ML19056A212

IMC 2504 Construction Inspection Program: Inspection of Construction and Operational Programs

ML19056A212
Person / Time
Issue date:	04/02/2019
From:	Michael Webb NRC/NRO/DCIP/CIPB
To:
Webb M, NRO/DCIP
Shared Package
ML19053A793, ML19092A025	List:
References
CN 19-012 IMC 2504
Download: ML19056A212 (25)

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NRC INSPECTION MANUAL CIPB INSPECTION MANUAL CHAPTER 2504 CONSTRUCTION INSPECTION PROGRAM:

INSPECTION OF CONSTRUCTION AND OPERATIONAL PROGRAMS

TABLE OF CONTENTS 2504-01 PURPOSE ............................................................................................................ 1 2504-02 OBJECTIVES ....................................................................................................... 1 2504-03 APPLICABILITY.................................................................................................... 1 2504-04 DEFINITIONS ....................................................................................................... 2 2504-05 RESPONSIBILITIES AND AUTHORITIES ............................................................ 2 05.01 Director, Office of New Reactors (NRO) ........................................................... 2 05.02 Regional Administrator, Region II .................................................................... 2 05.03 Construction Inspection Staff, Region II ........................................................... 2 05.04 Director, Division of Construction Inspection and Operational Programs, NRO (NRO/DCIP) .................................................................................................. 3 05.05 Regional Administrator, Host Region ............................................................... 3 05.06 Director, Office of Nuclear Reactor Regulation (NRR) ....................................... 3 2504-06 REQUIREMENTS ................................................................................................. 3 06.01 Construction Programs................................................................................... 3 06.02 Operational Programs .................................................................................... 3 06.03 Manual Chapter Completion ........................................................................... 3 06.04 Status of Operational Programs ...................................................................... 3 06.05 Inspection Findings & Enforcement ................................................................. 4 06.06 Transition to Host Region Inspection Activities ................................................. 4 06.07 Response to Significant Issues or Events ........................................................ 4 2504-07 GUIDANCE ........................................................................................................... 4 07.01 Construction Programs................................................................................... 4 07.02 Operational Programs .................................................................................... 4 07.03 Manual Chapter Completion ........................................................................... 5 07.04 Status of Operational Programs ...................................................................... 6 07.05 Inspection Findings and Enforcement .............................................................. 6 07.06 Transition to Host Region Inspection Activities ................................................. 7 07.07 Response to Significant Issues or Events ........................................................ 7 07.08 Witnessing Unsafe Situations ......................................................................... 7 2504-08 REFERENCES ..................................................................................................... 8 Appendix A Inspection of Construction Programs Appendix B Inspection of Operational Programs Appendix C Response to Significant Issues or Events Revision History for Inspection Manual Chapter (IMC) 2504 Issue Date: 04/02/19 i 2504

2504-01 PURPOSE 01.01 To specify the inspection policies for reviewing the construction programs not directly related to Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) that support construction of a plant licensed in accordance with 10 CFR Part 52.

01.02 To specify the inspection policies to assess whether a licensee conforms to and correctly implements the preoperational testing portion of the Initial Test Program (ITP) contained in the Final Safety Analysis Report (FSAR).

01.03 To specify the inspection policies for reviewing the operational programs described in the FSAR, for a plant licensed in accordance with 10 CFR Part 52.

01.04 To provide the input by which the staff will inform the Commission of the status of the operational programs before the anticipated date for loading fuel.

2504-02 OBJECTIVES 02.01 To assess whether the licensee has implemented construction programs that address quality assurance (QA), including corrective action for conditions adverse to quality, reporting of defects and failures to comply in accordance with 10 CFR 50.55(e), fitness for duty (FFD), and a process for completion and closure of ITAAC.

02.02 To evaluate the operational programs listed in the licensees FSAR.

02.03 To determine the status of the operational programs before the anticipated date for loading fuel.

02.04 To determine the adequacy of the preoperational testing portion of the ITP conducted by the licensee.

2504-03 APPLICABILITY This phase of the construction inspection program (CIP) will become effective upon issuance of a combined license (COL) or Limited Work Authorization (LWA). This manual chapter remains effective until inspection of the operational programs has been completed.

The CIP includes those inspection activities directed toward assessing a licensees construction and operational programs (including preoperational testing). Start-up Testing activities will be assessed under Inspection Manual Chapter 2514, Light Water Reactor Inspection Program -

Start-up Testing Phase. This manual chapter will be performed in parallel with, but independent of, IMC 2503, Construction Inspection Program: Inspections of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Related Work. All inspections directly related to ITAAC activities will be performed under IMC 2503. IMC 2504 inspections will involve the inspection of QA activities affecting systems, structures, and components (SSCs) that are installed in the plant, thereby having the potential to impact ITAAC. Therefore, ITAAC will be indirectly evaluated by programmatic inspections (such as those of the QA program) because such programs affect the quality of the SSCs that are the subject of the ITAAC.

Issue Date: 04/02/19 1 2504

The general requirements identified in this IMC are applicable to all COL designs. However, the detailed inspection procedures to be implemented may differ, depending upon the type of plant design contained in the COL.

