**NRC INSPECTION MANUAL** NMSS/FCSS

MANUAL CHAPTER 2630

MIXED OXIDE FUEL FABRICATION FACILITY CONSTRUCTION INSPECTION PROGRAM

2630‑01 PURPOSE

The purpose of this Inspection Manual Chapter (IMC) is to define the
Construction Inspection Program (CIP) for the Mixed Oxide (MOX) Fuel
Fabrication Facility (MFFF). Specifically, the CIP will (1) verify that
the design bases of the principal systems, structures, and components
(PSSCs) and the Quality Assurance (QA) Program are being adequately
implemented during construction to provide reasonable assurance of
protection against natural phenomena and the consequences of potential
accidents; and (2) verify that the construction of the PSSCs and items
relied on for safety (IROFS) have been completed in accordance with the
construction authorization and license application to possess and use
special nuclear material in the MFFF.

Under a U.S. Department of Energy (DOE) initiative to determine options
for the disposition of surplus plutonium from the weapons program, DOE
selected an approach of fabricating mixed oxide fuel for use in
commercial nuclear power plants, and selected the Savannah River Site
for the MFFF. The Defense Appropriations Act of 1999, Section 202 of the
Energy Reorganization Act of 1974, was amended to require U.S. Nuclear
Regulatory Commission (NRC) licensing of the facility for fabricating
mixed plutonium-uranium oxide nuclear reactor fuel for use in commercial
nuclear reactors. NRC will perform the licensing under the provisions of
10 CFR Part 70.

Before an applicant is granted a license to operate a plutonium
processing and fuel fabrication plant, the Commission must verify that
the construction of the PSSCs has been in accordance with the
application. In addition, the license application must include a
description of the applicant\'s safety program and a summary of the
integrated safety analysis (ISA). The safety program must demonstrate
that each IROFS will perform its intended function to limit risks at the
facility. The safety program is composed of process safety information,
ISA, and management measures.

The MFFF CIP applies to all construction activities, including, the
design, procurement, fabrication, construction, and pre-operational
testing activities. Implementation of this IMC will begin at an
applicable time as determined by NRC, but no later than the NRC issuance
of the construction authorization, and will continue through facility
construction activities as noted above.

2630‑02 OBJECTIVES

The primary objective of this manual chapter is to establish a CIP for
inspecting PSSCs and IROFS and inspecting associated activities that are
conducted by the applicant and its consultants, contractors, and
suppliers, to support the decision on issuance of a license to possess
and use special nuclear material in the MFFF. The following objectives
are included in the CIP:

02.01 Provide reasonable assurance that regulatory requirements and
applicant commitments for design bases, quality assurance, and
management measures are adequately included in the design, procurement,
and construction of the MFFF.

02.02 Provide reasonable assurance that the MFFF and the associated
PSSCs and IROFS were constructed in accordance with the quality
assurance program, construction authorization, and license application
to possess and use special nuclear material.

02.03 Verify the effective implementation of a safety program that
includes the following elements: process safety information, ISA, and
management measures.

02.04 Verify the effective implementation of the quality assurance
program as specified in the MOX Project Quality Assurance Plan (MPQAP)
and that it includes timely implementation of organizational staffing,
procedures, instructions, QA activities, and administrative controls
necessary to achieve quality objectives important to safety.

02.05 Identify conditions that may adversely affect public and worker
safety so that appropriate corrective actions can be taken.

02.06 Conduct risk-informed and performance based inspections across key
functional areas to support the decision on issuance of a license to
possess and use special nuclear material in the MFFF.

2630-03 DEFINITIONS

03.01 [Construction Authorization Request (CAR).]{.underline}
Document(s) submitted by the applicant providing a description of the
facility site; a description and safety assessment of the design bases
of the principal SSCs of the facility; and a description of the MPQAP.

03.02 [Design Bases.]{.underline} Information that identifies the
specific functions to be performed by a PSSC, and the specific values or
ranges of values chosen for controlling parameters as reference bounds
for design.

03.03 [In-Office (or Field) Review]{.underline}. Assessments, audits, or
reviews conducted to assess licensing related activities.

03.04 [Inspection]{.underline}. Measures consisting of examinations,
observations, or measurements to determine the conformance of materials,
parts, SSCs, services, or processes to predetermined quality
requirements. Activities include performing audits, inspections,
surveillance, and observations.

