 Well good morning everyone, I want to welcome our panelists from Southern Company and South Carolina Electric and Gas Company as well as the NRC staff we'll hear from later and then as well as members of the public who may be here or listening in. Purpose of today's meeting is to provide the commission an update on industry and staff activities related to completing inspections, tests, analyses and acceptance criteria otherwise affectionately known as ITAC and that will allow that acronym today because it is a long we're going to need to and it has become you know part of our vocabulary particularly in the new reactor licensing area under part 52. We'll also learn or hear about ITAC inspections and the staff's verification of ITAC completion and we'll begin with discussions from the external panel which will provide industry perspectives on ITAC and we want to welcome Alan Torres, General Manager of Nuclear Construction, South Carolina Electric and Gas Company and Mark Ruckerst, Construction Vice President for Vogel Units 3 and 4 of the Southern Operating Company. Following this panel we'll have about a five minute break and then hear from the staff and we look forward to hearing the presentations and the ensuing discussion. Before we begin, my fellow commissioners have anything to say? Very good. Mr. Torres, will you begin? Thanks. Well again, thank you for the opportunity to speak before you this morning and we'll give you just a quick overview of our position and some of the things that we've been experiencing over the last several years since we came before your staff in 2011 to give an initial briefing on the licensees approach to ITAC. We'll go to the first slide. One of the things I wanted to refresh everybody on, it's a basic premise of course as part 52 is ITAC providing reasonable assurance that the facility has been constructed and will be operated in conformance with the license. Those are key words because we do experience challenges on a regular basis, ensuring that we're complying with the license. So ITAC is a very integral part of that verification for the licensees. ITAC originated from the COLA including those from the reference to DCD and ESPs if applicable. And one correction here, there are currently about 843 ITAC per unit for summer. Now that may vary by the time we get done with the plant depending upon how things might change. But that's about a ballpark number. I'd put on here about 900. That's an outdated number, but about that number about 843. Next slide. Requirements for ITAC performance. And this is a slide when I talk to external stakeholders and also our team, one of the things that I find it's very important to do is help everybody understand the basic premise of what's supposed to happen when we talk about ITAC. An area that seems to get neglected sometimes by folks that aren't in our business on a regular basis, that's part 50. Tennessee F-R-50 Appendix B is, of course, our foundation for building these plants to ensure compliance with the Code of Federal Regulations. And oftentimes it's misunderstood that okay, we're part 52 plant. Well, some people assume that means that you're not adhering to part 50. Well, you know, that's not the right thing. We still comply with the 18 criteria. The 18 criteria are essential in the verification and validation of ITAC processes. They actually lead us to many of the ways of verification of the ITAC process. So it's a very critical element for us to follow. Then, of course, we have Reg Guides. We have various codes and standards that I've listed here. ASME3 probably being one of the larger codes and standards that we use, mainly for the N-TRIPLE-S and its support systems. From a concrete standpoint, we have ACI and then the bulk of our welding non-ASME related would be covered under AWS and then not to leave out the I-TRIPLE-E standard for our electrical compliance, all of which roll up under the method for verification. Again, you know, part 50 being the cornerstone and then you begin to matriculate down through the various codes and standards that are built into our license for compliance and each one of those gives specific direction on how to apply safety-related inspection and then that gets rolled up into ITAC performance. And then, of course, the last item would be the additional programs and procedures that we have for implementation of the ITAC program. Everything from development of the closure letter to filling in the documentation required when we're going to submit something that may not be complete yet after the 225-day requirement. Next slide. Just a pictorial on the ITAC completion process, early block being out of the way now, an area that will begin to get more focus on would be the blue shaded area. As we begin to close ITAC in the field, an area that'll be critical for the licensees is further development on the ITAC maintenance approach and how important that is to ensure the staff is well-informed on when we perform maintenance or when the need for maintenance is happening to a component that's already been closed under the ITAC process and prior to the 103G finding. So that'll be a very critical area that we begin to put more focus on as we go down the road of continuing to close ITAC. And then ultimately, of course, the 103G finding prior to us loading fuel. Next slide, please. This is a good slide for myself and a lot of other folks. It helps put the ITAC into perspective categorizing a standard plant. This is a standard AP1000 plant. And this is the way the ITAC are broken down so that when you see a block that says engineering and it has 220 ITAC, well, you say, what does that mean to you? And here we break it down such that you can get a good feel of what that means as built analysis, ASME, EQ qualification, environmental qualification, engineering analysis, and individual equipment qualification. Then you go down to construction, 187. So here also is an area that a lot of folks thought when we talked about ITAC that all 800 and some odd ITAC would be done during construction. That's not necessarily the case. Here you can see that specific construction ITAC, there are 187 of those in the standard plant. 220, as I said, in engineering space. Now you go into initial test program, 274. So another large population that occurs in an area other than the construction phase of ITAC. So that'll occur a little bit further down the line. And then all the way down to security and that pertains to the systems that support the physical security plans. Next slide. I wanted to give you a couple of examples of significant evolutions that have occurred on the construction site, but they have multiple ITAC associated with them. Oftentimes when we talk about ITAC, it's viewed as, okay, a system has an ITAC or a component has an ITAC. Well, here are some very large elements of the construction process that have multiple ITAC associated with it. And I think that in itself shows the depth and breadth of the inspection and test and analysis program that takes place. For example, on ring number one, and this one happened to be for unit two, there's the functional arrangement ITAC. There's an ASME ITAC because the containment vessel is a pressure boundary component covered under ASME. Then we have the individual NDE associated with an ASME. Weld, which is also an ITAC. And then finally, a seismic category one equipment component relative to the CV itself. Then we go on to something like CA-20, a large structural module. Well, of course, we go back to the physical arrangement. Spent fuel volume because CA-20 contains the spent fuel pools. Cast wash down pit, again, that's self-contained inside CA-20. And then finally, ASB built concrete wall thickness for determination of ensuring we have sufficient wall thickness for radiation. Next slide, please. Some examples on the unit three side. Again, with the placement of the CV bottom head on unit three, we have functional arrangement, ASME, seismic, ASB built concrete thickness for the shield building. Exterior walls in unit three, simple things like wall thickness for non-RAD. And they appear to be simple, but there's a great deal of detail that goes into the accomplishment of the inspection. Not only have we completed the normal Appendix B requirements for ensuring that that's safety-related concrete, but we've also developed with the help of your staff a common methodology of how many measurements take place to make that determination of thickness. You don't just go to five spots on the wall to determine thickness. So that's been well laid out. Shield wall and floor thickness, several of those ITAC. And then finally on the bottom of the page, turbine building foundation. And it's interesting, most people would assume that, well, that's non-safety related, but that's also still part of our physical arrangement because of its potential impact to the nuclear island. Next slide, we'll talk about lessons learned. And I'll be covering this for both us and Southern. Clarifications on ITAC requirements to vendors has been very key to us. We learned that early on through both vendor inspection and self-assessment inspection by the licensees. Importance of understanding documentation requirements, what do you need from the vendor to show closure of an ITAC? That level of documentation, we had to help the vendors understand the needs for that development of documentation. Validation in the vendor shops, we have residents in several of the vendor shops to help us with that. We also avail ourselves of opportunities via both quality assurance surveillance and customer witness and hold points to coincide with critical ITAC evolutions. Completeness of critical information, again going back to the documentation components, some pieces of paper require more detail than others. For example, ultrasonic measurement thickness on the accumulator tank, how many places where the measurement's done, what was the calibration of the equipment, how was the process done. Closure package preparation, that's no small task because we wanna ensure that we have a completed package sent to your staff so that there are a minimal number of questions that helps expedite the process and ensures that the opportunity for the public when the package or the notice goes into the Federal Registry of Closure. So it's very important for us to ensure we have an expedited closure package process. Periodic assessment of the process itself, this is a check and adjust. We avail ourselves of both a peer benchmarking from Southern and also external from prospective license applicants such as Dominion have participated on some of our benchmarking at our site and our assessments, independent assessments on the ITAC process itself. Next slide. I will note that there was a change that I sent late last evening. I had an incorrect statement on this slide and that deals with NEI 0801 Rev 5. It's in the process of endorsement into the Reg Guide so it has not been completed yet. But this is an important document for the licensees and the industry as a whole. We've worked well with the staff to ensure that the proper guidance is placed in the 01 document so that all the stakeholders have a say in the process and to help ensure clarity in the entire process. So that's worked very well. Next item on there is ITAC integrated project teams on our sites. Each one of our ITAC teams are comprised of multiple stakeholders in both the design and construction side as well as the licensee. We've now implemented monthly and quarterly inspection planning meetings with your staff which will continue to help us streamline the process and get better at what we're doing. And then finally the two utilities currently, the AP1000 utilities are both in alignment on the process to which we're going forward with. And I say currently because there has been another license issued to a different design group. With my last couple of minutes, I'll just briefly go over the next couple of slides. This is just for the folks that haven't had an opportunity to be out on the site to give you a quick perspective of how things are going at the site. And I'll just briefly cover these with the last couple of minutes I have. This first aerial shot shows the low profile cooling towers. That probably is the most significant difference between our two sites is that we have mechanical draft towers as opposed to the larger natural draft towers that they have down at Southern. Everything else would be about the same on the two sites. Next slide. This is a picture of CA-20 being transported out to give you an idea of the size. If you look to the left, that building that it's coming out of is 120 feet tall. So that gives you a respective size of CA-20. Next slide. This is a completed CA-01 module inside the module assembly building. We will be placing CA-01 toward the latter part of this month. It's coming out of the building in the next week or so. So this is our steam generator and refueling cavity module that goes inside the containment vessel as multiple attack associated with it. Next slide. This is a picture of placing the lower head on unit three. Again, as I showed you in the milestone slide, there were multiple attack associated with that. The lower left-hand corner is showing the placement of CA-20 against the CV and there you see ring number one has been placed next to CA-20. And then finally on the right-hand side, it's a different perspective from the shield building side of CA-20. Next slide. One of the critical components inside the containment vessel is CA-04. It has multiple attacks. That is the location where the containment, I mean the reactor vessel will actually sit. Both units now have their CA-04s in place. Next slide. Again, another critical component that has multiple attack and this is CA-05 going inside the containment vessel. Next slide. We get a couple of equipment pictures here. This is the first steam generators being offloaded. You'll note that the end of the steam generator looks a little different and that's because the reactor coolant pump casing has been welded onto the steam generators. Since we did have some time in our schedule due to other issues, we were able to make that critical weld in the shop environment as opposed to having to make that in the field which lent ourselves to a great deal more quality evolution. And then finally the last slide is a picture of the pressurizer prior to shipment and it has been received on site. That ends my remarks. Thank you very much. Okay, Mr. Rackers. Good morning. I appreciate the opportunity to come here today to discuss ITAC, which is an important element in the construction of Vogel III and IV. The presentation is designed to be an update and the progress and lessons learned since our last ITAC discussion with the commission in 2011. Next slide. Southern has approximately 873 ITACs per unit that must be closed prior to fuel load. The differences are we have standard plant which are the same between both units or both VC summer and Vogel and then the site-specific ITACs that are related to our specific construction locations. The distribution that you see shows the closure notices that we will submit ultimately to the NRC during the construction of each unit. And as Alan discussed, it represents the phases of construction activities that we'll go through and the blue line represents the combination of both units. The peak of the curve is driven primarily by the testing that we will perform as construction completes. It's important to note, as Alan said in his remarks, the significant number of ITACs that will be performed during pre-op and startup testing of both of the units. We're applying the knowledge and the experience that it gained early on and the lessons learned to date. It has been an interactive process and a process in which we have been fortunate enough to have significant dialogue and conversation with the staff. And NEI 0801, I