ML24033A212

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January 11, 2024, Public Meeting Summary - Fuel Cycle Construction Oversight Public Meeting
ML24033A212
Person / Time
Issue date: 02/05/2024
From: Fuentes L
NRC/RGN-II
To: Nicole Coovert
NRC/RGN-II
References
Download: ML24033A212 (6)


Text

Enclosure MEMORANDUM TO: Nicole Coovert, Director (Acting)

Division of Construction Oversight Region II FROM: Luis Colon Fuentes, Construction Inspector Construction Inspection Branch 1 Division of Construction Oversight Region II

SUBJECT:

PUBLIC MEETING

SUMMARY

- FUEL CYCLE CONSTRUCTION OVERSIGHT WORKSHOP PUBLIC MEETING ON JANUARY 11, 2024 The staff of the U.S. Nuclear Regulatory Commission (NRC) conducted a hybrid meeting (in-person and virtual via Microsoft Teams) with representatives of the Nuclear Energy Institute (NEI), licensees and applicants in the fuel facility industry, and members of the public on January 11, 2024. The purpose of the meeting was to discuss proposed updates to the construction inspection program for fuel cycle facilities. Topics discussed included: updates to and applicability of Inspection Manual Chapters (IMC) 2600 and IMC 2694 regarding inspection of modifications at existing facilities and construction of new facilities; description and development of new consolidated Inspection Procedures (IP) 88200, 88201, and 88202 associated with inspection of safety significant items (and services), management measures, and operational readiness, respectively, for major modifications at existing facilities and construction of new facilities; and fuel facility budget and fee topics.

The public meeting notice with the agenda, and the meeting presentations are available in the Agencywide Documents Access and Management System (ADAMS) under Accession Numbers: ML24010A123, ML23335A175, and ML24010A098.

Meeting Summary:

The meeting began with the NRC providing an overview of the meetings purpose and logistics.

Opening remarks were made by Anthony Masters, Director, Division of Fuel Facility Inspection, Region II.

After opening remarks, the NRC staff provided a series of presentations followed by question-and-answer sessions. The presentations covered draft language and proposed updates to IMCs 2600 and 2694 and the associated IPs 88200 - 88202 series. Discussions of proposed changes to IMC 2600 pertained to modifications to existing licensees of fuel cycle facilities (FCFs),

including estimated inspection hours for major modifications performed by existing licensees under the IMC 2600 oversight process. Discussions of proposed changes to IMC 2694 pertained to construction and pre-operational readiness review inspection program for new applicants and new licensees of FCFs. The staff presented the new construction IPs 88200, 88201, and 88202 for technical, management measures, and operational readiness review February 5, 2024 Signed by Colon Fuentes, Luis on 02/05/24

N. Coovert 2

inspections, respectively. These discussions included draft language and examples of IP implementation for the different types of inspections. After the IMC and IP presentations, Office of Nuclear Material Safety and Safeguards (NMSS) staff led a discussion on fuel facility budget and fee topics.

Closing remarks were given by Omar López-Santiago, Deputy Director (Acting), Division of Fuel Management, NMSS.

Below is a summary of comments and discussions:

  • During the presentation, the staff emphasized that the inspection guidance updates for the 5-year periodic programmatic review were intended to add clarity, transparency, and consistency as part of these revisions.
  • The staff discussed that the existing framework and guidance provided by IMC 2600 continues to adequately address inspection oversight for modifications for existing licensees, including those modifications that are large and complex.
  • The staff discussed the NRCs graded approach to modification inspections and highlighted the NRCs focus and efforts to ensure inspection scope is risk informed and right sized for the activity at hand. For IMC 2600, the staff discussed the draft language for the term major modification and noted inspection hours in IMC 2600 Appendix B to address these inspections, on an as needed frequency.
  • For construction activities associated with new applicants or new licensees, the staff discussed continuing to utilize IMC 2694, which establishes a construction inspection program for inspecting safety significant items and services, like items relied on for safety (IROFS) and associated activities, that are conducted by the licensee and its consultants, contractors, and suppliers to support the decision to allow operation of the facility.
  • Stemming from this meeting, the NRC has committed to continued dialogue with interested stakeholders related to fuel facility construction inspection program IMC and IP development via additional public meetings, as needed. Staff was asked questions and provided comments for the following topics:

- NRC communications with the licensee/applicant regarding when the Principal Inspection Plan is developed.

- Consider use of wording for at-risk associated with open items and self-imposed standard.

- Consider providing examples of non-IROFS that fall into the category of safety significant items (and services).