03.05 [Inspection Types]{.underline}. Inspections are classified as
compliance-based or performance-based and are defined below.

a\. Compliance-based inspections emphasize inspection of compliance with
prescriptive NRC requirements or regulatory commitments that specify
SSCs important to safety (as in the applicant=s CAR), features, actions,
or programmatic elements.

b\. Performance-based inspections emphasize inspection of actual
activity performance and results. Performance-based inspections require
measurable or calculable parameters and objective performance assessment
criteria. Note that a performance-based approach does not change the
need for compliance with NRC requirements. In addition, a
performance-based approach is typically more applicable to an operating
facility and may not be appropriate to perform certain construction or
pre-operational inspections.

03.06 [Items Relied on for Safety (IROFS)]{.underline}. Structures,
systems, equipment, components, and activities of personnel that are
relied on to prevent potential accidents at a facility that could exceed
the performance requirements in 10 CFR 70.61 or to mitigate their
potential consequences. This does not limit the licensee from
identifying additional structures, systems, components, or activities of
personnel (i.e., beyond those in the minimum set necessary for
compliance with the performance requirements) as items relied on for
safety.

03.07 [Management Measures]{.underline}. The functions performed by the
licensee, generally on a continuing basis, that are applied to items
relied on for safety, to ensure the items are available and reliable to
perform their functions when needed. Management measures include
configuration management, maintenance, training and qualifications,
procedures, audits and assessments, incident investigations, records
management, and other quality assurance elements.

03.08 [MFFF startup]{.underline}. Activities associated with the cold
start-up or hot start-up of the MFFF as defined below.

a\. [Cold Start-up]{.underline}. Pre-operational inspection, testing, or
measurement activities not involving the use of licensed material on
MFFF process systems or components.

b\. [Hot Start-up]{.underline}. Pre-operational inspection, testing, or
measurement activities involving the use of NRC licensed material on
MFFF systems or components.

03.09 [Mixed Oxide (MOX) fuel]{.underline}. For the purposes of this
manual chapter, a mixture of plutonium dioxide (PuO~2~) in a depleted or
natural uranium oxide (UO~2~) matrix. Approximately 95% of the MOX
material is composed of UO~2~. The MOX fuel is characterized in terms of
plutonium isotopics as reactor-grade or weapons-grade.

03.10 [MOX Project Quality Assurance Plan (MPQAP)]{.underline}. The
applicant=s or licensee=s plan that defines the actions taken by
applicant or licensee management and personnel during the performance of
quality-affecting activities on the project to ensure quality assurance
requirements are consistently met.

03.11 [Operational Readiness Review (ORR)]{.underline}. An assessment
review inspection performed by a multi-disciplined inspection team to
assure that a facility, or a major modification to a previously approved
facility, can be operated safely within the intended safety basis. In
order to support a decision on issuance of a license to process special
nuclear material, NRC will review and assess the state of readiness of
facility operation based on the results of the ORR inspection.

03.12 [Principal Systems, Structures, and Components
(PSSCs)]{.underline}. Safety controls, required support systems, and
associated safety functions identified in the design bases of the
applicant=s CAR that are required to satisfy the performance
requirements of 10 CFR 70.61.

03.13 [Quality Assurance (QA) Program.]{.underline} The applicant=s or
licensee=s overall QA program to be applied to the design, fabrication,
construction, testing, and operation of the SSCs. This includes the
MPQAP, QA procedures, and all supporting procedures and program
activities. The quality assurance program also provides a management
control system to assure the attainment of quality objectives.

2630-04 RESPONSIBILITIES AND AUTHORITIES

04.01 [Office of Nuclear Material Safety and Safeguards
(NMSS)]{.underline}.

a\. Responsible for regulatory oversight of the MOX Fuel Fabrication
Facility Project.

b\. Responsible for the overall safety inspection program policy,
guidance, and approval.

c\. Responsible for the planning, performance, documentation, and
enforcement associated with the aspects of the Headquarters criticality
safety inspection program.

04.02 [Region II Office]{.underline}.

a\. Ensures that adequate resources necessary to carry out the
inspection process described in this IMC are provided to the staff.

b\. Responsible for the planning, performance, documentation, and
enforcement associated with the aspects of the inspection program that
are performed by Region II.

c\. Responsible for developing and maintaining the procedures to
implement the Construction Inspection Program for the MFFF Project.

d\. Concurs on the approval of the IMC and inspection procedures for
activities relating to the MFFF.

