POLICY ISSUE

NOTATION VOTE

February 22, 2006 SECY-06-0041

FOR: The Commissioners

FROM: Luis A. Reyes

Executive Director for Operations 

SUBJECT: PROPOSED STRATEGY TO SUPPORT IMPLEMENTATION OF THE

NEW-REACTOR CONSTRUCTION INSPECTION PROGRAM

PURPOSE:

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.

BACKGROUND:

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.

CONTACT: Mary Ann Ashley, NRR/DIRS

 301-415-1073
The Commissioners 2

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). 

DISCUSSION:

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). Options for implementation of the vendor function within the

CIP are still being developed.

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:

• There should be an onsite construction inspection staff at each construction site.

• In accordance with 10 CFR 52.99, the Nuclear Regulatory Commission (NRC) will issue a

notice in the Federal Register informing the public of the successful completion of an

ITAAC. The Office of Nuclear Reactor Regulation (NRR) will issue the notices based on

licensee documentation and the NRC’s inspection history related to an ITAAC. 

• Contractors to support the regional implementation of the CIP will be managed in NRR. 

Contractors may be needed if the number of units to be constructed increases faster than

the agency can recruit and train inspectors; if the agency has trouble recruiting staff, in part

because of competition from the industry for the same individuals; or if unique technical

expertise is required. NRR has broad experience with contract administration and is colocated with the other agency offices that participate in establishing and administering

contracts. 

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. 
The Commissioners 3

In considering these two issues, the staff concluded that the following benefits apply equally to

Option 1, 2 and 3.

• Greater ease of recruiting in the regions due to the lower costs of living in the regions, in

contrast to the Washington, D.C., area.

• The proximity of a major airport to each of the regional offices.

• The ability of the regions to leverage existing inspection staff to initially staff the construction

program with experienced inspectors.

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). With respect to the cost of each option,

the staff believes that the total cost for Option 1, Option 3, or Option 4 will be greater than the

total cost for Option 2.

Option 1: Locate all specialized inspection resources in a single region which would schedule

all specialist inspectors nationwide. 

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.

Option 2: Locate specialist inspectors in all of the regions proportional to the number of plants

planned for construction in each region. Each region would control its own

resources. 

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.
The Commissioners 4

Option 3: Locate a majority of the specialist inspectors within a single region which would be

designated a “center of construction inspection expertise.” The remaining inspectors

would be divided among the other three regions. Under this option, the center of

expertise would manage the specialist inspection function and would supplement the

specialist inspectors in the other regions as circumstances dictated. 

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.

Option 4: Form a separate and independent Construction Inspection Office at a new location

either away from or near an existing regional office. Responsibility for the

construction inspection program at all sites would rest totally with this office. The

existing four regional offices would assume responsibility for sites of new reactors at

some point during the transition from construction to operation. Under Option 4, an 

operations resident would be assigned to the site as construction neared conclusion

and would report directly to the Regional administrator for the geographic area in

which the site is located. All other construction inspection staff would report to the

Director of the Construction Inspection Office. This new office would report to the

Deputy Executive Director for Reactor and Preparedness Programs.

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.

COMMITMENTS:

This paper contains no new commitments. The staff will implement the construction inspection

program consistent with the Commission’s direction.
The Commissioners 5

RECOMMENDATION:

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.

COORDINATION:

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.

/RA/

Luis A. Reyes

Executive Director

 for Operations

Enclosures:

1. Functional Statements

2. Comparison of Options
The Commissioners 5

RECOMMENDATION:

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.

COORDINATION:

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.

