associated with projects that have ceased with open items was important to discontinued construction projects, as construction, consistent with record retention establishing a comprehensive applicable and consistent with agency policies.

basis for the resumption of guidance.

discontinued projects.

Aspects of this recommendation have been implemented for 10 CFR Part 52 inspection program; CIPIMS has the ability to record inspections.

1 .d Progress of the inspection 10 CFR Part 50: Evaluate the need for detailed IP sample program (including lP samples) This lesson directly applies to both documenting and accounting. As learned should be thoroughly documented 10 CFR Part 50 and 10 CFR Part 52 throughout the WBN2 project, thorough and and accounted for to ensure projects. detailed accounting of inspection objectives completion. The documentation proved valuable because of project delays. It is and status of top-level and lower Part 10 CFR 52: important to note that some lPs may take level inspection steps should The NRC has implemented aspects of this several years to complete and therefore rely on contain sufficient detail such that recommendation in part for the a cumulative sample and satisfaction of they can be reconstituted if the 10 CFR Part 52 inspection program. inspection objectives.

need arises.

For 10 CFR Part 52, CIPIMS provides the ability to track IP completion to the desired level; however, at this time it is unclear how to determine whether the intent of the IP steps have been met. Even though IP samples are recorded at the top-level steps, consistent with IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document, dated February 20, 2017 (ADAMS Accession No. ML16315A349), detailed recording may be warranted to ensure that 14

WBN2 Lesson Learned Applicability to 10 CFR Part 50 and Recommendations 10 CFR_Part_52 the intent of IPs and supporting objectives have been satisfied.

1 .e Use onsite NRC project 10 CFR Part 50: Evaluate results from the pilot for efficiencies management to continuously This lesson directly applies to both and aspects transferrable to current evaluate, monitor, corroborate, and 10 CFR Part 50 and 10 CFR Part 52 construction project manager (CPM) activities, modify inspection schedules in projects. including conduct of CPM activities onsite.

order to minimize impacts to NRC resources and support the 10 CFR Part 52:

agencys oversight responsibilities. The NRC recently piloted aspects of this recommendation at Virgil C. Summer Nuclear Station, Units 2 and 3.

2. Maintaining an Adequate Inspection Staff 2.a Project staffing within the 10 CFR Part 50: Develop early project staffing strategies through organization should be This lesson directly applies to both the use of detailed tabletop exercises. These commensurate with the level of 10 CFR Part 50 and 10 CFR Part 52 strategies should include the use of individuals activity at the site to provide projects. with varying technical expertise and extensive flexibility, continuity, and experience, the evaluation of training and assurance that the NRC is 10 CFR Part 52: programs, and the involvement of stakeholders.

equipped to handle attrition and The NRC has discussed aspects of this The following are considerations for the transition events, such as project recommendation as part of the tabletop exercises:

delays, turnover of personnel, or development of the construction ROP reprioritization of agency activities, transition plan.

• Use rotations and increased staffing, as applicable, commensurate with the level Refer to the following documents for more of activity.

information:

• Assign test inspectors to facilitate and respond to testing activities on short

• Construction Inspection Program notice.

Public Meeting, July 19, 2016

• Use a diversified group of (ADAMS Accession knowledgeable and experienced No. ML16197A125) inspectors (Tiger team) who can

. SECY-1 7-0048, Construction address targeted project needs.

Reactor Oversight Process Self-

• Maintain the presence of an onsite Assessment for Calendar Year project manager (see Lesson 1 .e).

15

WBN2 Lesson Learned Applicability to JO CFR Part 50 and Recommendations JO CFR Part 52 2016, dated April 1 1, 2017 (ADAMS

• Have a multidisciplinary and technical Accession No. ML17047A694). team (panel) collectively review tests for technical adequacy.

2.b Clearly establish and manage This lesson directly applies to both Evaluate the following:

expectations and guidance for 10 CFR Part 50 and 10 CFR Part 52 onsite inspection presence during projects.

• Revise the existing inspection program or construction and testing such that regional office guidance to include resources are evenly distributed expectations for onsite presence by and equitably assigned during nonresident inspectors.

backshift and weekend hours.