04.03 [Office of Nuclear Security and Incident Response]{.underline}.

a\. Responsible for the overall safeguards inspection program policy,
guidance, and approval.

b\. Responsible for the planning, performance, documentation, and
enforcement associated with the aspects of the Headquarters Material
Control and Accounting inspection program.

c\. Concurs on the approval of the IMC and inspection procedures for
activities relating to the safeguards aspects of the MFFF.

2630-05 BASIC REQUIREMENTS

05.01 [General]{.underline}. The MFFF Construction Inspection Program
provides the inspection requirements for selectively assessing the
adequacy of PSSCs, IROFS, regulatory and safety-related programs. This
includes the implementation of the applicant=s QA program and other
management measures used to ensure the availability and reliability of
safety and safeguards PSSCs/IROFS. Substantial emphasis is to be placed
on the inspection of the PSSCs/IROFS that are most important for
reducing the likelihood of high- and intermediate- consequence accidents
through the implementation of commitments made by the applicant in the
CAR, the ER, the MPQAP, and the license application.

Emphasis is also to be placed on the applicant=s activities that assure
principal contractors delegated authority to conduct activities related
to safety are implementing an acceptable QA program in accordance with
the applicant=s QA program. The inspection program provides for the
direct inspection throughout all stages of construction, including
equipment fabrication, assembly and installation, and structural
construction activities as may be necessary to ascertain whether
elements of the QA program are being effectively implemented.

05.03 [Inspection Planning and Scheduling Considerations]{.underline}.
The MFFF construction phase inspection schedule should be based on the
applicant=s construction schedule and should be modified and updated
periodically during the entire construction period.

Inspections should be coordinated and scheduled such that the efficiency
and effectiveness of the inspection effort is enhanced and unnecessary
burden to the applicant is minimized. To the extent practicable, the
construction and pre-operational inspections should be coordinated with
the applicant to ensure that key construction activities are in
accordance with the site construction project schedule. As appropriate,
inspections of various construction activities should be scheduled as
unannounced inspections.

Emphasis should be placed on early identification of problems.
Inspections will be conducted periodically throughout the construction.
Inspections will be scheduled early in the process implementation of
individual construction activities to develop confidence that the
specific construction activities have been adequately accomplished at
all stages of construction.

Comprehensive construction program reviews aimed at determining
underlying causes and extent of problem areas should be conducted if NRC
management concludes significant deficiencies are occurring. Inspection
depth and frequencies may be expanded to assure problem areas have been
corrected. Corrective action programs are essential to effective
resolution of individual deficiencies and programmatic issues.
Inspection effort should be planned to specifically evaluate program
effectiveness.

NRC Region II will develop, maintain and implement a Master Inspection
Plan (MIP) and schedule for the MOX FFF construction inspection project.
The MIP will be developed in coordination with the Technical Support
Group (TSG) and Special Projects Branch (SPB) and for specific time
frames related to licensing or construction milestones for the project.
The MIP will include the scope and the inspection procedures that will
be used for the inspections. The list of procedures for conducting
inspections is provided in Appendix A of this IMC. The MIP will provide
flexibility to address emerging issues that require additional
inspection efforts, receipt of allegations, changes in funding
activities by DOE or changes in scheduling activities by the applicant.

05.04 [Inspection and Technical Personnel Considerations]{.underline}.
Certified inspectors will be assigned responsibility for the conduct of
applicable inspection requirements consistent with their qualifications.
In conducting this inspection program, it is necessary that inspectors
be trained and/or experienced in the areas of QA, engineering,
procurement, and construction activities applicable to the activities
they are to inspect. Specialists may accompany or assist inspectors to
provide expertise in specific areas to enhance or expand the inspection
effort.

05.05 [Resident Inspector Program]{.underline}. Region II management
will designate a primary interface inspector. Resident inspector(s) may
be assigned to the site during the various phases of construction. The
Senior Resident Inspector would normally be the primary interface with
the applicant for coordination of inspection scheduling for specific
construction activities. The resident inspector(s) should also
participate in inspections within their areas of qualification using the
inspection procedures listed in Appendix A and coordinate the
preparation of integrated inspection reports. The resident inspector(s)
may be assigned to the site on a rotational basis during construction,
and may be changed periodically, based on the type of construction
activities being conducted.

