ML24123A217

Research Test Rx Construction Workshop Date 5.15.25 - Public

ML24123A217
Person / Time
Issue date:	05/15/2024
From:	Kevin Roche Office of Nuclear Reactor Regulation
To:
References
Download: ML24123A217 (1)

Text

Research and Test Reactor (RTR)

Construction Oversight Workshop May 15, 2024

Familiarize RTR construction permit (CP) holders, CP applicants, and the public with NRC construction oversight of RTRs by discussing:

1.

NRC inspection organization and points of contact (POCs) 2.

Lessons learned from nuclear construction projects 3.

Key inspection oversight guidance 4.

Conduct of NRC inspections 5.

Transition to operations Workshop Objectives 2

RTR Construction Oversight: NRC Introductions Key NRC Headquarters Staff for RTR Construction Oversight Rockville, MD 3

RTR Construction Oversight: NRC Introductions Key NRC Region 2 Staff for RTR Construction Oversight Atlanta, GA 4

NRC Inspection Organization for NPUFs NRC Office of Nuclear Reactor Regulation (NRR)

Rockville, MD NRC Region 2 Atlanta, GA Division of Advanced Reactors and NPUFs (NRR/DANU)

Construction Inspection Branch 1 (CIB)

Division of Construction Oversight (DCO)

NPUF Oversight Branch (UNPO)

NPUF Licensing Branch (UNPL) 5

NRC Inspection Organization NRC Office of Nuclear Reactor Regulation (NRR)

Rockville, MD Division of Advanced Reactors and NPUFs (NRR/DANU)

NPUF Oversight Branch (UNPO)

NRR/DANU/UNPO

- Oversees operating RTRs

- Inspects the operational readiness of RTRs prior to issuance of an operating license.

- Provides construction oversight program guidance via Inspection Manual Chapter (IMC 2550) and Inspection Procedures (IPs) 6

NRC Inspection Organization NRC Region 2 Atlanta, GA Construction Inspection Branch 1 Division of Construction Oversight R2/DCO/CIB1

- Plans and conducts inspections of RTR construction activities and assesses the results of inspections for enforcement and program adjustments.

7

NRC Terminology RTR: Research and Test Reactor NPUF: Non-power Production or Utilization Facility (includes RTRs and other non-power facilities such as accelerator-driven radioisotope production facilities)

Construction Quality Assurance: the procedures, processes, and programs that ensure the as-built facility conforms to the facilitys licensing and approved design bases Advanced RTR: an RTR that is non-light water reactor (LWR), or an RTR for an LWR SMR design. Note: the NRC uses the same oversight program for construction of both advanced and traditional RTRs.

8

Lessons Learned from Nuclear Construction Projects 9

Lessons learned from fuel cycle facilities, non-power production and utilization facilities (NPUFs), and reactor construction inspection programs:

• Urenco, Mixed Oxide, Nuclear Fuels Services Framatome, American Centrifuge Plant

• SHINE

• AP1000, Watts Bar Unit 2 Lessons Learned from Nuclear Construction Projects 10

Generic Challenges with Construction Activities

• Dynamic construction schedule

• Different technologies and new processes

• Emergent technical issues

• Contractor oversight Understanding key contractors and their roles When key contractors change during construction Processes, like internal reviews, licensees/applicants using to understand/identify challenges early in the process Safety culture programs/allegation processes 11

Construction Inspection Lessons The NRC inspects to licensing commitments (e.g.,

codes and standards), as applicable to each licensee/applicant.

• Past problems translating design requirements (including codes and standards) into design and construction documents and properly implementing design documents.

• Past problems initiating, performing, verifying and documenting design changes and evaluating the impact of those changes on the design bases.

• Repair, replace, or justify documentation incomplete (i.e., corrective actions).

