________________

POLICY ISSUE 

(Information) 

April 22, 2016 SECY-16-0055 

FOR: The Commissioners 

FROM: Victor M. McCree 

Executive Director for Operations 

SUBJECT: CONSTRUCTION REACTOR OVERSIGHT PROCESS 

SELF-ASSESSMENT FOR CALENDAR YEAR 2015 

PURPOSE: 

The purpose of this paper is to present the results of the U.S. Nuclear Regulatory Commission 

(NRC) staff’s calendar year (CY) 2015 self-assessment of the Construction Reactor Oversight 

Process (cROP). This paper does not address any new commitments. 

SUMMARY: 

The results of the CY 2015 self-assessment show that the staff effectively applied the NRC’s 

Principles of Good Regulation while implementing the cROP. The cROP met the agency’s 

strategic goals of ensuring safety and security through objective, risk-informed, transparent, and 

predictable oversight. The staff will continue to evaluate the efficacy of the program and solicit 

input from internal and external stakeholders to further improve the cROP. 

CONTACT: Thomas J. Kozak, NRO/DCIP 

 301-415-6892
The Commissioners 2 

BACKGROUND: 

The staff conducted the CY 2015 cROP self-assessment in accordance with Inspection Manual 

Chapter (IMC) 2522, “Construction Reactor Oversight Process Self-Assessment Program,” 

dated July 28, 2014 (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML14189A211). The staff has issued four previous cROP self-assessment 

Commission papers and has briefed the Commission annually on the results after the Agency 

Action Review Meeting. The Commission has provided the staff with direction in the form of a 

staff requirements memorandum (SRM) after these briefings. In its most recent SRM, “Staff 

Requirements—Briefing on Results of the Agency Action Review Meeting (AARM), 9:00 A.M., 

Thursday, May 21, 2015, [...],” dated June 01, 2015 (ADAMS Accession No. ML15152A411), 

the Commission did not identify any new cROP requirements for staff action. 

The staff also discussed cROP effectiveness with the Commission during the strategic 

programmatic overview of the New Reactors Business Line (NRBL) on September 24, 2015. 

In the SRM for this briefing, “Staff Requirements Memorandum—Briefing on Strategic 

Programmatic Overview of the New Reactors Business Line, 10:00 A.M., Thursday, September 

24, 2015 [...],” dated September 30, 2015 (ADAMS Accession No. ML15273A091), the 

Commission did not identify any new cROP requirements for staff action. 

DISCUSSION: 

To ensure that the cROP self-assessment for CY 2015 was comprehensive and robust, the staff 

conducted numerous activities and obtained data from many sources, including the cROP 

performance metrics described in IMC 2522, internal and external stakeholder feedback, and 

direction and insight supplied by the Commission in recent years. The staff analyzed the data to 

gauge cROP effectiveness and potential areas for improvement. The scope of the staff’s 

self-assessment included cROP program area evaluations (construction inspection program, 

construction significance determination process (SDP), and construction assessment and 

enforcement programs), staff progress in resolving issues associated with inspections, tests, 

analyses, and acceptance criteria (ITAAC), construction experience program, independent 

evaluations, cROP communications, and cROP resources. 

cROP Program Evaluations

Staff looked at program evaluations in the three key cROP areas: the construction inspection 

program, construction SDP, and construction assessment and enforcement programs. 

Construction Inspection Program 

During CY 2015, the staff continued to effectively implement the construction baseline 

inspection program and independently verify that the AP1000® licensees are constructing the 

four new reactors in accordance with the approved design. The staff met the two construction 

inspection program metrics as all inspection reports and all responses to technical assistance 

requests were issued within the timeliness goals. The staff ensured that inspection guidance for 

all phases of construction was available to the inspection staff. There are no outstanding 

procedure change requests that need resolution to support ongoing and planned inspections in 

CY 2016. 
The Commissioners 3 

In January 2015, the NRC Region II staff formed a process review team (PRT) to identify cROP 

inefficiencies and make recommendations for improvement. The PRT conducted a 

comprehensive review to understand the challenges and inefficiencies in planning, scheduling, 

and documenting construction inspections. The PRT identified 11 recommendations to improve 

the efficiency and effectiveness of planning, scheduling, and documenting the results of 

construction inspections. The staff has implemented the PRT recommendations, which 

included the realignment of duties and responsibilities, position designation and description 

changes, and personnel moves. The PRT Conclusions and Recommendations and PRT 

Transition Map are available in ADAMS at Accession No. ML15188A398. The staff will continue 

to evaluate and improve the planning, scheduling, and documenting of construction inspections. 