Luis A. Reyes

Executive Director

 for Operations

Enclosures:

1. Comparison of Options

2. Functional Statements

ADAMS Accession No.: ML060250030 *via email

OFFICE DIRS/IRIB TECH ED DIRS/DD PMAS DNRL/DD

NAME MAshley PKleene MCase

(SRichards

for)

CCarpenter DMatthews

(WBeckner

for)

DATE 02/06/2006 01/30/2006 2/8/2006 2/7/2006 2/7/2006

OFFICE OCFO* OGC NRR/OD OEDO

NAME LBarnett

(AAzeem for)

RWeisman JDyer

(BBoger for)

LReyes

DATE 2/8/2006 2/17/2006 2/8/2006

OFFICIAL RECORD COPY
 Enclosure 1

Functional Statements 

for Implementation of the Construction Inspection Program 

Onsite Construction Inspection

Assesses onsite reactor construction activities through day-to-day inspection. Primary interface

with the licensee for scheduling and planning inspections of ITAAC and ITAAC-related activities

and for assessing operational readiness. 

Construction Inspection Support 

Provides specialized inspection support to the onsite inspection organization for ITAAC and

ITAAC-related activities and processes in the areas of engineering (including first-of-a-kind

engineering) and technical specialties. Also supports inspection of operational programs and

operational readiness assessments. 

Vendor Inspections

Provides expertise for inspections related to procurement and fabrication processes and vendor

quality assurance programs (10 CFR Part 50, Appendix B). Supports inspections of

commercial grade dedication activities and processes for reporting defects of new reactor

services or components. Provides inspection support at remote fabrication facilities to ensure

compliance with QA commitments in the application and license related to vendors.

Licensing

Coordinates the review of licensee ITAAC closeout documentation when the region has

completed its inspection of an ITAAC. Documents the NRC’s basis for accepting the licensee’s

ITAAC closeout, and drafts and issues Federal Register notices announcing the licensee’s

successful completion of an ITAAC, as required by 10 CFR 52.99. Performs licensing project

management, as appropriate.
 Enclosure 2

Comparison of Options for Specialty Inspection Support

The level of staffing needed to implement the construction inspection program is still under

discussion pending completion of all of the construction inspection procedures. The

organization would include inspectors who would conduct structural, mechanical, and electrical

and instrumentation inspections. 

The following benefits apply equally to Options 1, 2, and 3. These benefits may, or may not,

apply to Option 4, as discussed further below. 

1. Greater ease of recruiting due to the lower costs of living in the regions than the

Washington, D.C., area. 

2. Proximity of a major airport to each of the regional offices. 

3. Ability to leverage existing inspection staff to initially staff the construction program with

experienced inspectors.

Option 1: Locate all specialized inspection resources within a single region which would

schedule all specialist inspectors nationwide. 

Benefits:

• Staff utilization will be improved as a result of centralizing resources. The off-site

organization will probably not need to grow incrementally to support multiple

projects. Specific needs will depend on the timing of the applications and

construction activities. This option minimizes the impact of uncertainty in the

number and location of plants to be built.

• Resources may be saved due to the economies of scale in establishing the

necessary infrastructure in a single location.

• Inspectors in the single region responsible for construction would develop an

extensive expertise in construction programs and processes by being focused only

on those activities.

• Implementation of the construction inspection program will be more consistent

nationwide. By having all off-site inspectors located in a single location, there would

be more consistent training provided to the inspectors, and there would be only a

single set of management expectations regarding program implementation for offsite inspectors.

• The generic nature of issues can be identified more rapidly. When technical or

programmatic issues are identified at a construction site, this option will allow easier

assessment of the applicability of the issue at other construction sites.

• If multiple licensees choose to implement modular construction techniques at a

remote location (for example, several licensees using a common shipyard to

fabricate modules for AP 1000 plants being built in different areas of the country),

Option 1 would be more efficient in providing inspection oversight and would reduce

coordination between regions.

• Centralization of construction inspection resources at the early stages of new
2 Enclosure 2

construction will be more efficient, but still allows for the potential to transition the

program to a more traditional distribution of resources if the number of construction

sites and the locations warrant. 

Challenges:

• Scheduling inspections in all regions will require greater coordination. This occurs

because the onsite inspection staff report to the region in which the construction site

is located, and the off-site staff may report to a different regional office. Scheduling

can also be affected by competing priorities from each region. In addition, distances

to plants in other regions will increase travel times and costs.

