ML18352A921

Completion of Action Items from the 2017 Inspections, Tests, Analyses, and Acceptance Criteria Demonstration Project

ML18352A921
Person / Time
Issue date:	01/17/2019
From:	Jones W B, McGinty T J Division of Construction Inspection and Operational Programs, NRC/RGN-II
To:	Brown F D, Catherine Haney Office of New Reactors, NRC/RGN-II
Cozens I A, NRO/DCIP
References
Download: ML18352A921 (11)

Text

January 17, 2019 MEMORANDUM TO:

Frederick D. Brown, Director Office of New Reactors Catherine Haney, Regional Administrator Region II FROM: Timothy J. McGinty , Director /RA/ Division of Construction Inspection and Operational Programs Office of New Reactors William B. Jones, Director

/RA/ Division of Construction Oversight Region II

SUBJECT:

COMPLETION OF ACTION ITEMS FROM THE 2017 INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA DEMONSTRATION PROJECT On June 1, 2017, the Nuclear Regulatory Commission (NRC), Office of New Reactors (NRO) issued an Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Closure and Verification Demonstration Final Report (Agencywide Document Access and Management System (ADAMS) Accession Numbers ML17135A415

). The purpose of this document was to evaluate the readiness and reliability of the ITAAC inspection and verification process, specifically during the last year of construction for the new units under construction. As a part of this effort, the NRC conducted two public meetings. The first was a Category II public meeting on April 24, 2017

, described in a memo dated May 18, 2017 ([ADAMS] No. ML17129A262), to demonstrate the agency's capacity to complete ITAAC inspections and notification reviews and validate the agency's agility and decision making processes for handling peak workloads. The second was a Category I public meeting held on December 12, 2017 which was structured to provide the status of staff's action from the 2017 ITAAC demonstration project, and to work through the closeout process of two example ITAAC from consolidation amendments.

Pursuant to the September 29, 2017

, memorandum to you (ADAMS Acc ession No. ML17263A152

), an action plan was developed with deliverable milestones to implement the recommendations of the final report. Th e action plan was included as enclosure 1 of that CONTACT: Ian Cozens

, NRO/DCIP/CIPB (301) 415-6203 F. Brown et al. memo. The recommendations from the final report have been implemented as appropriate and are detailed in enclosure 1 of this memo.

Enclosure:

ITAAC Demonstration Project Action Plan Summary

ML18352A921 *via e-mail NRC-001 OFFICE NRO/DCIP NRO/DCIP RII/DCO RII/DCO NAME OAyegbusi TMcGinty NCoovert* WJones DATE 12/19/18 12/21/18 01/17/19 12/21/18 Enclosure

Enclosure:

ITAAC Demonstration Project Action Plan Completion Summary Recommendation Detailed Action Items Completion Details Weekly Public Meetings

1. Utilize weekly public meetings to facilitate resolution of critical issues associated with Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) closure notification (ICN) and uncompleted ITAAC closure notification (UIN) reviews, including items such as the intent of an ITAAC, ICNs with challenges, methods for resolution of issues, and informed decision making.

In addition, establish standing agenda items during the weekly public meeting to discuss expected ICN submittal workloads to allow early notification of resource needs and critical process points.

Increase the frequency of public meetings to accelerate the resolution of emerging ITAAC closure issues as the surge approaches.

NRC-REG-103, "Inspections, Tests, Analyses, and Acceptance Criteria

[ITAAC] Closure Verification Process," will be updated and publicly released to include process and the purpose of meeting. Completed

- 1 Qtr. 2018 Staff are currently using weekly public meetings to efficiently discuss and address notification issues. The office instruction (OI) NRO

-REG-103 "Inspections, Tests, Analyses, and Acceptance Criteria [ITAAC]

Closure Verification Process," has been updated to include this process. The OI was made publicly available in 2 nd Qtr. 2018.

Clarity in Existing Industry Guidance

2. Develop an FAQ

-type process to provide a forum to document discussions and resolutions of issues associated with the content of ICNs and UINs, which may be due to gaps in existing guidance or interpretation discrepancies.

Assess existing guidance and determine if there is still a need for new process to deal with generic issues associated with the content of ITAAC notifications, or if issues will be dealt under the public meeting process in Recommendation 1.

Document staff assessment.

Completed

- 4 Qtr. 2018 Recommendation is addressed via the public meeting process facilitated by recommendation 1. Discussions regarding the resolution of issues associated with the content of ICNs and UINs are held during the routine weekly public meetings.

Complex ITAAC

3. Work with stakeholders to identify complex ITAAC issues by reviewing early submittals of uncompleted ITAAC notifications and develop clear expectations for the content of the associated ICN submittals. This effort will include identifying when complex ITAAC will be completed during the construction schedule.

