Date: 10/19/06 - 1 - 2696

NRC INSPECTION MANUAL NMSS

MANUAL CHAPTER 2696

LOUISIANA ENERGY SERVICES GAS CENTRIFUGE FACILITY CONSTRUCTION

AND PRE-OPERATIONAL READINESS REVIEW INSPECTION PROGRAMS

2696-01 PURPOSE

Under the provisions of 10 CFR 40.41(g) and 10 CFR 70.32(k) and their license, prior to

the Louisiana Energy Services (LES) National Enrichment Facility (NEF) Gas Centrifuge

being allowed to operate under their license, the Commission must verify that the facility

was constructed in accordance with the requirements of the license. 

The purpose of this Inspection Manual Chapter (IMC) is to define the Construction

Inspection Program (CIP) for the LES NEF. Specifically, the CIP will (1) provide reasonable

assurance that the design, construction, and implementation of items relied on for safety

(IROFS) will protect against natural phenomena and the consequences of potential

accidents, (2) verify the Quality Assurance (QA) Program was adequately implemented

during construction; and (3) verify that the construction of the IROFS was completed in

accordance with the documents comprising the license application (Safety Analysis Report

(SAR), etc.); the Integrated Safety Analysis (ISA), the Integrated Safety Analysis Summary

(ISAS), and the Safety Evaluation Report (SER). 

The LES CIP applies to all construction activities, including, design, procurement,

fabrication, construction, and pre-operational testing activities. Implementation of this IMC

will begin at an applicable time as determined by the NRC and will continue through facility

construction activities as noted above. 

2696-02 OBJECTIVES

The primary objective of this manual chapter is to establish a CIP for inspecting IROFS and

inspecting associated activities that are conducted by the licensee and their consultants,

contractors, and suppliers, to support the decision to allow operation of the NEF. The

following objectives are included in the CIP:

02.01 Provide reasonable assurance that regulatory requirements and licensee

commitments for quality assurance and management measures are adequately included

in the design, procurement, and construction of the NEF. 

02.02 Provide reasonable assurance that the NEF and associated IROFS were

constructed in accordance with the quality assurance program, the license application, the

ISA, the ISAS, and the SER.

02.03 Verify the effective implementation of a safety program that includes the following

elements: process safety information, the ISA, and management measures. 

02.04 Verify the effective implementation of the quality assurance program as specified

in the LES Quality Assurance Program Description (QAPD). Verify that this includes timely

implementation of organizational staffing, procedures, instructions, QA activities, and

administrative controls necessary to achieve quality objectives important to safety
2696 - 2 - Date: 10/19/06

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 (see Appendix B for a listing of these areas) to support the decision to allow

operations at the NEF. 

2696-03 DEFINITIONS

03.01 IROFS Boundary Packages: The IROFS boundary packages identify the specific

functions to be performed by an IROFS, and identify any items that may affect the function

of the IROFS. The boundary packages include information on planned and preventive

maintenance, functional testing and inspection, calibration, and support systems (including

instrumentation, cooling, etc.). They also include information on applicable management

measures and records requirements for the IROFS. 

03.02 In-Office (or Field) Review: Assessments, audits, or reviews conducted to assess

licensing related activities. 

03.03 Inspection: Measures consisting of examinations, observations, or measurements

to determine the conformance of materials, parts, structures, systems, components (SSCs),

services, or processes to predetermined quality requirements. Activities include performing

audits, inspections, surveillances, and observations. 

03.04 Inspection Types: Inspections are classified as compliance-based or performancebased and are defined below.

a. Compliance-based inspections emphasize inspection of compliance with

prescriptive NRC requirements or regulatory commitments that specify IROFS,

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.

03.05 Items Relied on for Safety (IROFS): SSCs, equipment, 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 SSCs, equipment, 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. 

03.06 The License Application: The license application comprises a set of documents

submitted by the licensee as listed in the license under Section 10. These documents

include the SAR, the Environmental Report, the QAPD, and the Emergency Plan. 

03.07 Management Measures: 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,
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audits and assessments, incident investigations, records management, and other quality

assurance elements.

03.08 NEF Start-up: Activities associated with the cold start-up or hot start-up of the NEF

as defined below.

a. Cold Start-up: Pre-operational inspection, testing, or measurement activities not

involving the use of licensed material in NEF process systems or components.

b. Hot Start-up: Pre-operational inspection, testing, or measurement activities

involving the use of NRC licensed material in NEF systems or components. This

would include centrifuge testing using uranium hexafluoride. 