2504-04 DEFINITIONS Applicable definitions are found in Inspection Manual Chapter 2506, Construction Reactor Oversight Process General Guidance and Basis Document.

2504-05 RESPONSIBILITIES AND AUTHORITIES 05.01 Director, Office of Nuclear Reactor Regulation (NRR)

a. Informs the Commission of the operational readiness of the plant and implementation status of the operational programs to support loading of fuel.

b. Concurs, along with the host region Regional Administrator, with the decision of the Regional Administrator, Region II, to allow a plant to transition to the oversight of the host region.

05.02 Regional Administrator, Region II

a. Provides overall direction for the implementation of the construction inspection program for all new construction sites.

b. Informs the Director, NRR, when the inspection staff has completed inspections of required operational programs.

c. Provides an assessment of the overall operational readiness to load fuel to the Director, NRO.

d. Makes the decision, with the concurrence of the Director, NRR; and the host region Regional Administrator, to allow a plant to transition to the oversight of the host region.

05.03 Construction Inspection Staff, Region II

a. Implements the CIP.

b. Coordinates development and review of the site-specific inspection plan and schedule (IP&S).

c. Ensures that inspections are promptly and properly documented.

d. Periodically assesses inspection findings in accordance with IMC 2505, Periodic Assessment of Construction Inspection Program Results.

Issue Date: 04/02/19 2 2504

05.04 Director, Division of Construction Inspection and Operational Programs, NRO (NRO/DCIP)

a. Provides overall program direction for the construction inspection program.

b. Develops and directs the implementation of policies, programs, and procedures for the construction inspection program.

Note: This function will transfer to NRR following the anticipated 2019 NRO/NRR merger.

05.05 Regional Administrator, Host Region

a. Provides support, as necessary, to the construction inspection staff, Region II, to conduct inspections of construction and operational programs.

b. Concurs, along with the Directors, NRO and NRR, with the decision of the Regional Administrator, Region II, to allow a plant to transition to oversight by the host region.

05.06 Director, Office of Nuclear Reactor Regulation (NRR)

Concurs, along with the Director, NRO, and the host region Regional Administrator, with the decision of the Regional Administrator, Region II, to allow a plant to transition to oversight by the host region.

2504-06 REQUIREMENTS 06.01 Construction Programs The NRC staff will perform inspections to evaluate the licensees construction programs listed in Appendix A of this IMC. These inspections will verify the programs have been developed and implemented by the licensee as described in its COL and updated FSAR as approved by the staff in its safety evaluation report, and that they meet regulatory requirements and licensee commitments.

06.02 Operational Programs The NRC staff will perform inspections to evaluate the Operational Programs listed in Appendix B of this IMC. These inspections will verify that the licensee has developed and implemented the programs in its COL and updated FSAR. It will also verify that the programs meet regulatory requirements and licensee commitments.

06.03 Manual Chapter Completion This IMC is completed when the staff has conducted each of the IPs in Appendix A, Construction Programs, and Appendix B, Operational Programs.

06.04 Status of Operational Programs Region II will use the results of the inspections conducted under this manual chapter as an input Issue Date: 04/02/19 3 2504

into the status of the operational programs to be reported to the Commission before the anticipated date for loading fuel, as discussed in SECY-06-0114, Description of the Construction Inspection Program for Plants Licensed Under 10 CFR Part 52. This status should be consistent with the requirements of combined NRR and NRO Office Instruction LIC-114 (NRR) / REG-106 (NRO), Title 10 of the Code of Federal Regulations (10 CFR) 52.103(g) Finding and Communication Process.

06.05 Inspection Findings & Enforcement For inspection findings associated with construction or operational programs identified prior to the 10 CFR 52.103(g) finding, Region II will evaluate the inspection findings in accordance with IMC 0613, Construction Inspection Reports, and IMC 2519, Construction Significance Determination Process. Those findings associated with operational programs identified after the 10 CFR 52.103(g) finding will be evaluated in accordance with IMC 0612, Issue Screening, and IMC 0609, Significance Determination Process.

06.06 Transition to Host Region Inspection Activities Region II will coordinate operational program inspection planning and IP completion with the host region for operational programs that have not achieved operational program inspection completion at the time of the 10 CFR 52.103(g) finding.

06.07 Response to Significant Issues or Events Region II construction inspection staff must be prepared to provide input to the joint decision between Region II, the host region (if applicable) and NRR in the circumstance that unplanned, potentially significant, issues or events arise.

2504-07 GUIDANCE This section provides guidance for implementing the inspection of the construction and operational programs portions of the construction inspection program. It establishes uniform inspection methodology and leaves sufficient latitude for the construction inspection staff to optimize the use of inspection resources. This manual chapter defines the inspection program for the evaluation of the licensee's construction programs, including QA, ITAAC maintenance, and FFD; operational programs; and preoperational testing. In addition, both Appendices A and B also include IPs, 92701, Follow-up, and 92702, Follow-up on Corrective Actions for Violations and Deviations, to conduct follow-up inspection activities.

