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POLICY ISSUE SECY-06-0041 February 22, 2006
This Commission paper requests approval of a strategy for implementation of the construction inspection program (CIP) for new reactors. The staff will incorporate the Commission's direction into development of the FY 2008 budget, including updating the FY 2007 budget. As discussed in SECY-06-0019, "Semiannual Update of the Status of New Reactor Licensing Activities and Future Planning for New Reactors," which updated the Commission on the status of new-reactor licensing activities, the industry has expressed increased interest in licensing and constructing new reactors. The industry has indicated that the first combined license (COL) applications will be submitted in late FY 2007, with fabrication of large components beginning about 18 months after a COL application is submitted. Although detailed industry schedules for new construction activities are not currently available to the staff, the above general schedule requires the staff to budget resources for the associated inspection activities as part of the FY2007-2008 budget cycle, in order to be prepared to begin construction related inspection activities as early as FY 2009. Additionally, depending on the staffing strategy selected, the staff may need to begin efforts soon to obtain office space to support the increase in staff. To prepare for the construction of new reactors licensed in accordance with 10 CFR Part 52, a new construction inspection program (CIP) is being developed. The new CIP builds on the lessons learned from the construction of the existing fleet of operating reactors. The CIP comprises four different parts, and is described in Inspection Manual Chapter (IMC) 2501, "Early Site Permit Inspections"; IMC 2502, "Pre-Combined License (Pre-COL) Inspections"; IMC 2503, "ITAAC Inspections"; and IMC 2504, "Non-ITAAC Inspections." These Inspection Manual Chapters will cover all aspects of the inspection program from early site preparation work, through construction, to the transition to inspections under the Reactor Oversight Process for operating reactors. IMCs 2501 and 2502, and the associated inspection procedures, are in place. IMCs 2503 and 2504, and their inspection procedures, are under development, and are scheduled to be in place well before the start of on-site construction activities. The results of inspections conducted under IMC 2503, "ITAAC Inspections," will support the Commission in determining whether the acceptance criteria in the combined license are met, as required by 10 CFR Part 52.103(g). Successful implementation of the CIP, as described in IMCs 2501 through 2504, will require four main functions: 1) day-to-day inspections at the construction site, 2) on-site inspections by specialist inspectors, 3) off-site inspections (e.g., vendor inspections), and 4) documentation and public notification of the successful completion of the inspections, tests, analyses and acceptance criteria (ITAAC). ITAAC are part of the combined license and define specific requirements to be met during construction. A functional statement for each of the above four areas is enclosed (Enclosure 1 The staff considered various options for allocating the work necessary to support the implementation of the CIP in the other functional areas. The staff first concluded that:
These conclusions are consistent with past staff practices. The primary issues remaining are: (1) where to locate the specialist inspection resources and (2) how to assign those resources to conduct construction inspections. In considering these two issues, the staff concluded that the following benefits apply equally to Option 1, 2 and 3.
The staff considered the following four options in detail. A list of the benefits and challenges of the options discussed below is enclosed (Enclosure 2
In general, locating all specialist inspectors in a single region offers the benefit of efficient staff utilization and improved communication among inspectors. This option has significant challenges including human capital and infrastructure issues arising from a large staff increase in a single region. The construction inspection program may have a negative impact on the operating reactor focus in the region where the specialist inspectors are assigned. Option 1 also complicates scheduling of specialist inspections because three of the regions would need to coordinate with the one region with the resources in order to obtain staff to complete some inspections. This option also largely removes a significant aspect of construction inspection from the other three regional offices, although each region will ultimately have responsibility for assuring the adequacy of construction for sites within its geographic area. The regional administrator of the selected region will be faced with managing both an operating inspection organization and a construction inspection organization.
In general, locating specialist inspectors in each region offers a greater opportunity for each regional administrator to directly control the construction inspection program for his or her region. In addition, accountability for inspection program completion is clear. Staffing on-site inspections by specialist inspectors would require less coordination with other regions and, when assistance from other regions was needed, would be accomplished consistent with the present staffing approach for operating reactors. This option also offers the benefit of facilitating communication with external stakeholders by allowing the region to build on existing outreach efforts. Under Option 2, regions where the number of construction projects is low would face the challenge of minimizing construction inspection staff underutilization.
In general, establishing a center of construction expertise in a single region and assigning each region some specialist inspectors would allow each region to expand its knowledge base in the construction area and would promote greater consistency in implementation of the construction inspection program. This option is arguably more flexible and would be better able to respond to uncertainties in the number of plants to be built. A significant challenge with Option 3 is that responsibility for completion of the inspection program would be distributed. In addition, like Option 1, this option would significantly increase the size of the staff in the region selected as the center of construction expertise, not only because a majority of the inspectors would be assigned to one region, but also because of the addition of onsite inspection staff for each construction site within that region. This option would also complicate the scheduling of resources.
In general, establishing a Construction Inspection Office would improve the consistency of the implementation of the construction inspection program nationwide. This option provides clear accountability for completion of the inspection program and eliminates the potential for diverting attention from operating reactors. Human capital benefits include more focused recruiting. A significant challenge associated with Option 4 is that the regional staff will be disconnected from the plant as it is being constructed. Other challenges include high potential impact if experienced inspectors are transferred to initially staff the organization. If experienced inspectors are not used, there will be significant training needed to adequately prepare new inspectors. Option 4 also has the potential to cost more than the other options. The costs would be associated with establishing a new organization at a new location. This paper contains no new commitments. The staff will implement the construction inspection program consistent with the Commission's direction. The staff recommends that the Commission approve Option 2. Under Option 2 each regional administrator will be provided the resources needed to accomplish the construction program for each new reactor unit in his or her region, thereby largely eliminating the coordination challenges created by the other options. As noted above, Option 2 is consistent with past staff practices. Because so much time has passed since the staff has had significant experience with "ground up" construction, the staff concludes that the best approach to staffing is the traditional approach. The staff anticipates that some use of contractor resources will likely be required and this will be coordinated by NRR. The Office of the General Counsel has reviewed this paper and has no legal objection to its content. The Office of the Chief Financial Officer has reviewed this paper for resource implications and has no objections.
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). Options for implementation of the vendor function within the CIP are still being developed.