• The regional staff, who will ultimately have responsibility for a plant, will be

disconnected from the plant as it is being constructed. The region responsible for

specialty construction inspections could be different than the region that will

ultimately be responsible for inspecting the plant when it is in operation. Under this

option the geographic separation of the inspectors reduces the opportunity for

routine interaction of regional inspectors with operational plant staff, and, as a result,

complicates the transition of the plant from construction to operations.

• This option could result in one region being much larger than the other three

regions, potentially distracting the region assigned the off-site inspections from 

operating plant safety focus. This challenge becomes greater as the number of

construction projects increases and is made more complex if a large number of the

plants being constructed are also within that region. Past experience has

demonstrated that construction activities can require a significant amount of senior

management focus. 

• The knowledge base of only one region is enhanced. Inspectors in the single region

responsible for specialty construction inspections would develop extensive expertise

in construction programs and processes. However, historically, inspections of

construction also served as an opportunity for inspectors to develop an

understanding of plant systems, which is important for understanding plant

performance during testing and later during operations. This option minimizes the

opportunity for inspectors from the ‘home’ regions to develop a detailed

understanding of the plant as it is being constructed from the ground up. This option

does not foster an efficient and effective knowledge transfer about the plant.

• Existing regional offices may not have sufficient space to accommodate a

centralized construction inspection organization. This option will likely result in

additional costs associated with obtaining sufficient office space for an entire

organization, particularly if the anticipated number of applications materialize in a

short period.

• This approach will be the first time the NRC has centralized such a large inspection

function. There is likely to be communications and logistical issues associated with

establishing the interfaces among the regions, headquarters licensing, and the

construction inspection organization.

• Licensees and other external stakeholders may have to interact with two separate

regions - one region for the on-site inspection staff and a second region for the offsite specialty inspectors. The region in which the site is located would be challenged
3 Enclosure 2

to remain abreast of issues residing with the off-site inspection staff. 

• Assigning responsibility for allegations followup and technical issue resolution could

be more complex. For some issues, it may not be readily clear which organization

(on-site inspection or off-site inspection) would have the lead. With these functions

located in different regions, resolution of these issues would be more challenging. A

process to address such issues would need to be developed and implemented.

• Tracking completion of the inspection program could be more complex with

inspections being conducted out of two locations.

Option 2: Locate specialist inspectors across all regions proportional to the number of plants

planned for that region, with each region managing the full construction inspection

function within its geographic area. This is the historical approach with which the

NRC has programmatic experience.

Benefits:

• Using a single region provides clear accountability for completion of the CIP at each

site. A single regional administrator will have responsibility for the plant during

construction, as the plant transitions into the ROP, and as the plant operates.

• The coordination challenges of the other options are largely eliminated by having a

single regional office responsible for the full process.

• Using a single region is the approach used by the NRC for construction inspection in

past. The NRC is aware of the benefits and challenges of this approach. The

current situation presents several major challenges including a large influx of new

NRC inspectors, the use of a new licensing approach, and the implementation of a

new construction inspection program. In addition, there are varying levels of

uncertainty associated with the number and location of the potential construction

projects. Option 2 presents an approach with which the staff is familiar and has

some confidence and will provide some degree of stability at a time of uncertainty. 

• If the number of projected construction projects fail to materialize, Option 2 provides

a greater ability to readily absorb construction inspection resources into the regional

operating reactor program. In contrast, if the construction resources are largely

centralized, then if construction projects fail to materialize, reassigning the resources

may require relocating to another region, with the associated relocation costs. 

• Easier accessibility to sites will mean that travel times to sites will generally be

shorter if traveling from the region in which the site is located. Travel costs are

thereby reduced, and inspection time is maximized. Longer travel times under

Options 1, 3, and 4 may result in an increased number of trips or more overtime for

inspectors, or both.