07.01 Construction Programs

a. Appendix A of this IMC lists each construction program and the corresponding inspection procedure(s) that must be completed to complete this manual chapter.

b. The inspection of the licensees construction programs will cover both the programmatic elements and implementation using the IPs provided in Appendix A of this IMC.

07.02 Operational Programs Issue Date: 04/02/19 4 2504

a. Appendix B of this IMC lists each operational program and the corresponding inspection procedure(s) that must be used to determine whether the operational programs developed by the licensee conform to the program described by the licensee in its COL and updated FSAR and approved by the staff in its safety evaluation report and that they meet regulatory requirements and licensee commitments.

b. The approach to inspection of operational programs reflects the staff positions detailed in SECY-05-0197, Review of Operational Programs in a Combined License and General Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria. The goal of the inspections conducted under this manual chapter is to determine whether the licensee has developed and implemented operational programs that conform to the program described by the licensee in its COL and updated FSAR and that they meet regulatory requirements and licensee commitments. The results of these inspections will be used to inform the Commission of the status of those programs before the anticipated date for loading fuel.

c. At sites with an operating unit where the licensee has chosen to take credit for similar operational programs as those that are already in use (e.g., corrective action program, radiation protection program, etc.), the inspectors shall focus on the differences between the program already in use and the newly developed program.

The operational program inspection should be limited to those steps in the IMC 2504 inspection procedures where the inspectors cannot verify that the operational program is the same or similar to the program being implemented at the operating unit.

d. Similar aspects among the various operational programs may allow the construction inspection staff to adjust the level of inspection of some operational programs based on the inspection results for programs already reviewed (e.g., Process and Effluent Monitoring, Liquid Waste Management, and Gas Waste Management). In these circumstances, the overlapping inspections should be completed and documented simultaneously. If the overlap is identified after the inspection has already taken place, the remaining uncompleted step(s) could be documented in the report by referring to the applicable input from a previous report.

e. The staff developed Inspection Manual Chapter, IMC 2200 (Official Use Only -

Security Related Information), Security Inspection Program during Construction, which specifically describes inspection policy for the security inspection program.

f. ITAAC inspection samples performed under IMC 2503 should be credited for IMC 2504 inspections if the IMC 2504 IP has similar sample requirements.

07.03 Manual Chapter Completion This IMC is completed when each of the IPs in Appendix A, Construction Programs, and Appendix B, Operational Programs, have been completed.

Issue Date: 04/02/19 5 2504

a. Construction Programs - Appendix A: Inspection of these programs will be completed when the corresponding IPs have been completed. This can be accomplished in one of two different ways depending on the specific IP.

1. IPs with periodic or cyclic inspection requirements - complete when there are no remaining open issues and the 10 CFR 52.103(g) finding memorandum has been issued (e.g. QA & FFD).

Or

2. IPs with a defined sample size (e.g., ITAAC Management and Preoperational Testing) - complete when inspection of the samples specified in the IP is complete.

b. Operational Programs - Appendix B: Inspection of these programs will be completed when the relevant IPs for a given operational program have been completed. If an inspector is performing an inspection after program implementation and is unable to perform IP steps at the time of inspection because the program requirements for those IP steps are not applicable at that point of construction/operation, then those IP steps need not be performed in order to complete the IP. Some operational programs have implementation milestones after the 10 CFR 52.103(g) finding. Therefore, licensees may not have developed and implemented some operational programs at the time of the 10 CFR 52.103(g) finding, and it may not be practical to complete operational program inspections for those operational programs with implementation milestones shortly before, or after, the 10 CFR 52.103(g) finding. The staff will turn over those inspections to the host region to be completed as part of the Reactor Oversight Process inspection program.

07.04 Status of Operational Programs

a. SECY-06-0114, Description of the Construction Inspection Program for Plants Licensed Under 10 CFR Part 52, states that the staff intends to inform the Commission of the status of the operational programs before the anticipated date for loading fuel.

b. The staff will report the status to the Commission in accordance with Combined NRR and NRO Office Instruction NRR-LIC-114 / NRO-REG-106, Title 10 of the Code of Federal Regulations (10 CFR) 52.103(g) Finding and Communication Process, which includes a discussion of the status of inspection activities, including those of operational programs. Appendix A to the Office Instruction provides the content to be included in a memorandum from the Director, NRR, to the Commission, the subject of which is Status of ITAAC Closure, Inspection, and Licensing Activities.

The Status of Inspection Activities section of the memorandum states that an enclosure lists the operational programs, their implementation dates, and NRC inspections associated with the implementation of these programs.

07.05 Inspection Findings and Enforcement

a. IMC 0613 will be used to process and document all findings and violations prior to the 10 CFR 52.103(g) finding. Findings identified after the10 CFR 52.103(g) finding Issue Date: 04/02/19 6 2504

associated with operational programs will be dispositioned using the SDP in IMC 0612, Issue Screening. All findings identified after the 10 CFR 52.103(g) finding will be assigned to the ROP cornerstone most closely related to the finding.

b. The NRC will inform the licensee of all inspection findings of inspections conducted under this manual chapter whether identified for onsite construction activities or for offsite fabrication activities.