- Clarification on management measures (MM) and how they are implemented during construction and what are the NRC expectations for implementation. (e.g. MM training and qualification implementation during construction)

- Clarification of expectations for MM flow down to subcontractors processes during construction.

Enclosure N. Coovert 3

  • During the discussion of fuel facilities budget and fees, NRC staff acknowledged that despite our continued focus to ensure the budget aligns with the anticipated workload, changes in the timing of submittals can have real impacts on existing licensees and their annual fees. NRC staff explained the relationship between the budget and fees and the points during budget formulation and execution at which the NRC can account for fact of life changes. The NRC staff also provided feedback on the proposals included in NEIs December 1, 2023, letter (Agencywide Document Access Management System Accession No. ML23335A175), offering options for funding the fuel facility business line to prevent large fluctuations in annual fees based on changes in the timing of licensee and applicant submittals. Finally, NRC staff identified ways for the NRC and industry to improve estimates of anticipated work during budget formulation.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this meeting, please contact Nicole Coovert at (404) 997-4510.

Enclosure:

List of Attendees

Enclosure N. Coovert 4

SUBJECT:

PUBLIC MEETING

SUMMARY

- FUEL CYCLE CONSTRUCTION OVERSIGHT WORKSHOP PUBLIC MEETING ON JANUARY 11, 2024

DISTRIBUTION:

S. Lav, NMSS O. López-Santiago, NMSS A. Masters, RII/DFFI

ADAMS ACCESSION NUMBER:ML24033A212

SUNSI Review Non-Sensitive Publicly Available Sensitive Non-Publicly Available

OFFICE RII/DCO RII/DCO RII:DCO

NAME G. Khouri A. Ponko L. Colon Fuentes DATE 2/2/2024 2/5/2024 2/5/2024

Enclosure LIST OF ATTENDEES

This list of Attendees was captured via the in-person and virtual attendance sheets:

Name Organization David H. Tiktinsky Boston Government Services, LLC Ashley R. Morris BWXT Daniel L. Ashworth BWXT Jason K. Krumenacker Centrus Energy Joshua W. Adams Centrus Energy Robert P. Jacobs Centrus Energy Calvin Manning Framatome Timothy Tate Framatome James C. Kinsey Jr Idaho National Laboratory Bob Link Nuclear Energy Institute Janet Schlueter Nuclear Energy Institute Tim Knowles Nuclear Fuel Services Zachary Betsill Southern Company Charlyne A. Smith University of Florida Chris Schwarz Urenco USA Wyatt Padgett Urenco USA Amanda J. Spalding Westinghouse Camille T. Zozula Westinghouse Stephen G. Subosits Westinghouse Gerard Couture No Organization Provided Jim Tomkins No Organization Provided Oliver Barrett No Organization Provided Tim No Organization Provided Aaron Thomlinson NRC Aida Rivera-Varona NRC Anthony Masters NRC Anthony Ponko NRC Anthony Rossi NRC Benjamin Karmiol NRC Billy Blaney NRC Cameron Ubben NRC Chad Oelstrom NRC Cindy Bladey NRC Cynthia Taylor NRC Dave Gasperson NRC Diana Woodyatt NRC Edward Madden NRC Emma Duncan NRC Eric C. Michel NRC Ethan Licon NRC Fred Miller NRC Gayatri Mostaghimi NRC

Enclosure LIST OF ATTENDEES

George Khouri NRC Gregg Goff NRC James Downs NRC Jasmine Stanley NRC Jen Scro NRC Jenny Tobin NRC Jo Jacobs NRC Joel Rivera Ortiz NRC Joseph Grice NRC Joseph Rudd NRC Joylynn Quinones-Navarro NRC Kellee Jamerson NRC Krupskaya Castellon NRC Larry Harris NRC Laura Dudes NRC Leonard Pitts NRC Lindsey Cooke NRC Luis Colon Fuentes NRC Marilyn Diaz Maldonado NRC Matt Bartlett NRC Matthew Doyle NRC Meg Day NRC Michael Greenleaf NRC Nicole Coovert NRC Noah Woodyard NRC Noel Pitoniak NRC Omar Lopez-Santiago NRC Raju Patel NRC Robert Mathis NRC Robert Williams NRC Samantha Lav NRC Shana Helton NRC Sheila Coleman-Turner NRC Suzanne Dennis NRC Thomas Vukovinsky NRC Timothy Sippel NRC Todd Shewmaker NRC Tricia Lizama NRC

Enclosure