ML21011A213

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Crop Metrics Report Memo for CY2020
ML21011A213
Person / Time
Issue date: 01/19/2021
From: Omar Lopez-Santiago
NRC/NRR/VPOB
To: Mark King
NRC/NRR/VPOB
Gaslevic J - NRR/VPOB
References
Download: ML21011A213 (15)


Text

January 19, 2021 MEMORANDUM TO: Michael F. King, Director Vogtle Project Office Office of Nuclear Reactor Regulation FROM: Omar Lpez-Santiago, Chief /RA/

Vogtle Project Office Office of Nuclear Reactor Regulation

SUBJECT:

CONSTRUCTION REACTOR OVERSIGHT PROCESS PERFORMANCE METRIC REPORT FOR CALENDAR YEAR 2020 The Construction Reactor Oversight Process (cROP) self-assessment program evaluates the effectiveness of the cROP through its success in meeting pre-established goals and intended outcomes. The staff performed the Calendar Year (CY) 2020 performance metric analysis in accordance with Inspection Manual Chapter (IMC) 2522, Construction Reactor Oversight Process Self-Assessment Program, dated July 28, 2014, and IMC 2522 Appendix A, Reactor Oversight Process Self-Assessment Metrics, dated October 4, 2017.

IMC 2522 and its associated appendix describe performance metrics associated with each of four cROP program areas: the inspection program (IP), significance determination process (SDP), assessment (AS) program, and inspections, tests, analyses, and acceptance criteria program (ITA). The staff designates the program-specific metrics as the IP, SDP, AS, and ITA metrics, respectively. The staff also monitors and analyzes a metric of a more general nature, which is designated as the O metric, to assess the overall performance of the cROP. provides a summary of the performance metric analysis results and Enclosure 2 provides the detailed report. The staff found that the cROP successfully met all applicable performance metrics by meeting the acceptance criteria defined in IMC 2522 Appendix A.

Three metrics were deemed not applicable for the CY 2020 self-assessment.

CONTACT: James Gaslevic, NRR/VPO 301-415-2776

M. King These metrics were related to significant events and timeliness of supplemental inspections.

There were no significant events in CY 2020, and there were no supplemental inspections.

Enclosures:

1. Self-Assessment Metric Overview
2. Self-Assessment Metric Report

ML21011A213 NRR-106 OFFICE RII/DPO RII/DPO NRR/VPO NAME BDavis NCoovert OLópez-Santiago DATE 01/19/2021 01/15/2021 01/19/2021 Calendar Year 2020 cROP Self-Assessment Metric Report (Enclosures 1 and 2)

cROP SELF-ASSESSMENT METRIC OVERVIEW INSPECTION PROGRAM (IP) METRICS IP1: Inspection Reports are issued within IP2: NRC's Response to Technical Timeliness Requirements Assistance Requests (TAR) Is Timely Met Met SIGNIFICANCE DETERMINATION PROCESS (SDP) METRICS SDP1: SDP Results Are Predictable and SDP2: Appeals of SDP Results Repeatable Met N/A ASSESSMENT (AS) PROGRAM METRICS AS1: Deviations AS2: Assessment AS3: Timeliness of AS4: Degradations from the Construction Program Results Are Supplemental in Quality of Action Matrix Completed in a Inspections Construction are Timely Manner Gradual and Allow Adequate Agency Engagement of the Licensee Met Met N/A Met Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) METRIC ITA1: Analysis of ITAAC Reopened After Closure Verification Met OVERALL Construction Reactor Oversight Process (cROP) METRIC (O)

O: Analysis of NRCs Responses to Significant Events N/A Enclosure 1

cROP SELF-ASSESSMENT METRIC REPORT INSPECTION MANUAL CHAPTER 2522 APPENDIX A CONSTRUCTION REACTOR OVERSIGHT PROCESS SELF-ASSESSMENT METRICS 2522A-01 INSPECTION PROGRAM (IP) METRICS IP-1 Inspection Reports are issued within Timeliness Requirements Met: Yes Definition: Audit 100% of reactor construction inspection reports issued during the calendar year in relation to the inspection report timeliness requirements in Inspection Manual Chapter (IMC) 0613, Power Reactor Construction Inspection Reports.

Acceptance Criteria: At least 90% of reactor construction inspection reports issued during the calendar year meet the inspection report timeliness requirements in IMC 0613.

Lead: Office of Nuclear Reactor Regulation (NRR)/Vogtle Project Office (VPO)

Goals Supported: Objective, Risk-Informed, Predictable, Effective, Open Note: For inspections not conducted by a resident inspector, inspection completion is normally defined as the day of the final exit meeting. For resident inspector and integrated inspection reports, inspection completion is normally defined as the last day covered by the inspection report. For stand-alone team inspection reports, the report is issued no later than 45 calendar days after inspection exit.

Analysis: All reactor construction inspection reports issued during Calendar Year (CY) 2020 met the timeliness requirements in IMC 0613.

Enclosure 2

IP-2 NRC's Response to Technical Assistance Requests (TAR) Is Timely Met: Yes Definition: Audit 100% of TARs completed in the calendar year in relation to the TAR timeliness requirements in NRR-COM-106, Revision 6, Technical Assistance Request (TAR) Process.

Acceptance Criteria: Construction TARs are expected to be completed in as timely a manner as possible in keeping with construction schedules and associated inspection and oversight. The nominal expectation for completion of construction TARs is 30 days.

Lead: NRR/VPO Goals Supported: Objective, Risk-Informed, Understandable, Open, Effective Analysis: All TARs closed in 2020 were closed in accordance with the timeliness requirements specified in NRR-COM-106.