07.06 Transition to Host Region Inspection Activities

a. Inspections of operational programs pursuant to this Manual Chapter prior to the 10 CFR 52.103(g) finding will be conducted by Region II inspectors or the host region, as determined by Region II. Certain operational programs have implementation milestones that will occur just prior to, or after, the 10 CFR 52.103(g) finding. Therefore, the required inspections of these operational programs may be completed after the 10 CFR 52.103(g) finding, depending on the licensees readiness for the inspections. Inspections of operational programs after the 10 CFR 52.103(g) finding will be conducted using the applicable inspection procedures in IMC 2504 or the applicable ROP IP. The operational program findings identified after the 10 CFR 52.103(g) finding will be assigned to the ROP cornerstone that is most closely related to the finding, and significance of the finding will be considered for determining the appropriate ROP Action Matrix column in accordance with IMC 0305.

b. A major focus of the construction inspection program is on licensee work being performed in support of ITAAC closure, which the staff inspects in accordance with IMC 2503. Completion of ITAAC supports the Commission in making the finding, required by 10 CFR 52.103(g), on whether the acceptance criteria in the COL have been met. The 10 CFR 52.103(g) finding represents the transition point (milestone) where the IMC 2503 will end and IMC 2514, AP1000 Reactor Inspection Program -

Startup Testing Phase will be implemented. IMC 2504 will remain in effect until the inspection of all the Operational Programs listed in Appendix B has been completed.

c. The transfer of the new plant to oversight by the host region will require the written approval of the Regional Administrator Region II, with the concurrence of the Director, NRR, and the host region Regional Administrator.

07.07 Response to Significant Issues or Events During construction, the NRC staff may need to respond to any number of events at the site. Appendix C provides the decision-making process for Regional and Headquarters staff to use in planning how to respond appropriately when potentially significant issues or events occur. Due to the large number of possible issues or events to which the NRC may need to respond, no specific guidance is provided on how to respond in any given situation. Rather, only general guidance is provided and the decision of how, and if, to respond will be made as a joint decision between Region II, the host region (if applicable), and NRR.

07.08 Witnessing Unsafe Situations When NRC personnel identify unsafe work practices or violations that could lead to an Issue Date: 04/02/19 7 2504

unsafe situation, they shall make every reasonable attempt to prevent them from occurring or continuing in their presence. When an inspector identifies such situations, the inspector shall promptly notify a licensee representative so that corrective or preventive measures can be taken. A goal of the NRC inspection program is to witness licensee activities in as close to a normal environment as possible. From the assessment of these observations, inspectors will draw conclusions relative to the licensee's ability to properly conduct licensed activities. Notwithstanding this goal, under no circumstances will an NRC inspector knowingly allow an unsafe work practice or a violation which could lead to an unsafe situation to occur or continue in his/her presence in order to provide a basis for enforcement action. If such a work practice or violation is in progress, or about to occur, the NRC inspector shall immediately bring the situation to the attention of the appropriate licensee personnel. This action shall be taken without regard for any impact it may have on the ability of the NRC to take future enforcement action.

2504-08 REFERENCES 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants" Inspection Manual Chapter (IMC) 0612, Issue Screening IMC 0613, Power Reactor Construction Inspection Reports IMC 2200, Security Inspection Program during Construction (Official Use Only - Security Related Information)

IMC 2503, Construction Inspection Program: Inspections of Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) Related Work IMC 2505, Periodic Assessment of Construction Inspection Program Results IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document IMC 2514, AP1000 Reactor Inspection Program - Startup Testing Phase IMC 2519, Construction Significance Determination Process LIC-114 (NRR) / REG-106 (NRO), Title 10 of the Code of Federal Regulations (10 CFR) 52.103(g) Finding and Communication Process.

SECY-05-0197, Review of Operational Programs in a Combined License and General Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria SECY-06-0114, Description of the Construction Inspection Program for Plants Licensed under 10 CFR Part 52 END Issue Date: 04/02/19 8 2504

Appendix A, Inspection of Construction Programs Appendix B, Inspection of Operational Programs Appendix C, Response to Significant Issues or Events : Revision History for IMC 2504 Issue Date: 04/02/19 9 2504

APPENDIX A INSPECTION OF CONSTRUCTION PROGRAMS This Appendix lists the Inspection Procedures (IPs) to be used when reviewing the licensee construction programs.

