ML24043A181

Lessons Learned Report Slides Public Meeting on 2-14-24 Rev1

ML24043A181
Person / Time
Issue date:	02/14/2024
From:	Office of Nuclear Reactor Regulation
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Download: ML24043A181 (1)

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10 CFR Part 52 Construction Lessons Learned Report Introduction

Title 10 of the Code of Federal Regulations (10 CFR) Part 52 Lessons Learned Working Group Charter -

ML21160A031

10 CFR Part 52 Construction Lessons Learned Report -

ML23325A202 Efforts and Achievements for Vogtle Units 3 and 4

Total ITAAC notifications reviewed 823 Uncompleted ITAAC Notifications 824 ITAAC Closure Notifications 9 ITAAC Post Closure Notifications Approximate direct inspection hours 34,400 Vogtle Unit 3 19,100 Vogtle Unit 4 Licensing actions 195 license amendment requests 9 exemptions 18 code alternatives Outreach and Public Involvement

August 19, 2021 - announced the lessons learned project during a public meeting

September 27, 2022 - public meeting with Southern Nuclear Company (SNC)

November 15, 2022 - public meeting with Nuclear Energy Institute (NEI) and Kozak Innovative Safety Solutions

February 14, 2024 - present report within 1 month of issuance Report Structure

Executive Summary

Background

Scope and Methodology Lessons Learned, Recommendations, and Suggestions Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)

Construction Inspection Program Licensing Overall Program Considerations for Future Rulemaking Summary

Recommendations - ITAAC

(R.1) Ensure there is flexibility to select a representative sample of inspections throughout any construction area and not require preselected ITAAC to make up the baseline inspections.

(R.2) Ensuring clarity of the scope of each ITAAC, providing clear acceptance criteria with appropriate flexibility, and defining terminology in the ITAAC will help to ensure that the licensee and the NRC have a common understanding of how the ITAAC will be met.

Recommendations - Construction Inspection

(R.3) The construction inspection program should shift to a plan that is more focused on inspecting the safety related activities during construction. This approach does not mandate specific ITAAC completion, but ITAAC could be selected as part of a risk -informed sampling method.

(R.4) Consider a flexible staffing model that can more readily adapt to the dynamic nature of construction.

(R.5) Evaluate whether changes to fee billing requirements would be feasible, appropriate, and improve efficiency while facilities are under construction.

Recommendations - Licensing

(R.6) Provide methods for ensuring effective and timely communication to resolve issues.

(R.7) Continue to identify those activities that will benefit from dedicated resources and allow resources to be assigned as priorities are adjusted.

Recommendations - Overall Program

(R.8) Continuously estimate and monitor the total cost to the licensee and assess the efficient use of hours in a transparent manner.

(R.9) Proactively identify and promptly resolve licensing , inspection, or regulatory challenges or gaps that could unnecessarily impact the schedule for completion of future nuclear facilities.

NRCs Oversight Performance

Did the staff achieve the NRCs mission of providing reasonable assurance of adequate protection of public health and safety?

Ye s

Did regulatory activities unnecessarily delay the construction schedule?

No

Were NRC resources expended efficiently and within the established goals?

Yes, with some exceptions, and there are opportunities to gain efficiencies.

Q & A

Industry Perspectives

Public Comments

Staff Responses