ML23219A028
| ML23219A028 | |
| Person / Time | |
|---|---|
| Issue date: | 08/15/2023 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | |
| Shared Package | |
| ML23219A024 | List: |
| References | |
| Download: ML23219A028 (1) | |
Text
Construction Oversight Program Update Fuel Facilities Construction Oversight Workshop - August 15, 2023
Key Messages
- IMC 2694 update is required by procedure, and addresses at-risk construction and new facility types
- IP revisions are technology-neutral for Fuels Construction Inspection Programs (FCIPs) and are scalable and agile
- Construction inspection prioritizes those activities that are made inaccessible as part of the construction process, first of a kind, etc.
IMC 2694 Review and Update
- IMC 2694 (Why Update Now?):
-NRC guidance requires a five-year review cycle for IMCs (IMC 0040: Preparing, Revising, and Issuing Document)
- Incorporate lessons-learned
-Preparing for ~10 major fuel cycle facility construction projects
- Variety of new technologies
- Variety of construction strategies
Existing Guidance
- IMC 2694 (Current Version):
- Revised in 2017 to become a non-licensee-specific program for construction inspection.
- Existing Inspection Procedures
- IPs referenced in IMC 2694 (current version):
- Last used for MOX, a Cat. I facility, which includes Part 50 Appendix B requirements, and will remain available for future construction projects, as applicable.
- Separate IP for each construction attribute.
- IPs developed and used for NPUFs (used as basis for update)
- Evaluate same construction attributes (structural, welding, electrical, etc.).
- Group attributes into technology neutral, scalable and flexible single IP with multiple attachments.
- Same approach is done for management measures/QA elements.
Timeline of Revision Project May 2022:
NRC formulates a working group to identify appropriate procedures and manual chapter(s) for new construction activities at fuel facilities.
Jun. 2022:
NRC identifies IMC 2694 and associated IPs as applicable and in need of review.
Jul. 2022:
NRC subject matter experts (SMEs) gather materials and review lessons-learned from other nuclear construction projects to identify potential improvements.
Oct. 2022:
NRC presents at public stakeholder meeting a project to update and improve IMC 2694.
Oct. 22 - Mar. 23:
Initial revision and identification of knowledge gaps in at-risk construction.
Mar. 23:
NRC presents more details on IMC 2694 update at public stakeholder meeting and receives feedback from industry.
Mar. - Jul. 2023:
Revision continues, and knowledge gaps filled.
Jul. 2023:
At-risk construction letter issued to applicant.
Aug. 2023:
Construction Oversight Workshop - provide detailed examples of changes and solicit feedback during the revision process.
Proposed Draft Changes in IMC 2694 Global Changes:
- Minor edits throughout the document to improve clarity.
- Shifted inspection focus attribute away from QA Program to focus on Management Measures.
- Broadened language to be inclusive of at-risk construction considerations.
- Broadened language to be inclusive of more facility/process types.
- Added lessons-learned from nuclear construction - as applicable.
Specific Changes
- Inspection and Technical Personnel Considerations - deleted
- Adjustment of assessment of licensee performance - desire for more real-time assessment.
- Resident Inspectors - new section to discuss considerations for resident inspector needs.
- Adding Appendices for master inspection plan (MIP) creation and report writing.
- Update to Appendix A to list new IPs based on NPUF model.
Examples of Revisions Please note that these are still in-draft and are not meant to convey a final regulatory position.
Specific Examples
- Consideration of Applicants
- Inspecting at-risk activities
Specific Examples
- Guidance for Developing a MIP
Specific Examples
- Clarifying Scope
Specific Examples
- Re-organization to include some lessons-learned Moved from other section of IMC to Focus of Inspection
Specific Examples
- Inspection Related Communications:
Path Forward
- Review and Consider feedback from Workshop and subsequent meetings (as applicable)
- Finalization of draft guidance
- Formatting draft guidance in accordance with NRC IMC
- NRC concurrence process
- Issuance
Questions?