will tell you, has been a very positive effort on all parties to get to a better place in terms of understanding expectations relative to ITAC and ICN submittals. In a moment, I'll highlight some steps we're taking to ensure the continued success of ITAC. Next slide. So a little bit different in terms of the ITAC life cycle is from what Alan presented is that it really goes through a planning cycle, an execution cycle, and then a notify where we would notify the NRC of our completion of individual ITACs. Let me go through this a little bit. The PDPs are the performance and documentation plan. It really outlines how we're going to address and satisfy each of the individual ITACs. We then get into work packages or we start to assemble the documentation, whether it be reports, whether it be construction, whether it be design drawings, whether it be other information that is there to support the individual ITAC and the satisfying of that ITAC. We go to the PCD, which is the principal closure document, which is the document cited in the ITAC determination basis, and it directly supports how we are concluding that the ITAC has been met. The completion package is really our way of putting all of that documentation together and it represents all of the supporting documentation that we will maintain as records to support that individual ITAC. And then finally, the ITAC closure notice, which is the letter sent by us, the licensees to the NRC, stating that the ITAC is complete in accordance with 10 CFR 52.99 Charlie 1. Next slide. So here's where we are today. We've completed the development of all of the PDPs. So we have our plans put together and ready to execute. Each plan is the guidance document to support the closure. For Vogel III and IV, we're now in the process of screening the work packages to ensure that each of the work packages that represent both field activities and vendor activities and other activities done by the design organizations are there to support the completion of the ITAC. As work increases, the number of work packages related to ITAC will rise. And as the construction increases and we get into the testing programs, we will have over 5,000 work packages that will have supporting ITAC closure. To date, 26 ITAC closure notices have been submitted to the NRC and approved. This includes both units for Vogel III and IV. And there's 25 additional ones that are anticipated to be issued this year. Next slide. Uncompleted ITAC notifications or UINs is a requirement under 10 CFR 52.99 Charlie 3 where the licensees shall submit a methodology for all ITACs that have not been completed by at least 225 days prior to fuel load. And that is to support of staff in its publication of a notice of intended operation. And as you can see from what we've been talking about earlier, with the testing, both pre-op and startup testing, there will be a significant number of ITACs that will not be completed prior to that 225 day notification. It's important. UINs must describe how the licensee will successfully complete all of the uncompleted ITAC. They'll state items completed as well as items to be completed and how the acceptance criteria will be met. The appropriate level of detail on the inspection testing and analysis and a schedule will also be included at that point in time. So we'll be through a majority of the construction-related activities and we'll have a very good understanding, both ourselves and VC Summer, about how the rest of the ITACs will be closed out. We're anticipating that, as noted earlier, a significant number of those ITACs will have final completion in that period. So SCANA and ourselves have been working on ways in which we together as licensees could present options and alternatives to the NRC about presenting uncompleted ITAC notices to the staff earlier than even this requirement. And today I can tell you that we have reached alignment on an approach that we would like to discuss with staff moving forward. And there is an upcoming construction and inspection program meeting, which is public, in which we will discuss some of the options and alternatives that we have identified for consideration by staff. Next slide. So moving forward, a significant amount of progress has been made in the last four years towards understanding and implementing ITAC. Both the Vogel and Summer projects are committed to continuing the interactions both with the industry, including any new licensees and the NRC to ensure that the best practice are shared and implemented. With the recent transfer of inspection planning to the projects branch within Region 2, we see this as an additional opportunity for us to work on the planning and coordination with the NRC relative to their inspection activities. I think you'll hear more about that today. But a lot of effort is in terms of coordination between our schedules, the work that's progressing on the projects and the inspection activities that both Region 2 and NRO does at the site. We believe that the changes is very positive and we're planning on to support the NRCs as it aligns with our project team approach. As Alan mentioned, we've now scheduled meetings in order to increase the coordination and planning efforts between our organizations. And we had a recent meeting in June in which we discussed the cable management program, the coatings on equipment inside containment, as well as the status of the ASME reports, which will be an important component for the components that are already here on site. So in closing, on behalf of Southern Company, I assure you that our organization is committed to the safe quality and compliant construction of these units. We understand the importance of ITAC and the way in which ITACs demonstrate our commitment to both the public, our customers, and to the NRC. On the next slide, I don't have as many pictures as Alan, I figured it's pretty much the same, but this is a picture of Vogelsight as it exists last week. And as you can see, there is a significant amount of progress in the construction activities. As the volume of construction increases, so will our focus and efforts on the quality and compliant construction. Working with our contractors and with our vendors, that's where we, as licensees, will ensure that we are meeting the requirements and expectations. Thank you, that concludes my remarks. Well, thank you for your presentations and we'll begin the questioning this morning with Commissioner Barron. Alan, Mark, good to see both of you again. Thanks for being here. I really enjoyed my recent visits to Summer and Vogel. Mark, you discussed your planning and scheduling to ensure timely completion of the ITAC and submission of the ITAC closure notifications to NRC. You focused on that, but this is really, all these questions are for both of you. Of course there have been several unanticipated design changes with the AP1000. Can you walk us through how you analyze those design changes as they occur to determine if they affect any ITAC? Sure, my organization is comprised of multiple technical groups. I have a technical compliance organization and I have a supplier compliance organization. And when we see issued or design changes that are being issued by the design authority, we review and evaluate those design changes relative to its impact on ITAC. We incorporate that information into those work packages in order to make sure that we are correctly getting the information, whether it be from a vendor or in the field, that meets the ITAC requirements. So that's really where my organization is focused is on the front end as the design changes come out to ensure that we have that information on the back end. And how much uncertainty in the scheduling and the work planning are those changes creating? It is a construction project. And with a construction project, the best laid plans will always have changes. And we have had some challenges related to some of the schedule impacts. I don't know that I would characterize it as necessarily affecting ITAC, but it is related to the overall construction process. And I don't know, Fallon, if you want to say anything more about it, that's really where we're seeing it. So not in the ultimate information that we get, but just in the sequence of activities that we're having to execute. Yeah, I would just like to add a couple of things here. The first phase of the change process involves the development of the design change paper at the designer Westinghouse. And it, too, has a flow process that includes a scrub VITAC compliance in the license. And then the licensees get that document to do an additional scrub VITAC. So I agree with Mark. To date, most of the changes are very limiting to ITAC. But to answer your question relative to uncertainty, there have been a number of stumbling blocks for us to deal with relative to design changes impacting the overall completion of the projects. And all that information is public information relative to the current schedules that we're on. But there are challenges. We do continue to work with our stakeholders, both from our state regulator standpoint and our contractors, to help understand how each one of these changes impacts the overall schedule completion. Yeah. OK. A lot of the construction work on the site, obviously, is being done by contractors with SCANA and Southern overseeing the work. I'd like to ask about the level of licensee management for ITAC. Will someone from your company's physically observe the closure of every ITAC? Or for some ITAC, will it be a review of documents prepared by a contractor? Well, I'll take that question first. Well, the process we've set up at site and it's contractually required, actually, is the Westinghouse has the lead for the ITAC team. The consortium works together on the construction site, supplying the information to Westinghouse to develop the ITAC closure process. It's then submitted to the licensee. The licensee goes through a series of reviews with that and ultimately we're responsible for the accuracy of that closure package. And then final submittal to the staff for posting in the federal registry. We do a series of inspections where we can do inspections in field. We do a series of document reviews for vendors that we may or may not have had the opportunity to avail ourselves of the actual inspection. But we do try to take the opportunity of both the quality assurance surveillance and the witness and hold point program to observe as many ITAC as possible to put eyes on stuff. I think both utilities are very focused on eyes on critical areas. And ITAC is a critical area for completion of the projects. How do you determine which of the ITAC related issues are ones you're going to have eyes on? Presumably you can't. We usually look at a risk review of significance of the system and or component, both from a commercial and a nuclear safety standpoint. Do you have anything to add on that, Mark? No, I would just support what Alan has said. And we review as many as we can and understand that the documentation supplied by, I'll just say, vendors in a lot of cases is what we'll make sure we have done a thorough review and evaluation of. And if we need to do additional inspections as a result of that, then that's where we'll get ourselves involved. When I look at the timeline for ITAC and construction inspection for Vogel in summer, I have the same reaction probably many people do, which is I'm struck by just the volume of activity that has to happen in those last few months of construction. The significant number of ITAC closure notifications, likely ITAC hearings going on for two units at different plants pretty much simultaneously, NRC completing remaining inspections for a 103G finding. At the same time, you all are preparing for potential fuel loading. You're getting operational programs in place implemented. So just a huge amount of activity that will be occurring in a very short period of time. How are you preparing your management and staff to perform all of those tasks that are your tasks while keeping a focus on safety? I mean, that's just a huge amount of workload and scheduling pressure. How do we make sure that if there are safety concerns or issues, people raise those? You know, we talk about whenever you see the curves, right, when you show this huge peak, it's really focused on the ITAC closure notice. But up until that point in time, there is a significant amount of work that is being performed and inspection activities that are being performed that then get to a point at which you're submitting the ICN. So I'll just tell you that it might have been an issue where we were thinking that down the road, this was going to be hard to manage. But as we've gotten into the process and learned going through this, it is about all of the significant work that is done prior to that. And that's really where both ourselves, in terms of an oversight capacity, as well as, I think, from the NRC in terms of inspection activities, really, really will help us as we get and go forward. I would just offer one additional comment, and that would be directed at your safety comment. You don't get a good safety culture overnight. This is a built-in process from day one when we started when we received the license. We pulse how we're performing in the safety culture environment to ensure that we're not putting that undue pressure on personnel. We're not losing focus on the ultimate goal, which is safe design, construction, and eventual operation of the facility. And that falls on the licensee. Again, ultimately, we're responsible for that. And we ensure, through methods of going back to the checks and balances, not only do we do assessments and design in ITAC area, but we do assessments in the skiway area also to ensure safety culture work environment, to ensure that we're pulsing and getting the right mentality out of the folks that they know that they're free to raise a question, whether it be, you're pushing me too hard on schedule or there's an outstanding question relative to design that I'm not satisfied with an answer or any of those type items. So it's not just at the end that it becomes a concern. From day one, you always want to keep that at the forefront of your mind to ensure that you're building that as you build the plan. Thank you. Thanks, Mr. Chairman. Thanks. Thanks. And again, thanks for both of your presentations. I think the interesting thing as we proceed through Part 52 is we recall Part 52 is now 25, 26 years old, first promulgated in 1989. And we are still in the midst of testing key components, if you will, of it. And this, the ITAC for both of you are going through, which is essentially the first time we've gone through the ITAC process at the during construction or the latter stages of construction. So I think it'll be important for us to keep attention. And I think both us as the regulator, but I think of the industry as well, I think we'll learn from your experience in terms of the management of ITAC, how they work, what particular challenges are with them as we go through the process. But I might ask that my prompt, that observation might prompt at least this question, sort of a wide open or general question, is as you reflect back, even at the stages where you are now, recognizing there's some significant work in that val wave to come, are there things about the ITAC process that you think you've learned or come across that have surprised you or didn't quite meet the expectation of when you started into this, but particularly at the COL point in time. And either one of you can have any thoughts on that. I'd appreciate it. So I'd say that ITACs related to vendors have added a level of complexity only because it's important for us to understand the work that the vendor is doing and how does it relate to the ultimate ITAC that we have to satisfy. For the plant monitoring system, PMS, we went through a significant review and