CONSTRUCTION PROGRAM INSPECTIONS Program Requirement IP No. IP Title 50.54(a)

Quality Assurance Program Quality Assurance 50.55(f) 35007 Implementation during Construction (QA) - Construction Part 50, and Pre-Construction Activities Appendix B Reporting Defects Inspection of 10 CFR 50.55(e) and Noncompliance - 50.55(e)(3) 36100.01 Programs for Reporting Defects and Construction Noncompliance during Construction Licensee Program for Inspections, ITAAC Management 52.99 40600 Tests, Analyses and Acceptance Criteria (ITAAC)

Fitness for Duty Program for Security (including Part 26, 81504 Construction Fitness for Duty - Subpart K Protection of Safeguards Information Construction) 73.55(b) 81505 for Construction Inspection of Preoperational Test Preoperational 70367 50.34 Program Testing portion of 52.79(a)(28) Inspection of Preoperational Test Initial Test Program 70702 Performance 92701 Followup Inspection Followup Followup on Corrective Actions for 92702 Violations and Deviations Issue Date: 04/02/19 AppA-1 2504

APPENDIX B INSPECTION OF OPERATIONAL PROGRAMS This Appendix lists the Inspection Procedures (IPs) to be conducted to determine the status of operational programs.

OPERATIONAL PROGRAM INSPECTIONS Program Requirement IP No. IP Title Part 52, Preservice and Inservice 73054 Inspection - Review of Program 73754 Part 52 - Preservice Inspection - Non-Preservice Inspection /

50.55a(g) Destructive Examination Inservice Inspection Part 52, Preservice Inspection - Data 73757 Review and Evaluation Part 52, Functional Design and Qualification, and Preservice and Inservice Testing Programs for Inservice Testing 50.55a(f) 73758 Pumps, Valves and Dynamic Restraints Part 52 Environmental Qualification Environmental 50.49 51080 (EQ) Under 10 CFR 50.49 Qualification Reactor Vessel Material Reactor Vessel Material Surveillance 50.60, App. H 50054 Surveillance Program Part 52, Functional Design and Qualification, and Preservice and Inservice Testing Programs for Preservice Testing 50.55a(f) 73758 Pumps, Valves and Dynamic Restraints Containment Leak Rate Part 52 Containment Leakage Rate 50.54(o) 70368 Testing Testing Program (Programmatic)

Issue Date: 04/02/19 AppB-1 2504

OPERATIONAL PROGRAM INSPECTIONS Program Requirement IP No. IP Title Part 52, Fire Protection Operational Fire Protection 50.48 64705 Program Part 52, Solid Waste Management 84527 System Part 52, Liquid Waste Management 84528 Program Part 52, Gaseous Waste 84529 Management Program Process and Effluent 50.34(b)(3), Part 52, Radiological Environmental Monitoring Part 50, App. I 80522 Monitoring Program (REMP)

Part 52, Offsite Dose Calculation 83746 Manual (ODCM)

Part 52, Life Cycle Minimization of 83531 Contamination and Groundwater Protection Program Part 52, External Occupational 83533 Exposure Control and Personal Dosimetry 83534 Part 52, Internal Exposure Control Radiation Protection Part 20, Part 52, Control of Radioactive Subpart B 83535 Materials and Contamination, Surveys, and Monitoring 83536 Part 52, Facilities and Equipment Part 52, Maintaining Occupational 83537 Exposures ALARA Non-licensed Plant 50.120 Part 52, Review of Training and 41501 Staff Training Program 52.79(a)(33) Qualification Programs 52.79(a)(33), Part 52, Review of Training and 41501 Reactor Operator 55.13, 55.31, Qualification Programs Training 55.41, 55.43, Nuclear Power Plant Simulation 41502 55.45 Facilities Reactor Operator 52.79(a)(34) 71111.11 Licensed Operator Requalification Requalification 50.34(b) Part 52, Review of Training and 50.54(i) 41501 Qualification Programs Issue Date: 04/02/19 AppB-2 2504

OPERATIONAL PROGRAM INSPECTIONS Program Requirement IP No. IP Title 55.59 Nuclear Power Plant Simulation 41502 Facilities 50.34(b)(6)(v),

50.47, Emergency Part 52, Emergency Preparedness 50.54(q), 82002 Preparedness Program 50.54(t) 50.34(c) Security Inspection Program for IMC 2200 Security (including 50.34(d) Construction training, vehicle and 50.34(e) 71130 Attachment .08 personnel access 50.54(p)(1) 81000 Attachments .01 - .11 and .14 control, FFD, 50.54(v) safeguards Part 26, contingencies, cyber Subpart K Fixed Site Physical Protection of security, SNM Material 73.54(b) 81431 Special Nuclear Material of Low Control and Accounting, Part 74, Strategic Significance and Part 37) Subpart B Part 37 QA Program Implementation 35101 Inspection for Operational Programs Inspection of 10 CFR Part 21 and Part 21 36100 Programs for Reporting Defects and 50.54(a) Noncompliance Quality Assurance 36302 Part 52, Operational Staffing Part 50, (Operation)

Appendix B 42401 Part 52, Plant Procedures Part 52, Operating Procedures 42453 Inspection 42454 Part 52, Emergency Procedures Maintenance Rule 50.65 62712 Part 52, Maintenance Rule Part 52, Functional Design and Qualification, and Preservice and Inservice Testing Programs for Motor-Operated Valves 50.55a(b)(3)(ii) 73758 Pumps, Valves and Dynamic Restraints Issue Date: 04/02/19 AppB-3 2504

OPERATIONAL PROGRAM INSPECTIONS Program Requirement IP No. IP Title 50.34 Startup Testing portion Part 52, Inspection of Startup Test 52.79(a)(28) 72401 of Initial Test Program Program 92701 Followup Inspection Followup Followup on Corrective Actions for 92702 Violations and Deviations Issue Date: 04/02/19 AppB-4 2504

APPENDIX C RESPONSE TO SIGNIFICANT ISSUES OR EVENTS The purpose of this Appendix is to provide a structured decision-making process for Regional and Headquarters staff to use in planning how to respond appropriately when potentially significant, issues or events occur at reactor construction sites.

