ML22318A140
| ML22318A140 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/14/2022 |
| From: | NRC |
| To: | NRC/NRR/DNRL |
| References | |
| Download: ML22318A140 (11) | |
Text
From:
Cayetano Santos Sent:
Monday, November 14, 2022 10:48 AM To:
Vogtle PEmails Cc:
Subject:
NEI Slides for 11-15-22 Public Meeting on Lessons Learned from Construction Oversight at Vogtle and Summer Attachments:
NEI Part 52 Construction LL - NRC Meeting (2022-11-15).pdf NEI Slides for 11-15-22 Public Meeting on Lessons Learned from Construction Oversight at Vogtle and Summer.
Hearing Identifier:
Vogtle_COL_Docs_Public Email Number:
640 Mail Envelope Properties (MW4PR09MB9010B9EEB5FA569F6DB4522DE5059)
Subject:
NEI Slides for 11-15-22 Public Meeting on Lessons Learned from Construction Oversight at Vogtle and Summer Sent Date:
11/14/2022 10:48:08 AM Received Date:
11/14/2022 10:48:12 AM From:
Cayetano Santos Created By:
Cayetano.Santos@nrc.gov Recipients:
"James Gaslevic" <James.Gaslevic@nrc.gov>
Tracking Status: None "Vogtle PEmails" <Vogtle.PEmails@usnrc.onmicrosoft.com>
Tracking Status: None Post Office:
MW4PR09MB9010.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 109 11/14/2022 10:48:12 AM NEI Part 52 Construction LL - NRC Meeting (2022-11-15).pdf 364665 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Marc Nichol Nuclear Energy Institute Part 52 Construction Lessons Learned November 15th, 2022
©2022 Nuclear Energy Institute 2 Initial Plan Unit 3 2016 Completion (5 years after first nuclear concrete)
Unit 4 2017 Completion Regulatory Delays Aircraft Impact Redesign Design Approval - 11 months delay Construction License - 8 months delay 215 Licensing Actions*
143,000 inspection hours (Vogtle 3 and 4) - direct and indirect Vogtle Impact Overview
- Source: SNC Presentation 9/27/2022 (ML22265A097)
©2022 Nuclear Energy Institute 3 Develop expedited and more efficient process for reviewing licensing actions with minimal safety significance Update cROP to reflect latest risk insights and incorporate lessons learned Utilize low safety significance issue resolution (LSSIR)
Limit significance of licensee identified findings Revise SDP to ensure resources are focused on most safety significant issues Create a new mechanism to enable the agency to pilot new approaches or processes for the first licensee as unintended challenges are identified Top Recommendations
©2022 Nuclear Energy Institute 4 Replace unnecessary regulatory submittals with NRC-Licensee information exchange Program schedule submittals derived from SECY-05-0197 that impose license conditions ITAAC completion schedule required by 52.99(a)
- Post both direct and indirect inspection hours (actuals and forecasts) on the NRC website to provide transparency on NRC resource plans
- Focus on performance-based acceptance criteria, and not the process for achieving the safety standards Improve Regulatory Efficiency (1 of 2)
©2022 Nuclear Energy Institute 5 Optimize ITAAC number and scope NEI 15-02: Proposal for standardized and optimized ITAAC Take credit for NRC-approved licensee programs (e.g., QA, ASME, EQ, structural reconciliation, system-level testing), and NRCs inspection program.
Utilize ITAAC to provide reasonable assurance, not as a 1:1 check of detailed design and construction features.
ITAAC are not necessary when:
SSC design features and performance characteristics are not safety or risk significant Component-level testing are challenged during system testing They duplicate other ITAAC They directly duplicate regulation with no site-specific design attributes Improve Regulatory Efficiency (2 of 2)
©2022 Nuclear Energy Institute 6 Update cROP for Construction Lessons Learned SDPTruly consider the actual risk to the public in cROP, which was based on ROP where public actually incurs some risk; however, this risk is never realized by the public during cROP, as plant programs ensure non-conforming conditions are addressed prior to operation.
Licensee identified findingslimit significance (consider minor violations) for licensee-identified findings since plant programs ensure such issues are addressed prior to operation.
Implementing LSSIR would be extremely helpful in the construction environment, particularly when verbatim compliance issues arise within ITAAC inspections when there is no significance or impact to ITAAC intent.
Low-Safety Significance-Issue Resolution (LSSIR)
©2022 Nuclear Energy Institute 7 FOAK Mitigation Strategies Tabletop each step of first of a kind actions with Licensees Apply learnings from first-time licensing process in real time through ISG, RIS or other mechanisms so that the first licensee can benefit from overcoming regulatory obstacles License amendment process optimization Focus Tier 1 and ITAAC during Design Certification on safety significant structure, systems, and components and make language succinct, to reduce the possibility of LARs during construction Create a process for Licensee to proceed at risk for modification of Tier 1 prior to NRC approval via 50.59-like process, since there is no radiological danger to the public prior to fuel loading Benefits
Reduce potential for delays during construction due to license amendments
Eliminate the need for large resources to maintain an emergency LAR/PAR process Planning for SMR Implementation (1 of 2)
©2022 Nuclear Energy Institute 8 Changes to inspection program New reactors anticipate minimal onsite construction.
If the ratio to vendor to site construction activities swap, so should the ratio to vendor to site inspection of activities.
Life-cycle inspection approach for new supplier
Prior to fabrication startingconduct inspection of suppliers programs
Shortly after fabrication commencementinspect execution of programs
Inform follow-up inspections based on supplier performance Ensure inspection program does not repeat inspections onsite Planning for SMR Implementation (2 of 2)
Additional Details: NEI Assessment of Licensing Impacts on Construction (ML18305B421)
©2022 Nuclear Energy Institute 9 Questions?