03.09 NEF Quality Assurance Program Description (QAPD): The licensee’s plan that

defines the actions to be taken by licensee management and personnel during the

performance of activities affecting quality, to ensure that quality assurance requirements

are consistently met.

03.10 Operational Readiness Review (ORR): 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 to allow operation of the facility, the NRC will review and assess

the state of readiness of facility operation based on the results of the ORR inspection. The

regulations in 10 CFR 40.41(g) and 10 CFR 70.32(k) require that “No person may

commence operation of a uranium enrichment facility until the Commission verifies through

inspection that the facility has been constructed in accordance with the requirements of the

license. The Commission shall publish notice of the inspection results in the Federal

Register.”

03.11 Quality Assurance (QA) Program: The licensee’s overall QA program to be applied

to the design, fabrication, construction, testing, and operation of the SSCs. This includes

the NEF QAPD, 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. 

2696-04 RESPONSIBILITIES AND AUTHORITIES

04.01 Office of Nuclear Material Safety and Safeguards (NMSS)

a. Responsible for regulatory oversight of the LES NEF.

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

approval.

c. Responsible for the planning, performance, documentation, and enforcement

associated with the Headquarters criticality safety inspection program.

d. Concurs on the approval of this IMC. 

04.02 Region II Office

a. Ensures that adequate resources necessary to carry out the inspection process

described in this IMC are provided to the staff.
2696 - 4 - Date: 10/19/06

b. Responsible for the planning, performance, documentation, and enforcement

associated with the construction inspection program that are performed by

Region II. 

c. Concurs on the approval of this IMC. 

04.03 Office of Nuclear Security and Incident Response (NSIR)

a. Responsible for policy, guidance, and approval for the physical security, classified

material security, transportation security, and material control and accounting

inspection programs.

b. Responsible for the planning, performance, documentation, and enforcement

associated with the Headquarters physical security, classified material security,

transportation security, and material control and accounting inspection programs.

Inspection of the transportation security inspections of classified centrifuge

components will be developed and coordinated by NSIR. 

c. Concurs on the approval of this IMC.

2696-05 BASIC REQUIREMENTS

05.01 General. The NEF Construction Inspection Program provides the inspection

requirements for selectively assessing the adequacy of the IROFS, and regulatory and

safety-related programs. This includes the implementation of the licensee’s QA program

and other management measures used to ensure the availability and reliability of safety and

safeguards IROFS. Substantial emphasis is to be placed on the inspection of the IROFS

that are most important for reducing the likelihood of high- and intermediate- consequence

accidents through the implementation of commitments made by the licensee in the SAR,

the Environmental Report, the NEF QAPD, and other documents that comprise the license

application. Other documents to be referenced include the SER, the ISA, the ISAS.

Emphasis is also to be placed on the licensee’s oversight that assure principal contractors

who are delegated authority to conduct activities related to safety are implementing an

acceptable QA program in accordance with the licensee’s QA program. The inspection

program should include direct inspections as necessary to determine whether the elements

of the license’s QA program are being effectively implemented throughout all stages of

construction, including equipment fabrication, assembly and installation, and structural

construction activities. 

05.02 Inspection Planning and Scheduling Considerations. The NEF construction phase

inspection schedule should be based on the licensee’s construction schedule and should

be modified and updated periodically during the entire construction period. 

Program inspections should be announced, coordinated, and scheduled with the licensee

such that the efficiency and effectiveness of the inspection effort are enhanced and

unnecessary burden to the licensee is minimized. To the extent practicable, the construction

and pre-operational inspections should be coordinated with the licensee to ensure that key

construction activities are in accordance with the site construction project schedule. As

appropriate, inspections of various construction activities may be scheduled as

unannounced inspections.

Emphasis should be placed on early identification of problems. Inspections will be

conducted periodically throughout construction. Inspections will be scheduled early in the

process during implementation of individual construction activities to develop confidence
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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

a schedule for the LES NEF construction inspection project. The MIP will be developed in

coordination with the Special Projects Branch and NSIR, 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,

or changes in scheduling activities by the licensee. 