Construction Significance Determination Process 

During CY 2015, the staff continued to effectively implement the construction significance 

determination process in support of the cROP goals to be objective, predictable, 

understandable, and open. The staff met the two construction significance determination 

process metrics. A review of inspection findings determined that the documentation for all 

findings contained adequate detail to enable an independent auditor to reach the same 

significance color characterization and there were no appeals to any of the findings’ significance 

determination. In 2015, no revisions were carried out for the construction significance 

determination process, and the construction significance determination process has no pending 

updates. The staff will continue to monitor the significance determination process 

implementation and consider improvements as necessary. 

Construction Performance Assessment and Enforcement Programs 

During CY 2015, the staff continued to effectively implement the construction assessment 

program, and ensured that the NRC and licensees took appropriate actions to address 

performance issues commensurate with their safety significance. The staff met the four 

construction assessment program metrics. There were no deviations from the Construction 

Action Matrix, all assessment program timeliness goals were met, and construction inspections 

were conducted in a timely manner. All inspection findings were of very low safety significance 

(Green) and all four units under construction remained in the licensee response column of the 

Construction Action Matrix. 

The Reactor Oversight Process (ROP) Independent Assessment Report of 2013 (ADAMS 

Accession No. ML14035A571) included a recommendation to review the criteria for transition to 

Column 3 of the Action Matrix against the original ROP program goals to ensure that the 

significance of White inspection findings is not being overemphasized and to ensure that agency 

resources used to process White inspection findings are commensurate with findings that, by 

definition, are of low-to-moderate safety significance. In SECY-15-0108, “Recommendation to 

Revise the Definition of Degraded Cornerstone as Used in the Reactor Oversight Process,” 

dated August 28, 2015 (ADAMS Accession No. ML15076A066), the staff recommended 

changing the definition of a degraded cornerstone from two White inputs to three White inputs in 

the same cornerstone. The staff also informed the Commissioners in SECY-15-0108 that, if 

approved, the staff planned to incorporate this recommendation into the Construction Action 

Matrix. The Commission approved the staff recommendation in the SRM to SECY-15-0108 

(ADAMS Accession No. ML15335A559). In CY 2016, the staff plans to revise the Construction 
The Commissioners 4 

Action Matrix definition of a degraded cornerstone accordingly in a revision to IMC 2505, 

“Periodic Assessment of Construction Inspection Program Results.” 

The ROP Independent Assessment Report of 2013 also included a recommendation that the 

staff perform an analysis to determine whether the use of the substantive cross-cutting issue 

(SCCI) process provided regulatory value in terms of assessing licensee safety performance. 

The report also suggested that the staff consider replacing the use of SCCIs with a process that 

uses the Nuclear Safety Culture Common Language traits and attributes in a graded regulatory 

response. A working group was formed to evaluate the effectiveness of the SCCI process that 

the staff has applied to the ROP and cROP, and to develop recommendations to replace or 

revise the process. The working group made several recommendations to revise the SCCI 

process (ADAMS Accession No. ML14309A612). The recommendations included: 

(1) changing the threshold for a cross-cutting theme, (2) creating a new cross-cutting theme at 

the cross-cutting area level, (3) eliminating the subjective questions to determine if an SCCI 

existed, and (4) changing the name of SCCIs to cross-cutting issues (CCIs). In 2016, the staff 

will incorporate recommendations from the SCCI working group into the cROP through a 

revision to IMC 2505. 

