ML22354A026
| ML22354A026 | |
| Person / Time | |
|---|---|
| Issue date: | 01/06/2023 |
| From: | James Gaslevic NRC/NRR/VPOB |
| To: | Victor Hall NRC/NRR/VPOB |
| References | |
| Download: ML22354A026 (15) | |
Text
January 6, 2023 MEMORANDUM TO: Victor Hall, Director Vogtle Project Office Office of Nuclear Reactor Regulation FROM: James E. Gaslevic, Reactor Operations Engineer Vogtle Project Office Signed by Gaslevic, James Office of Nuclear Reactor Regulation on 01/06/23
SUBJECT:
CONSTRUCTION REACTOR OVERSIGHT PROCESS PERFORMANCE METRIC REPORT FOR CALENDAR YEAR 2022 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) 2022 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 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 (ITAAC) program. 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.
Vogtle Electric Generating Plant (Vogtle), Unit 4 remained under the cROP for the entire CY2022, but Unit 3 transferred to the Reactor Oversight Process in August 2022, after staff issued the 10 CFR 52.103(g) finding based on its determination that all of the ITAAC in Appendix C of the Vogtle Unit 3 combined license were successfully completed. 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. Two metrics were deemed not applicable for the CY 2022 self-assessment, which were related to significant events and appeals of SDP results. There were no significant events in CY 2022 for both Vogtle Unit 3 and Unit 4, and no appeals were received.
CONTACT: James E. Gaslevic, NRR/VPO 301415-2776
V. Hall
Enclosures:
- 1. Self-Assessment Metric Overview
- 2. Self-Assessment Metric Report
ML22354A026 NRR106 OFFICE RII/DPO RII/DPO NRR/VPO NAME BDavis NCoovert JGaslevic DATE 01/03/2023 01/05/2023 01/06/2023 Calendar Year 2022 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 from AS2: Assessment AS3: Timeliness of AS4: Degradations in the Construction Program Results Are Supplemental Quality of Action Matrix Completed in a Inspections Construction are Timely Manner Gradual and Allow Adequate Agency Engagement of the Licensee Met Met Met 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 2522A01 INSPECTION PROGRAM (IP) METRICS IP1 Inspection Reports are issued within Timeliness Requirements Met: Yes Definition: Audit 100 percent 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 percent 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) 2022 met the timeliness requirements in IMC 0613.
Enclosure 2
IP2 NRC's Response to Technical Assistance Requests (TAR) Is Timely Met: Yes Definition: Audit 100 percent of TARs completed in the calendar year in relation to the TAR timeliness requirements in NRR-COM106, 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 2022 were closed in accordance with the timeliness requirements specified in NRR-COM106.
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2522A02 SIGNIFICANCE DETERMINATION PROCESS (SDP) METRICS SDP1 SDP Results Are Predictable and Repeatable Met: Yes Definition: Audit 100 percent 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 appendixes.
Acceptance Criteria: If greater than 10 findings were issued during the calendar year, then at least 90 percent of them contain adequate detail to enable an independent auditor to trace through the significance determination process in IMC 2519 and its appendixes 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 appendixes 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: There were eleven GREEN findings documented in 2022 and reviewed through independent audit. All findings contained the necessary detail to enable the independent auditor, using IMC 2519 Construction Significance Determination Process, to obtain the same finding color characterization.
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SDP2 Appeals of SDP Results Met: N/A 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 2022.
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2522A03 ASSESSMENT (AS) PROGRAM METRICS AS1 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 2022.
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AS2 Assessment Program Results (Assessment Reviews, Assessment Letters and Public Meetings) Are Completed in a Timely Manner Met Yes Definition: Audit 100 percent 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 percent 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 2022 met the timeliness requirements in IMC 2505, Periodic Assessment of Construction Inspection Program Results.
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AS3 Timeliness of Supplemental Inspections Met: Yes Definition: Count the number of instances during the calendar year where a finding was held open for more than six 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 six months for which the licensee had indicated they were prepared for the inspection.
Lead: Region, NRR/VPO Goals Supported: Effective, Predictable Assessment: A Special Inspection was conducted at Vogtle in June 2021 to assess electrical cable separation and related cable installation deficiencies (Inspection Report No. 05200025/2021010 and 05200026/2021010, ADAMS Accession No. ML21236A057). As a result of this inspection, two WHITE findings were identified and subsequently issued in November 2021 (Inspection Report 05200025/202101, ADAMS Accession No. ML21312A412). The report noted that the licensee was in the Regulatory Response Column as of the beginning of the third quarter 2021. On January 11, 2022, the NRC issued a letter to the licensee, Vogtle Electric Generating Plant, Unit 3 - Assessment Follow-up Letter for Inspection Report 05200025/2021011 (ADAMS Accession No. ML22011A275) which noted that the licensee remained in the Regulatory Response column for greater than six months and would remain so until the licensee indicated they were prepared for the inspection and a supplemental inspection was successfully completed. The licensee subsequently verbally notified the NRC they were ready for an inspection by the end of the first quarter 2022. A Supplemental Inspection was completed in March 2022 to close out these inspection findings. The planned Supplemental Inspection was within the 6-month calendar window of when the licensee had indicated they were prepared for the inspection, and as a result for this metric was met.
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AS4 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 2022 in which a construction site moved more than one column to the right in the Construction Action Matrix.
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2522A04 ITAAC METRICS ITA1 Analysis of ITAAC Reopened After Closure Verification Met: Yes Definition: Audit 100 percent 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 in the process that was within the NRCs ability to identify before closure verification during CY 2022.
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2522A05 OVERALL cROP METRICS O1 Analysis of NRCs Responses to Significant Events Met: N/A Definition: Review 100 percent 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 Assessment: There were no IITs or AITs performed or issued during CY 2022.
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