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:	William Jones, Mcginty T Division of Construction Inspection and Operational Programs, NRC/RGN-II
To:	Frederick Brown, Catherine Haney Office of New Reactors, NRC/RGN-II
Cozens I, 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 agencys capacity to complete ITAAC inspections and notification reviews and validate the agencys 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 staffs 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 Accession No. ML17263A152), an action plan was developed with deliverable milestones to implement the recommendations of the final report. The 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:

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

1. Utilize weekly public meetings to NRC-REG-103, Inspections, Tests, Completed - 1 Qtr. 2018 facilitate resolution of critical issues Analyses, and Acceptance Criteria associated with Inspections, Tests, [ITAAC] Closure Verification Process, Staff are currently using weekly public Analyses, and Acceptance Criteria will be updated and publicly released to meetings to efficiently discuss and (ITAAC) closure notification (ICN) include process and the purpose of address notification issues. The office and uncompleted ITAAC closure meeting. instruction (OI) NRO-REG-103 notification (UIN) reviews, including Inspections, Tests, Analyses, and items such as the intent of an ITAAC, Acceptance Criteria [ITAAC] Closure ICNs with challenges, methods for Verification Process, has been resolution of issues, and informed updated to include this process. The decision making. OI was made publicly available in 2nd Qtr. 2018.

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.

Enclosure

Clarity in Existing Industry Guidance

2. Develop an FAQ-type process to Assess existing guidance and determine Completed - 4 Qtr. 2018 provide a forum to document if there is still a need for new process to discussions and resolutions of issues deal with generic issues associated with Recommendation is addressed via the associated with the content of ICNs the content of ITAAC notifications, or if public meeting process facilitated by and UINs, which may be due to gaps issues will be dealt under the public recommendation 1. Discussions in existing guidance or interpretation meeting process in Recommendation 1. regarding the resolution of issues discrepancies. associated with the content of ICNs and Document staff assessment. UINs are held during the routine weekly public meetings.

Complex ITAAC

3. Work with stakeholders to identify Update and publicly release NRC-REG- Completed - 4 Qtr. 2017 complex ITAAC issues by reviewing 103 to capture definition of complex early submittals of uncompleted ITAAC, how complex ITAAC are The Category I public meeting held on ITAAC notifications and develop clear assessed, and how issues will be December 12, 2017, facilitated a expectations for the content of the resolved. discussion of complex ITAAC. The associated ICN submittals. This public meeting summary is available effort will include identifying when (ADAMs Accession No. ML17129A262) complex ITAAC will be completed during the construction schedule. 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 Update and publicly release Completed - 1 Qtr. 2018 instructions to ensure lessons NRC-REG-103 to capture:

learned and enhancements for the Revisions to NRO-REG-103 include the ICN process, identified during this 1) lessons learned and enhancements to criteria for technical reviewer demonstration project, are the ITAAC review process that enable assignment, ending the requirement of

institutionalized. The revision should staff to resolve ITAAC closure issues completing half of targeted ITAAC before include, but is not limited to, the consistently and efficiently completing verification of non-targeted development of the criteria of when ITAAC within an ITAAC family, and technical reviewer referral is needed 2) the evaluation of the requirement of process improvement points for review of during the reviews of ITAAC completing half of targeted ITAAC before ICNs, UINs, and ITAAC post closure notifications, the evaluation of the completing verification of non-targeted notifications (IPCNs).

requirement of completing half of ITAAC within an ITAAC family targeted ITAAC before completing verification of non-targeted ITAAC 3) criteria for including technical reviewer within an ITAAC family, and the during reviews of ITAAC notifications 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 NRCs ITAAC notification review process.

Enhance NRC processes for ITAAC inspection and documentation

5. Enhance NRC processes, including Complete each of the following items for Completed - 2 Qtr. 2018 associated governing documents, NRC processes TARs, URIs, ITAAC communications, and training, to inspection findings, allegations, and Staff developed metrics and other ensure timely identification and IPCNs. process enhancements for inspection resolution of concerns or findings inputs and ICN schedules. The region material to ITAAC, such that ITAAC 1) Pilot process enhancement for two completed a pilot on these items to inspection results support key topics: Inspection Inputs and ICN evaluate methodology and capture activities and milestones in the Inspection Schedule Accountability, lessons learned for other metrics.

ITAAC closure verification process. in order to identify lessons learned and incorporate into the Action Plan From the lessons learned, staff

a. Enhance/develop, as applicable, the for other processes. developed metrics on TAR execution, following processes: technical URIs, ITAAC findings, and IPCNs. No assistance requests (TARs), a. Develop timeliness metrics for additional staff guidance was needed for unresolved items (URIs), ITAAC Inspection Inputs and ICN these processes. For allegations, a inspection findings, allegations and

petitions, and IPCNs. For TARS, Inspection Schedule metric was developed along with consider the frequency of performing Accountability. additional guidance.