evaluation and inspection activities related to that. And we learned a lot. And it was something that I think we went into thinking it was not going to be as long of a process, but I think we're coming out of it with a better understanding of the expectations related to some of these critical systems and how ITAC supports that. And I really am glad that we've been able to do that early on because those lessons learned are going to help us as we get into the testing and turnover of the plant from the contractor to us. Is there some complex issues there, too? I think so, too. Yeah, about the only other thing I would add, not necessarily from a surprise, but yet to be fully developed would be the ITAC maintenance portion. You know, I guess at face value, when you read the initial regulation, once you had completed ITAC and submitted a closure package, you'd like to think you're done. But the element of ensuring the compliance of the ITAC until 103G adds an element that will cause us to do some more work to ensure that we have programs in place to maintain the validity of those ITAC until the end. And as a construction schedule stretches, that could mean something that I've completed early on in the construction process requires constant revisiting all the way through to the end. So that does add a little bit more to it than at face value. Mark, coming off of your comments, is how would you say that the process or the ITAC, in terms of the vendor oversight or the vendor interaction, it would be different from what I'll call the first wave of construction or under part 50? I won't say it's different in terms of the actual implementation. What I'll say is it's different because in some areas, it's not cut and dried. When we talk about CA20 or we talk about CA04, we talk about physical structures. It's very clear whether you meet or don't meet the ITAC requirement. When you're dealing with systems, like what I mentioned earlier, a little bit more complex, and that's where I think the interactions have been very helpful, is to understand those individual differences and how we need to approach those. I'm satisfied. And it's your sense and as they said, I think both, certainly when I visited Vogo, some of the discussion we had touch on this, but for both of you, do you have a sense or what I had the sense of is that sort of either bringing the vendors to understand the significance on the ITAC, particularly for you guys who are building it, who ultimately want to operate it, was some of the challenge. Do you feel like you've made progress in that area? Yes, actually, in the lessons learned comment relative to vendors, that was the driving point there. We did experience early on both the translation of critical information in design and ITAC space to foreign vendors to ensure that number one, they fully understand the literal translation of what the requirements are, but also ensuring with all our vendors that they understood the level of importance of what the ITAC was. Too often when you go to a vendor, he looks at his technical requirements, says, oh yeah, we've got that covered and on about their business they go. So it is very important and I know both our companies do spend a significant amount of time and manpower in the vendor shops after we had the early challenges with several of our vendors understanding the significance of ITAC. Yeah, good. One of the, you mentioned the NEI 0801, maybe just to help inform us in the general audience, what do you think, and you also indicated in terms of talking to the staff and potential endorsement, what do you think that brings to the table in terms of the process for ITAC and ensuring our ability to look at the plants as they're completed? Well, from early outset, even prior to the issuance of the license, I will give credit to both the staff and NEI that we sat down as collective groups and said, okay, here's a requirement in part 52, how will we implement this? What will be the end product? And early on, again, before any of the licenses were issued, both groups got together with prospective licensees and began to develop the process. And once we had the basic premise of what ITAC is and isn't, then the next step of, okay, what's the end product gotta look like and then how do we facilitate that? So the guideline itself is just that it is that structure, that outline, that hard fast document that helps lead you through the overall process of ITAC. In the development of that document, I thought was extremely beneficial to the licensee in that we not only had the industry stakeholder in NEI, but also the staff. We submitted drafts and said, here's an approach and we also did this in a public forum, such that if there were opportunities for the public to make comments on the process, it was there. So this gives us the structure that we need to go back and develop the detailed level of procedures on each one of the sites to actually make the process flow. And it's a work in progress. As you see, we're at Rev Five, so yeah, we've gone through several iterations and we'll continue to do that. The good sign of an industry that understands itself is constantly improving, checks and balance. And we will do that until each one of us receives a 103G, and then we'll continue to do that in operational space under our operational programs. So a document like 0801 is essential to the process that we have in place. You want to add anything? No, I was going to say, we learned early on, right? At Vogel, we had some ICNs that did not meet expectations. And I think by getting an alignment in terms of expectations and understanding of the level of detail of information has been incredibly valuable for us as we move forward. We're going to continue to learn and apply those lessons learned. It will be an important element, as Helen mentioned, for us moving forward. Okay, thank you, Bill. Commissioner Semeni. Well, I'll add my thanks to both of you being here today. I think each of you mentioned the fact that it's been since 2011 that we have had perhaps your organizations represented in front of the commission, and that reminds me, and perhaps even my colleagues sitting here are not aware that when I joined the commission, given at the time the forecasts of the amount of new reactor activity in the United States, our commission met quarterly and in a public session such as this on new reactor activities. That was the pace of things then. So now, I think it's very timely that we're discussing this today. I know that some might ask the question, well, if the commission's meeting on ITAC, what's the issue with ITAC? And there doesn't, in my view, always have to be some challenge or issue. This process is a very, very important part of the demonstration of safety prior to operation and therefore it's also acronym laden and full of a lot of jargon. So I think that our commission meeting to discuss this today is important. And as your presentations pointed out, this will only be of growing importance in the coming years as you proceed towards operation at these reactor construction. What are now construction sites? All that being said, it's interesting in this country when you look at it, the chairman mentioned was it 1989, the part two came into existence and you have an option in this country. You have two-step licensing or one-step licensing. And I think my staff is very aware that sometimes when issues are encountered in construction and we say when as a fact certain, these reactors, if constructed as designed and licensed, provide additional levels of passive safety and margin in the current operating fleet in the United States. So that's simply an established fact given the designs. So if they are constructed according to that design and licensing, we sometimes look at the issues being examined during construction and say, has the appropriate risk threshold of these various individual issues been established? And again, my staff is aware that I occasionally step back and remind us that if you would like to have a more flexible, perhaps, construction process, part 50 is available to you because then you will apply for an operating license and you get to have a second step. The compact, the regulatory compact in my view with one-step licensing is that the commission and the agency in effect have pre-approved your operation and then the burden shifts to you to show that everything that is the underpinning of that pre-approval has then occurs as you move through the construction phase. So I don't doubt that when we look at the establishment of the risk significance of certain approval levels for changes with the NRC, I don't doubt that if we all had it to do over again, there are probably some changes we would make, not only perhaps in looking once again at ITAC establishment, but also in the what we call the tier two, tier two star types of information that comes out of the approved design, the certified design. So I think certainly if there were going to be in this country a lot of follow-on construction after Vogel and Summer are complete, I don't know whether that will occur or not. Right now it doesn't look like it. I don't doubt that we would have a very robust lessons learned to go back and look at some of those threshold determinations that we made. I think at this point, we're so deep into this and the level of activity is high enough that we're not going to pause to go back to first principles and look at some of that. We're going to push through with the early thresholds that we set and move forward with that. I will ask some specific questions. Roles and responsibilities is obviously very, very important. I would ask each of you, as you've looked at the clarity of engaging between NRC's office of new reactors and Region II, do you think NRC has well-established and clear roles and responsibilities of where you need to turn for various engagements between NRO and Region II? Is that clearly understood and does it work well? I'll take that first. I'd say yes. I think we have extremely good access to both groups. We communicate on a regular basis. I think once you ask your staff that same question, they would reiterate the same thing. It's important to note that everybody doesn't agree all the time on a technical issue. But the forms that have been established to put this information out before each one of the groups and if needed to go from Region to Washington or the other way around, I think that process works well. It's availed us the opportunity to sit and talk about license amendments or proposed license amendments and the direction that's needed to give the clarity that's ultimately required to satisfy the regulation to make that change to our design. I think early on, we may have been challenged a little bit on understanding the overall process to get to the end state. But as we mature and go through this, unfortunately, because of the number of changes, we've had some opportunities to practice. But I do believe the process works well. I think going back to your initial comment about when we started the process, there were some 26 licensed applicants. I do believe that we are forging the future for our industry and the opportunity for somebody else to go behind us and build an AP1000 once these units are completed. They will find the process significantly more streamlined and easier since we will have worked most of the kinks out by then. But I do believe the cooperation from your staffs is extraordinary. Thank you, Mark. Did you want to add anything? I'd say it boils down to communication. And we as the licensees own that accountability for a lot of that communication and coordination. And again, a lesson learned from us from early on is that we needed to understand ourselves, the roles of each of those organizations, and to ensure that there was good communication by ourselves with each of those groups. And I think as the level of communication has increased, the level of coordination and planning has increased. And we're in a very good position right now. But it has been one in which we've, this is part of those lessons learned that we've gotten from the beginning, is how did we get from, get that early on interaction to ensure that we're aligned. And we are in a much better place today. I appreciate that. And I would note that when there was a view that there would be more follow on construction activity occurring immediately after these experiences at Vogel and Summer, I think the view was that maybe some of the same experience personnel could carry that from project to project. I would note that if the United States takes another decade long or multi-decade long pause in new reactor activity inevitably, I think that, well, I think what it will do is shift a burden that these lessons be well documented because I think that that will be the mechanism through which they will be communicated to those who will follow on in similar activities. I appreciate that you've shown the charts about ITEC closure. It is inevitably, I think making reference to my earlier comments saying that ITEC are this foundational showing that things were constructed as approved. Of course they occur late. If any of us went to Watts Bar two right now, we'd see a level of activity there again under part 50, but a lot of it just happens at the end. It's no different if you're constructing a home or anything else. All the punch lists occur right before occupancy as it were. So I have worried about that in the past. It is a resourcing issue for, I think, everyone participating in it, NRC and the consortia. I will note that I began with some concerns about the ability to surge to the need. I feel, again, it's not gonna be easy, but I actually, my confidence through engaging with the NRC staff both at NRO and in Region Two, my confidence grew quite a bit. Every question I asked had been thought about. A lot of tools have been developed to manage what we are engaging in. And I think when I reflect on your presentations and the responses that you've given this morning, I think you've really reinforced something that the NRC staff said very recently in a response to our Office of Inspector General who did a review of construction oversight processes at NRC. They were looking at efficiency and effectiveness, which is always a very useful thing for us to be looking at. And in response, though, to an Inspector General observation that NRC regional construction inspection staff currently spends more time on administrative work than on construction inspection, the NRC staff responded to that by saying, an important point is that many of the activities in the administrative hours portion of the IG's assessment are associated with planning the effective and efficient execution of future inspections. These activities are not and should not be characterized as administrative, and I think administration doesn't necessarily need to be a pejorative term, but I think the staff meant, to the extent that the term administrative minimizes the significance of planning, I appreciate that both of you talked about the exquisite orchestration that the planning component provides to everything that follows after, both on ITEC and on construction inspection. So I think in a way, whether or not you intended to your presentations have strongly enforced that point, that without having very experienced planners up front and having planning processes, it would never be possible to respond to that kind of surge in activity. So again, I thank you for being here today, Mr. Chairman, thank you very much. Thank you. Commissioner Ostendorff. Thank you Chairman, thank you both for your presentations. My colleagues have asked some very thoughtful questions. I have a couple of areas I want to explore. I know that, as Commissioner Finnecke noted, we had a meeting similar to this four years ago, and I recall that, and the bow wave issues were discussed, and so forth and so on, and