It should be noted that the NRC has entered into a protocol agreement with the State of New

Mexico’s Environmental Department (NM). This agreement allows NM to send state

representatives to observe the NRC’s inspections at the NEF. Effective implementation of

the agreement will require advance coordination by the NRC and NM, of the inspection

schedule and inspections. It is imperative that this agreement is reviewed and understood

by NRC inspectors and schedulers. 

05.03 Inspection and Technical Personnel Considerations. Qualified inspectors will be

assigned responsibility for the conduct of applicable inspection requirements consistent with

their experience. 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. To this aim, the inspectors may be regional, headquarters, Office of Nuclear Security

and Incident Response, or the Office of Nuclear Material Safety and Safeguards inspectors.

2696-06 GUIDANCE

06.01 General. The licensee is ultimately responsible for the safety of the nuclear facility.

The NRC ensures through a sampling 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

licensee’s QA and construction programs and their implementation. NRC will perform

inspections of selected activities at the licensee’s project offices at the NEF site and other

project facilities. Inspections will also be performed, as necessary, at the facilities of the

licensee’s consultants, contractors, and suppliers. This IMC establishes priorities for

inspection by planned sampling of IROFS and related activities consistent with their

importance to safety and should consider the performance of the licensee in the areas

inspected. 

06.02 Program Areas. The specific areas to be inspected will include a sampling of the

licensee’s IROFS and of regulatory and safety commitments as identified in the approved

SAR, ISA, ISAS, and in the latest revision of the approved NEF QAPD. IROFS for

inspection will be chosen based on safety significance and evaluated with respect to multiple
2696 - 6 - Date: 10/19/06

safety disciplines (criticality, fire, chemical, radiological, environmental) and engineering

disciplines (civil, mechanical, electrical). The NEF’s IROFS boundary packages should be

used as a resource for these inspections.

The NRC will periodically inspect the licensee’s programs for adequate assurance that

IROFS are designed, procured, fabricated, and installed in accordance with the ISAS and

IROFS boundary packages. The inspections will also verify that as-built construction meets

the approved design. In addition, the licensee’s design change and design control process

will be reviewed to verify that the design process effectively implements NRC requirements

and other licensing design commitments made by the licensee. 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

that the environmental protection programs are consistent with the license application

documentation (SAR, ER, etc.), the SER, the ISA, the ISAS, and design specifications and

drawings.

06.03 Inspection Procedures. The NEF CIP will use the Mixed Oxide QA and construction

inspection procedures (IPs), as applicable. These IPs are listed in Appendix A. Some IPs

may cover more than one program area and additional IPs may be used as necessary.

06.04 Implementation. 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, the NMSS Division of Fuel Cycle Safety and Safeguards

(FCSS), and NSIR, 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 inspections 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. The schedule

will be maintained on a common drive, allowing FCSS and NSIR access to the schedule.

Any changes in the schedule directly impacting inspections coordinated with FCSS and/or

NSIR personnel should be communicated to the affected individuals in as timely a manner

as possible. 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,

including coordination of inspections with the State of New Mexico’s Environmental

Department (see Sections 05.02 and 06.11 for more details).

c. Communicating inspection results, findings, and open items to appropriate NRC

and 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, “Interaction Activities Between Regional Offices and OSHA.”
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06.05 Inspection and Technical Personnel Considerations. Inspectors and technical

representatives will be assigned responsibility for performing inspections consistent with

their qualifications. In addition, inspectors performing NEF inspection activities will either

be provided familiarization training on this IMC and related procedures and/or become

familiar with the requirements of this IMC and the applicable requirements of 10 CFR Parts

30, 40, 70, and 95, as appropriate. 

06.06 Inspection Requirements. Inspections will be based on 10 CFR Part 30, 10 CFR

Part 40, 10 CFR Part 70, and other applicable regulations, commitments, and license

conditions, including the documents included as part of the license application (the SAR,

etc.). Other documents to be referenced include the applicable SER, and the ISA.

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. In order to effectively and efficiently allocate inspection

resources, the NRC will perform sampling-type inspections to verify that the licensee is in

compliance with NRC regulations. A combination of IROFS sample selection, risk-based

approaches, and inspections of the quality assurance program, will be used to help

determine the necessary level of inspection effort. 