Update and publicly release NRC

-REG-103 to capture definition of complex ITAAC, how complex ITAAC are assessed, and how issues will be resolved. Completed

- 4 Qtr. 2017 The Category I public meeting held on December 12, 2017

, facilitated a discussion of complex ITAAC. The public meeting summary is available (ADAMs Accession No. ML17129A262)

The resolution of many issues related to complex ITAAC were determined to be inspection related, and has not been captured in NRO

-REG-103 due to being outside the scope of the office instruction. The term complex ITAAC has been replaced with high schedule risk ITAAC, and associated issues are resolved on an as needed basis.

Nuclear Regulatory Commission (NRC) Processes Guidance Enhancement

4. Revise applicable NRO office instructions to ensure lessons learned and enhancements for the ICN process, identified during this demonstration project, are Update and publicly release NRC-REG-103 to capture: 1) lessons learned and enhancements to the ITAAC review process that enable Completed

- 1 Qtr. 2018 Revisions to NRO

-REG-103 include the criteria for technical reviewer assignment, ending the requirement of institutionalized. The revision should include, but is not limited to, the development of the criteria of when technical reviewer referral is needed during the reviews of ITAAC notifications, the evaluation of the requirement of completing half of targeted ITAAC before completing verification of non

-targeted ITAAC within an ITAAC family, and the involvement of technical staff for all ITAAC notifications related to security and emergency

-preparedness.

Make the revised NRC office instruction NRO

-REG-103 publicly available to give stakeholders insight into the NRC's ITAAC notification review process.

staff to resolve ITAAC closure issues consistently and efficiently

2) the evaluation of the requirement of completing half of targeted ITAAC before completing verification of non

-targeted ITAAC within an ITAAC family

3) criteria for including technical reviewer during reviews of ITAAC notifications completing half of targeted ITAAC before completing verification of non

-targeted ITAAC within an ITAAC family, and process improvement points for review of ICNs, UINs, and ITAAC post closure notifications (IPCNs).

Enhance NRC processes for ITAAC inspection and documentation

5. Enhance NRC processes, including associated governing documents, communications, and training, to ensure timely identification and resolution of concerns or findings material to ITAAC, such that ITAAC inspection results support key activities and milestones in the ITAAC closure verification process.

a. Enhance/develop, as applicable, the following processes: technical assistance requests (TARs), unresolved items (URIs), ITAAC inspection findings, allegations and Complete each of the following items for NRC processes TARs, URIs, ITAAC inspection findings, allegations, and IPCNs. 1) Pilot process enhancement for two topics: Inspection Inputs and ICN Inspection Schedule Accountability, in order to identify lessons learned and incorporate into the Action Plan for other processes.

a. Develop timeliness metrics for Inspection Inputs and ICN Completed

- 2 Qtr. 2018 Staff developed metrics and other process enhancements for inspection inputs and ICN schedules. The region completed a pilot on these items to evaluate methodology and capture lessons learned for other metrics.

From the lessons learned, staff developed metrics on TAR execution, URIs, ITAAC findings, and IPCNs. No additional staff guidance was needed for these processes. For allegations, a petitions, and IPCNs. For TARS, consider the frequency of performing this process; the timeliness of TAR processing; and interactions with licensees for visibility purposes.

b. For inspection findings, consider enforcement actions and internally and externally disputed findings. Consider which NRC process activities, if any, can be done in parallel with the evaluation of an ITAAC technical concer

n. Inspection Schedule Accountability.

b. Execute pilot and evaluate effectiveness of metrics and process enhancements.

c. Finalize metrics from pilot lesson learned. d. Incorporate lessons learned into the development process of additional timeliness metrics (Step 2). 2) Develop process enhancements for the following areas: TARs, URIs, ITAAC inspection findings, allegations and petitions, and IPCNs. a. Develop timeliness metrics for the above areas.

b. Execute and evaluate effectiveness of metrics and process enhancements.

c. Finalize metrics from lesson learned. d. Incorporate lessons learned into the development process of additional timeliness metrics, as determined.

3) Determine if additional guidance is needed for each process affecting ITAAC closures. Create working level guidance (i.e. Desktop Guides) for RII and NRO staff. Revision of guidance documents, such as metric was developed along with additional guidance. A change management plan was developed for training needs and internal communications.

External communications with the public and the licensee regarding timely identification and resolution of concerns or findings material to ITAAC occurs at a minimum bi-annually.

inspection manual chapters (IMCs) and inspection procedures (IPs), will be completed under the regularly scheduled update for each of those documents.

4) Develop and implement change management plan for training needs and communication plan, which includes follow up public meeting, with the licensee and the public.

Performance Dashboards

6. Create an integrated, highly visible, internal, color

-coded performance dashboard to track the status of each step for ICN reviews and inspection process for early identification of ITAAC closure related issues for management attention and resolution.

Specific process steps to measure should include:

The status of each step for ICN reviews. Key aspects of the inspection process, including the timeliness of report issuance, inspection initiators, and inspection outcomes. Potential inspection scheduling or resource issues.

Develop performance dashboards to track the status and timeliness of ICN reviews and ITAAC inspections based on program metrics

. Develop performance dashboards for inspections that affect ITAAC closures to highlight issues based on program metrics. Completed

- 4 Qtr. 2017 Dashboards were developed to provide the ongoing status of ICNs currently under review to NRC management and for public information. The dashboards provide the status of each ICN and UIN under review, the number received and closed per month, and the length of time in review per month.