12

• Early and frequent communications with the licensee, program office, and inspection division

• Inspection planning meetings

• Awareness of construction schedules and changes

• NRC accessibility to and familiarity with scheduling tools

• Best times to inspect or strategies to inspect complex or first-of-a-kind processes, structures, systems, and components (SSCs)

What Worked Well with Other Construction Projects 13

• Using tabletop approaches to pilot new inspection guidance or new inspection techniques

• NRC resource planning to remain prepared, efficient, and flexible

• NRC use of data to inform decision making

• Remote information sharing reduces on-site time What Worked Well with Other Construction Projects 14

Public Participation At this time, the industry stakeholders and the public are afforded an opportunity to ask questions and/or provide comments.

15

Key Inspection Oversight Guidance 16

NPUF Construction Oversight Guidance Inspection Manual Chapter (IMC) 2550 Non-Power Production and Utilization Facilities (NPUFs) Licensed Under 10 CFR PART 50:

Construction Inspection Program (CIP) https://www.nrc.gov/reading-rm/doc-collections/insp-manual/manual-chapter/index.html Inspection Procedures (IP) 69020, 69021, 69022 https://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html Search words: NRC IMC or NRC IP 17

IMC 2550 Topics

• Purpose

• Inspection Areas and Procedures

• Inspection Findings

• Inspection Reports 18

IMC 2550 Purpose to define the Construction Inspection Program (CIP) for non-power production and utilization facilities (NPUFs) holding a construction permit and pursuing an operating license under 10 CFR Part 50. This CIP will provide reasonable assurance that the final design and construction of NPUFs have been completed in accordance with applicable regulations, license requirements, and commitments.

Note: Throughout this IMC, the term permit holder is used to refer to a construction permit (CP) holder. However, the NPUF CIP may also be applied to construction permit applicants performing safety-significant pre-construction and procurement activities.

19

IMC 2550: Inspection Areas and Procedures The NPUF CIP is divided into 3 areas of construction inspection:

1. Inspections of Safety-Related Items (and Services) During Construction of NPUFs (IP 69020)

2. Inspection of Quality Assurance Program Implementation During Construction of NPUFs (IP 69021)

3. Inspections of Operational Readiness During Construction of NPUFs (IP 69022) 20

Inspection Procedure 69020

• Primarily engineering and hardware inspections.

• Divides inspections into technical areas using separate appendices for each.

• Requires one inspection per area (if the technical area is applicable to the design)

• Includes work in progress inspections to the extent practicable.

• Multiple appendices are generally inspected during each site visit.

• May be performed off-site if necessary. (e.g., at a manufacturing facility or vendor) 21

Inspection Procedure 69021

• Quality Assurance Program (QAP) inspections (one IP appendix for each of the 18 ANSI/ANI 15.8, Quality Assurance Program Requirements for Research Reactors requirements)

• Completed in parallel with IP 69020 inspections 22

Inspection Procedure 69022

• Operational Readiness Inspection including:

Operational Programs (e.g., operator training, radiation protection, fire protection, etc.)

Security (completed prior to possessing special nuclear material)

Verification that all NRC construction findings are closed or appropriately scheduled for closure

Verification that construction is substantially complete.

• Successful inspection represents completion of the construction inspection program and results in a recommendation to issue an operating license 23

Construction IPs Under Revision Existing IPs 69020 - 69022 were written for NPUFs with consideration of licensing requirements for SHINE Medical Technologies.

Considering the changing landscape of the nuclear industry, construction IPs need to be agile, scalable, and flexible, and incorporate lessons learned from other NRC construction oversight processes.

Technical and QA inspection attributes have minimal changes, but only applicable based upon each facilitys licensing requirements.

Inspection samples and hours are based upon each facilitys licensing bases, safety analysis report, applicable codes and standards, requirements in the construction permit and operating license, etc. Requires one inspection per area, if applicable - additional inspections are performed if necessary.

Updating IP format in accordance with IMC 0040, Preparation, Revision, Issuance, and Ongoing Oversight of NRC Inspection Manual Documents.

Restructured each appendix to be consistent for inspection objectives, requirements, and procedure completion.