because of various construction delays, you've had it both sites, and things are just facts of life issues, as Mark mentioned, in a construction project. We're not exactly where we thought we'd be, but we are where we are. If you can, one of the things when I've talked to visit the sites and talked to our construction resident inspectors at both Vogel and Summer, one of the things I know that has been a little bit of a challenge is inspection planning based on changes in schedule issues at both sites. Just at a high level, I ask both of you the same question. If you compare where we are today in July of 2015 to where we were, let's say two years ago, is there greater predictability of the schedule path ahead for each site, or how do you characterize your predictability of construction milestones? Well, as we drive forward and get more clarity on design completion of the unit, we begin to build in more reliability into the schedule. And then comes the next phase is the constructor's ability to execute as written in the schedule. We try to do a good job of continually communicating with the residents about specific things that they may or may not want to be involved in. We do work with the region with respect to sending scheduled both ITAC and non-ITAC related to the region to ensure that we're able to help to the extent possible manage resources. Because just like any other organization, you have a set of resources to accomplish a task, whether it be an inspection coming up on corrective action or it's an ITAC inspection on the placement of a major component. It's still all set in a finite set of resources. So it's important that we continue that evolution. But directly to your question, as we move forward, we begin to increase the level of confidence in the schedule. So for example, in a normal major construction project, you like to maintain a rolling 90-day window that you have 95% to 98% reliability on the execution dates. And then as you move out further 90 to six months you get, you may try to shoot forward 85% of a load. And then beyond six months, you begin to lower that expectation. Because as you near those given milestones, you've got a clearer picture of what the constraints are. So overall, I'd say we're building a greater degree of confidence in the schedule and thereby helping control where resources need to go. Would we have 100% confidence in the exact completion of the overall schedule that I wouldn't have to give you that answer? He's a three-month horizon. Let's just look at that. Just because of the 90-day horizon. So how do you feel about that right now? I feel very confident on 90-day horizon. I'd say we're well above 95% on doing things when we say we're going to do them. Now, that being said, in a construction environment, for example, critical pour coming up on summer tonight, well, depending upon the weather, this is the day we're shooting for. You're pouring concrete in the south in the summer. You got temperature and you got weather. If I get a pop-up thunderstorm tonight, I'll delay it till tomorrow night. This time of the year, you're prone to have that kind of thing. So that date could move four or five days, not due to not being ready, but just due to environmental circumstances. So we have to factor all those kind of things into our overall schedule. But a roll in 90-day, I'd say we're in the high 90s in confidence. Thanks, Alan. Mark? I think one of the initiatives that the contractor made towards the end of last year and really is implementing this year is a project management organization. And as Alan said, we're seeing a lot more predictability in the execution associated with getting dedicated folks that are doing, I'll say, that near-term planning now. And as we get more predictable with that near-term planning and execution, they're getting planning teams established to go out six months, 12 months, 18 months out. We will always have issues that will come up that will impact a specific construction activity. That's just the nature of this. But what I can tell you is that we are glad that they've been able to implement what we think is more structure and rigor into their organization. I've aligned my organization to also have project managers that are overseeing the schedule development as well as the execution to give me some feedback as we go forward. So I expect, and I think Alan will agree, much better schedule performance as we continue to move forward. Thank you. Alan, one of the slides you used was the Types of Standard Plan ITAC. And I found this helpful. 1982, I was part of a submarine crew being built in Newport News Shipyard for 688 class, Los Angeles class submarine. And then came back years later, 1987, 1989 did a similar thing and a different job on the ship. But even though there's some differences between the two submarine radar plans to control raw drive mechanisms and a couple other things, overall, the testing program was pretty much the same. X number of days of cold ops, hot ops, et cetera. So the question I've got to using your slide as a foundation is, if I look at the summer and Vogel projects in ITAC in a given area, and I know there's some site-specific differences, but on cooling towers, you've already identified those. But for the other things that are, quote, standardized, how standardized would the ITAC be between the two sites? Would I see a pretty document for Vogel on a particular ASME code or a pre-operational testing item that looks the same as it does at summer? They should look almost identical. We work together with one another on. And we oftentimes share a review of a proposed ITAC closure between the sites. Is that being done by the licensees and what's a role of, I guess, what's the role of Westinghouse? And this is a design agent. Do they have a role in structuring the ITAC for a particular? Well, there's always going to be a slight site difference depending upon who is running their ITAC organization. But I would say the majority of the time, they will have gotten together also prior to submittal to the licensees. But I do know for a fact that the licensees sit down together and review four commonalities. Yeah, again, one of the things that we learned as we were getting into ITACs was the need to have an integrated team. And so what we did is we formed an ITAC team that is comprised of CB&I, Westinghouse, and Southern Nuclear individuals. They're co-located. And so as they go through the development, both as the planning documents, the review of the work packages, and then the ultimate review of the documentation, is all done together in order to make sure that we as an organization, as a project, understand all of what's coming to us. Our interface with BCSummer from a licensees perspective, it also is occurring from Westinghouse and CB&I. There will be differences in, I'll just say, the physical data, but the ITAC requirements will be the same. Thank you. Thank you both. Thank you, Chairman. Thank you. Again, thank you for giving us your insights into your experience with the ITAC. We'll take a brief break, about five, six minutes or so, and then hear from our staff panel. Thank you. Thank you. OK, well, welcome back. And again, we'll hear from the staff, and their presentation. We have a number of presenters, and I'll let Mike Johnson introduce them, or at least begin at this point. Thank you. Good morning, Chairman and commissioners. We're here to update you on activities related to inspection, test analyses, and acceptance criteria, ITAC, recognizing the important role that ITAC play in the Part 52 licensing process. Chairman, I think your observation earlier is noteworthy, regarding the time from initial, I guess, effectiveness of Part 52 in today, 25-plus years. It's important to note, or noteworthy, I think that we are still conducting first-time implementation of a few aspects of the Part 52 licensing process. And I'm proud of the staff's substantial efforts in developing first-of-a-kind programs and procedures, as well as the way we've proactively looked for and been ready to deal with emerging issues and future challenges. As you've heard from the prior panel, and you'll hear from our staff, there has been and continues to be notable success in executing our processes, and in the staff's oversight and documentation, and in fact, formal closure of new reactive construction activities as we verify the safety and the compliance of these plants that are being constructed with the approved design and the license. I also want to note that, in addition to the details, that will be presented during the presentation, regarding the construction reactor oversight process and our ongoing field inspections, the ITAC verification and program enhancements, that the staff has been addressing emerging design changes, admits construction for these first-of-a-kind builds in a highly effective and efficient manner. And today, the staff has met every request for a license amendment without impacting construction schedules, and I think that's a significant accomplishment. And it's a result of the staff's effective presence in the field, the close interface that we have with licensees, and our careful and safety focused effort of the highly technical competent staff, technical staff, and our legal folks working alongside of each other. With me today are members of the Office of New Reactors and Region 2, who will highlight our activities to date, and will discuss our readiness to support completion of this portion of the process. And so now, I'll turn over to Mr. Gary Holohan, who's the Deputy Director of the Office of New Reactors to begin. Thank you, Mike. Good morning, Chairman, commissioners. It's been approximately four years since we last briefed the commission, specifically on the subject of ITAC. In the intervening period, we have discussed ITAC as part of two commission briefings, one on the new reactor business line and one on construction inspection activities in general. We've also scheduled a commission briefing for later this year on the new reactor business line, September 24th. Among the topics we expect to discuss during that meeting will be the construction reactor oversight process and a vendor inspection program in more detail at that point. And we may provide any update on the ITAC as necessary. Today's briefing will focus on the processes and procedures we have in place to oversee the implementation of ITAC at the new plant construction sites. We will also talk about staff preparation for the expected surge in ITAC in their completions, which will begin starting in 2017 timeframe. As mentioned earlier, ITAC are an essential part of the licensing review process constructed by the staff and approved by the commission to support the certification of reactor designs, the issuance of combined licenses. ITAC also support limited work authorizations and early site permits as appropriate. As such, programs and policies associated with ITAC and supporting ITAC have been developed and refined over a relatively long period of time. We are now confident that the programs and policies will ensure that ITAC serve their intended purpose and that they will address the challenges that we will be facing as we go through future construction. For more detail on the ITAC-related staff activities, I will now turn to Michael Chiak. Mike is the Director of the Division of Construction Inspection and Operational Programs in the Office of New Reactors. Mike. Thank you, Gary. Good morning, Chairman, Commissioners. We appreciate the opportunity to brief you today. I would like to start by providing an overview of the topics we will be talking about and by introducing the NRC staff who will be presenting today. We will update you on staff activities since our last ITAC-specific Commission briefing, which was on August 2011. And we will discuss ongoing activities related to the conducting inspections on ITAC and on the verification of ITAC completion. Mike, could you move the microphone a little? Yeah, I think that'll help. Thanks. Thanks. To my immediate left is Jim Beardsley, the Chief of the Construction Inspection Program branch in the Office of New Reactors. Jim will discuss the Construction Inspection Program and he will talk about how the inspection of the licensee's completion of ITAC fits within the overall program. To Mike Johnson's left is Bill Jones, who is the Director of the Division of Construction Projects in Region II. Bill will discuss the regional ITAC inspection activities in greater detail. Finally, Brian Anderson will discuss staff activities related to the ITAC closure process. Brian is the Chief of the ITAC and Generic Communications branch in the Office of New Reactors. I would like to now acknowledge Laura Dudes, who is sitting behind us. Laura is a former leader in the Office of New Reactors prior to her assignment in the Office of the Nuclear Safety and Safeguards. Laura is now the Deputy Regional Administrator for Construction in Region II. I would also like to acknowledge Michael Spencer right there from the Office of General Counsel, who has helped us tremendously on all the legal aspects of ITAC. Next slide, please. When we briefed the Commission in 2011, many of our inspection and ITAC activities were in the planning and developmental stages. Since that time, the staff has completed our certification of the AP1000 reactor design and has issued combined licenses for Vogels Unit 3 and 4 and for EC Summer Units 2 and 3. We have fully and successfully implemented the construction inspection program and the construction reactor oversight process. We are conducting inspections to confirm that the approved ITAC are being successfully completed and that the built plan design satisfies license requirements. We have also been conducting ITAC inspections at many vendor facilities to supplement our inspections at the plant sites. During our implementation activities, we have identified areas for improvement and have incorporated lessons learned to enhance our programs. Brian Anderson and Jim Beardsley will talk more in detail about our lessons learned activities. We have continued to engage stakeholders to enhance the transparency, efficiency, and predictability of our process and procedures. We continue to hold public meetings once every three months. At these meetings, we share the findings and insights from our inspections and from other oversight activities and we have obtained feedback on our process and procedures. One issue, and you have heard about this earlier, that has come up to our attention during our public discussions is the expected surge in the number of ITAC completion notifications starting at about eight to 10 months before fuel load. As a result, we have developed processes to ensure that the staff is ready to soften the effects of the surge. We will continue to interact with our stakeholders to refine these processes. As you have heard from Mark Rockhouse and Ellen Torres earlier, we will be continuing to work with them on the UIN process, the Uncomplete ITAC notification processes and we will work with them in the near future. I will now turn the presentation award to Jim Buensley. Next slide, please. Good morning, Mr. Chairman and Commissioners. Good morning, Mr. Chairman and Commissioners. This morning I'll provide you a brief review of the Part 52 construction inspection program and provide context on where the ITAC fit into that program. Next slide, please. The Part 52 construction inspection programs broke it up into two high level areas, ITAC inspection and programmatic inspection. Based on historical construction inspection data, the preliminary per unit estimate for direct inspection hours is 35,000 hours. The estimate breaks up into 15,000 hours for ITAC inspection, 10,000 hours for programmatic inspection, 5,000 hours for reactive and allegation inspection and 5,000 hours for headquarters technical inspection support. We