ML22319A123

Kozak Slides for November 15, 2022 Public Meeting on Part 52 Lessons Learned

ML22319A123
Person / Time
Site:	Vogtle
Issue date:	11/15/2022
From:	Kozak T Kozak Innovative Safety Solutions
To:	NRC/NRR/VPOB
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ML22319A120	List: ML22319A123
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Download: ML22319A123 (1)

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Lessons Learned from Part 52 Implementation TO M KO Z A K K O Z A K I N N O V AT I V E S A F E T Y S O L U T I O N S , I N C

Lessons Learned from Part 52 Implementation NOTABLE SUCCESSES CROP LESSONS LEARNED INSPECTION PROGRAM AND SIGNIFICANCE DETERMINATION PROCESS LESSONS LEARNED

Notable Successes IMC 2506-07.01: Construction Regulatory Oversight Framework The staff identified those aspects of licensee performance that are important to the mission and therefore merit regulatory oversight.

NRC met its mission to ensure public health and safety during the construction of Vogtle Unit 3 and continues to be effective while Unit 4 is under construction.

The cROP framework met its intended function

Notable Successes IMC 2506-07.17: ITAAC Closeout Process The results of the reviews of the ITAAC closure notifications (ICNs) by the staff and the documentation of the completion of the Construction Inspection Program for COL ITAAC facilitate the staff recommendation regarding the 10 CFR 52.103(g) finding on whether all the COL acceptance criteria are met.

Efficient and Effective implementation of the 10 CFR 52.103(g) finding process by both NRC and SNC

cROP Lessons Learned IMC 2506-03.01: The cROP is expected to be dynamic and to respond to changes in the nuclear power industry and construction experience. Therefore, the program office expects the regions and inspectors to identify challenges in implementing the program, and to recommend improvements to the program for consideration by the program office.

SNC recommended that industry lessons learned and ROP improvements be implemented in a timely manner for units under construction.

I endorse this recommendation. Consider more closely monitoring ROP improvements/revisions for timely incorporation into the cROP. Also, consider revising wording to expect all stakeholders to recommend improvements, not just regions and inspectors - and actively solicit and incorporate improvement recommendations

Inspection Program Lessons Learned 2506-07.07: The NRC staff can increase or decrease the number of construction activities and SSCs planned for inspection based on program results. The NRC staff will review and adjust the number of SSCs to be inspected as part of the annual performance review assessment process described in IMC 2505, Periodic Assessment of Construction Inspection Program Results. This can be done at any stage of the annual assessment process, including during continuous, quarterly, or end-of-cycle reviews.

Incorporate this assessment (and inspection) program flexibility into the inspection planning process, especially to gain efficiencies when construction projects extend beyond original completion schedules. For instance, per 2506-07.07 guidance, successfully completed inspections do not need to be repeated (e.g., foundations and concrete inspections at Vogtle 3 and 4).

Inspection Program Lessons Learned 2506-07.16 Construction Project Resource Estimate. The initial direct inspection effort estimate is 35,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per unit over the life of the construction project. This estimate is based on the inspection hours that were expended during construction of the last several completed reactor units.

2506A03.03: Staffing levels at the construction resident offices will depend on many factors but will largely be based on the amount and type of ITAAC activities occurring on-site.

Resource estimate did not include indirect hours, which were approximately 3x direct hours. Indirect resource expenditures do not align with past NRC resource budget models and appears to be a direct correlation to the construction resident inspector office (CRO) staffing levels. Include indirect hours in construction project resource estimate. Consider a detailed review of CRO staffing levels and management of indirect hours and appropriately apply lessons learned to future construction projects.

Significance Determination Process Lessons Learned The SDP essentially begins with IMC 0613, Appendix B, Issue Screening.

Current screening does not provide licensee identification credit for potentially greater than green findings.

A goal of the cROP is to prevent latent construction deficiencies from impacting operations A licensee identified violation, when properly corrected, will not impact plant operations Screen licensee identified violations to a minor violation

Significance Determination Process Lessons Learned In the initial version of IMC 2505, the significance of findings was determined using a traditional enforcement approach. The staff provided a description of the construction assessment program to the Commission in SECY-08-0155, Update on the Development of the Construction Inspection Program for New Reactor Construction under 10 CFR Part 52, dated October 17, 2008.

On December 5, 2008, the Commission issued SRM M081022, which directed the staff to reconsider the construction assessment process as presented in IMC 2505 and propose policy options to the Commission. The Commission directed that the staff should address the inclusion in the construction oversight process of objective elements such as construction program performance indicators (PIs) and significance determination processes (SDPs) analogous to those used in the ROP.

Consider replacing the existing SDP with traditional enforcement as was originally intended for determining the significance of findings. This can be implemented within the cROP framework, but will most likely need Commission approval given the direction provided in SRM M081022.

Significance Determination Process Lessons Learned AP 1000 Construction Significance Determination Matrix Row 4 Green White Yellow Red Row 3 Green Green White Yellow Quality of Construction Row 2 Green Green Green White Row 1 Green Green Green Green Very Low Low Intermediate High System/Structure Risk Importance

Significance Determination Process Lessons Learned AP 1000 Construction Significance Determination Matrix has an unintended consequence Matrix Structure results in different significance for similar findings Example: preliminary significance for Vogtle Unit 3 electrical separation findings Consider eliminating the use of the Construction Significance Determination Matrix in the construction SDP.

Utilize risk-informed qualitative analyses to estimate the risk significance of inspection findings related to licensee performance in meeting construction Cornerstone objectives and performance expectations (see ROP deterministic SDPs in IMC 0609 Appendices). This approach can be applied to traditional enforcement severity level determinations.

Significance Determination Process Lessons Learned Ideas for risk-informed qualitative analyses Incorporate Matrix Y-axis - Focus on Quality of Construction vs Impairing Design Function Clarify guidance for Quality Assuarance Program breakdowns and incorporate into significance determination - must be present for escalated enforcement (greater than green/Severity Level III or higher)

Consider likelihood of subsequent licensee identification of a finding through remaining licensee processes, such as remaining QC inspections, ITAAC closure process, etc.

Conclusions The cROP worked as intended to ensure safety during construction - keep existing framework Capture NRC and licensee best practices from 10 CFR 52.103(g) finding Implement Traditional Enforcement for Significance Determination, if approved.

Regardless, utilize risk-informed qualitative analyses to estimate the risk significance Eliminate Construction Significance Determination Matrix to avoid unintended consequences