Enforcement Guidance Memorandum (EGM) 11-006, “Enforcement Actions Related to the 

Construction Reactor Oversight Process,” dated December 21, 2011 (ADAMS Accession 

No. ML11354A092), authorizes the staff to disposition construction enforcement actions in a 

similar manner to its practice for operating reactors. The staff has incorporated EGM-11-006 

guidance into a proposed revision to the Enforcement Policy. In SECY-15-0163, “Proposed 

Revisions to the U.S. Nuclear Regulatory Commission Enforcement Policy,” dated 

December 13, 2015 (ADAMS Accession No. ML15229A093), the staff requested Commission 

approval of the proposed Enforcement Policy revisions. 

Staff Progress in Resolving Issues Associated with ITAAC

During CY 2015, the staff continued to effectively implement and refine the processes and 

guidance developed for ITAAC closure. Through CY 2015, Southern Nuclear Operating 

Company had submitted a total of 37 ITAAC closure notifications (ICNs) for Vogtle, Units 3 

and 4. South Carolina Electric and Gas Company had submitted a total of 35 ICNs for 

V.C. Summer, Units 2 and 3. A significant increase in the number of ICN submittals from each 

new plant site is expected in 2016 as construction progresses. The staff met the ITAAC closure 

metric as there were no ICNs verified as complete and then reopened by the staff. No 

adjustments to the closure process or the existing resources are required to improve the 

effectiveness of the ITAAC closure review program. 

The staff and industry are participating in a pilot exercise that focuses on the review of 

Uncompleted ITAAC Notifications (UINs) that are voluntarily submitted by licensees earlier than 

required by Title 10 of the Code of Federal Regulations (10 CFR) 52.99(c)(3). As part of the 

pilot, the staff will evaluate the potential benefits and costs of the voluntary early submittal of 

UINs. Potential benefits include (1) a reduction to the NRC staff’s review time during the 

expected surge of ICNs late in construction and (2) earlier availability of information to the public 

on licensee ITAAC closure plans. These earlier submittals could also allow the NRC to identify 

potential ITAAC closure issues earlier in the construction process. Potential costs include those 

from (1) additional overall NRC staff UIN review times and (2) development of required 

infrastructure to process, track, and adequately document the status of the UINs. The UIN pilot 
The Commissioners 5 

project began in September 2015 and is expected to be completed by the end of CY 2016. The 

pilot results will be evaluated to determine whether the staff should review early UIN submittals 

to facilitate the verification reviews of ICNs. 

The NRC staff submitted SECY-13-0033, “Allowing Interim Operation under Title 10 of the Code 

of Federal Regulations Section 52.103,” to the Commission on April 4, 2013 (ADAMS Accession 

No. ML12289A928), and the associated SRM was issued on July 19, 2013 (ADAMS Accession 

No. ML13200A115). SECY informed the Commission of issues associated with interim 

operation while ITAAC hearings were pending. In the SRM, the Commission approved the 

staff’s recommendation that the Commission delegate the 10 CFR 52.103(g) finding to the staff. 

Since the issuance of SECY-13-0033 and the associated SRM, the NRC staff, the Office of the 

General Counsel, and the Office of Commission Appellate Adjudication have formed an ITAAC 

Hearing Procedures Working Group which developed procedures and templates for use in the 

hearing process. In April 2014, the draft procedures were published in the Federal Register for 

public comment. Public meetings were held in May and September of 2014 to discuss issues 

related to the procedures, and final comments were collected in October 2014. The staff 

transmitted the draft procedures to the Commission in SECY-15-0010, “Final Procedures for 

Hearings on Conformance with the Acceptance Criteria in Combined Licenses,” dated 

January 20, 2015 (ADAMS Accession No. ML14343A747). In the associated SRM issued on 

April 1, 2016 (ADAMS Accession No. ML16092A099), the Commission approved finalizing the 

ITAAC hearing process procedures. 

The NRC staff continues to develop an Office of New Reactors (NRO) office instruction on the 

staff’s determination process to support 10 CFR 52.103. This instruction will provide guidance 

on the review of the licensee’s ITAAC completion to support the staff in making the finding in 

accordance with 10 CFR 52.103(g) that all acceptance criteria are met. In addition, the 

instruction will provide guidance on the staff’s conclusion on the 10 CFR 52.103(g) finding for 

interim operation under 10 CFR 52.103(c). The staff is also developing a template for a 

Commission paper that will be submitted to inform the Commission that the staff is ready to 

make the 10 CFR 52.103(g) finding. The staff is coordinating the development of the office 

instruction with the progress on the ITAAC hearing procedures to ensure full compatibility. 