expect that inspections for the first two units will exceed the estimate due to the first of the kind inspection challenges and construction schedule delays. It is likely that the second two units will require less inspection than the estimate. Once the program is complete for the first four units, the staff will analyze actual data and adjust our estimate as necessary. For the AP1000s, the ITAC inspection process starts with a sample that makes up approximately 35% or 345 of the 875 ITAC. The selected ITAC are considered targeted for inspection. The targeted ITAC were selected by a panel of experts using a risk-informed methodology. As part of the targeting process, the ITAC are broken up into sets or families with similar characteristics. The staff has developed 32 ITAC inspection procedures. Each ITAC family has been assigned at least two procedures as a starting point for inspection planning. As the inspectors plan and conduct inspections, they have the flexibility to shift the focus of their inspection or expand to non-targeted ITAC to ensure they gain appropriate insight into the associated construction activity. In addition to ITAC inspection, the staff will inspect programs that support construction. Routine inspections will be conducted in quality assurance, ITAC management, and fitness for duty. The staff will also inspect the licensee's pre-operational testing program prior to the start of that phase of construction. Construction program inspections complement the ITAC inspections by sampling factors that cut across the breadth of the ITAC and have potential to impact ITAC closure. In addition to construction inspections, the staff will inspect the licensee's operational programs as they are developed. These inspections verify the programs will be implemented in accordance with the regulations and combined license requirements. Some examples of operational programs are security, radiation protection, emergency preparedness, and environmental qualification program. On a quarterly basis, the staff assesses the licensee's performance and effectiveness in assuring construction quality. Similar to the reactor oversight process, the construction reactor oversight process, or CROP, integrates various sources relevant to the licensee's safety performance and makes objective conclusions regarding significance of inspection findings and takes actions based on these conclusions. The assessment process is conducted in a predictable manner and the results are communicated semi-annually to the licensees and the public. The NRC's Inventor Inspection Program also complements the ITAC process. When a vendor supplying components to the construction projects is inspected, the staff will use the results to enrich our knowledge about the development and manufacturing of the associated ITAC systems, structures, and components. If an ITAC-related finding determination is made as a result of an Inventor Inspection finding, that finding and its resolution will be included in the staff's review of their particular ITAC's closure notice. Next slide, please. Two of the processes that the staff uses to facilitate construction inspection program are technical assistance requests and the Construction Inspection Program Information Management System, or SIPMs. In an effort to maximize communication in support of the construction inspections and provide a record of that communication, the staff has established a process to document questions and answers between the inspection and technical staffs. Specific to ITAC, the TARS, as we call them, may be used to resolve licensing basis questions by the inspection staff. The resolution of TARS is coordinated through the appropriate Region 2 and headquarters technical branches to provide the inspectors with comprehensive support. When appropriate, TARS will be reviewed by the Office of General Counsel to ensure there is clarity in ITAC requirements and acceptance criteria. The TAR process may also be used by headquarters staff to request additional inspection activity assisting in the resolution of questions that arise from the ITAC closure notice reviews. Once the TARS been completed, the response is entered into ADAMS. The completed TARS are maintained in a searchable database to provide the inspectors and technical staff with an accessible record of issues for the future. To date, the volume of TARS has been lower than expected, but there have been enough to prove the process. All the TARS to date have been high quality and have met their expected timeliness goals. Two examples of TARS are an early request for clarification on the Vogel Waterproof Membrane ITAC and a TAR with questions on the minimum and maximum stud spacing for structural modules. Both of these were completed and the answers were provided to inspectors and then incorporated into the associated inspection reports. The Construction Inspection Program Information Management System, or SIPMMS, is a database tool developed by NRO to facilitate the planning and execution of ITAC inspections. The system is used to develop detailed inspection records for ITAC and their associated structures, systems, and components. SIPMMS brings together ITAC requirements from the combined licenses and the ITAC inspection procedures to facilitate construction inspection planning. During inspections, the staff's insights are entered into the database as discrete activities. Following completion of an inspection period, the ITAC, the SIPMMS is used to combine multiple inspections and generate a draft inspection report. As the repository of all ITAC-related inspection results, SIPMMS is used by the staff to verify the licensee's ITAC closure notices. Next slide, please. In 2013, the opposite new reactors issued lessons learned reports on Part 52 licensing and the first year of construction oversight. The reports noted that the identification and resolution of technical issues and timely regulatory decision making were challenges to the successful execution of the Part 52 process. In an effort to improve in these areas, the staff is engaged with the licensees to conduct a series of detailed design discussions. Once the licensees have completed their internal review of the detailed designs in areas that are new or technically challenging, a public meeting is conducted to provide headquarters technical staff and the construction inspectors with an opportunity to gain insight and review the detailed designs. This process provides early engagement between the licensees and the NRC in preparation for construction inspections. Some future areas planned for meetings of this type are the upper shield building design, cybersecurity, and the electrical system design. Over the next few years, the staff will engage with industry and the public in preparation for the initial test program. The first phase of that program, pre-operational testing, includes a large number of ITAC, as you saw earlier today in some of the graphs. We're conducting public meetings to gain a better understanding of the licensees' plans for the initial test program and are finding the NRC's inspection plans accordingly. These early engagement opportunities continue as the plans for pre-operational test inspection mature. In addition, the staff is engaged with our counterparts in China to share the NRC's plans and the results from the Chinese commissioning test program. Starting in the next few months, a number of NRC staff members will be traveling to China to observe AP1000 testing and share experiences between the agencies. The staff evaluates the effectiveness of the construction reactor oversight program on a routine basis. Annually, we conduct a self-assessment of the CROP using specific criteria to ensure the program is meeting the NRC's strategic goals. The self-assessment includes engagement with internal and external stakeholders. Over the past four years, the staff has made a number of changes to the program as a result of these assessments. At this point, I'd like to introduce Bill Jones, the Director of the Vision of Construction Projects in Region II, to discuss the implementation of the construction inspection process in more detail. Next slide, please. Good morning, Chairman Browns and Commissioners. I'm pleased to have this opportunity to discuss the implementation of the construction inspection program by a dedicated Region II staff. I have with me today Mr. Patrick Donnelly. The resident inspector. Push the button. Yes. Good. Good. Okay, thank you. All right. I have with me today Mr. Patrick Donnelly, a resident inspector at summer two and three, and over the last six months, he has served as the senior resident inspector. Mr. Steve Smith is a senior civil engineering constructed inspector in the Division of Construction Inspection. Both these individuals represent the high quality inspection staff we have in the Region II construction group. As we implement the Part 52 construction oversight process, we are adjusting to reflect the current environment with the most recent improvements focusing on effective and efficient planning and scheduling process. Last fall, Region II took a hard look at how the roles and responsibilities for conducting planning and scheduling in the organizational interfaces were being conducted. This issue was further discussed during the Region II Inspector counterpart meeting, and in January of 2015, a process review team was initiated to perform a comprehensive demonstration, including a tabletop, of the existing inspection process for effectiveness and to find opportunities for approved efficiency. Their review included identifying, documenting, and approving inspection scopes in order to support the applicable inspection manual chapters, scheduling inspections to have the right person at the right place at the right time, performing inspections, documenting inspection results, tracking inspection status, including certification and inspections are complete. We began implementing these recommendations from this team in March of this year. Region II will be assessing the implementation effectiveness in an assessment to be conducted in the fourth quarter of this calendar year. I will discuss some of the recommendations in the subsequent slide. In June, the Office of the Inspector General issued a report on the construction reactor oversight program. The Inspector General documented issues regarding program implementation, which I will be discussing. Planning and scheduling of inspection activities was an area where redundancy and communication challenges existed in the process depicted in this slide. The process review team interviewed the resident inspectors, senior project managers, and region-based inspectors as well as conducted the tabletop exercises. Both Patrick and Steve were part of this effort. Patrick as a resident inspector and Steve as a team member. The process review team concluded that further centralizing planning, scheduling, and development of inspection activities would streamline communications and eliminate unnecessary handoffs. These functions were consolidated in the Division of Construction Projects. The Division of Construction Inspections focus is on providing technical expertise, support of the inspection plan development, and resources. An organizational realignment of individuals and responsibilities within the construction group was one of the outcomes from the process review team. Construction project managers, one for Vogel and one for Summer, were established. This construction projects division is responsible for planning, scheduling, inspection plans, and ITAC inspection closure. Good working relationships have been established with each of the site representatives. We have seen positive outcomes from the realignment of staff and responsibilities. There is a high level project oversight and a good working knowledge of the inspection plans. The duplication in planning and scheduling have been minimized and construction inspectors are available to mentor junior inspectors and focus on inspection plans and execution. The Office of the Inspector General's recent audit noted that the construction reactor oversight process could be more effective, specifically with respect to time spent on program support rather than on direct construction inspection. Delays in the construction schedule resulted in delays in the construction inspection implementation. The NRC inspection hours expended were consistent with the licensees ongoing construction activities. The staff inspected and planned all safety significant systems, structures and components under construction since the license was issued. In addition, our indirect inspection efforts have yielded robust safety findings and our additional planning and program efforts have positioned us to be more effective in the future. As Jim Beersley mentioned earlier, the inspection plans and the status of each inspection resides in SIPMs. The inspection plans are linked to the appropriate construction activity in the licensees construction schedule and updated in our Primavera file, which is our scheduling tool. This is an area that remains a challenge for our scheduling of inspection activities. The method by which we receive each licensees updated construction schedules requires a significant amount of staff involvement to upload the information and then to update the schedule for shorter term activities. The process review team accounted for this challenge and designated responsibilities for ensuring we have an updated understanding of the schedule using single points of contact and the ability to update our schedule regularly. After an inspection is approved by the branch chief, the inspectors will go to the site and conduct the inspection. The results of each inspection are issued in inspection reports and placed in the agency's document system, Adams. Next slide, please. For efficiency and to take advantage of inspection opportunities, inspection schedules have been developed at bundle inspection activities for different ITAC as they become available. In many cases, there are multiple inspection plans associated with a targeted ITAC. An example where we currently conducted inspections across different ITAC was an inspection of the containment vessel, a mechanical ITAC, and welding of both the spent fuel pool floor and inside a containment refueling water storage tank wall. Both of those were civil ITAC. ITAC are generally inspected by individuals with specific engineering knowledge for the activity. In addition to many of the inspectors being subject matter experts, there are subject matter experts that the inspectors can call on to assist. A recent example was the collaborative reviews associated with the embed plates and code requirements. The collaborative review involved the resident inspectors and regional and headquarters subject matter experts. Region two inspectors continue to regularly participate in vendor inspections, particularly in the instrumentation and control areas. The results of these inspections are captured in the symptoms database discussed previously and contribute toward the NRC having confidence that the inspection aspects of the ITAC have been met. The staff has completed approximately 20% of the inspections associated with ITAC inspection plans on each of the lead units and about 10% on each of the second units. The construction project managers review and revise the inspection schedules to facilitate changes to construction activities. Region two has the inspection resources needed to complete the inspections associated with ITAC, as well as the operational program inspections. The inspections performed by the NRC are based on construction activities, which peak earlier than the ITAC closure notice submittals. This graph represents two aspects of the inspection plan completion in ITAC closure notice. We could put the graph up please. Thank you. First is that the