this process; the timeliness of TAR b. Execute pilot and evaluate processing; and interactions with effectiveness of metrics and A change management plan was licensees for visibility purposes. process enhancements. developed for training needs and internal

c. Finalize metrics from pilot lesson communications. External

b. For inspection findings, consider learned. communications with the public and the enforcement actions and internally d. Incorporate lessons learned into licensee regarding timely identification and externally disputed findings. the development process of and resolution of concerns or findings Consider which NRC process additional timeliness metrics material to ITAAC occurs at a minimum activities, if any, can be done in (Step 2). bi-annually.

parallel with the evaluation of an ITAAC technical concern. 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

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, Develop performance dashboards to Completed - 4 Qtr. 2017 internal, color-coded performance track the status and timeliness of ICN dashboard to track the status of each reviews and ITAAC inspections based on Dashboards were developed to provide step for ICN reviews and inspection program metrics. the ongoing status of ICNs currently process for early identification of under review to NRC management and ITAAC closure related issues for Develop performance dashboards for for public information. The dashboards management attention and inspections that affect ITAAC closures to provide the status of each ICN and UIN resolution. highlight issues based on program under review, the number received and metrics. closed per month, and the length of time Specific process steps to measure in review per month.

should include:

• The status of each step for ICN Dashboards related to inspections have reviews. also been developed. These

• Key aspects of the inspection dashboards track the inspection process, including the timeliness completion status versus those ICNs of report issuance, inspection which have been submitted, and the initiators, and inspection ITAAC inspection plan completion rate.

outcomes.

• Potential inspection scheduling or The ICN and UIN review dashboards resource issues. have been developed and are currently being shared through the NRCs public website.

Inspection Scheduling Efficiency

7. Determine the most efficient location Incorporate scheduling process lessons Completed - 2 Qtr. 2018 and time for inspections. Continue to learned into Desktop Guide(s) including focus on short-duration construction decision making on how to schedule Scheduling process lessons learned activities, such as installing the different types of inspections. have been incorporated into a desktop reactor vessel, which are unlikely to guide. These lessons learned include be repeated for additional inspection Produce a schedule of pre-op test decision making on how to schedule opportunities. procedure reviews and tests to verify different types of inspections.

inspections are scheduled ahead of Additionally a schedule of pre-Additionally, verify that test procedure tests. operational test procedure reviews and inspections are scheduled when process to verify inspections are procedures are issued and available scheduled ahead of tests has been versus when the tests are being produced.

performed.

Timeliness of Inspection Reports

8. Establish timeliness requirements for Review existing process(s) for inspection Completed - 3 Qtr. 2018 inspection disposition including report timeliness requirements, including inspection completion in CIPIMS and dispositioning inspection findings for IMC 0613 was updated during its inspection report issuance to support potential efficiencies. regularly scheduled revision. In addition, the ITAAC surge and the Title 10 of IMC 0613 captures the issuance of the Code of Federal Regulations Create or revise working level guidance reports independent of the quarterly (10 CFR) 52.103(g) finding. (i.e. Desktop Guides) for RII and NRO inspection report to document ITAAC staff to capture efficiencies for inspection inspections as the scheduled fuel load report timeliness. Revision of guidance approaches. Final inspection reports do documents, such as IMCs and IPs, will not need to be issued for the 52.103(g) be completed under the regularly finding to be made by staff, however the scheduled update for each of those NRC does require that all inspections are documents. complete and no findings were issued.

Maintain Qualified Staff

9. To ensure continued ICN review and Update and publicly release Completed - 1 Qtr. 2018 inspection capacity, cross-train NRC-REG-103 to capture the additional staff to support ICN cross-training procedure, including The office instruction NRO-REG-103 has workflow capacities and ITAAC developing a metric to track amount of been updated to capture the inspections. staff cross-trained and number of ICN cross-training procedure in Appendix A5.

reviewed in a given year to maintain Construction inspector qualification has For inspector qualification, the NRC will proficiency in ICN reviews. been incorporated into IMC 1245 incorporate construction inspector Construction inspector qualification will Appendix C-15 which cross-qualifies new training into IMC-1245. be incorporated into IMC 1245 construction inspectors for plants being Appendix C-15 constructed under 10 CFR Part 52.

Organizational Structures

10. Establish a temporary organizational Develop and capture in a memorandum Completed - 1 Qtr. 2018 structure with senior executive the criteria for establishing a temporary leadership approximately 12 months organization to oversee the ITAAC This was developed as part of the Vogtle before projected fuel load. This closure verification process. Readiness Group (VRG) Charter organization would oversee and (ML18059A273). The VRGs primary coordinate the ITAAC closure objective is to identify and resolve any verification process to ensure licensing, inspection, or regulatory appropriate decision making and the challenges or gaps that could impact the prompt identification and resolution of schedule for completion of Vogtle Units 3 issues. 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 Develop a message map that includes Completed - 4 Qtr. 2017 aspects and updates of the ITAAC key aspects of the ITAAC process.

process for external stakeholders. A message map was developed which Update this message map on a Update and publicly release includes key aspects of the ITAAC quarterly basis. NRC-REG-103 to capture that the process and is available on our public message map will be reviewed and website. The message map will be updated on a quarterly basis. 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.