Construction Experience Program

During 2015, the Office of Nuclear Reactor Regulation (NRR) Operating Experience (OpE) staff 

and the NRO Construction Experience (ConE) staff continued to collect, evaluate, and 

communicate OpE and ConE information. The NRO ConE staff reviewed and evaluated 

operational events and new reactor construction issues for applicability to domestic reactor 

designs, the new reactor licensing process, and the vendor and construction inspection 

programs. 

In 2015, the ConE staff published and supported the issuance of three information notices on 

topics related to important-to-safety components, snubber lubricant degradation, and fatigue in 

branch connection welds. The ConE staff published two regulatory issue summaries on topics 

related to oversight of counterfeit, fraudulent, and suspect items, and licensing applications for 

reactor coolant pressure boundary components. The ConE staff also coordinated with the NRR 

OpE staff to address operating experience issues for resolution on topics related to the 

installation of unqualified relays, willful misconduct while performing nuclear safety-related 
The Commissioners 6 

construction activities at Watts Bar Nuclear Plant Unit 2, and original construction deficiencies 

that contributed to safety injection line flaws at McGuire Nuclear Station. 

In 2015, the ConE staff continued to support the agency’s international partnerships by 

exchanging information and lessons learned within the Nuclear Energy Agency’s (NEA) 

international construction experience exchange database (ConEx) and in associated NEA 

reports. In 2015, the ConE staff shared two construction-related issues identified through NRC 

inspections and licensee event reporting programs in the United States, including the failure to 

implement appropriate procedures for drilling into concrete and deviations from pipe support 

coating requirements at the AP1000® units. The ConE staff also conducted a peer review of two 

international ConEx submittals, including the mis-installation of containment vertical tendon 

sheaths at Olkiluoto, Unit 3 and the design mismatch of control room display windows of the 

plant monitoring and alarm system at Shinwolsung, Unit 2. In 2014, the staff had identified 20 

issues for the ConEx database through a review of events occurring in previous years. In 2016, 

the staff will continue to evaluate events as they occur and will also continue to evaluate past 

events that occurred at operating reactor sites to determine if they are also applicable to 

reactors under construction. 

Independent Evaluations

In addition to the previously discussed evaluations that were conducted by the staff in the key 

cROP program areas, the Office of the Inspector General (OIG) completed an independent 

audit of the cROP and documented its results in OIG 15-A-14, “Audit of NRC’s Construction 

Reactor Oversight Process (cROP),” dated June 16, 2015 (ADAMS Accession 

No. ML15167A491). The OIG audit report included two recommendations to improve cROP 

efficiency. The staff took actions to address the two recommendations and OIG status 

memorandum, “Status of Recommendations: Audit of NRC’s Construction Reactor Oversight 

Process (cROP) (OIG-15-A-14),” dated March 7, 2016 (ADAMS Accession No. ML16067A193), 

listed all recommendations as closed. 

The OIG also completed an audit of the staff’s ITAAC process and made 10 recommendations 

in OIG-12-A-16, “Audit of NRC’s Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) 

Process,” dated July 12, 2012 (ADAMS Accession No. ML12194A434). The staff took actions 

to address the 10 recommendations, and OIG status memorandum, “Status of 

Recommendations: Audit of NRC’s Inspections, Tests, Analyses, and Acceptance Criteria 

(ITAAC) Process (OIG-12-A-16),” dated September 23, 2015 (ADAMS Accession 

No. ML15266A055), listed all recommendations as closed. The staff is actively implementing 

actions recommended in the OIG audit. For example, the staff developed a comprehensive, 

web-based training course on the ITAAC process and has delivered this training to technical 

staff and mangers. Also, the staff issued Office Instruction NRO-COM-108, “NRO Construction 

Inspection Interfaces with Region II” to enhance communication and coordination between staff 

from NRC headquarters and Region II. Regional and headquarters construction inspection staff 

regularly interface at weekly meetings and other programmatic briefings to discuss and to 

resolve issues as they arise. 

cROP Communications 

The staff continued to provide external stakeholders with several methods to access cROP 

information and to offer feedback. The annual public end-of-cycle performance assessment 
The Commissioners 7 

meetings were conducted near Vogtle, Units 3 and 4, and V. C. Summer, Units 2 and 3. 