Revise position descriptions and performance elements and standards to include backshift and weekend coverage for nonresident inspectors, and communicate the change as appropriate 2.c Engage site supervisory staff 10 CFR Part 50: Evaluate the need for modifying the selection (i.e., the SRI) and regional This lesson directly applies to both and interview process to include the following:

leadership during the selection of 10 CFR Part 50 and 10 CFR Part 52 candidates for projects that require projects.

• onsite interviews, as applicable unique skill sets and experience.

• involvement of site supervisory staff 10 CFR Part 52: (i.e., the SRI) during the interview and The NRC implemented aspects of this selection process recommendation during the selection of

• training of supervisory staff on how to resident inspector development program interview candidates candidates for APi 000. During the interview process, all resident inspector development program candidates were interviewed on site to meet with the site supervisory staff (i.e., the SRI) and briefly experience the work site.

Include the SRI in the resident inspector selection process, including onsite and field interviews.

16

WBN2 Lesson Learned Applicability to 10 CFR Part 50 and Recommendations 10 CFR_Part_52 2.d Proactive regional training 10 CFR Part 50: The latest revision of IMC 1245 addresses this enhancements during the testing This lesson directly applies to both recommendation for all qualifications.

phases of WBN2 contributed to the 10 CFR Part 50 and 10 CFR Part 52 successful completion of key and projects. As continued improvements to the qualification targeted testing inspections, program are made, consider the following:

10 CFR Part 52:

The NRC addressed aspects of this

• just-in-time training for testing and recommendation in the latest revision of operational programs IMC 1245, Qualification Program for New

• postqualification mentoring and on-the-job and Operating Reactor Programs, dated training August 24, 2017. IMC 1245 includes a new Appendix 0-15, which integrates the different qualifications and recognizes the experience needed to perform operational

)ns. such as IThT

3. Effective Communications with Internal and External Stakeholders 3.a The WRAG proved to be a key 10 CFR Part 50: Evaluate the need for and consider the component of the WBN2 oversight The NRC would have to evaluate future establishment of an oversight group for plants effort. The WRAG closely 10 CFR Part 50 projects on a case-by-case under construction.

integrated project priorities and basis to determine whether this lesson and focused the NRCs management recommendation apply.

oversight.

10 CFR Part 52:

The Office of New Reactors and Rh conduct oversight of 10 CFR Part 52 plants. The use of CIPIMS, weekly project meetings, periodic senior management meetings with the licensee, and periodic agency assessments accomplish some of the objectives similar to the WRAG.

However, the staff should consider the benefits of a project-specific and integrated 17

WBN2 Lesson Learned Applicability to 10 CFR Part 50 and Recommendations 10 CFR Part 52 management oversight group for 10 CFR Part 52 plants.

3.b The use of several detailed This lesson directly applies to both Consider early review and development, as communication plans for WBN2 10 CFR Part 50 and 10 CFR Part 52 applicable, of an integrated, comprehensive, proved valuable; however, the projects. Instead of developing multiple and project-specific communication plan that development of one integrated and communications plans for a single project, includes periodicity of communication, roles comprehensive communication consider developing one integrated project and responsibilities, frequently asked plan would be easier to update and communications plan. questions, use of social media for public enhance communications at all outreach, and partnering with the Office of levels. Public Affairs.

4. Construction to Operations Transition Readiness Review 4.a Inspections of construction 10 CFR Part 50: This recommendation has been addressed for component testing should be The NRC would have to evaluate future 10 CFR Part 52 in the latest revision of incorporated into the inspection 10 CFR Part 50 projects on a case-by-case IMC 2503.

program and should be used to basis to determine whether this lesson and inform preoperational and startup recommendation apply. Consideration should be given as to whether testing inspections, component testing inspections should be JO CFR Part 52: incorporated in the 10 CFR Part 50 inspection The NRC incorporated aspects of this program and applicable IPs and potential recommendation into IMC 2503, revisions to IMC 1252.

Construction Inspection Program: ITAAC Related Work, dated July 5, 2012.