2

2522A-02 SIGNIFICANCE DETERMINATION PROCESS (SDP) METRICS SDP-1 SDP Results Are Predictable and Repeatable Met: Yes Definition: Audit 100% of construction inspection program inspection findings issued during the calendar year against the significance determination process in IMC 2519, Construction Significance Determination Process, and its appendices.

Acceptance Criteria: If greater than 10 findings were issued during the calendar year, then at least 90% of them contain adequate detail to enable an independent auditor to trace through the significance determination process in IMC 2519 and its appendices and reach the same significance color characterization.

If 10 or fewer findings were issued during the calendar year, then no more than 1 of them did not contain adequate detail to enable an independent auditor to trace through the significance determination process in IMC 2519 and its appendices and reach the same significance color characterization.

Lead: NRR/VPO Goals Supported: Risk-Informed, Predictable Note: The number of inspection findings in a calendar year are those that are issued during that calendar year, independent of the inspection report number.

Analysis: Six findings were documented in 2020 and reviewed via independent audit. All findings contained adequate detail to enable the independent auditor, using IMC 2519 and appendices, to trace through the significance determination process for the findings and reach the same finding color characterization.

3

SDP-2 Appeals of SDP Results Met: Yes Definition: Track the total number of appeals of final SDP results during the calendar year.

Acceptance Criteria: Zero appeals of SDP significance that result in a final determination being overturned during the calendar year.

Lead: Regions, NRR/VPO Goals Supported: Risk-Informed, Objective, Predictable, Understandable, Open Assessment: There were no appeals of final SDP results during CY 2020.

4

2522A-03 ASSESSMENT (AS) PROGRAM METRICS AS-1 Deviations from the Construction Action Matrix Met: Yes Definition: Audit all assessment-related letters during the calendar year and count the number of deviations from the Construction Action Matrix.

Acceptance Criteria: Zero deviations from the Construction Action Matrix during the calendar year.

Lead: NRR/VPO Goals Supported: Objective, Risk-Informed, Open Assessment: There were no deviations from the Construction Action Matrix during CY 2020.

5

AS-2 Assessment Program Results (Assessment Reviews, Assessment Letters and Public Meetings) Are Completed in a Timely Manner Met Yes Definition: Audit 100% of Assessment Reviews, Assessment Letters and Public Meetings issued/conducted during the calendar year in relation to the timeliness requirements in IMC 2505, Periodic Assessment of Construction Inspection Program Results.

Acceptance Criteria: At least 90% of the timeliness goals for the assessment process are met during the calendar year.

Lead: Region, NRR/VPO Goals Supported: Effective, Open, Predictable Assessment: All Assessment Reviews, Assessment Letters and Public Meetings issued/conducted during CY 2020 met the timeliness requirements in IMC 2505, Periodic Assessment of Construction Inspection Program Results.

6

AS-3 Timeliness of Supplemental Inspections Met: N/A Definition: Count the number of instances during the calendar year where a finding was held open for more than 6 months due to the need to complete the supplemental inspection.

Acceptance Criteria: No instances during the calendar year when a supplemental inspection has not been completed within 6 months for which the licensee had indicated they were prepared for the inspection.

Lead: Region, NRR/VPO Goals Supported: Effective, Predictable Assessment: There were no supplemental inspections required during CY 2020.

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AS-4 Degradations in Quality of Construction are Gradual and Allow Adequate Agency Engagement of the Licensee Met: Yes Definition: Track the number of instances during the calendar year in which a construction site moves more than one column to the right in the Construction Action Matrix.

Acceptance Criteria: No instances during the calendar year in which performance issues cause a construction site to move more than one column to the right in the Construction Action Matrix.

Lead: NRR/VPO Goals Supported: Risk-Informed, Predictable Assessment: There were no instances during CY 2020 in which a construction site moved more than one column to the right in the Construction Action Matrix.

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2522A-04 ITAAC METRICS ITA-1 Analysis of ITAAC Reopened After Closure Verification Met: Yes Definition: Audit 100% of ITAAC that are reopened after closure verification during the calendar year.

Acceptance Criteria: No ITAAC have been verified as having been met that are reopened during the calendar year because of a deficiency in the process that was within the NRCs ability to identify before closure verification.

Lead: NRR/VPO Goals Supported: Effective, Risk-Informed Assessment: There were no ITAAC that were reopened as a result of a deficiency during CY 2020.

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2522A-05 OVERALL cROP METRICS O-1 Analysis of NRCs Responses to Significant Events Met: N/A Definition: Review 100% of incident investigation teams (IITs) and augmented inspection teams (AITs) reports that are issued during the calendar year to determine if major programmatic voids were identified during the cROP review portion of IITs and AITs.

Acceptance Criteria: No major programmatic voids are identified during the cROP review portion of IITs and AITs.

Lead: NRR/VPO Goals Supported: Effective, Predictable Note: In December 2020, Region II completed two inspections, Inspection Procedure (IP) 93100, Safety-Conscious Work Environment Issue of Concern Followup, and Confirmatory Order follow-up inspection for Enforcement Action (EA)-18-130 and EA-18-171 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML19249B552). The use of IP 93100 to inspect allegations must be specifically directed by an Allegation Review Board with Regional Administrator approval. As a result, this inspection report would be assessed under metric O-1. However, the inspection report will not be issued until January 2021 and will be assessed under the CY 2021 cROP self-assessment program.

Assessment: There were no IITs or AITs performed or issued during CY 2020.

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