Inspectors should use applicable risk-based information from the license submittals,

process hazard analyses, and ISA to identify those IROFS whose failure would most greatly

impact the NEF’s risk profile. This approach would allow the more risk significant IROFS

to be identified so that the construction and pre-operational inspection samples could be

focused on those IROFS. The amount of inspection and activities selected for inspection

should be consistent with the importance to safety of the IROFS, and the performance of

the 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. Determine the extent and the effectiveness of licensee oversight of quality related

activities.

b. Determine compliance of previously identified problem areas and/or on recurring

problems. 

c. Focus inspection efforts on problems that indicate programmatic weaknesses. 

d. Periodically, verify the adequacy of the licensee’s corrective action program to

identify, track, trend, resolve, and prevent problem recurrence.

e. Review deficiencies, audit findings, and problems identified by the licensee or by

its consultants, contractors, or suppliers to identify trends and/or problem areas;

and

f. Ascertain whether additional NRC inspection effort is merited in the areas of

concern.
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06.08 Management Entrance and Exit Meetings. Inspectors are required to meet with

licensee management as part of every inspection. Inspectors should hold an entrance

meeting with the senior licensee representative who has responsibility for the areas to be

inspected. Each inspection must include the discussion of inspection results with licensee

management. At the conclusion of an inspection, inspectors must discuss their preliminary

findings with the licensee’s management at a scheduled exit meeting. Management

entrance and exit meetings with licensee personnel should be scheduled to minimize the

impact on other licensee activities necessary to assure the safe and proper construction

of the facility.

06.09 Inspection Reports. Inspection findings shall be documented in inspection reports

in accordance with the applicable revision to IMC 0610, “Nuclear Material Safety and

Safeguards Inspection Reports.” When possible, inspection findings should be integrated

into a single inspection report to encompass findings from in-office reviews, and/or one or

more visits by regional or headquarters inspectors. 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, Nuclear Material Safety and Safeguards Inspection

Reports. 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. 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 licensee 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. As a matter of NRC philosophy, the

NRC maintains an “open 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 a licensee'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

NEF and applicable regional office procedures. The NRC has entered into a protocol

agreement with the State of New Mexico’s Environmental Department (NM). This

agreement allows NM to send state representatives to observe the NRC’s inspections at

the NEF. Effective implementation of the agreement will require advance coordination by

the NRC and NM, of the inspection schedule and inspections. It is imperative that this

agreement is reviewed and understood by NRC inspectors and schedulers. 

06.12 Inspection Findings and Enforcement. All inspection findings identified during the

construction and pre-operational periods will be documented in accordance with the

applicable revision to IMC 0610, “Nuclear Material Safety and Safeguards Inspection

Reports,” 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

Enforcement Policy“ (available on the NRC public web site at http://www.nrc.gov ), using

traditional enforcement tools. During construction and pre-operational activities, the

guidance in Supplement II - Part 50 Facility Construction, will apply, along with other

applicable supplements, for determining the appropriate severity level for quality assurance

violations. The inspection findings (or open items) will then be categorized as violations,

non-cited violations, apparent violations, deviations, non-conformances, unresolved items,

or inspector follow-up items. This includes the use of notices of violations for violations of
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severity level IV and above and civil penalties, as appropriate. Please note that, although

IMC 0610 references IMC 0612, Power Reactor Inspection Reports, this reference is not

applicable to construction projects, and IMC 0612 should not be used for determination of

what constitutes a minor violation. 

It is important to note that if the NRC determines that the construction is not in accordance

with the licensee's commitments, then permission to operate may be denied (see 10 CFR

40.41(g), 10 CFR 70.32 (k), and NEF License Condition 11). The failure of the licensee to

meet commitments specified in the license application (including the SAR and QAPD) or

other ancillary documents (the SER, ISA, ISAS), shall be documented in the inspection

report(s) as noted above. It is imperative that open items are appropriately documented

in the inspection reports so that subsequent inspections can verify whether or not the

licensee took the appropriate corrective actions. The failure of the licensee to take the

appropriate corrective actions to address the open items by the end of the construction

phase could result in a denial by the NRC to allow operations.

06.13 Assessment of Licensee Performance (ALP). 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 licensee performance. Periodic reviews of the licensee’s performance

of construction and pre-operational activities may be warranted to provide NRC

management with an overview of the licensee’s performance, and provide feedback of NRC

management’s conclusions regarding the quality of the licensee’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

NEF construction and pre-operational inspection programs. IMC 2604, “Licensee

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 licensee’s performance in the construction phase of the NEF. The

responsibilities and authorities, performance review scheduling, review process, and

documentation guidelines, specified in IMC 2604 should be used in conducting the ALP.