Although the meetings were lightly attended, the staff responded to several questions from 

members of the public. The cROP public web page includes a readily accessible feedback link 

that allows stakeholders to offer direct feedback to the staff by selecting a link that generates an 

e-mail to the cROP team. The staff held three public meetings to discuss the construction 

inspection program, the implementation of ITAAC lessons learned, and other related topics. 

Members of the public, industry representatives, and other external stakeholders routinely 

participate in these public meetings. In addition, senior managers from Region II and NRO 

visited the two construction sites quarterly, during which time topics of mutual interest were 

discussed with senior licensee and other consortium management. 

In October 2015, staff participated in a bilateral exchange with representatives of China’s 

National Nuclear Safety Administration (NNSA) regarding China’s reactor commissioning 

program. The NNSA supplied status updates on China’s reactor commissioning program, 

challenges encountered, and discussed a possible joint inspection protocol. Discussions with 

the NNSA focused on future inspection exchanges and the initial test program that is underway 

at the AP1000® units in China. The NRC delegation toured the Haiyang AP1000® construction 

site. As part of the NRC’s continued cooperation with the NNSA, the NRC sent two Region II 

inspectors to Sanmen to observe commissioning activities during the summer of 2015. In 

addition, NNSA sent a representative to observe NRC activities for 6 months, which was divided 

between NRC headquarters vendor inspection branches and Region II construction inspection 

branches. The next interaction with NNSA is planned for September 2016 in China. 

cROP Resources 

Resources for cROP activities are budgeted under the NRBL. At the end of CY 2015, 44 fulltime equivalents (FTEs) assigned to Region II were qualified construction inspectors. Four 

more employees were undergoing construction inspector qualifications (two cross-training, two 

initial qualifications). Construction resident inspector (CRI) staffing is largely based on the 

amount and type of safety-related activities occurring on site. During CY 2015, the NRC 

assigned one senior CRI and three CRIs to Vogtle, Units 3 and 4, and also to V. C. Summer, 

Units 2 and 3. Additional inspectors were dispatched to the sites on a temporary basis to 

perform specialty inspections. 

The staff originally estimated that the direct inspection effort will be 35,000 hours per unit over 

the course of the construction project. Through CY 2015, actual construction inspection hours 

expended at Vogtle, Unit 3, and V. C. Summer, Unit 2, slightly exceed the original direct 

inspection effort estimate when prorated over the expected construction duration for these units. 

This is primarily due to inspections needed to review licensee corrective actions for design 

control and module receipt inspection performance deficiencies, and the need to inspect issues 

with construction that lead to license amendment requests. Therefore, it is likely that the 

original direct inspection estimate will be exceeded at Vogtle, Unit 3, and V. C. Summer, Unit 2. 

However, corrective actions implemented by the licensees have for the most part been effective 

in preventing similar performance deficiencies from occurring at Vogtle, Unit 4, and V. C. 

Summer, Unit 3. Therefore, the staff anticipates that direct inspection effort will meet or be less 

than the 35,000 hour estimate at Vogtle, Unit 4, and V. C. Summer, Unit 3. The staff has 

determined that the original estimate of 35,000 direct inspection hours is reasonably accurate 

and no changes to the estimate are planned based on field experience to date. The staff will 

continue to closely monitor direct inspection resource expenditures. 
The Commissioners 8 

The staff routinely reviews NRBL resource allocations during the Planning, Budgeting, and 

Performance Management (PBPM) process. With the completion of construction activities and 

issuance of an operating license for Watts Bar Nuclear Plant, Unit 2, and efficiencies identified 

for the new reactor construction inspection program through internal reviews, there has been a 

reduction in FTEs allocated to the NRBL for construction inspection in the fiscal year (FY) 2016 

budget. Further FTE reductions were included in the formulation of the FY 2017 budget 

proposal. The staff will continue to right-size NRBL allocated resources through the PBPM in 

future years. Detailed resources for the cROP are provided in the enclosure to this paper. 