2630-06 GUIDANCE

06.01 [General]{.underline}. The applicant/licensee is ultimately
responsible for the safety of the nuclear facility. The NRC ensures
through an audit type of inspection program that the responsibility is
carried out in an effective manner during the activities of facility
construction. The construction inspection program presented in this
manual chapter is considered the minimum necessary to achieve an
acceptable level of confidence as to the adequacy of construction at the
facility.

This IMC emphasizes a systematic evaluation of the adequacy and
effectiveness of the applicant=s QA and construction programs and their
implementation. NRC will perform inspections of selected activities at
the applicant=s or licensee=s project offices at the proposed MFFF site
and other project facilities. Inspections will also be performed, as
necessary, at the facilities of the applicant=s consultants,
contractors, and suppliers. This IMC establishes priorities for
inspection by planned sampling of PSSCs/IROFS and related activities
consistent with their importance to safety and should consider the
performance of the applicant in the areas inspected.

06.02 [Program Areas]{.underline}. The specific areas to be inspected
will include a sampling of the applicant=s PSSCs/IROFS and regulatory
and safety commitments as identified in the approved CAR and in the
latest revision of the approved MPQAP. PSSCs/IROFS for inspection will
be chosen based on safety significance and evaluated through an
integrated approach with respect to multiple safety disciplines
(criticality, fire, chemical, radiological, environmental) and
engineering disciplines (civil, mechanical, electrical).

The NRC will periodically inspect the applicant=s programs for adequate
assurance that PSSCs/IROFS are designed, procured, fabricated, and
installed in accordance with approved design bases. The inspections will
also ensure that as-built construction meets the approved design. In
addition, the applicant=s design change and design control process will
be reviewed to gain additional assurance that the design process used
for the facility effectively implemented NRC requirements and other
licensing design commitments made by the applicant. These reviews may be
accomplished by multi-disciplinary technical review and/or inspection
teams to verify the quality of design products and, inferentially, the
entire facility design. Inspections will verify reasonable assurance
that the environmental protection programs are consistent with the CAR
and its associated SER, the environmental report, and design
specifications and drawings.

06.03 [Inspection Procedures]{.underline}. The planned IPs for the
construction inspection program are listed in Appendix A. Some IPs may
cover more than one program area and additional IPs may be prepared as
necessary.

06.04 [Implementation]{.underline}. Region II is responsible for
managing and implementing the inspection program described in this IMC.
The scheduling and conduct of inspections will be coordinated with
Region II and FCSS, as appropriate, to ensure the effective and
efficient completion of the inspection program.

This IMC is intended to provide the framework for managing the
inspection effort. Where needed, sample sizes, frequencies of periodic
inspections, and the time frame when certain inspection activities are
to be performed are provided in the appropriate Inspection Procedure
and/or inspection plan.

The inspection staff is expected to plan and conduct assessments,
audits, inspections, surveillances, and observations based on safety
considerations, current activities, and performance. Region II staff
should develop, on at least an annual basis, a schedule of inspections
to be conducted, based on the anticipated site activities that are to be
performed in the upcoming year. Region II staff should review and revise
the schedule as needed to account for changes in site activities. Region
II management should inform FCSS and document any changes from the
planned inspections. The activities for conducting inspections should
include the following:

a\. Developing and documenting detailed inspection plans.

b\. Scheduling and coordinating inspection activities in accordance with
this IMC.

c\. Communicating inspection results, findings, and open items to
appropriate NRC and applicant or licensee management.

d\. Documenting completed inspections, findings, and open items.

Inspection issues related to occupational health and safety should be
evaluated in accordance with IMC 1007, AInteraction Activities Between
Regional Offices and OSHA.@

06.05 [Inspection and Technical Personnel Considerations]{.underline}.
Inspectors and technical representatives will be assigned responsibility
for performing inspections consistent with their qualifications. In
addition, inspectors performing MOX inspection activities will either be
provided familiarization training on this IMC and related procedures or
become familiar with the requirements of this IMC and the applicable
requirements of 10 CFR Part 70.

06.06 [Inspection Requirements]{.underline}. Inspections will be based
on 10 CFR Part 70 and other applicable regulations, commitments,
conditions, the CAR, the applicable SER, and the construction
authorization. Inspections will confirm that applicable regulations,
requirements, and commitments have been met. Selection of inspection
attributes will be based on safety considerations, status of work
activities, and performance.