Because fuel has not yet been loaded into the reactor and there is no spent fuel, deterministic criteria should be used to determine how and when to respond to issues/events at reactor construction sites. Therefore, these incidents will be examined solely against deterministic criteria when deciding on the appropriate level of response. In addition, factors such as openness, public interest, and public safety should be appropriately considered when deciding whether to dispatch a Special Inspection (SI) or Augmented Inspection Team (AIT) (it is not envisioned that an Incident Investigation Team (IIT) would be appropriate for issues/events at reactor construction sites due to the low likelihood of public safety consequence). Management Directive 8.3, NRC Incident Investigation Program, defines the authorities, responsibilities, and basic requirements of personnel investigating significant operational events. Management Directive 8.3 also characterizes the differences between an AIT, SI and IIT.

An AIT consists of technical experts augmented by personnel from headquarters or other regions or by contractors as necessary and performs an inspection of a significant, issue or event. AIT members may have had prior involvement with licensing and inspection activities at the affected facility. The AIT reports directly to the RII Deputy Regional Administrator for Construction (DRAC) (or designee). An SI is similar to an AIT inspection except that the group generally is smaller (the number of members is based on management's judgment) and is not generally augmented by personnel from headquarters or other regions or by contractors. The SI reports directly to the RII Director of Construction Projects (or designee). Regardless of the type of inspection (SI or AIT) the results should be documented in accordance with IMC 0613, Documenting 10 CFR Part 52 Construction and Test Inspections. The guidance in Part III of Management Directive 8.3, NRC Incident Investigation Program, for AITs should be followed to the extent practical. This guidance can also be used, in part, for SIs. For both AITs and SIs a charter should be issued to the team leader and should include guidance on what inspection procedure(s) are to be used.

Because of the large number of possible issues/events that the NRC may need to respond to during construction no specific guidance is provided on how to respond in any given situation.

Rather, only general guidance is provided and the decision of how, and if, to respond will be made as a joint decision between Region II and the program office. The decision to dispatch an SI or AIT is a management decision that should be based on the specific circumstances and how significant and/or complex the issue or event is and considering all available information.

These factors will determine if a response is warranted and whether it should be an SI or AIT.

Additionally, the interests of stakeholders, such as the public and local communities, needs to be considered.

Upon notification of a potentially significant, issue or event, the Region II staff should perform the initial review to assess the significance of the issue or event in order to assess the level of response required. Region II staff should also ensure that the appropriate headquarters project manager (PM) is aware of the issue or event.

Issue Date: 04/02/19 AppC-1 2504

Following the staffs review, Region II management should be briefed on the outcome. If the initial review indicates that the issue or event warrants at most consideration of an SI (based on the deterministic criteria listed below), the Region II Regional Administrator (RA) makes the decision on whether or not to initiate an SI. In this case, regional management may consult with the program office and the Office of Nuclear Security and Incident Response (NSIR) but are not required to do so.

If the event or issue meets one or more of the AIT deterministic criteria this should be communicated to the appropriate PM so that program office management can be briefed on the issue or event. The PM will coordinate with the appropriate NRO technical branches. If the issue or event has security-related aspects then the Division of Preparedness and Response (DPR) in NSIR should be consulted. The RA shall consult with the Director of the program office to decide if an SI or an AIT response is appropriate using their collective judgment and available information.

Figure 1 shows the flow of communication among the participating staff organizations and the decision making points.

The following are the deterministic criteria to be used in evaluating what type of response, if any, is appropriate:

Any significant weather-related event or natural disaster (hurricanes/tornados, earthquakes, fire, flooding, etc.) or human error that may have significant impact on structures, systems, and components (SSCs) or other program elements with the Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) that are in some phase of construction (ongoing or completed). The staff should consider the use of either an SI or AIT depending on the type and amount of damage the facility sustained. The purpose of either would be to monitor and assess the licensees actions to recover damaged or potentially damaged SSCs with ITAAC. If the event involves the loss or damage of special nuclear material (SNM) or sources, coordination with state and local governments should be part of the response and should generally result in an AIT. A review of the licensees implementation of their emergency plan should be accomplished as appropriate to the circumstances.

Any significant security-related issues (loss or theft of SNM, potential tampering/sabotage, multiple fitness-for-duty (FFD) issues, etc.). Either an SI or AIT should be considered depending on the complexity and significance of the issue. Issues such as the loss or theft of SNM or confirmed tampering or sabotage should generally result in an AIT. Issues such as potential tampering, multiple FFD issues, or an unauthorized, actual discharge of a weapon should generally result in an SI.