CONCLUSION: 

The self-assessment results for CY 2015 show that the cROP provided effective oversight by 

meeting program goals and achieving intended outcomes. The cROP was objective, 

risk-informed, transparent, and predictable. The cROP also ensured openness and 

effectiveness in support of the agency’s mission and its strategic goals of safety and security. 

During CY 2015, the staff continued to find opportunities to strengthen program effectiveness 

and implementation. The staff recognizes the value of continuous improvement and will 

continue to consider stakeholder feedback in its efforts to apply lessons-learned and improve 

various aspects of the cROP. The staff will continue to monitor and to right-size NRBL allocated 

resources through the PBPM. 

COORDINATION: 

This paper has been coordinated with the Office of the General Counsel, which has no legal 

objection. The Office of the Chief Financial Officer has reviewed this paper for resource 

implications and has no objections. 

 /RA/ 

 

Victor M. McCree 

Executive Director 

 for Operations 

Enclosure: As stated
The Commissioners 8 

The staff routinely reviews NRBL resource allocations during the Planning, Budgeting, and 

Performance Management (PBPM) process. With the completion of construction activities and 

issuance of an operating license for Watts Bar Nuclear Plant, Unit 2, and efficiencies identified 

for the new reactor construction inspection program through internal reviews, there has been a 

reduction in FTEs allocated to the NRBL for construction inspection in the fiscal year (FY) 2016 

budget. Further FTE reductions were included in the formulation of the FY 2017 budget 

proposal. The staff will continue to right-size NRBL allocated resources through the PBPM in 

future years. Detailed resources for the cROP are provided in the enclosure to this paper. 

CONCLUSION: 

The self-assessment results for CY 2015 show that the cROP provided effective oversight by 

meeting program goals and achieving intended outcomes. The cROP was objective, 

risk-informed, transparent, and predictable. The cROP also ensured openness and 

effectiveness in support of the agency’s mission and its strategic goals of safety and security. 

During CY 2015, the staff continued to find opportunities to strengthen program effectiveness 

and implementation. The staff recognizes the value of continuous improvement and will 

continue to consider stakeholder feedback in its efforts to apply lessons-learned and improve 

various aspects of the cROP. The staff will continue to monitor and to right-size NRBL allocated 

resources through the PBPM. 

COORDINATION: 

This paper has been coordinated with the Office of the General Counsel, which has no legal 

objection. The Office of the Chief Financial Officer has reviewed this paper for resource 

implications and has no objections. 

 /RA/ 

 

Victor M. McCree 

Executive Director 

 for Operations 

Enclosure: As stated 

ADAMS Accession No: ML16061A168 WITS: 201100140 *via email SECY-012

OFFICE NRO/DCIP/CIPB* NRO/DCIP/CIPB NRO/DCIP/IGCB NRO/DCIP:DD 

NAME TKozak RLukes BAnderson MCheok 

DATE 2/26/16 3/2/16 3/4/16 3/9/16 

OFFICE NRO/PMDA RGN II:DRAC* OE* OCFO* 

NAME DHumerick LDudes* (KO’Donohue for) RFretz BFicks (SHurd for) 

DATE 3/11/16 3/21/16 3/14/16 3/28/16 

OFFICE Tech Editor* OGC/NLO NRO EDO 

NAME JDougherty PMoulding JUhle VMcCree 

DATE 3/16/16 3/25/16 4/15/16 04/22/16 

OFFICIAL RECORD COPY
Enclosure 

Construction Reactor Oversight Process (cROP) Resources 

The staff estimates that the direct inspection effort will be 35,000 hours per unit over the course 

of the construction project. This estimate includes 15,000 hours for inspections, tests, analyses, 

and acceptance criteria (ITAAC)-related inspections; 10,000 hours for construction and 

operational program inspections; 5,000 hours for reactive inspections above the baseline 

program in response to licensee performance issues, allegations, and nonperformance 

issues/events; and 5,000 hours for technical support for construction inspection. These have 

always been stated as average values, with initial units likely to require more inspection than 

subsequent units. 