06.07 [Focus of Inspections]{.underline}. In order to effectively and
efficiently allocate inspection resources, the NRC will perform
sampling-type inspections to verify that the applicant/licensee is in
compliance with NRC regulations. A combination of PSSCs/IROFS sample
selection, statistical methods, risk-based approaches, and inspections
of the quality assurance program, will be used to help determine the
necessary level of inspection effort.

Risk based information from the applicant=s license submittals, process
hazards analyses, and ISAs should be used to identify those PSSCs and
IROFS whose failure would most greatly impact the MFFF=s risk profile.
This approach would allow the more risk significant PSSCs and IROFS to
be identified so that the construction and pre-operational inspection
samples could be focused on those PSSCs and IROFS. The amount of
inspection and activities selected for inspection should be consistent
with the importance to safety of the PSSCs, IROFS, and the performance
of the applicant or licensee in those areas.

It should be noted that a performance-based approach is more directly
applicable to an operating facility and may not be readily applied to
construction or pre-operational inspections. In the early stages of the
project, the majority of inspections may be compliance-based and will
focus on QA program implementation. Inspection activities should
emphasize the early identification of problem areas. It is important
that inspectors evaluate whether noted problems represent isolated cases
or are symptomatic of more systemic problems. To provide the perspective
to perform this evaluation, inspectors should:

a\. Focus inspections on the compliance of previously identified problem
areas and/or on recurring problems.

b\. Focus inspection efforts on problems that indicate programmatic
weaknesses.

c\. Periodically, verify the adequacy of the applicant=s corrective
action program to identify, track, trend, resolve, and prevent problem
recurrence.

d\. Review deficiencies, audit findings, and problems identified by the
applicant or by its consultants, contractors, or suppliers to identify
trends and/or problem areas; and

e\. Ascertain whether additional NRC inspection effort is merited in the
areas of concern.

06.08 [Management Entrance and Exit Meetings]{.underline}. Inspectors
are required to meet with applicant management as part of every
inspection. Inspectors should hold an entrance meeting with the senior
applicant representative who has responsibility for the areas to be
inspected. Each inspection must include the discussion of inspection
results with applicant management. At the conclusion of an inspection,
inspectors must discuss their preliminary findings with the applicant=s
management at a scheduled exit meeting. Management entrance and exit
meetings with applicant personnel should be scheduled to minimize the
impact on other applicant activities necessary to assure the safe and
proper construction of the facility.

06.09 [Inspection Reports]{.underline}. Inspection findings shall be
documented in inspection reports in accordance with the applicable
revision to IMC 0610, AInspection Reports.@ The inspection findings
should be integrated into a single inspection report to encompass
findings from resident inspections, in-office reviews, and/or one or
more visits by regional or headquarters inspectors over a specific
period of time (e.g., a 6-week period). Special inspections may be
documented in a separate inspection report. Inspection issues that
cannot be resolved at the time of the inspection will be documented as
open items, inspection follow-up items, or unresolved items, in
accordance with IMC 0610. Region II will track open items in an
inspection program information management system and subsequent
inspections will include resolution of these issues.

06.10 [Findings Outside of Inspector=s Qualifications]{.underline}.
Inspectors sometimes identify issues or violations outside of the
inspector=s qualifications or expertise. In these cases, the inspector
is responsible for (1) determining if an immediate threat to the public
or worker health or safety exists, and if one does exist to notify
applicant management immediately; and (2) determining if the issue is
better addressed by an inspector with different qualifications (i.e., a
specialist inspector). Inspectors may follow issues outside of their
qualifications or expertise with the concurrence of a regional manager
responsible for the area associated with the issue and the inspector=s
supervisor.

06.11 [Communication With Local Public Officials]{.underline}. As a
matter of NRC philosophy, the NRC maintains an Aopen door@ policy with
regard to access by the public or federal, state and local officials to
the NRC staff and to publicly available electronic documentation
concerning an applicant\'s performance. The degree of interaction that
is considered necessary to enhance public confidence in the NRC is
expected to vary widely dependant upon the situation at each facility.
Guidance pertaining to communication with stakeholders external to the
NRC can be found in the latest revision of the Communication Plan for
the MFFF and applicable regional office procedures.

06.12 [Inspection Findings and Enforcement]{.underline}. All inspection
findings identified during the construction and pre-operational periods
will be documented in accordance with the applicable revision to IMC
0610 after they have been placed in context and assessed for safety
significance. Potential violations from inspection activities will be
processed in accordance with the NRC=s Enforcement Policy, NUREG-1600,
AGeneral Statement of Policy and Procedures for NRC Enforcement
Actions,@ using traditional enforcement tools. The inspection findings
(or open items) will then be categorized as violations, deviations,
non-conformances, unresolved items, or inspector follow-up items. This
includes the use of notices of violations for violations of severity
level IV and above and civil penalties, as appropriate.