4.b Perform a detailed 10 CFR Part 50: The NRC addressed this recommendation for assessment of the licensees The NRC would have to evaluate future 10 CFR Part 52 through implementation of the readiness for an ORAT inspection 10 CFR Part 50 projects on a case-by-case combined license process and IMC 2504.

immediately before the inspection basis to determine how this lesson and to validate that the licensees recommendation could be applied. For future 10 CFR Part 50 projects, consider operational programs and whether detailed assessments of the licensees safety-related systems have met 10 CFR Part 52: readiness for an ORAT inspection should be the ORAT prerequisites. This lesson does not directly apply to performed immediately before the inspection.

10 CFR Part 52 plants because operational readiness was incorporated into the combined license process and 18

WBN2 Lesson Learned Applicability to 10 CFR Part 50 and Recommendations 10 CFR_Part_52 10 CFR Part 52 inspection program

( I MC 2504, Construction Inspection ProgramInspection of Construction and Operational Programs). For 10 CFR Part 52 plants, operational readiness is based on satisfactory completion of inspections of ITAAC.

Completion of targeted ITAAC is closely monitored, inspected, and recorded through the use of CIPIMS.

Additionally, IMC 2504 specifically discusses the confirmation of operational programs and the NRC staffs role in informing the Commission of the status of these programs before making the determination that the licensee can load fuel (see 10 CFR 52.103(g)).

4.c Phase the transition from This lesson directly applies to both Evaluate the need for a phased approach for construction to operations 10 CFR Part 50 and 10 CFR Part 52 the transition of ROP cornerstones. The inspections and assessment projects since both programs transition evaluation should address which process programs (including enforcement) from a construction assessment program (construction or ROP) is better suited to assess to reflect the licensees operational to the ROP. findings during the different stages of the transition and ensure applicable project where the cornerstone may not have yet NRC processes are being used. Scenarios may exist in the future where transitioned to the ROP.

testing activities associated with operational programs may be taking place while the plant remains under construction, yet the applicable cornerstones have not transitioned to the ROP.

19

Attachment Watts Bar 2 Construction Oversight Lessons Learned Working Group Charter A-i

I UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 June 26, 2017 MEMORANDUM TO: William B. Jones, Director Division of Construction Oversight FROM: Laura A. Dudes, Deputy Regional Administrator for Construction Office of the Regional Administrator IRN

SUBJECT:

WATTS BAR UNIT 2 CONSTRUCTION INSPECTION AND OVERSIGHT LESSONS-LEARNED This memorandum transmits the enclosed Waifs Bar Unit 2 Construction Inspection and Oversight Lessons-Learned Working Group Charter. The Working Group (WG) is comprised of inter-office staff that have broad knowledge of the construction inspection and assessment programs as implemented under 10 CFR Part 50 and Part 52. The purpose of the Working Group is to assess the U.S. Nuclear Regulatory Commissions (NRCs) construction oversight and inspection actMties at Watts Bar 2 and identify lessons learned from that project that can be used to further enhance our construction oversight and inspection activities going forward for both 10 CFR Part 50 and 10 CFR Part 52 facilities.

As the lead for the assessment, you should ensure the WG focuses on the different aspects of the construction inspection programs, included in the Construction Reactor Oversight Process (cROP) through the transition to the Reactor Oversight Process (ROP). This will include development and implementation of the IMC 2517, Watts Bar Unit 2 Construction Inspection Program, and the transition to IMC 2515, Light Water Inspection Program-Operations Phase.

The lessons-learned should include, for example those attributes that made the development of the Inspection, Planning and Scheduling (IPS) for Watts Bar Unit 2 under IMC 2517 effective and areas to focus on to improve any future implementation. Addressing the different areas in the March 9, 2017, staffs Watts Bar Lessons Learned Memorandum (ML17067A458), in this context should provide guidance for any future 10 CFR Part 50 new or reactivation activities.

You are also to consider the ongoing 10 CFR Part 52 oversight and inspection activities and provide a comparison to the lessons-learned from Watts Bar Unit 2 as a separate attachment for follow up by the Region II Division of Construction Oversight and other divisions within the NRC as applicable.

