POLICY ISSUE

(Information)

March 8, 2007 SECY-07-0049

FOR: The Commissioners

FROM: Luis A. Reyes

Executive Director for Operations /RA/

SUBJECT: CONSTRUCTION INSPECTION ROLES AND RESPONSIBILITIES

PURPOSE:

The purpose of this paper is to provide additional details and clarifications regarding the roles

and responsibilities of the Office of New Reactors (NRO) and the Region II Construction

Inspection Organization, as described in SECY-06-0144, “Proposed Reorganization of the

Office of Nuclear Reactor Regulation and Region II,” for implementing the various aspects of the

Construction Inspection Program (CIP) for new reactors. This paper does not address any new

commitments or resource implications.

BACKGROUND:

The purpose of the CIP is to gather information that the staff will use when determining the

operational readiness of the licensee and when formulating a recommendation to the

Commission on the finding required by Title 10, Section 52.103(g), of the Code of Federal

Regulations (10 CFR 52.103(g)) on whether or not the acceptance criteria in the combined

license (COL) are met. The program will require inspection of on-site and off-site activities,

including component manufacturers, to evaluate: (1) the work contributing to the completion of

the inspections, tests, analyses, and acceptance criteria (ITAAC) of the COL; and (2) the

licensee’s development and implementation of the required operational programs.

CONTACTS: Mary Ann Ashley, NRO/DCIP

301-415-1073

Mark Lesser, Region II, DCI

404-562-0544
The Commissioners -2-

DISCUSSION:

Since the formation of the Region II Construction Inspection Organization and NRO in late 2006,

the staff has evaluated the roles and responsibilities for the inspections needed to support the

successful CIP implementation. Table 1, AResponsibilities for Inspection Activities,@

summarizes the inspections required by the CIP Inspection Manual Chapters (IMC) 2501, AEarly

Site Permits (ESP),@ IMC-2502, APre-Combined License (COL) Inspections,@ IMC-2503, AITAAC

Inspections,@ and IMC-2504, ANon-ITAAC Inspections.@ Table 1 shows the inspections in the

approximate order that they will occur and identifies the organization assigned lead and support

responsibility for each type of inspection.

The first two entries in Table 1 are inspections and reviews of quality assurance (QA), which will

occur in the early phases of the ESP process. QA inspections and reviews are used here and

throughout the CIP to gain confidence that the QA program is being used effectively to monitor

the quality of the materials and services. The ESP inspections and reviews provide regulatory

oversight of the actions taken by the applicant to ensure that the information in the application is

accurate and was collected with appropriate methods. The inspections consider the applicant=s

plans for monitoring a variety of activities including analyzing performance, designing,

fabricating, handling, shipping, storing, installing, testing, and maintaining structures, systems,

and components. On-going inspections then monitor QA program implementation by both the

applicant and the various vendors and contractors who are providing equipment or services to

the specific project. QA inspections are conducted under both IMC-2501 and IMC-2502. In

addition to inspecting the applicant’s QA program, the CIP will review of quality oversight of

vendors supplying safety-related structures, systems, and components. 

The current NRC vendor inspection program is driven primarily by allegation and operational

experience follow-up, and observations of a limited number (about two per year) of activities by

the Nuclear Procurement Issues Committee (NUPIC). NUPIC is an industry group that

conducts periodic audits and surveys of vendors supplying safety-related equipment. The audit

and survey results are shared by participating licensees. 

With the significant increase in the services provided by vendors and the fabrication of

safety-related items necessary to support new reactor construction, the existing vendor

inspection program will need to be enhanced substantially to provide the assurance that

vendors are providing items and services that are consistent with their safety significance.

The staff is updating the program and inspection documents and will keep the Commission

informed of our progress. The Quality and Vendor Branches (QVB) in the NRO Division of

Construction Inspection and Operational Programs has been assigned responsibility for

developing, managing, and implementing the Vendor Inspection Program. 

Personnel from QVB will lead the QA inspections supporting the issuance of an ESP and a

COL. Assigning this responsibility to QVB organization in NRO is appropriate because there is

a direct connection between the technical reviews and CIP inspections performed by that group. 

Key to this decision are the synergistic effects realized through routine direct interactions among

QVB staff and other new reactor licensing technical reviewers, particularly in the area of codes

and standards. As indicated in Table 2, Region II will provide support to off-site inspections of

vendors related to the fabrication of components or modules for a specific application or license. 
The Commissioners -3-

Participation by Region II will help their staff to maintain an awareness of the on-going activities

and to develop a comprehensive view of licensee oversight of work activities related to the

construction of a specific plant, which may contribute to the successful completion of the

acceptance criteria of the combined license.

The last four entries in Table 1 are the major inspections to be led by the Region II construction

inspection staff. These inspections will cover the installation and testing of structures, systems,

and components and the on-site fabrication of modules. Since this work supports the

successful completion of various ITAAC, it will be inspected under IMC-2503. The nature of the

acceptance criteria of some of the ITAAC targeted for inspection under IMC-2503 will result in

Region II requiring technical assistance from NRO in assessing the success of some installation

activities and reviewing the adequacy of some test outcomes. For example, some ITAAC have

design commitments requiring that the components be designed and constructed in 

accordance with the requirements of Section III of the American Society of Mechanical

Engineers (ASME) Boiler and Pressure Vessel Code. Although the inspection program can

collect information about the installation practices, the NRO technical staff will be needed to

evaluate the as-built design to ensure that required detailed design or changes that might have

been needed to accommodate field conditions continue to meet the acceptance criteria. There

are approximately 100 ITAAC for the AP1000 and approximately 170 ITAAC for the ABWR that

fall into this category. 