It is important to note that if the applicant or licensee has been
granted the authorization to begin construction of the MFFF, and the NRC
determines that the construction is not in accordance with the
applicant\'s commitments, then the operating license may be denied (see
10 CFR 70.23(a)(8)). The failure of the applicant or licensee to meet
commitments specified in the CAR shall be documented in the inspection
report(s) as noted above. It is imperative that open items be
appropriately documented in the inspection reports so that subsequent
inspections can verify whether or not the applicant took the appropriate
corrective actions. The failure of the applicant to take the appropriate
corrective actions to address the open items by the end of the
construction phase could result in either a denial to issue the
operating license or a delay in the issuance of the operating license.

06.13 [Assessment of Applicant Performance (AAP)]{.underline}. Different
types of construction activities may require certain levels of
inspection effort to provide the same degree of assurance of quality
work. Increases or decreases in inspection oversight will be based on an
assessment of applicant performance. Periodic reviews of the applicant=s
performance of construction and pre-operational activities may be
warranted to provide NRC management with an overview of the applicant=s
performance, and provide feedback of NRC management=s conclusions
regarding the quality of the applicant=s programs for protecting the
public health and safety. An objective of the program is to provide a
body of information that will be used as guidance to NRC management on
changes that may be required in the MFFF construction and
pre-operational inspection programs. IMC 2604, ALicensee Performance
Review@ describes the program for conducting and documenting evaluations
of licensee performance for operating fuel cycle facilities. Appendix B
provides guidance to assess the applicant=s performance in the
construction phase of the MFFF. The responsibilities and authorities,
performance review scheduling, review process, and documentation
guidelines, specified in IMC 2604 should be used in conducting the AAP.
Region II is responsible for adjusting the scope and frequency of the
review during the construction phase, as needed, based on MFFF
construction schedules and inspection findings.

06.14 [Operational Readiness Reviews]{.underline}. The NRC may consider
the use of phased operational readiness review (ORR) inspections as a
tool to provide input for NRC decisions regarding the operational
readiness of MFFF areas or processes. In order to support a decision on
issuance of a license to process special nuclear material, NRC senior
management reviews and assesses the state of readiness of facility
operation based on the results of the ORR inspection(s). The status of
previously identified inspection findings are also considered during the
decision-making process.

END

Appendix A

MIXED-OXIDE (MOX) FUEL FABRICATION FACILITY INSPECTION PROGRAM

CONSTRUCTION PHASE INSPECTION PROCEDURES

(INSPECTION PROCEDURES MAY BE ADDED OR DELETED AS REQUIRED)

+---------+------------------------------------------------------------+
| QA      |                                                            |
| Ins     |                                                            |
| pection |                                                            |
| Pro     |                                                            |
| cedures |                                                            |
+---------+------------------------------------------------------------+
| IP      | Quality Assurance: Program Development and Implementation  |
| 88106   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Quality Assurance: Design and Documentation Control        |
| 88107   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Quality Assurance: Control of Materials, Equipment, and    |
| 88108   | Services                                                   |
+---------+------------------------------------------------------------+
| IP      | Quality Assurance: Inspection, Test Control, and Control   |
| 88109   | of Measuring and Test Equipment                            |
+---------+------------------------------------------------------------+
| IP      | Quality Assurance: Problem Identification, Resolution, and |
| 88110   | Corrective Action                                          |
+---------+------------------------------------------------------------+
| IP      | 10 CFR Part 21 Inspection-Facility Construction            |
| 88111   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Software Validation                                        |
| 88112   |                                                            |
+---------+------------------------------------------------------------+
| IP88113 | Control of the Electronic Management of Data               |
+---------+------------------------------------------------------------+
| IP      | Quality Affecting Item Procurement (10 CFR Part 21) and    |
| 88114   |                                                            |
|         | Commercial Grade Item Dedication Process (Reactive)        |
+---------+------------------------------------------------------------+
| IP      | Supplier/Vendor Inspection                                 |
| 88115   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Inspection of Quality Assurance Interfaces                 |
| 88116   |                                                            |
+---------+------------------------------------------------------------+
| R       |                                                            |
| esident |                                                            |
| In      |                                                            |
| spector |                                                            |
| Pro     |                                                            |
| cedures |                                                            |
+---------+------------------------------------------------------------+
| IP      | Resident Inspection Program for On-Site Construction       |
| 88130   | Activities at the Mixed Oxide Fuel Fabrication Facility    |
+---------+------------------------------------------------------------+
| Const   |                                                            |
| ruction |                                                            |
| Ins     |                                                            |
| pection |                                                            |
| Pro     |                                                            |
| cedures |                                                            |
+---------+------------------------------------------------------------+
| IP      | Geotechnical/Foundation Activities                         |
| 88131   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Structural Concrete                                        |
| 88132   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Structural Steel and Supports                              |
| 88133   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Piping Relied on For Safety                                |
| 88134   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Pipe Supports and Restraints                               |
| 88135   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Mechanical Components                                      |
| 88136   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Electric Cable                                             |
| 88137   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Electrical Components and Systems                          |
| 88138   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Ventilation and Confinement Systems                        |
| 88139   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Instrumentation and Control Systems                        |
| 88140   |                                                            |
+---------+------------------------------------------------------------+
| IP      | Nuclear Welding General Inspection Procedure               |
| 55050   |                                                            |
+---------+------------------------------------------------------------+