In addition to the members in your group, Headquarters or Regional support will be provided to you, as requested. The WG should provide a written report to the Region II, Regional Administrator, by August 25, 2017, which at a minimum documents the areas for improvement, their bases, and any WG recommendations.

CONTACT: Laura A. Dudes, ORA (404) 997-4472

W. Jones 2 Documentation of the recommendations should be completed in accordance with Exhibit 2, Effectiveness Review Report Template, of Management Directive 6.8 Lessons-Learned Program. Region II DCO will ensure that program office recommendations are submitted to the appropriate contact.

Enclosure:

1. Watts Bar Unit 2 Construction Inspection and Oversight Lessons-Learned Working Group Charter

Watts Bar Unit 2 Construction Inspection and Oversight Lessons Learned Working Group Charter PURPOSE The purpose of this working group (WG) is to assess the U.S. Nuclear Regulatory Commission (NRC) Watts Bar Unit 2 construction inspection and assessment reactivation through power operation. Lessons learned through this initiative shall consider specific insights into the different areas identified in the staffs March 9, 2017, Watts Bar Lessons Learned Memorandum (ML17067A458) and to identify areas to emphasize. This lessons-learned review should evaluate the NRCs construction inspection and oversight implementation for the effectiveness of the programs and processes, highlight actions that contributed to the effectiveness of program implementation and areas to specifically emphasize where improvements can be made in keeping with the NRCs Principles of Good Regulation (Independence, Openness, Efficiency, Clarity, and Reliability).

The WGs review should also consider the inspection and oversight program implementation for the AP-1000 plants as compared to the lessons-learned from Watts Bar Unit 2. Specific areas of focus will be provided as a separate attachment for follow up by the Region II Division of Construction Oversight.

WORKING GROUP MEMBERSHIP The WG will be led by Mr. Jason Eargle, Senior Construction Inspector, Division Construction Oversight (DCO). The other full time members are Mr. Phil OBryan, Division of Construction Inspection and Operational Programs (DCIP), and Mr. Steven Campbell, Division of Inspection and Regional Support (DIRS).

SCOPE The WG should focus on the different aspects of the Watts Bar Unit 2 construction program development, through the transition of program responsibilities to operating reactors. The staffs March 9, 2017, Watts Bar Lessons Learned Memorandum provides insights into the program implementation areas of Organization, Construction Inspection, Testing, and Transition. The WG should utilize applicable inspection manual chapters (IMCs), including IMC 2517, Watts Bar Unit 2 Construction Inspection Program, IMC 2515, Light-Water Reactor Inspection Program Operations Phase, and those related to the 10 CFR Part 52 Light Water Reactor Inspection Program. This comparison will inform the lessons-learned, and identify areas for follow-up separate to this WGs activities.

PROCESS The WG should remain focused on the implementation of the inspection and oversight programs at Watts Bar Unit 2. A comparison to the inspection and oversight program implementation at the AP-1 000 facilities should be conducted to identify areas for consideration by Region IIs DCO and NRO as needed. Duplication of work already in process or completed as part of other efforts should be avoided. This specific assessment may include vertical slice reviews of the major inspection activities, planning processes and resource loading implemented at WB2 using the staffs lessons-learned and other background information. Vertical slice reviews are examinations of the portions of the requirements, policies, procedures or guidance applicable to the specific actions considered significant within this assessment. WG observations that are Enclosure

2 best suited for incorporation into other oversight programs such as the Reactor Oversight Self-Assessment or the Construction Reactor Oversight Process Self-Assessment, should be coordinated and submitted for such consideration.

DOCUMENTATION The WG should provide a written report to the Region II, Regional Administrator, by August 25, 2017, which at a minimum documents the WG recommendations. Documentation should be completed in accordancewith Exhibit 2, Effectiveness Review Report Template, of Management Directive 6.8 Lessons-Learned Program, and submitted to the contact for that program. The report will be made publically available.

ML17192A031 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:ORA I SIGNATURE LAD I NAME L. Dudes I DATE 06/26/2017 I