• This option allows the inspectors in the region that will have responsibility for the

operating plant to expand the overall regional inspection knowledge base and to

develop a detailed understanding of the plant as it is being constructed from the

ground up. 
4 Enclosure 2

• Communication with external stakeholders will be easier by having all

communication about the plant from a single point of contact who is both familiar

with the inspection results and the stakeholders. New plant construction will be of

interest to those in the local community as well as to state and local officials. Under

Option 2, the communication would be more efficient and direct since the regional

administrator would have full knowledge of the inspection program activities. In

addition, because many of the proposed new plants are at the sites of existing

reactors, the regions will have a better opportunity to build on already established

channels of communications with the state and local officials and with the local

community. 

• Option 2 is adaptable. Current estimates for the number of plants to be built and

their location indicate that three of the four regions may need to prepare for

construction inspection work. The current schedules indicate that Region II will likely

be the first region to actively form a construction inspection organization. Lessons

learned from that experience together with more definitive plans for additional

construction can be used to determine if there is a need to adopt a different staffing

approach over time. The total number and location of the new construction projects

affect the benefits of the various options. Adopting Option 2 allows for flexibility over

time to allow for more definitive information to become available.

• The existing regional infrastructure can be used best under Option 2. Over time, the

inspection resources will likely spread over all four regions, thereby minimizing the

impact on any single region.

Challenges:

• Implementing the construction inspection program through four regions has a

greater potential for inconsistencies in inspections among the regions. When

considering the set of design-specific plus site-specific inspections, test, analyses

and acceptance criteria (ITAAC) to be inspected, each project will have some unique

inspection needs which each region may approach differently. Experience with the

implementation of the ROP has provided some insights on how to minimize

diverging approaches.

• This option does not take advantage of the economies of scale that occur with the

centralization of resources and will likely require some redundant staffing among the

regions.

• Option 2 cannot adapt as well to unforseen increases in the number of plants being

built within a single region and as a result will have a high potential impact from

applications not currently anticipated. 

• Assessing the impact of potentially generic construction issues is more difficult.

• Providing uniform training to inspectors is more difficult.
5 Enclosure 2

Option 3: Locate a majority of the specialist inspectors within a single region which would be

designated a “center of construction inspection expertise.” The remaining inspectors

would be divided among the other three regions. Under this option, the center of

expertise would manage the function and would supplement the technical inspectors

in the other regions as circumstances dictated. 

Benefits:

• Option 3 is a hybrid of Options 1 and 2, and thereby contains some of the benefits

and challenges of both options. 

• Communications among specialist inspectors located at the center is improved.

However, this benefit is limited when considering communication with inspectors

located in other regions.

• A center of expertise approach could promote more balanced staffing among the

regions but is dependent on the distribution of resources. Minimal construction

staffing in regions other than that selected as the center would reduce this benefit

significantly.

• Consistency in inspection results among regions would be improved. A single point

of contact for the decisions and results of the off-site inspections is the most

significant benefit of this option.

• The impact of multiple construction projects is spread among multiple regions. The

actual distribution of resources among the region selected as the center and the

other regions would have a significant impact on this benefit. If only minimal staffing

is assigned to the regions, then the impact of multiple projects is focused on the

center and then becomes a challenge. If the staffing is more evenly spread among

the regions, the outcome is no longer a center of expertise, but rather is a variation

of Option 2.

Challenges:

• Most of the challenges of Option 1 apply to this option also, however, some to a

lesser degree.

• Scheduling and coordinating inspections become more challenging using staff

located in other regions. This is particularly true if the staff is not dedicated to work

on construction, which is likely to be true in the early years when fewer projects are

underway.

• The addition of a large number of staff to a single region could impact that region’s

focus on operating reactors. Maintaining a focus on operating reactors will be a

challenge regardless of the option selected. However, the responsibilities of a

center of expertise would require the Regional administrator to deal not only with the

expected challenges which come with construction, but also with the challenges of

ensuring that construction nationwide is being adequately monitored.