number of inspections completed will significantly outnumber the total number of ITAC closure notices. This represents the different aspects of an ITAC addressed through multiple inspection plans. Second is that the actual number of inspections conducted towards the end of each unit's construction decreases such as the inspection staff's workload is highest over the next three years. This workload is managed in part through in-process inspections, early sampling, adjusted samples based on the performance and crediting inspection aspects common to both units and sites. Next slide please. This graphical depiction provides a slightly different perspective of the inspection activities and the timing during the construction of the four units. The top line illustrates the project projected inspection resources needed, which are linked through Primavera to the targeted ITAC inspections and the construction schedule plans. This graph also shows the difference when projected resources are needed to accomplish the inspections, the inspection plans and the ICN reviews. Next slide please. Regional and resident inspectors have completed numerous ITAC inspections since the license was issued. Many of the inspections have focused on the module construction. An example of an area inspected is the construction and installation of overlay plates. Overlay plates, such as the one depicted in this slide, are temporarily welded to the sides of a module to serve as an anchor point for various components in the nuclear islands such as piping. Each plate has mechanical connectors for securing rebar or welded studs which penetrate corresponding holes in a module wall. Concrete is then used to fill the gap between the walls securing the overlay plate. The inspectors identified through field observations undersized welds securing the base plate and the stutter mechanical rebar couplers. This example demonstrates that inspectors are conducting comprehensive field inspections of safety components to give us assurance that the plants are being constructed safely and in accordance with the applicable codes. Now I'd like to introduce Brian Anderson, Chief of the ITAC and Generic Communications Branch in the Office of New Reactors. Thank you, Bill. Good morning, Mr. Chairman and Commissioners. My name is Brian Anderson and I'll be highlighting several aspects of the ITAC closure process, including the staff's readiness for the ITAC surge you heard about in earlier presentations. I'll also discuss activities to address lessons learned from ITAC, both from the staff's licensing reviews and after issuance of the Vogel and VC summer combined operating licenses. Next slide, please. The process to verify a licensee's completion of ITAC has developed over several years and has resulted from significant staff effort and stakeholder involvement. Numerous public meetings and a comprehensive ITAC demonstration project have informed the development of NEI 0801, the industry guideline for the ITAC closure process under 10 CFR Part 52. In Regulatory Guide 1.215, the staff has endorsed the use of NEI 0801 as an acceptable approach to satisfy NRC requirements for documenting the completion of ITAC. The staff has approved the use of the most recent revision of NEI 0801 pending the publication of revision two to Regulatory Guide 1.215, which I'll expect will take place later this year. These documents have served as the primary sources of guidance for the 48 ITAC closure notices that have been submitted to date and the staff has verified the completion of each one of those closure notices. The NRC uses a disciplined and consistent process to verify that licensees have properly documented the completion of inspections, tests, and analyses and that the acceptance criteria are met. Based on the 48 ITAC closure notices submitted so far, we have not needed to make significant changes to our verification process. I'd like to emphasize that this verification is neither a technical review nor an inspection. Technical reviews for ITAC are completed as part of NRC review activities for design certification, the issuance of a combined operating license, or for license amendment requests for design changes during construction. As Jim described earlier, ITAC inspections are performed to confirm that the facility has been constructed in accordance with the NRC approved design and conditions of the license. The staff has also developed a transparent approach for sharing ITAC closure information with the public and external stakeholders. The staff uses verification evaluation forms to document its verification of each ITAC closure notice. The verification evaluation forms are provided on publicly available ITAC status reports on the nrc.gov website. These status reports also reference the licensees closure notices and federal register page numbers associated with each individual ITAC. On the next slide, I'm going to discuss the staff's preparations for the ITAC surge that you heard about during Bill's presentation. Because of the scope of work activities that ITAC covers, most ITAC won't be completed until late in the construction process, thereby resulting in a surge of ITAC closure work. The staff will verify 100% of ITAC closure notices, so our workload will generally follow the shape of the ITAC surge. The NRC is ready for the ITAC surge and has sufficient staff and technology resources to complete our ITAC closure verification activities in a timely manner. We've implemented the verification of ITAC closure evaluation and status, known to us as Voices, and I do recognize that we've cleverly inserted an acronym inside of an acronym there to efficiently manage the workflow for verifying each ITAC closure notice. Voices is used to generate the ITAC status reports I mentioned earlier, so it also serves as an information sharing tool. To prepare for the possibility of staff turnover, we've developed a comprehensive online training module to assist new ITAC closure staff in learning our processes for verifying ITAC closure. This training module was developed in part to ensure that new staff could support the consistent and disciplined verification process I mentioned earlier. A licensee is not permitted to load fuel until the commission finds that all acceptance criteria are met. Referring to its associated regulation, this is known as the 52103G finding, which the commission has delegated to the staff. The staff is finalizing its process for making the 52103G finding, which will include written instructions for the staff, a SECI paper to inform the commission, and a basis document to describe the staff's rationale for this decision. To support the staff's readiness for the expected ITAC surge, we've held numerous public meetings since 2011 to discuss ITAC closure-related topics. We continue to interact with stakeholders on ensuring an efficient and effective method of receiving, verifying, and communicating information related to ITAC closure. Next slide, please. In addition to our ITAC closure verification efforts, the staff has undertaken several activities to identify lessons learned related to ITAC. In 2008, we issued a regulatory issue summary that identified areas for improvement in the clarity and consistency of ITAC in design certification applications. This was updated in 2010 to provide additional lessons learned since the original publication. In 2013, the Office of New Reactors issued two lessons learned reports that identified other areas for improvement with ITAC. Based on the recommendations in those two lessons learned reports, the staff began a series of public meetings to discuss a standardized approach for ITAC information and licensing applications. By utilizing an approach that is applicable across reactor designs, there will be increased efficiency in the staff's review and approval of ITAC and greater consistency of ITAC among different designs. The staff intends to formalize this effort through the issues of regulatory guidance with the goal of having that guidance published on a timeline that supports use by future applicants. This concludes my presentation. I'll turn back to Mr. Mike Giak. Next slide, please. In summary, the construction inspection program has been fully implemented. Programs and processes are in place and we have been inspecting the activities at the Vogel and VC summer sites and also at vendor locations to ensure that ITAC are being properly completed by the licensees and suppliers. We have also been verifying the ITAC closure notifications that have been submitted to us. We do this to ensure that the built plan design satisfies license requirements. While the implementation has been successful, there has been some challenges. We have found solutions to these challenges and we have enhanced our processes using lessons learned. During program implementation and as part of making enhancements to our processes, we have continued to engage all our stakeholders. These interactions have made our processes more efficient, more predictable, and more transparent. Finally, we expect a surge of ITAC closure activities beginning in 2017. The NRC has adequate resources, processes, and procedures in place to support the inspection and verification of ITAC completion and to support timely staff decisions related to the authorization of field load. This concludes our prepared presentations. Thank you. And with that, we're ready to take your questions. Thank you. Again, Commissioner Barron. Thanks. Thanks for your presentations and for all of your work in this area. Bill, Commissioner Svinicki mentioned the Inspector General Report from last month, which found that while NRC's construction reactor oversight process is generally effective, the regional construction inspection staff were spending more time on administrative work than direct construction inspection. I think the breakdown was like 60% administrative, 40% direct inspection. Can you walk us through the kind of work that fell into the category of administrative for purposes of the IG report in your sense about what we should be aiming for in this regard? Is there a breakdown that, from your point of view, would be ideal? Well, I don't have the exact information that they use to come up with the 60, 40 numbers, but I can tell you that of the elements that I believe were in, the administrative function included things such as training, training of a staff coming into the Part 52, becoming familiar with the inspection procedures and also the inspection plans themselves. Development of the inspection plans. We heard earlier that the schedule has moved. We did plan, we were prepared to conduct inspections based on when activities would be ready based on as we understood the schedule to be, and so therefore a lot of effort was put into development of those inspection activities and those plans to be ready to perform those, should those activities come off, and that was part of the scheduling and primavera coordination that we utilized to ensure that we're ready for that. And then also it's just the scheduling attributes of how we go about getting the schedule information, verifying that the activities are going to go off as expected and then also to ensure that the inspectors are there, so that involved previously involvement by branch chiefs, by scheduling individuals, and also on occasion involvement by the inspectors themselves. And I'd like to point out that from the inspection planning, the development of the inspection plans and the scheduling activities, that those were both activities that were reviewed under the process review team. And I would just like to state that I'm very proud of the work that that process review team did and the individuals behind me, Patrick and both Steve and their participation in that. This was a, they were tasked with looking for efficiencies and effectiveness and how we go about conducting our planning, scheduling and its implementation and how we feed that information back after an inspection into our process to make sure that we learn that our inspection plans are updated and that we do truly become more effective. And that team took that task on and started in January. And in March, I had an implementation plan and was able to actually begin implementing that. So those were activities that we had in place, the inspector general did not get an opportunity to see that, but those are things that we did have in place and we're working forward. So I wouldn't want to break it down into a percentage. What I would say is that the continued development of inspection plans, particularly in the electrical digital areas, looking at the pre-operational programs, looking at the information we get back from the China visits, learning from that and then feeding that back into our inspection plan developments and implementing that. That's how I would answer that question. Going forward, are there additional changes to the process that you think should be made or that you anticipate making? I had a learning opportunity back in high school and I had a football coach who told me you either get better or worse, but you never stay the same. And right now we have definitely implemented a process that is better, but we are not going to stay there. We are looking at an opportunity after a period of implementation, about six months, where we're gonna go back and look in the fourth quarter of this year, this fiscal year, and see how well we're implementing and use that type of approach that we used with the team and looking at the workshops and looking at how we're implementing to continue to develop. So yes, there are more improvements that we can make. I feel very good about where we are today as to what we have learned and the changes that have made and the ability to focus individuals into the scheduling area on lessons learned and to get out and do the inspections themselves. Thanks. Brian and Bill, there's been a lot of talk about the bow wave or the surge or whatever we're calling it. The tremendous amount of work that's gonna have to happen in those last few months of construction. And I know that there's been an effort on the agency's part, on your part, to make sure that our role in this on the inspection side that's kind of smoothed out over time. Can you talk a little bit more about that so that we all have a clear understanding or I have a clear understanding of how are we managing that so that it isn't really a surge at the end, but instead that work's getting accomplished in a kind of more on a hump kind of a way over time and we don't have just a huge amount to do right at the end. I'll start off with the inspection because that actually feeds into the work that he does. We've identified for each of the targeted ITAC and identified the inspection plans and developed those. What we're looking to do is to touch on as many of the targeted ITAC inspections that we can perform. So in other words, we're not waiting for, if we've got five inspection plans associated with the targeted ITAC, two of them can be performed within the next three months. Those are the ones that we wanna make sure that we do perform, so that we don't get two years down the road and have five activities we need to perform. Instead, we're down to two or three. So those are the type of activities we're looking forward on. Also, we're looking at when we have inspectors out, how can we bundle activities to take advantage of their presence on site with their skills and be able to look at opportunities to conduct those inspectors. And that was the example I used somewhat during the discussion was looking at the pool, welding activities, as well as the mechanical ITAC on the containment. So the schedulers are looking for those opportunities to go out and to make the most efficient use of the inspectors while they're on site based on the input from the schedule and then utilizing those insights into making sure our inspectors are