Region II is responsible for adjusting the scope and frequency of the review during the

construction and pre-operational phases, as needed, based on NEF construction schedules

and inspection findings. An initial recommended frequency for this assessment is once per

year, with the initial assessment occurring approximately one year after the start of

construction activities.

06.14 Operational Readiness Reviews. As stated earlier, 10 CFR 40.41(g) and 10 CFR

70.32 (k) does not allow operation of a uranium enrichment facility until the Commission

verifies through inspection that the facility has been constructed in accordance with the

requirements of the license. The NRC verifies that this requirement is met by performing

operational readiness reviews. 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 NEF areas or processes. In order to support a decision to allow

operations, 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
Issued Date: 10/19/06 A-1 2696, Appendix A

Appendix A

LES NEF GAS CENTRIFUGE INSPECTION PROGRAM 

CONSTRUCTION AND PRE-OPERATIONAL INSPECTION PROCEDURES 

See IMC 2683 for a complete list of material control and accounting IPs.

Inspection procedures may be added or deleted as required. Portions of these

inspection procedures will not apply to the LES NEF.

See appropriate IMCs for a list of physical security and information security IPs.

QA Inspection Procedures

IP 88106 Quality Assurance: Program Development and Implementation

IP 88107 Quality Assurance: Design and Documentation Control 

IP 88108 Quality Assurance: Control of Materials, Equipment, and Services

IP 88109 Quality Assurance: Inspection, Test Control, and Control of Measuring

and Test Equipment

IP 88110 Quality Assurance: Problem Identification, Resolution, and Corrective

Action

IP 88111 10 CFR Part 21 Inspection-Facility Construction

IP 88112 Software Validation

IP88113 Control of the Electronic Management of Data

IP 88114 Quality Affecting Item Procurement (10 CFR Part 21) and 

Commercial Grade Item Dedication Process (Reactive)

IP 88115 Supplier/Vendor Inspection

IP 88116 Inspection of Safety Function Interfaces

Construction Inspection Procedures

IP 88131 Geotechnical/Foundation Activities

IP 88132 Structural Concrete

IP 88133 Structural Steel and Supports

IP 88136 Mechanical Components

IP 88137 Electric Cable

IP 88138 Electrical Components and Systems

IP 88139 Ventilation and Confinement Systems

IP 88140 Instrumentation and Control Systems

IP 55100 Structural Welding General Inspection Procedure

IP 88141 Procedures- Fire Prevention/Protection
2696, Appendix A A-2 Issue Date: 10/19/06

IP 88142 Underground Fire Water Loop and Equipment Installation

Pre-Operational Inspection Procedures

IP 83030 Radiation Protection

IP 86740 Inspection of Transportation Activities

IP 88005 Management Organization and Controls

IP 88010 Operator Training/Retraining

IP 88015 Nuclear Criticality Safety Program

IP 88016 Nuclear Criticality Evaluations and Analyses

IP 88017 Criticality Alarm Systems

IP 88020 Operational Safety

IP 88025 Maintenance and Surveillance Testing

IP 88035 Radioactive Waste Management

IP 88045 Environmental Protection and Effluent Control

IP 88050 Emergency Preparedness

IP 88051 Evaluation of Exercises and Drills

IP 88055 Fire Protection

IP 88056 Process Safety Information

IP 88070 Permanent Plant Modifications

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 of 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
Issued Date: 10/19/06 B-1 2696, Appendix B

Appendix B

LOUISIANA ENERGY SERVICES (LES) NATIONAL ENRICHMENT FACILITY (NEF) 

GAS CENTRIFUGE INSPECTION PROGRAM 

ASSESSMENT OF LICENSEE PERFORMANCE (ALP) PROCESS

1. PURPOSE

This appendix provides guidance for assessing the licensee’s performance in the

construction and pre-operational phases of the LES NEF gas centrifuge and to provide

feedback of NRC management’s conclusions regarding the quality of the licensee’s

construction and pre-operational programs. The responsibilities and authorities,

performance review scheduling, review process, and documentation guidelines, specified

in IMC 2604, Licensee Performance Review, should be used in conducting the ALP. The

results of such a review should:

1.1 Provide an assessment of licensee performance to NRC management.

1.2 Inform the licensee and the public how the NRC assesses facility performance.

1.3 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 the NEF’s 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: The following definitions describe the program and functional

areas that form the basis for the Assessment of Licensee Performance (ALP). 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 comprises two or more inspection program areas.

a. Management Measures: This includes activities involving implementation of

the applicable management measures as described in the licensee’s Quality

Assurance Program Description and in Chapter 11 of the Safety Analysis

Report. 