Region II will lead the IMC-2504 inspections of site-specific construction programs including

problem identification and resolution (PI&R) and training and qualification of construction staff. 

Also assigned to Region II are the inspections of the implementation of the site QA program and

the development and implementation of the operational programs. The scope and development

and implementation schedule for the operational programs will have been reviewed and

approved by the NRO technical staff during the COL application review. Region II may require

assistance from NRO technical staff to ensure that the operational programs being developed

and implemented are consistent with the program descriptions and development schedules

approved when the COL was issued. No specific areas for assistance have been identified. 

However, the potential need for this support is identified in Table 1.

Table 1 illustrates that a combined effort by the Region II construction inspection staff, the

headquarters QVB staff, and the NRO technical staff will be needed to ensure adequate

inspection of construction and construction-related activities. However, the size of the

inspection effort associated with each item is significantly different. While the QVB staff will

have the lead on many of the activities listed, the level of effort required to complete those

inspections will be less than the effort that will be required by Region II to implement those

items for which it has lead responsibility. 

Table 2, “Responsibilities for Vendor Oversight Activities,@ identifies the activities that will be

performed by QVB in fulfilling its responsibility for conducting licensing reviews in support of the

design certification process and for monitoring fabrication of components for use in nuclear

power plants. QVB will focus on the content and implementation of the QA program and may

be supported by Region II when the inspections involve the fabrication of modules and

components at vendor locations. To the extent possible, Region II will use the results of vendor

inspections and reviews to inform its inspections at specific sites. By maintaining a broad 
The Commissioners -4-

awareness of vendors and their activities, QVB and Region II will be improving their abilities to

effectively and efficiently conduct the CIP inspections for which they have assigned

responsibility.

COORDINATION:

The Office of the General Counsel reviewed this package and has no legal objection.

/RA/

Luis A. Reyes

Executive Director

 for Operations

Enclosures:

1. Table 1, Responsibilities for Inspection

 Activities

2. Table 2, Responsibilities for Vendor 

 Oversight Activities
The Commissioners -4-

awareness of vendors and their activities, QVB and Region II will be improving their abilities to

effectively and efficiently conduct the CIP inspections for which they have assigned

responsibility.

COORDINATION:

The Office of the General Counsel reviewed this package and has no legal objection.

/RA/

Luis A. Reyes

Executive Director

 for Operations

Enclosures:

1. Table 1, Responsibilities for Inspection

 Activities

2. Table 2, Responsibilities for Vendor 

 Oversight Activities

ADAMS Accession# ML070460059 Secy-012

Office DCIP/CCIB TechEd BC:DCIP D:DCIP/NRO

Name MAshley* HChang (via email)* RRasmussen* GTracy*

Date 02/21/07 02/21/07 02/22/07 02/22/07

Office RII OGC OD:NRO EDO

Name LPlisco*

(via telecon)

KWinsberg* RWBorchardt*

(GHolahan for)

LReyes*

Date 02/22/07 02/26/07 03/01/07 03/08/07

OFFICIAL RECORD COPY

* See Previous
Enclosure 1

Table 1 - Responsibilities for Inspection Activities

RESPONSIBILITIES

Legend: L = Lead S = Support

Inspection Focus Region II NRO 

QVB Staff

NRO

Tech Staff

QA program implementation used for development of

an ESP application (IMC-2501) S L

Data collection, analysis and use of data in support of

the ESP application (IMC-2501) LS S

Geotechnical /foundation activity in support of an ESP

(IMC-2501) LS S

Procedures used for Geotechnical /foundation activity

in support of a COL (IMC-2502) SL S

QA program implementation used for COL application

development, fabrication, and procurement (IMC-2502

and new IMC on vendor inspections)

S L

Implementation of Architect /Engineer QA program

including first-of-a-kind-engineering (IMC-2502) L S

QA program implementation at fabricators of

components and modules (IMC-2502 and new IMC on

vendor inspections)

S L

Fabrication and testing of components and modules

(IMC-2503) SL S

QA program implementation at a licensee construction

site (IMC-2504) L

Development and implementation of licensee

operational programs (IMC-2504) LS S

On-site fabrication of modules (IMC-2503) L S S

On-site installation of systems, structures, components

(IMC-2503) LS S
Enclosure 2

Table 2 - Responsibilities for Vendor Oversight Activities

RESPONSIBILITIES

Legend: L = Lead S = Support

Examples of Vendor Oversight Activities Region II NRO 

QVB Staff

NRO Tech

Staff

Pre-application inspections of facilities performing

testing to support a design certification application

(Chapter 21 testing)

L S

Inspection of QA program implementation for

development of design certification application L S

Inspections of vendors fabricating components and

fabricating modules off-site SLS