Table 1 summarizes the U.S. Nuclear Regulatory Commission (NRC) staff resources expended 

at the four AP1000® units under construction, in hours, for the construction inspection program 

(CIP) during the past five calendar year (CY) inspection cycles. Tables 2 through 5 reflect direct 

inspection hours expended by calendar year for Virgil C. Summer, Unit 2, Virgil C. Summer, 

Unit 3, Vogtle, Unit 3, and Vogtle, Unit 4, respectively. The NRC inspection effort increased in 

CY 2015 as compared with CY 2014. Through CY 2015, 28 percent to 31 percent of the 

estimated direct inspection hours were expended at Virgil C. Summer, Unit 2, and Vogtle, 

Unit 3, and 10 percent to 12 percent of the estimated direct inspection hours were expended at 

Virgil C. Summer, Unit 3, and Vogtle, Unit 4. As anticipated, the majority of the ITAAC direct 

inspection hours to date were for ITAAC that have not yet been completed by the respective 

licensees. 

Through CY 2015, actual direct inspection hours at the lead units have been slightly above the 

direct inspection effort of 35,000 hours per unit over the course of the construction project. This 

is primarily due to inspections needed to review corrective actions for design control and module 

receipt inspection performance deficiencies and the need to inspect constructability issues that 

lead to license amendment requests. Therefore, it is likely that the original direct inspection 

estimate will be exceeded at Vogtle, Unit 3, and V.C. Summer, Unit 2. However, corrective 

actions implemented by the licensees have for the most part been effective in preventing similar 

performance deficiencies from occurring at Vogtle, Unit 4, and V.C. Summer, Unit 3. Therefore, 

the staff anticipates that direct inspection effort will meet or be less than the 35,000 hour 

estimate at Vogtle, Unit 4, and V.C. Summer, Unit 3. Thus, the staff has determined that the 

original estimate of 35,000 direct inspection hours is reasonably accurate and no changes to the 

estimate are planned based on field experience to date. 

A majority of ITAAC will be closed by licensees near the end of construction, but whenever 

possible, Region II staff is performing inspections early in the process to minimize the inspection 

resource demand peak and to facilitate timely ITAAC closure. Tracking Smart Plan completion 

provides the best available method for assessing progress in implementing the required CIP 

inspections. Smart Plans are the detailed inspection plans used to translate the general 

inspection guidance in the inspection procedures into plant-specific activities. Through 

CY 2015, approximately 20 percent of Smart Plans were complete at Virgil C. Summer, Unit 2, 

and Vogtle, Unit 3; approximately 14 percent were complete at Virgil C. Summer, Unit 3; and 

approximately 13 percent were complete at Vogtle, Unit 4. The percentage of ITAAC-related 

direct inspection hours expended was about 10 percent higher for Virgil C. Summer, Unit 2, and 

Vogtle, Unit 3, when compared to the direct inspection hours estimated in the Smart Plans that 

have been completed for these units. The percentage of ITAAC-related direct inspection hours 

expended was about same as the direct inspection hours estimated in the Smart Plans that 
2 

have been completed for Virgil C. Summer, Unit 3, and Vogtle, Unit 4. The staff’s overall direct 

inspection effort will increase over the next several years as the units proceed through 

construction and into the preoperational testing phase. 

 

Direct inspection charges for allegation followup at the two sites are very low in proportion to the 

number of allegations received. Most of the staff’s allegation followup activities have occurred 

in-office rather than during onsite inspections. The staff will continue to ensure that allegation 

followup time is appropriately charged. 

Table 1: Actual Total Construction Inspection Program Resource Expenditures 

Calendar Years 2011–2015 (Hours) 

Inspection Activity 

Hour 

Estimate Per 

Unit 

Summer 

U2 

Summer 

U3 

Vogtle 

U3 

Vogtle 

U4 

ITAAC direct Inspections 15,000 4,473 1,182 4,979 1,585 

Program direct inspections 10,000 3,962 2,054 4,582 2,083 

Reactive and allegation 

inspections 5,000 157 19 110 53 

Headquarters technical staff 

inspection support* 5,000 1,049 399 1,179 461 

TOTAL 35,000 9,642 3,654 10,850 4,182 

* To date, headquarters technical staff inspection support has not been linked to a specific docket and has not 

been fee-billable. Therefore, it is not possible to distinguish the Office of New Reactors technical support hours 

expended on each unit. In this table, the total hours expended on technical support have been pro-rated 

between the four units under construction based on total inspection hours. 