1. Quality Assurance: Evaluate the effectiveness of the licensee

implementation of the controls as established in the NEF Quality

Assurance Program Description (QAPD).

2. Design Control: Evaluate the control of the designs for items relied on

for safety (IROFS), and the control of activities associated with the

preparation, review, approval, and verification of documents used for

design, procurement, and fabrication.
2696, Appendix B B-2 Issue Date: 10/19/06

3. Categorization of IROFS: Evaluate the implementation of a graded

quality assurance approach to the categorization of IROFS, based on

safety significance, if applicable. Note that all of the IROFS at the NEF

are rated as NQA Category I, however, some of these IROFS are “sole”

IROFS. 

4. Configuration Management: Evaluate whether the licensee’s

configuration management system documented an established baseline

configuration; that changes to IROFS were in conformance with 10 CFR

70.72 and controlled to preclude inadvertent degradation of safety; and

that a system was established and implemented to evaluate, implement,

document, and track changes to the site, IROFS, processes,

equipment, computer programs, and activities of personnel.

5. Procedures: Evaluate the control of management procedures with

regard to distribution, version control, management review and

approval.

6. Audits and Assessments: Evaluate the performance of audits and

assessments required during construction.

7. Records Management: Evaluate 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: This includes activities involving

construction and pre-operational activities. 

1. Construction Activities: Evaluate construction activities (foundation,

structural concrete and steel, mechanical, electrical, and instrument

components). Evaluate whether the activities were conducted in

accordance with the license application, the Safety Evaluation Report,

the Integrated Safety Analysis, and the Integrated Safety Analysis

Summary. Evaluate whether the licensee recognized non routine

events affecting safety, used an internal reporting system, and identified

and executed corrective actions to resolve deviations from

commitments made in the NEF QAPD. 

2. Pre-Operational Activities: Evaluate whether the licensee’s

management measures provided for the safe startup testing of the

facility during both routine and upset conditions, recognized non routine

events affecting safety, used an internal reporting system, and identified

and executed corrective actions to return the facility to a safe and

secure pre-operational condition after possible upsets. Evaluate preoperational activities, including whether the licensee has implemented

an acceptable safety operations program (including chemical safety,

criticality safety, operational safety, fire protection, and radiological

controls programs).

c. Facility Support: This includes management measures and systems, including

training, emergency preparedness, and maintenance.

1. Training and Qualification of Plant Personnel: Evaluate 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
Issued Date: 10/19/06 B-3 2696, Appendix B

personnel, technicians, and other personnel whose actions are relied

on for safety.

2. Emergency Preparedness: Evaluate the effectiveness of the licensee’s

emergency management program in to protect the workers, public, and the

environment during reasonably postulated events that could threaten the

facility.

3. Maintenance: Evaluate the effectiveness of the licensee’s maintenance

program to ensure the functionality and operability of IROFS during

reasonably postulated events that could threaten the facility and surrounding

population.

d. Safeguards and Security: Evaluate activities involving implementation of the

applicable safeguards and security measures to assure adequate accounting

and protection of special nuclear material during receipt and transfer

operations.

e. Special Topics: 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 licensee

performance. Examples include the quality of application and licensing

submittals, labor-management issues, and contractor difficulties.

3.2 Areas Needing Improvement: 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 licensee’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 licensee’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 ALP should review the licensee’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.
2696, Appendix B B-4 Issue Date: 10/19/06

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, Licensee Performance Review,

should be used in conducting the ALP. 
Issue Date: 10/19/06 2696, Attachment 1 A1-1

Attachment 1

Revision History of IMC 2696

Commitment

Tracking

Number

Issue Date Description of Change Training

Required

Training

Completion

Date

Comment Resolution

Accession Number

N/A 10/19/06 CN 06-028

Document created to implement theconstruction and operationalreadiness review inspection program at LES NEF

None N/A ML062620225