Dashboards related to inspections have also been developed. These dashboards track the inspection completion status versus those ICNs which have been submitted, and the ITAAC inspection plan completion rate.

The ICN and UIN review dashboards have been developed and are currently being shared through the NRCs public website.

Inspection Scheduling Efficiency

7. Determine the most efficient location and time for inspections. Continue to focus on short

-duration construction activities, such as installing the reactor vessel, which are unlikely to be repeated for additional inspection opportunities.

Additionally, verify that test procedure inspections are scheduled when procedures are issued and available versus when the tests are being performed.

Incorporate scheduling process lessons learned into Desktop Guide(s) including decision making on how to schedule different types of inspections.

Produce a schedule of pre

-op test procedure reviews and tests to verify inspections are scheduled ahead of tests. Completed

- 2 Qtr. 2018 Scheduling process lessons learned have been incorporated into a desktop guide. These lessons learned include decision making on how to schedule different types of inspections. Additionally a schedule of pre

-operational test procedure reviews and process to verify inspections are scheduled ahead of tests has been produced. Timeliness of Inspection Reports

8. Establish timeliness requirements for inspection disposition including inspection completion in CIPIMS and inspection report issuance to support the ITAAC surge and the Title 10 of the Code of Federal Regulations (10 CFR) 52.103(g) finding.

Review existing process(s) for inspection report timeliness requirements, including dispositioning inspection findings for potential efficiencies.

Create or revise working level guidance (i.e. Desktop Guides) for RII and NRO staff to capture efficiencies for inspection report timeliness. Revision of guidance documents, such as IMCs and IPs, will be completed under the regularly scheduled update for each of those documents.

Completed

- 3 Qtr. 2018 IMC 0613 was updated during its regularly scheduled revision. In addition, IMC 0613 captures the issuance of reports independent of the quarterly inspection report to document ITAAC inspections as the scheduled fuel load approaches. Final inspection reports do not need to be issued for the 52.103(g) finding to be made by staff, however the NRC does require that all inspections are complete and no findings were issued.

Maintain Qualified Staff

9. To ensure continued ICN review and inspection capacity, cross

-train additional staff to support ICN workflow capacities and ITAAC inspections.

Update and publicly release NRC-REG-103 to capture the cross-training procedure, including developing a metric to track amount of staff cross

-trained and number of ICN Completed

- 1 Qtr. 2018 The office instruction NRO

-REG-103 has been updated to capture the cross-training procedure in Appendix A5.

For inspector qualification, the NRC will incorporate construction inspector training into IMC

-1245. reviewed in a given year to maintain proficiency in ICN reviews.

Construction inspector qualification will be incorporated into IMC 1245 Appendix C-15 Construction inspector qualification has been incorporated into IMC 1245 Appendix C

-15 which cross

-qualifies new construction inspectors for plants being constructed under 10 CFR Part 52.

Organizational Structures

10. Establish a temporary organizational structure with senior executive leadership approximately 12 months before projected fuel load. This organization would oversee and coordinate the ITAAC closure verification process to ensure appropriate decision making and the prompt identification and resolution of issues. Develop and capture in a memorandum the criteria for establishing a temporary organization to oversee the ITAA C closure verification process.

Completed

- 1 Qtr. 2018 This was developed as part of the Vogtle Readiness Group (VRG) Charter (ML18059A273). The VRG's primary objective is to identify and resolve any licensing, inspection, or regulatory challenges or gaps that could impact the schedule for completion of Vogtle Units 3 and 4. To accomplish this objective, the VRG will provide high

-level assessments, coordination, oversight, and management direction of NRC activities associated with the licensing, inspection, testing, and operation of Vogtle Units 3 and 4. Each of the NRC offices/region and associated staff retains responsibility for the activities related to licensing, inspection, and assessment of Vogtle Units 3 and 4 under their purview.

The VRG will provide periodic status updates to the Directors of NRO and NRR and the Regional Administrator, Region II. These periodic updates will include information on topics such as license reviews; ITAAC inspections; ICNs; operational programs; initial test programs; and startup activities. The updates will also include the status of hearings, contentions, late

-filed allegations, inspection issues, and licensing activities that could impact the project, as applicable. The Directors of NRO and NRR, Region II Regional Administrator, and VRG co

-chairs will determine the frequency of the updates.

External Stakeholders

11. Create a message map on key aspects and updates of the ITAAC process for external stakeholders. Update this message map on a quarterly basis.

Develop a message map that includes key aspects of the ITAAC process.

Update and publicly release NRC-REG-103 to capture that the message map will be reviewed and updated on a quarterly basis.

Completed

- 4 Qtr. 2017 A message map was developed which includes key aspects of the ITAAC process and is available on our public website. The message map will be updated on a quarterly basis, or as needed to reflect recent changes to the process. The process of updating the process map is captured in the office instruction NRO

-REG-103.