there when they need to be there. And when you look at the inspection activities, we get through the civil, we get through a lot of the mechanical. In the end, we'll be dealing with the digital I&C issues, those target inspection activities, and then carrying over into the pre-operational which have specific ITAC to them and then the operational programs which were discussed somewhat, although they don't have ITAC to them, those will be looked at also. And so from an ITAC closure verification perspective, I'll start by saying that I'm confident in the staff's ability to verify ITAC closure even with the shape of that surge towards the end. I think that's a function of how and when ITAC related work gets completed during construction. So to a certain extent, that shape of work, the ITAC closure notices coming in, peaking late is inherent to the Part 52 process. But having said that, I believe that we've got the right tools, processes and people in place. You heard during early presentations, I mentioned it also in mind, the development of the NEI-O801 guidance document has not only taken place over many years and many public meeting discussions but has brought a lot of structure, discipline and kind of a standardized approach for ITAC closure. That's been a key part of what we've built into our process today. So you think with the guidance, at this point we have a good shared understanding with the licensees about what's expected for ITAC's admittals and what's gonna be adequate? Absolutely. I'll admit it took a long time, I think, to get there. But we've definitely, that's been an effort, a long-term effort that's been well worth the input and participation. I think there's full mutual understanding of the level of detail that's required for ITAC closure notices. And this is a little bit of an in-the-weeds question, but just thinking about the big picture, we're gonna have all these ITAC closure notices kind of in the same period of time there's gonna be the run-up to the ITAC hearings for two different sites potentially. And there's gonna be a large volume of information that's gonna have to be made available on the website. All these hundreds and hundreds of ITAC closure notices and it sounds like you're also putting your verification evaluation forms that's also going online. So it's just a huge amount going up online. Are we confident that we have the IT in place to get this stuff turned around quickly so that when days matter during the run-up to these hearing processes, these notices are gonna go up and the evaluations are gonna go up in a timely way? I am, I can certainly speak to the IT infrastructure that supports ITAC closure verification. We have a comprehensive IT platform in place. It's routinely monitored and tested. It's been upgraded several times since its initial implementation. We have not to date had any issues with data or performance. So even with the increased volume, the day-to-day processing capabilities we've already verified are robust. Okay, and Gary I just wanna close, I'm a little bit over but I wanna close this panel the same way, close the first one which is there's a lot of work happening in a short period of time. And on the NRC side, well on both sides, but on the NRC side it's really important work because it's basically the final steps to ensure that these plants are built to be operated safely. And so how is an agency, how is a leadership team? Do we make sure that the staff understands that although the schedules are important, the number one priority's gotta be safety? Thank you, I always enjoy safety questions. I think the staff is very well prepared and want to do a quality safety review all the time. They just need to see that their management is fully supportive. Safety culture starts at the top, it's a standard definition. It is by having management at commission, EDO, office level, sending the message to the staff that it's fully supportive of them taking the time and the resources they need to do the job right to get the quality into the product. I think we for example in NRO have taken to naming things in such a way that that message should be clear to the staff. So for example, the highest priority items we expect to close this year are on a safe closure list. It's important to get them done, but you gotta do them safely. On the top of that list is license amendments, those, all the activities that support continued construction activities at Vogel and Summer. But they're on a safe closure list. For example, when we prepare to do a timely and efficient review of the next design certification, the signs in the hallway say 42, meaning 42 months, 42 safely. So I think it's management's responsibility to send a message to the staff that we know they want to do a good job and we're supportive of the quality and safety reviews that they have in mind. So I'm optimistic. I think it will be done well. I appreciate that. Thank you. Oh, thanks again for your presentations. I'll start off with a similar or the same question I asked the prior panel, then maybe get to more specifics. As we look at, as they said, and Mike acknowledged as well, as we're implementing this process conceived of a generation ago, really, is there something that surprises you about the ITAC process at this point? Or perhaps some of those surprises work themselves out during the initial licensing phase of the COL phase. But as you look at it now, the things that surprise you would say, perhaps we're spending time in terms of ITAC that might be better spent on other aspects of the safe operation or safe construction of these plants. I'm gonna offer it. Then Jim will tell me once I get it right or not. Okay. It seems to me that ITAC has an essential role in the one-step licensing process. It is the verification. It allows you to make the decision about safe construction and safe operation early in the process. I think the nature of ITAC is something that we were figuring out early on long before the actual construction took place. So I think you see now we have exercises on developing standardized ITAC to figure out what is really necessary. I think the idea of tier one, tier two, tier two star, exactly how important, how risk-significant are each ITAC, what's their role. I think that will probably be better informed by the fact that we've gone through the construction the first time. And I think that we've done it in a, I would say a conservative cautious way the first time. It could probably be done with better risk and safety insights with informed by the actual construction activities. I think so we can make improvements as you go through that process. The other thing that I think is surprising to me is how many ITAC would be uncompleted at the 225-day stage and that would therefore have to be very clearly and definitively planned out so that decisions about their acceptability of implementing those plans could be taken forward. But the fact that there will be a larger number than at least I envisioned is something new and that we'll be prepared for and that we'll have to, it's not just in the last few days, it is to be prepared now and working up process and procedurally to make sure that that end game does go according to plan. In terms of the uncompleted, and I think some have touched on this and it just may not have sunk in with me, but when you look at the uncompleted, it's sort of rough, perhaps rough percentages. What do they relate to in terms of what I say? Construction completion, operation testing, and then of course, as I've been reminded here, ITAC also go to things like what you do during operations, things that are really post construction, posts, well, basically being in the operational phase. So can you give me a percentage of what that goes to in terms of the uncomplete, just? You mean sort of percentage of how many ITAC would you like to put? How much it has to deal with completion of construction, how much it has to deal with in effect what I'll call pre-op testing, I realize that can be considered part of the ops phase. And then how much is really about those programs that you need for operations? I know we have, because we have in statute, we must have emergency planning ITAC, whether that makes, whether that's the best way of doing it or not doesn't really matter, because we have a statutory requirement for it. So the emergency planning ITAC are really the only ITAC that are programmatically focused. And what they really are is a requirement to run EP exercises. All the other, there's 19 operational programs that are committed to in the license. And all of those have programmatic inspections that are non-ITAC. They were physically separated from ITAC well early in the process. So I think that pre-operational test program is something that is heavily loaded into that later steps, the later steps of the ITAC. The other piece of it is when you break down an ITAC to take one of the big mechanical systems, we're gonna do lots of inspection of elements of that system, but they still have to do a walk down at the end. And they still have to do systematic testing, system level testing. And that has to be completed before the ITAC can be closed. So we may have a significant amount of inspection activity on that ITAC before they get to the end, and we'll audit and we'll go on those walk downs with them. But at that point, we have a high assurance based on all the inspection activity we've done that they built the system appropriately. So that's where we feel that, although that there's a lot of activity at the end, we will have pretty good knowledge based on those systems before we walk into it. So I'm trying to give you a little bit of assurance that we're looking forward at it and understanding what we have to get to before we get there. And the other thing that you answer your initial question, when we plan the program, we looked at ITAC as just a characterization of the construction process. So they're gonna build the plant the same whether it was part 50 or part 52. ITAC just characterized some elements of that construction. And so we had people from the previous phase of construction involved in our planning process, helping us to write the procedures. And so the ITAC, all we did was we used the ITAC to focus the procedures in certain areas. So from a differences, surprises point of view, I think that ITAC is just a way of breaking down construction and we're using it to help us focus, but we're doing lots of inspection beyond ITAC. So the targeted ITAC are required for inspection, but that doesn't mean that's all we're inspecting. The resident inspectors are inspecting what goes on on a day-to-day basis and they understand what ITAC are associated with those activities, but they're continuing to inspect to make sure there's quality construction. Thanks, and thanks actually for reminding me because that was a debate some years ago about whether operational programs should be within the scope of ITAC, but for my one example that we were gifted with, you reminded me that operational programs aren't, so thanks for that, yeah. I'm sorry, and I just wanted to give another perspective on the question that's been well-answered about surprises. And I'll just note that Gary's been here probably associated with directors longer than anybody. I think I joined and then folks, probably the rest of the folks at the table joined after me. I didn't find big surprises, but there have been, I think, a lot of little learnings. When we were first crafting ITAC, for example, we were doing that in the context of the licensing folks and the licensing environment, and someone said, well, gee, what happens if you get an inspector along looking at an ITAC as we're formulating those? What would that do with the ITAC? And we said, holy crap, some of these ITAC aren't gonna be all that inspectable, and so that little learning enabled us to change the way in which we developed ITAC. That's an example. We knew we needed templates for ITAC closure. We knew the concept of ITAC closure. We knew that templates would help. We began crafting those. We refined those based on that little learning. And I think one of the things that these guys maybe have been a little bit modest about has been the success of the staff in taking these little learnings, improving the program or processes to avoid these big surprises. Thanks for that, Mike. One of the things actually somewhat you, a couple of you touched on, sort of reminding me of one of the sort of initiatives or objectives coming out of Project AIM, which the commission has endorsed. And that is, this is in terms of this flexibility in terms of redirecting resources where you need particular expertise in certain areas. And one of these, this is at a number of meetings, I've heard the reverse of having sort of NRO reviewers looking at things in the context of operating reactors. Now we may be doing the other way in terms we have folks who have done more operational inspections or the like or have more experience on the part 50 side of the house going the other way. What is being done to sort of prepare those folks, as you say, to be able to use them for this important and significant amount of work at the end. So let me just start at a high level and then Jim will help. I was a party to a meeting that was really initiated by Glenn Tracy, director and Vic McCree, director, regional administrator to talk about how do we make a seamless handoff for example from construction, post construction to operations oversight. And as a result of that activity, they kicked off, we kicked off a multifaceted plan to make sure that as we reach the 2016, 17, 18, 19 timeframe, we are in fact paving the way to have that handoff of responsibility of those AP 1000 units in operation, the folks migrate to that office that will have that responsibility. And so we've got a plan that's been developed and we're implementing the steps on that plan. So I think the best way to answer your question is to use an example. A number of years ago, the center of expertise for electrical engineering was moved to NRR. So NRR does not have any electrical engineering folks anymore. We have worked closely with the branch chief to look at the makeup of his staff and the experience he had from new reactor licensing and much of that experience has retired. So we're planning a series of meetings where we're gonna bring the entire electrical branch down in two or three different groups to one of the licensee sites and we've coordinated with the licensees on this, give them tours of the site so they understand what AP 1000 looks like, what the construction site looks like so they can engage with the licensee engineers prior to the electrical construction work getting going so that as electrical questions come from the inspectors, we have a staff that understands AP 1000 is familiar with it and knows the right people to call. So that's one example of what we're trying to do to be forward thinking and look at things like that. Setters after T's I think are probably the focus area that we'll be addressing these. And that has really nothing to do with what happens with the sides of the new reactor workload. That has, we always knew there would be a time when we need to hand off oversight. The way in which you do oversight or the oversight that is done, transitions organizations. And so that's why we had that meeting, even someone say in advance of project name, it's to make sure that we're ready to support that transition. All right, thanks. Thanks for the discussion. Commissioner Symonic. I think also I'm a little surprised the staff didn't mention this in response to the chairman's question just now. Not handing off oversight, but if you should find for agility's sake that you need to bring people into the ITAC inspection enclosure process late, I had inquired of the staff and I think you mentioned it in your presentation that there has been a