Onsite accidents resulting in significant damage to SSCs having ITAAC (e.g., crane collapse, train or other significant vehicle accident). Consideration of either an SI or AIT is appropriate depending on the type and amount of damage sustained. As with responses to weather or man-made events discussed above the purpose of either would be to monitor the licensees recovery from damaged SSCs with ITAAC.

Significant offsite or onsite industrial events that impact the site (e.g., hazardous chemical spill, nearby chemical plant or refinery fire, etc.). An SI may be appropriate if there is a possibility of significant impact on constructed items or materials.

Issue Date: 04/02/19 AppC-2 2504

Consideration of whether or not airborne chemical fumes could have an adverse impact on SSCs or other program elements with ITAAC or material in storage should be given.

For instance, chlorine gas that comes in contact with stainless steel items may be detrimental. The purpose of the inspection would be to ensure that the licensee has conducted an adequate evaluation of any potential impacts, including extent of condition.

Generally, an AIT would not be warranted. A review of the licensees implementation of their emergency plan should be accomplished as appropriate to the circumstances.

Stop work order issued by the licensee for which the underlying issue(s) are not already fully understood. The use of an SI may be appropriate to ensure that the NRC fully understands the underlying issues. Generally, an AIT would not be warranted.

Plant strike. The use of an SI may be appropriate to review and/or monitor licensee actions to ensure that malicious mischief is not taking place that could impact the quality of construction. Generally, an AIT would not be warranted.

Potential financial impact on programs or quality of work. Augmented review of the licensees quality oversight of construction activities with an SI may be appropriate to determine if degradation of quality or programs is occurring. Inspection or review of the licensees finances is not appropriate. Generally, an AIT would not be warranted.

Significant safety conscious work environment (SCWE) issues or allegations which do not have a specific performance aspect that could be addressed thorough the IMC 2505 process or independent licensee action. The use of an SI may be appropriate.

Generally, an AIT would not be warranted.

Any significant issue(s) not covered by the above that in the judgment of management warrants additional inspection or oversight. The use of an SI may be appropriate.

Generally, an AIT would not be warranted.

Table 1 provides a summary outline of the different possible issues orevents that could occur at a reactor construction site and the possible response level for each.

Because many new reactors under construction are co-located next to an operating facility appropriate coordination between inspectors responding to an event that impacts both a construction site and operating site is needed. Coordination is important to ensure that any response to an event at a construction site does not have an adverse impact on the operating site. Also, because a number of the possible types of events discussed above are likely to have impacted the operating facility close coordination with the Division of Reactor Projects (DRP) in the appropriate region is important so that resources are used in an efficient manner.

Inspectors responding to an event at a construction site also need to be sensitive to looking for any potential impacts to the operating facility and promptly communicating those to the operating facilities resident inspector staff.

Exhibit 1 provides a form for regional personnel to use when documenting their decision whether or not to pursue a reactive inspection based on evaluation of the deterministic criteria listed above. This form should be completed once a response decision is made but can be completed while the decision process is ongoing. As noted in Exhibit 1, Region II may customize the form in order to fit regional protocols, but the deterministic criteria should not be Issue Date: 04/02/19 AppC-3 2504

changed. The form, along with specific instructions for its completion by regional staff, should be included in regional office instructions or implementing procedures. Basic guidelines include:

If none of the deterministic criteria were met, briefly document the key points of discussion in the Remarks section of the criteria that were the principal focus areas.

Also, state that no deterministic criteria were met in the Response Decision section of the form.

If one or more of the deterministic criteria were met, briefly indicate the basis for each in the Remarks section of the applicable criteria.

Use the Response Decision section to provide the basis for deciding whether or not to conduct an inspection, and which level of inspection is recommended as specified in the guidance in this procedure. Document the decision by placing the evaluation results in ADAMS. Then generate an e-mail to the Director, Division of Construction and Operational Programs, Office of New Reactors with the unique ADAMS Accession Number. This will notify headquarters staff of the regions intentions and will allow for process tracking.

Whenever an SI or AIT is planned, the region should also notify the licensee of its intentions once a final decision is made.

Issue Date: 04/02/19 AppC-4 2504

Exhibit 1 to Appendix C- Decision Documentation for Significant Issues or Events At Reactor Construction Sites Figure 1: Flow Chart for Deciding an SI or AIT Project Manager Program Office Program Office Management Director Significant Technical event/issue DPR/NSIR requiring Branches DPR/NSIR SI Management Director consideration of AIT an SI or AIT Regional Administrator Region II Staff Region II Management Table 1: Construction Event Response Issue/Event Response level Significant weather-related or human error events which may SI or AIT have a significant impact on SSCs or other program elements such as hurricanes, tornados, fire, flooding, etc.

Significant security-related issues (e.g., loss or theft of SNM, SI or AIT potential tampering, multiple FFD issues, etc.)

Onsite accidents resulting in significant damage to SSCs (e.g., SI or AIT crane collapse, train or other significant vehicle accident).