  ----------------- ------------------------------------------------------------
  IP 55100          Structural Welding General Inspection Procedure

  IP 88141          Procedures- Fire Prevention/Protection

  IP 88142          Underground Fire Water Loop and Equipment Installation

  Pre-Operational   
  Inspection        
  Procedures        

  IP 88150          Training and Qualification of Plant Personnel

  IP 88151          Facility Changes and Change Process (10 CFR 70.72)

  IP 88152          Physical Protection Equipment and Barriers

  IP 88153          Material Control and Accounting

  IP 88154          Fire Safety and Protection Systems

  IP 88155          Functional Verification IROFS

  IP 88156          Integrated Safety Analysis Implementation

  IP 88157          Waste Management Equipment and Systems

  IP 88158          Environmental Protection-Initial and Periodic Inspections

  IP 88159          Process Enclosures and Vessels

  IP 88160          Utilities and Bulk Chemicals

  IP 88050          Emergency Preparedness
  ----------------- ------------------------------------------------------------

Appendix B

MIXED-OXIDE (MOX) FUEL FABRICATION FACILITY

ASSESSMENT OF APPLICANT PERFORMANCE (AAP) PROCESS -

1\. PURPOSE

This appendix provides guidance for assessing the applicant=s
performance in the construction phase of the MOX fuel fabrication
facility (MFFF) and to provide feedback of NRC management=s conclusions
regarding the quality of the applicant=s/licensee=s construction and
pre-operational programs. The results of such a review should:

-   Provide an assessment of applicant performance to U.S. Nuclear
    Regulatory Commission (NRC) management.

-   Inform the applicant/licensee and the public how the NRC assesses
    facility performance.

-   Provide a basis for adjusting the construction and pre-operational
    inspection program, including such areas as focus, frequency, and
    resources.

2\. OBJECTIVES

2.1. To describe the processes for assessing MFFF performance.

2.2. To ensure that the assessments are performed in a timely,
effective, and efficient manner.

2.3. To ensure that the assessments are focused on determining whether
safety has been adequately and effectively maintained.

3\. DEFINITIONS

3.1 [Functional Areas]{.underline}. The following definitions describe
the program and functional areas that form the basis for the Assessment
of Applicant Performance (AAP). It should be noted that depending on the
stage of the construction project, not all functional areas would be
applicable during a given assessment period. Each functional area is
comprised of two or more inspection program areas.

a\. [Management Measures]{.underline}. Activities involving
implementation of the applicable management measures as described in the
applicant=s quality assurance program.

1\. [Quality Assurance]{.underline}. Verifying that the applicant has
implemented the controls as established in the DCS MPQAP (all sections).

2\. [Design Control]{.underline}. Verifying the control of the design of
PSSCs, IROFS, and for activities associated with the preparation,
review, approval, and verification of documents used for design,
procurement, and fabrication;

3\. [Categorization of Systems, Structures and Components.]{.underline}
Verifying the proper implementation of a graded QA approach to the
categorization of PSSCs and IROFS, based on safety significance;

4\. [Configuration Management]{.underline}. Verifying the configuration
management system for documenting an established baseline configuration
and controlling changes to PSSCs and IROFS to preclude inadvertent
degradation of safety and verifying that a system to evaluate,
implement, document, and track each change to the site, PSSCs, IROFS,
processes, equipment, computer programs, and activities of personnel has
been established and implemented.