24

Additional Specific Revisions for Construction IPs IP 69020 specific changes:

• Consolidated Appendices K: Structural Welding and Appendix L:

Nuclear Welding into one welding appendix (new K)

• Re-lettered Appendix M: Fire Protection System (new L)

• Added new technical area for Appendix M: Inspection of Digital Instrumentation and Control System/Software Design 25

Additional Specific Revisions for Construction IPs IP 69021 specific changes:

Three Phases of QAP Inspections (Concept):

1. Initial Team Inspection/Program Review

2. Sampling of implementation during in-process construction inspections (focused on construction applicable QA elements)

3. Operational Readiness Inspection (focused on operational applicable QA elements) 26

Additional Specific Revisions for Construction IPs IP 69022 specific changes:

• No specifics changes identified.

27

Recent Revision to IMC 2550

• Simplified the inspection program assessments to 1) continuous assessment, and 2) escalated significance violation assessment.

• Removed repetitive enforcement language - refers to NRC Enforcement Policy instead.

• Public meetings only required in special circumstances (or by request) vs. annually to better align with the continuous assessment strategy.

28

NRC Inspection Findings

• IMC 2550 provides some amplifying guidance about enforcement of rules and regulations, however, the NRC Enforcement Policy (https://www.nrc.gov/docs/ML2333/ML23333A447.pdf) contains the full description of the NRC enforcement process.

• For NPUFs, NRC findings are classified by significance using one of the following categories:

• Minor

• Severity Level 4

• Severity Level 3

• Severity Level 2

• Severity Level 1 29

NRC Inspection Findings

• Minor findings: usually not documented.

• Severity Level 4 violations: Notice or Violation or Non-Cited Violation

• Severity Level 1 - 3 violations: Escalated enforcement actions, including consideration of a civil penalty. Follow up NRC inspection(s).

30

NRC Inspection Reports

• Contain details of inspections that ultimately support recommendation to issue an operating license.

• Finding are opened and/or closed only in inspection reports.

• Issued after each inspection or every quarter if multiple inspections occur in a quarter.

• Posted on the NRC public website.

31

Public Participation At this time, the industry stakeholders and the public is afforded an opportunity to ask questions and/or provide comments.

32

Conduct of NRC Inspections 33

Conduct of NRC Inspections:

Key to Success Inspection program completion requires frequent communications between CP holder/applicant and the NRC inspection staff:

- up-to-date construction schedules are key to inspection success.

- consider sharing an information portal (secure file sharing) with the NRC inspection staff to facilitate inspection preparations and schedule sharing.

34

Conduct of NRC Inspections:

Inspection Preparations What to expect prior to an NRC inspection:

1. Schedule coordination - construction activities

2. Document requests: drawings, procedures, etc.

3. Schedule coordination - entrance and exit meetings, logistics

4. Establish technical area POCs

5. Establish licensing POCs 35

Conduct of NRC Inspections:

Required Inspection Team Meetings

• Entrance Meeting:

- Held on the first day at the site.

Purpose:

inform CP holder management and staff of the inspection areas and inspection objectives and meet the POCs.

• Exit Meeting:

- Held on site at the completion of the inspection

Purpose:

debrief CP holder management on the inspection results, including details of any findings identified.

36

Conduct of NRC Inspections

• RTR construction inspections are typically scheduled for 1-week on-site inspection windows.

• Inspections typically use multiple inspection procedures during the on-site week.

• Inspection activities may include in-process work observation, walk downs of as-built SSCs, interviews with staff, and/or review of procedures and quality assurance records.

37

Transition to Operations

• The NRC Construction Inspection Program (CIP) is complete when:

- IP 69020 hardware inspections are complete

- IP 69021 QAP inspections are complete

- IP 69022 Operational Readiness inspection is complete, And

- the CP holder has declared construction of the facility to be substantially complete i.a.w. 10 CFR 50.57.

- NRC findings have been corrected, or corrective actions are appropriately scheduled.

- all safety significant inspection items have been addressed.

38

Transition to Operations (cont)

• Operational Readiness inspection plans are project-specific.

• Factors affecting scope include:

- Operational commitments in the OL application

- Existing programs at similar existing facilities (i.e., sister plants) or existing generic corporate programs

- Use of first of a kind technologies 39

Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments.

40