Significant offsite or onsite industrial events impacting the site SI (hazardous chemical spill (e.g., chlorine or ammonia),

etc.

Site wide stop work order SI Strikes SI Potential financial impact on programs or quality of work SI Significant SCWE issues, allegations, etc. SI Significant issues not covered above but judged by SI management to warrant additional inspection or oversight.

Issue Date: 04/02/19 AppC-5 2504

Decision Documentation for a Construction SI/AIT PLANT: EVENT/ ISSUE DATE: EVALUATION DATE:

Brief Description of the Event/Issue:

Significant Weather-Related, Natural Disaster, or Man-Made Event Y/N SI Deterministic Criteria Significant damage to SSCs having ITAAC Remarks:

Y/N AIT Deterministic Criteria Extensive damage to SSCs having ITAAC Remarks:

Involved the loss or damage of SNM or sources Remarks:

SIGNIFICANT SECURITY-RELATED ISSUE Y/N SI Deterministic Criteria Potential tampering or sabotage Remarks:

Unauthorized, actual discharge of a weapon Remarks:

Multiple FFD issues Remarks:

Other (explain in remarks)

Remarks:

Y/N AIT Deterministic Criteria Loss or theft of SNM Remarks:

Confirmed tampering or sabotage Remarks:

Other (explain in remarks)

Remarks:

Issue Date: 04/02/19 AppC-6 2504

ONSITE ACCIDENT RESULTING IN SIGNIFICANT DAMAGE TO SSCs WITH ITAAC Y/N SI Deterministic Criteria Significant damage to SSCs or other program elements with ITAAC Remarks:

Y/N AIT Deterministic Criteria Extensive damage to SSCs with ITAAC Remarks:

SIGNIFICANT OFFSITE OR ONSITE INDUSTRIAL EVENT Y/N SI Deterministic Criteria Possibility of significant impact on stored or constructed items or materials Remarks:

Y/N AIT Deterministic Criteria Provide rationale in response decision block Remarks:

STOP WORK ORDER ISSUED BY LICENSEE Y/N SI Deterministic Criteria Stop work order for which the underlying issues are not fully understood Remarks:

Y/N AIT Deterministic Criteria Provide rationale in response decision block Remarks:

PLANT STRIKE Y/N SI Deterministic Criteria Plant strike Remarks:

Y/N AIT Deterministic Criteria Provide rationale in response decision block Remarks:

POTENTIAL FINANCIAL IMPACT ON PROGAMS/QUALITY Y/N SI Deterministic Criteria Potential financial impact on programs or quality Remarks:

Y/N AIT Deterministic Criteria Provide rationale in response decision block Remarks:

Issue Date: 04/02/19 AppC-7 2504

SIGNIFICANT SCWE ISSUE OR ALLEGATION Y/N SI Deterministic Criteria Significant SCWE issue or allegation that cannot be addressed through IMC 2505 or independent licensee action Remarks:

Y/N AIT Deterministic Criteria Provide rationale in remarks Remarks:

ANY OTHER SIGNIFICANT ISSUE Y/N SI Deterministic Criteria Significant issue not covered above judged by management to warrant additional inspection or followup Remarks:

Y/N AIT Deterministic Criteria Provide rationale in remarks Remarks:

RESPONSE DECISION USING THE ABOVE INFORMATION AND OTHER KEY ELEMENTS OF CONSIDERATION AS APPROPRIATE, DOCUMENT THE RESPONSE DECISION TO THE EVENT OR ISSUE, AND THE BASIS FOR THAT DECISION DECISION AND DETAILS OF THE BASIS FOR THE DECISION:

BRANCH CHIEF REVIEW: DATE:

DIVISION DIRECTOR REVIEW: DATE:

RA REVIEW: DATE:

Note: The above tables are provided as examples only. Region II has discretion to modify these tables in their implementing procedures or office instructions.

Issue Date: 04/02/19 AppC-8 2504

Attachment 1- Revision History for IMC 2504 Commitment Accession Number Description of Change Description of Comment Resolution and Tracking Number Issue Date Training Required Closed Feedback Form Change Notice and Completion Date Accession Number (Pre-Decisional, Non-Public Information)

N/A 04/25/2006 Initial Issuance None N/A N/A Revision 1, revised to reflect changes in None ML072620276 10/03/2007 program, IP revisions and editorial ML072620292 CN 07-030 corrections. Researched commitments for 4 ML072620283 years and found none. ML072620289 N/A Complete rewrite to reflect substantial None ML092460435 10/15/2009 changes in program scope as well as revised CN 09-024 and new IPs.

N/A ML12298A106 Revised throughout to reflect changes and None ML12261A398 10/24/12 refinements in program scope, updated IP CN 12-025 versions and editorial corrections.

N/A ML19056A212 Complete rewrite to make format consistent None ML19056A213 04/02/19 with revised IMC 0040. Provides further CN 19-012 revisions to reflect changes and refinements in program scope, clarification regarding operational program implementation assessment, updated IP versions and editorial corrections.

Issue Date: 04/02/19 Att1-1 2504