5\. [Procedures]{.underline}. Verifying the control of management
procedures with regard to distribution, version control, management
review and approval;

6\. [Audits and Assessments]{.underline}. Verifying the performance of
audits and assessments required during construction;

7\. [Records Management]{.underline}. Assessing the records management
system for the handling and storing of records generated or required in
the design, construction, and operation phases of the facility;

b\. [Facility Construction and Pre-Operation]{.underline}. Activities
involving construction and pre-operational activities;

1\. [Construction Activities]{.underline}. Verifying that construction
activities (foundation, structural concrete and steel, piping systems
and supports, mechanical, electrical, and instrument components) are
conducted in accordance with the construction authorization and quality
assurance program. Verifying that the applicant can recognize
non‑routine events affecting safety, utilize an internal reporting
system, and to identify and execute corrective actions to resolve
deviations from commitments made in the CAR and MPQAP.

2\. [Pre-Operational Activities]{.underline}. Verifying that the
applicant has instituted effective management measures to provide for
the safe startup testing of the facility during both routine and upset
conditions, to recognize non‑routine events affecting safety, utilize an
internal reporting system, and to identify and execute corrective
actions to return the facility to a safe and secure pre-operational
condition after possible upsets. Pre-operational activities may also
include the verification that the applicant has implemented an
acceptable Safety Operations program (including Chemical Safety,
Criticality Safety, Operational Safety, Fire Protection, and
Radiological Controls programs).

c\. [Facility Support]{.underline}. Management measures and systems,
including training, emergency preparedness, and maintenance.

1\. [Training and Qualification of Plant Personnel]{.underline}.
Verifying the training and qualification of facility personnel for
activities relied on for the development of safety controls; including
the training, testing, retesting, and qualification of managers,
designers, technical staff, construction personnel, technicians, and
other personnel whose level of knowledge is relied on for safety;

2\. [Emergency Preparedness]{.underline}. Verifying that the applicant
has established an effective emergency management program to protect the
workers, public, and the environment in the event of reasonably
postulated events that could threaten the facility.

3\. [Maintenance.]{.underline} Verifying that the applicant has
established an effective maintenance program to ensure the functionality
and operability of IROFS in the event of reasonably postulated events
that could threaten the facility and surrounding population.

d\. [Safeguards and Security]{.underline}. Activities involving
implementation of the applicable safeguards and security measures to
assure adequate accounting and protection of special nuclear materials
during receipt and transfer operations.

e\. [Special Topics]{.underline}. These are issues that may arise on an
occasional basis, but are not included in the review on a routine basis
unless the significance of the issue rises to a level that is perceived
to affect the quality of applicant performance. Examples include quality
of application and licensing submittals, deviations from commitments in
the Construction Authorization Request, labor-management issues, and
contractor difficulties.

3.2 [Areas Needing Improvement]{.underline}. Actual and/or potential
risk-significant recurring performance (root causes or events) requiring
resolution or corrective action. If a number of deficiencies occurred
early in the period and the applicant=s management corrected the
problems as evidenced by no events for the last half of the cycle, then
less weight should be given to those issues when evaluating the
applicant=s performance. On the other hand, more weight should be given
to issues that are identified late in the assessment period.

4\. EVALUATION FACTORS

4.1 The AAP should review the applicant=s performance in each of the
applicable functional areas, using a common set of evaluation criteria.
A suggested set of evaluation factors are provided below:

a\. Management involvement and control;

b\. Approach to identification and resolution of technical issues from a
safety and safeguards perspective;

c\. Approach to (operational) events (including timeliness, analysis,
reporting, effectiveness of corrective actions, and recognition of
generic issues within the facility);

d\. Staffing (considering experience, expertise, and availability of
staff and management);

e\. Aspects of performance that may reflect on the effectiveness of
training and qualification programs relative to the specific functional
area; and

f\. Evidence of positive or negative performance trends.

4.2 NMSS and the Region II Branch Chiefs may confer occasionally to
consider the suitability of the current evaluation factors and recommend
any necessary changes.

5.  IMPLEMENTATION

5.1 The responsibilities and authorities, performance review scheduling,
review process, and documentation guidelines, specified in IMC 2604
should be used in conducting the AAP.