• Increased travel times to locations outside of the region would result in inefficiencies

and has a potential to increase overtime.
6 Enclosure 2

• Human capital impacts associated with a large staffing increase in a region if the

majority of the specialist inspectors are located in a region which also has a

significant number of plants being constructed. This increase will be twofold: one

increase will be in the area of resident staff and the other will be in the increase in

the number of off-site support staff.

Option 4: Form a separate and independent Construction Inspection Office at a new location

either away from or near an existing regional office. Responsibility for the

construction inspection program at all sites would rest totally with this office. The

existing four regional offices would assume responsibility for sites of new reactors at

some point during the transition from construction to operation. Under Option 4, an 

operations resident would be assigned to the site as construction neared conclusion

and would report directly to the Regional administrator for the geographic area in

which the site is located. All other construction inspection staff would report to the

Director of the Construction Inspection Office. This new office would report to the

Deputy Executive Director for Reactor and Preparedness Programs.

Benefits

• Centralizing resources improves staff utilization. The off-site organization will

probably not need to grow incrementally to support multiple projects. Specific needs

will depend on the timing of the applications and construction activities. This option

minimizes the impact of uncertainty in the number and location of plants to be built.

• Having all construction inspectors reporting to the same office results in the most

consistent results from the construction inspection program on a national basis.

• The organization will be fully focused on construction inspections. There would be

little potential under this option for the construction staff to be diverted to operating

reactor inspections.

• Economies of scale are realized in establishing the necessary infrastructure.

• Clear accountability exists for completion of the CIP at each site. The option will

result in the most consistent implementation of the construction inspection program.

• Past experience has demonstrated that construction activities can require a

significant amount of senior management focus. New reactor construction would

have little or no impact on the safety focus of the regions regarding plants already in

operation. This option eliminates any additional burden being placed on the regions

until a new reactor starts the transition to operation.

• Licensees and other public stakeholders would have a single agency point of contact

for all construction inspection issues.

• Having a single point of contact for construction would increase the effectiveness of

communications between licensing of new reactors and construction inspection of

new reactors.

• Eliminates the challenge of developing additional office space in the regional offices.
7 Enclosure 2

• Allows for focused recruiting of staff for construction inspections.

• Allows for greater flexibility because inspection resources can be used for any site

under construction.

Challenges

• The regional staff, who will ultimately have responsibility for a plant, will be

disconnected from the plant as it is being constructed. The region in which a new

reactor is located would not be involved with construction activities until the site

started to make the transition to the operations phase. This option eliminates the

opportunity for inspectors from the ‘home’ region to develop a detailed

understanding of the plant as it is being constructed from the ground up. In addition,

the transition from a construction project to an operational status occurs gradually as

systems are turned over to the operating staff. The opportunity for routine

interaction of regional inspectors with operational plant staff is more limited, and, as

a result, complicates the transition of the plant from construction to operations and

transfer of the plant to the ROP.

• Establishing an organization at an alternate location has the greatest cost. Each of

the options adds staff and creates a need for additional office space. Under the

other options, the additional staff would be located at the regional office and would

be supported by expanding the existing infrastructure. However, Option 4 would

require not only obtaining the additional office space, but also creating an entirely

new infrastructure.

• It could be more difficult under this option to draw on existing inspection experience

to staff the new office because inspectors would be required to relocate. If the new

office under this option were to be located in the same general area as one of the

region offices, then that one regional office would likely be heavily impacted by the

reassignment of inspectors to the new office.

• This approach will be the first time the NRC has centralized such a large inspection

function. There are likely to be logistical issues associated with establishing the

interfaces among the regions, headquarters licensing, and the construction

inspection organization.

• If the anticipated number of new reactors does not materialize, this option will be the

least efficient. In the worst case, the office infrastructure would serve only a few

construction sites. If new construction does not continue for a long period of time,

the agency will be faced with disestablishment of this office.

• This option could result in a large number of inspectors who have only construction

skills, making integration of these inspectors into the operating reactor program

difficult.

• Average travel costs would be higher and average travel times longer due to the

centralized location.