training module developed. And again, these people will not need to be trained on their subject matter expertise. It would train them on the ITAC process so that I thought that was a very commendable agility measure that was developed some well long before project aim, frankly. So I, when I mentioned earlier that my confidence in this process has grown, it seems overwhelming when you first start to look at the surge and think about all that needs to be done. But I think we see it, and our C staff stepping up very competently right now at Watts Bar two. And I think this will likely be no different than that. It does have some uniqueness with this ITAC process, but at bottom it really is the same kind of demonstration or showing and then building the record, which is of its nature and administrative type of activity. I don't know if any of my colleagues have ever been on an inspection team. I have in quality assurance and you do feel like a good large component of being an inspector is the documentation of what you did without that. I don't know that inspection is really all that usable without the component of planning, conducting, but then documenting. And two of those three phases are administrative in nature. So I think that that's important to note. I also appreciate that the important role of OGC has been mentioned in the staff's presentation. As Commissioner Barron notes, there is an important opportunity for hearing that presents itself through the ITAC process. OGC has been working closely with the region and the Office of New Reactors to make sure that everything having to do with that process is in place. So I appreciate that mention's been made of that. A lot of questions have been asked of the nature. If all of us, each of us could nominate one thing to be re-looked out if there was gonna be another wave of new reactor construction in the United States. Gary, you hit on the one thing that I think for me would come to mind and it is the uncompleted ITAC notices in the 225 days. For me, any regulatory requirement that takes the form of X number of days before this trigger report to me on the status of all undone work, if at that moment in time, more than half of it's not done, it would be my instinct to go back and say, maybe I wanna get that a little bit later in the process when more of it. Because if you ask for the status on something and if at that point in time, so many things will have to be statused. I do think it kind of recommends itself to say, is that just then an overwhelming amount of information that has to be provided? But something that's helpful of course is all the development that the staff has done of templates and we know at least the form and the content of a lot of these notices that we'll get. Nobody began by discussing what an ITAC was and earlier I talked about this being an important discussion today merely because we are shining a spotlight on a complex agency process. But I think worth mentioning and if I don't get the terminology right, I'll ask Mike or someone to step in. But ITAC don't take the form of, hey, this component is significant. They take the form of this component will be demonstrated to operate within this range and there's a lot of specificity there. Could one of you speak to that? This is not something, it's not like in addition to all of the activity, at the end we're gonna have to be making a lot of threshold judgment about what success looks like. So could someone speak to that at a high level? Gary maybe you wanna start? I think maybe the way I think of it is ITAC is not just something done at the end of the process. It's an integral part of the process. And clearly defining what needs to be done in building the plant at the early stages and being quite clear about what the expectations are. It seems to me the more we think of ITAC as separate from and occurring after all the inspections and everything else is done, is that's probably wrong. You need to think of ITAC as integral to both the licensing, the inspection, oversight and the whole process. So, yeah, ITAC. So much is established already, so at least that much. Now that doesn't mean that life isn't gonna be interesting because even though you've said that component X will demonstrate, it will run for X amount of time and demonstrate performance in this range, if you get enough technical people together and I'm subject to this myself, I might question whether or not what I actually observed did that or not. So that's why, again, it's not as if this is merely a box-checking exercise. I'm sure there'll be lots of technical complexity at the end as our inspectors well know and encounter routinely again, but so that's not a new circumstance for us. The chairman mentioned Project AIM and it's interesting to me. I don't mean to keep returning to the Inspector General Report, but something that I read in there really struck me. I asked the previous panel about roles and responsibilities and how we had organized ourselves to conduct construction oversight. And one observation in the IG report just stands in isolation. It follows, one experienced senior manager opined that if it could be done over again, all construction inspectors should be located at the construction sites and they would not have hired any regional inspectors. Now the difficulty in any observation when it stands in isolation is I don't know the context of the engagement that resulted in that. I have certainly questioned, we designed this for a system that might have had us dispatching regional inspectors to construction all around the country and not at two relatively near sites to region two. So under that paradigm, I think you would wanna have a really strong core of regional inspectors. That isn't where we find ourselves today but as I've inquired when I go to Vogel in summer, you're met by an NRC team there, a number of them are just there temporarily. They've been dispatched to be on the site for a period of time. Of course, most of us know, we know who our construction resident inspectors are there if we visit multiple times. But I ask about it. I'm like, are you being sent up here? You know, like Monday, Wednesday, Friday and it's not rational and how long are you coming and staying? Is it needlessly kind of logistically complicated? And I have a sense that it's working well. So this one experienced senior manager's observation strikes me as something I didn't think was an issue. Would anyone like to kind of react to how the complimenting the resident inspectors with the regional inspectors, how is that going in your mind? I'll take that one. What we're at right now is we have a compliment of resident inspectors at each of the two sites. I'm currently at a full compliment at each site. In addition, I have a diverse group of disciplines at each of the sites, including civil, mechanical and electrical. And at summer, we actually have an individual with an extensive operational background. And these individuals communicate with each other extensively so that issues and inspections that are being conducted at one site are being reviewed and discussed at the other site. I think what we're seeing is, and I don't know the context of that discussion either, but I think we are seeing with the realignment that occurred under the process review team that the regional staff is out at the facilities when they need to be there. They're integrated into more of the inspection plans and meeting the targeted ITAC inspections and as such that they're being more efficiently and effectively utilized because they're bringing their experiences and they're spreading it across more inspection activities than they would if they were just going out as a civil engineer and looking at two inspection plans. They are actually able to work on a lot more. They're actually spending more time than just a week in some cases, depending upon the work in front of them, conducting those activities, so. Well, and that was another strong foundation, was it not, in complimenting resident inspectors with regional inspectors is in the response you just gave and also the chart that Commissioner Ostendorf was holding up that gives the different nature of the ITAC is that right now, and perhaps in the coming months, maybe migrating a bit, but we've been heavy civil and structural. And so the point in dispatching people from a regional office is that you're gonna have an evolution over time of the nature of the ITAC and the inspection that's being done. Therefore, you wanna bring in, you don't wanna have a bunch of structural folks at both of these sites permanently and after that work is long over, what are they to be doing? They should be off contributing to other agency mission and you should bring in the relevant expertise. So again, I think that that was a part of the understanding there. And so to the second part of the question, as far as you're observing, it's working well. It isn't that we can't get the right people there at the right time. No, I am seeing particularly after the improvements that were made, I'm seeing it's working very well. Okay, thank you. Thank you, Chairman. Thank you, Commissioner Ostendorf. Thank you all for being here today and I'm gonna revisit a couple of points that my colleagues have already addressed because I think there's a couple of pieces worth emphasizing. Bill, I'm gonna start out with you. I appreciated your comment in response to IG's report about the relative time spent on inspection versus administrative support and I think the IG serves a very important role. It's important to address their findings, observations. At the same time, and it was discussed in the first panel, the reality of construction projects doesn't lend itself to a linear approach day-to-day. And I know that going back to my experience 28 years ago on a submarine that had three months before expected criticality had a 15 month delay because of misalignment of the main condensers with the propulsion turbine complex required ripping out the ship service turbine generators, turbines, main condensers, condensate pumps, feed pumps, you name it, is ripped out. And then we found ourselves rather than three months away from criticality, at least 15 to 16 months, then what do you do? You train people, you keep them productively employed and so I think the realities of construction delays at Sumner and Vogel, it's just a fact of life. And so I appreciated your comment which I thought was, I wrote it down, was that your inspection hours expended were consistent with the licensees ongoing construction activities. And I think the reality of construction is just as you noted that you've inspected those things and needed to be inspected. So I appreciate you're making that point. It's not a criticism, the IG report, it's just there's two sides to everything. And since this is a public meeting, I appreciate other commissioners talking about the IG report to provide the public a fulsome perspective of that issue that was raised by the IG. Bill in your slot 11, you also mentioned, I think as I understood it, I want to make sure that I didn't misinterpret your comment that there had been some challenges in using Primavera for scheduling. Did I correctly understand your comment there? I think that- You did. Okay, is there a proposed fix or any projected fix underway or being considered to help make that a more useful tool? The tool itself is effective. It provides for the ability to link the schedule with our inspection activities and inspection plans that we have developed. The challenge has been in getting the latest up-to-date infrastructure and information and particularly looking out several months for the planning itself and being able to incorporate that efficiently into the Primavera. Right now, it's a very labor-intensive effort to take the scheduling information that we get from the licensees and to put it into Primavera so that we can then align our inspection activity and resources with what the inspection schedule is. And to speak to the process review team, we were taking information on the construction activities from a lot of different sources. We have refined that down to essentially two individuals who have established very effective working relationships with the licensees. And although the means in which we're getting a lot of the information is we're getting the schedule, hard copy of PDF, and we have to input that in or look to, if we do get it electronic, if it's not the most current, we could actually end up causing problems as far as the scheduling, if something has shifted. So those are some of the challenges, but I think for what is in front of us for our ability right now to get the information the way that we are, I think that we have established single points of communications, individuals with knowledge of how to work the system and are pretty much working at its best of our abilities right now with our interface with the licensees. I wanna just make an observation that's consistent with what commissioners just finicky addressed about the balance between on-site and regional inspectors, but I think that's a very important point. I would say my experience from time in submarines, seeing analogous processes that work between ship's force, shipyard, intermediate maintenance activity personnel, naval reactors, et cetera, I think my observations on looking at Pat and Steve back there in the back row next to Laura, I think that my gut feel is that your system today is working very well and that you've achieved a good balance and I think you are flexible and agile and taking the right talent to bring to bear on-site when needed. And so this is my two cents worth, I'd say that watching this now for three and a half years, whatever, since the licenses were issued for a vote on summer that I think galved in a good job in adapting your staffing on-site in response to the realities of where the projects are. So I had soft to you for that. Well, sir, I thank you on part of region two and the construction staff, including the two behind me on that comment. Thank you. I would also comment that earlier other commissioners discussed the uncompleted items 225 days out and I think Gary had raised that and I appreciate the earlier dialogue. Reality is what it is. And I can remember many a Sunday afternoon before Monday underway as engineer commanding all sorts of submarine going down to the boat and closing out quality assurance packages. Is it ideal? No, is it reality? Yes. Look at US nuclear aircraft carrier when they finished an overhaul period that's maybe two years in a shipyard and I guarantee you the activity level prior to in 30 days and seven days and three days before their initial underway after two years shut down in a shipyard is a very, very busy time period. It's not rocket science. It doesn't require multi variable calculus to figure out how to do it. What requires is hard work and attention and detail. I think you're gonna see nothing other than that with respect to the quote bow wave or whatever you want to call it for ITAC closure for the Vogue and Summer Project. So I think we seem to be, this is a marathon, it's not a sprint. It's not something that ought to be the source of great anxiety or any philosophical struggling to figure out how you can deal with it. It's just gonna be hard work and attention and detail by the licensee as well as by the staff. I don't think we're gonna make it more than that. So I'll stop there. Thank you. Thank you. Anything else for my fellow commissioners? Well again, I wanna thank the staff for its presentations and as well as our two panelists from Southern and Scana for the dialogue today on ITAC. I think it's been very interesting, very useful for us to bring us back up to date. And I know as we mentioned this acronym, something perhaps we can nominate for the Oxford English Dictionary next year is a new entry. So with that, we are adjourned.