 
3 

Table 2: Actual Construction Inspection Program Resource Expenditures 

VC Summer, Unit 2, Calendar Years 2011–2015 (Hours) 

Inspection Activity 

Hour 

Estimate Per 

Plant 

2011 2012 2013 2014 2015 Total 

ITAAC direct 

Inspections 15,000 0 636 1,269 1,388 1,180 4,473 

Program direct 

inspections 10,000 98 1,169 1,035 787 874 3,962 

Reactive and 

allegation 

inspections 

5,000 0 0 0 0 157 157 

Headquarters 

technical staff 

inspection support 

5,000 13 292 228 214 302 1,049 

TOTAL 35,000 111 2,097 2,532 2,389 2,513 9,642 

Total hours expended at V.C. Summer, Unit 2, were slightly higher in CY 2015 as compared to CY 2014. 

Approximately 28 percent of the total estimated hours have been expended at V.C. Summer, Unit 2, through the 

end of CY 2015. 

Table 3: Actual Construction Inspection Program Resource Expenditures 

V.C. Summer, Unit 3, Calendar Years 2011–2015 (Hours) 

Inspection Activity 

Hour 

Estimate Per 

Unit 

2011 2012 2013 2014 2015 Total 

ITAAC direct 

Inspections 15,000 0 18 313 359 493 1182 

Program direct 

inspections 10,000 105 550 597 289 513 2,054 

Reactive and 

allegation 

inspections 

5,000 0 0 0 0 19 19 

Headquarters 

technical staff 

inspection support 

5,000 14 92 90 64 140 399 

TOTAL 35,000 119 660 1,000 712 1,164 3,654 

Total hours expended at V.C. Summer, Unit 3, were higher in CY 2015 as compared to CY 2014. Approximately 

10 percent of the total estimated hours have been expended at V.C. Summer, Unit 3, through the end of CY 2015. 

 
4 

Table 4: Actual Construction Inspection Program Resource Expenditures 

Vogtle, Unit 3, Calendar Years 2011–2015 (Hours) 

Inspection Activity 

Hour 

Estimate 

Per Unit 

2011 2012 2013 2014 2015 Total 

ITAAC direct 

inspections 15,000 7 739 1,049 1,552 1,632 4,979 

Program direct 

inspections 10,000 135 1,187 1,324 1,031 906 4,582 

Reactive and allegation 

inspections 5,000 0 0 39 12 59 110 

Headquarters technical 

staff inspection support 5,000 19 311 239 256 355 1,179 

TOTAL 35,000 161 2,237 2,651 2,850 2,952 10,850 

Total hours expended at Vogtle, Unit 3, were slightly higher in CY 2015 as compared to CY 2014. Approximately 31 percent 

of the total estimated hours have been expended at Vogtle, Unit 3, through the end of CY 2015. 

 
5 

Table 5: Actual Construction Inspection Program Resource Expenditures 

Vogtle, Unit 4, Calendar Years 2011 - 2015 (Hours) 

Inspection Activity 

Hour 

Estimate 

Per Unit 

2011 2012 2013 2014 2015 Total 

ITAAC direct 

Inspections 15,000 0 229 301 391 664 1,585 

Program direct 

inspections 10,000 26 391 572 401 693 2,083 

Reactive and allegation 

inspections 5,000 0 0 0 0 53 53 

Headquarters technical 

staff inspection support 5,000 3 100 86 78 192 461 

TOTAL 35,000 29 721 960 870 1,602 4,182 

Total hours expended at Vogtle, Unit 4, were higher in CY 2015 as compared to CY 2014. Approximately 

12 percent of the total estimated hours have been expended at Vogtle, Unit 4, through the end of CY 2015.