ML24046A154
| ML24046A154 | |
| Person / Time | |
|---|---|
| Issue date: | 02/15/2024 |
| From: | Mohamed Shams NRC/NRR/DANU |
| To: | |
| References | |
| Download: ML24046A154 (69) | |
Text
NRC Advanced Reactor Construction Oversight Process (ARCOP) 1 Vogtle Units 1-4 Photo Credit: Georgia Power Stakeholder Workshop Series
Welcome 2
Mohamed Shams, Director Division of Advanced Reactors and Non-power Production and Utilization Facilities (DANU)
Office of Nuclear Reactor Regulation (NRR)
Meeting Introductions and Guidelines 3
Purpose and Desired Outcome 4
Purposes of Workshops Discuss the objectives and draft conceptual framework of the proposed NRC Advanced Reactor Construction Oversight Process (ARCOP).
Initiate dialogue with the public stakeholders about advanced reactor construction oversight options.
Gain understanding of various perspectives on options being considered
- Please note that NRC guidance discussions are preliminary and are not meant to convey a final regulatory position.
Planned Workshop Sessions 5
Session 1, February 28, 2024:
Introduction to NRC Advanced Reactor Construction Oversight, and the ARCOP (draft) Framework.
Session 2, Date TBD:
Inspection Scoping Session 3, Date TBD:
Enforcement and Assessment Session 4, Date TBD:
Follow up discussions
Session 1:
Introduction to ARCOP (draft) Framework 6
Topics ARCOP-Purpose, Applicability, and Conceptual Framework Areas for Adjustment
Inspection Scoping
Determining Significance of Noncompliances
Assessing Inspection Results ARCOP Development Timeline
ARCOP Focus: Construction Quality 7
ARCOP Focus: Verify advanced reactor construction Quality.
Provide confidence that SSCs will perform satisfactorily in service.
Verify security and other programs in place to support operations.
Reactor Construction Oversight Objectives: Establish reasonable assurance that facilities are built and will operate in accordance with their approved design and licensing bases NRC Mission: Safety and Security of Public Health and the Environment
Construction Quality SECY-23-0048 VISION FOR THE NUCLEAR REGULATORY COMMISSIONS ADVANCED REACTOR CONSTRUCTION OVERSIGHT PROGRAM 8
Quality of Construction, construction quality, adequate quality, etc. are all terms that refer to quality assurance during the design, manufacture, and construction of reactor plant structures, systems, and components. The NRC defines quality assurance in 10 CFR 50, appendix B Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, as:
those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service. Quality assurance includes quality control, which comprises those quality assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means to control the quality of the material, structure, component, or system to predetermined requirements.
Risk-Informed Technology Inclusive Informed by Experience Innovative Performance-Based Scalable Comprehensive Key Guiding Principles (SECY 23-0048) in addition to the NRC principles of good regulation 9
ARCOP Reactor Applicability 10 ARCOP will apply to:
Non-Light Water Reactors Light water, small modular reactors Microreactors ARCOP will not apply to:
Research and test reactors Radioisotope production facilities
Why ARCOP?
11 A scalable and risk-informed oversight program is required that:
Adapts to all advanced reactor technologies.
Accounts for different licensing pathways (Parts 50, 52, and 53).
Applies lessons learned from AP1000 construction projects and other nuclear construction projects.
Adjusts for potentially greater use of factory manufacturing and shorter expected construction timelines.
12 NRC Oversight Program Elements Performance Monitoring Inspection, allegations, operating experience (OpE) and construction experience (ConE)
Enforcement Dispositioning noncompliances using safety/security significance Assessment Characterizing performance and determining NRC response
Technology Inclusiveness ARCOP proposes to use Fundamental Safety Functions (FSFs) to form the basis of the risk-informed technology inclusive oversight program.
13
Technology Inclusiveness -
Fundamental Safety Functions (FSFs)
- 1. Control of reactor power and reactivity
- 2. Removal of heat from the reactor and fuel stores
- 3. Confinement of radioactive materials 14
QUALITY OF REACTOR PLANT CONSTRUCTION Provide reasonable assurance that advanced reactors will be built and operated in accordance with their licensing and design bases, the atomic energy act of 1954 (as amended), and the NRCs rules and regulations SAFEGUARDS and SECURITY OPERATIONAL READINESS OPERATIONAL PROGRAMS License and regulate the use of byproduct, source, and special nuclear materials to ensure adequate security and safety for the public and the environment REACTIVITY CONTROL FSF HEAT REMOVAL FSF RADIONUCLIDE RETENTION FSF NRC Mission ARCOP Objective ARCOP Strategic Performance Areas ARCOP Cornerstones of Safety SAFEGUARDS AND SECURITY PROGRAMS ARCOP Framework (Conceptual) 15
NRC Oversight Elements and FSFs*
1.
Inspection: SSC inspection scoping focuses on those SSCs important to fulfilling FSFs.
2.
Enforcement: Significance of findings are based on their potential impact on the designs ability to maintain FSFs with the deficiency present during operations.
3.
Assessment: Performance is characterized by considering the Quality of Construction of SSCs supporting the FSFs.
- This slide applies to the Quality of Reactor Plant Construction strategic performance area only. Operational Readiness and Safeguards and Security areas are based on measures of safety/safeguards applicable to the design.
16
17 Stakeholder Engagement Point
Key ARCOP Decision Points Discussion topics for each of the ARCOP oversight elements:
- Inspection Scoping
- Enforcement
- Assessment Workshop format for key decision points:
- Considerations
- Options considered
- Option requiring further development 18
Key Decision Point #1:
How is inspection scope determined?
19
- Inspection should verify the reactor plants ability to fulfill the FSFs in a risk-informed manner.
- Inspection scoping should be flexible to account for development of experience (e.g., adjustments from first reactor to Nth reactor).
- Inspection should be results-driven and performance-based (e.g., quality focused and prioritizes observing performance versus reviewing paperwork).
Considerations
20 A. Specific SSC and ITAAC inspection sample targeting (AP1000)
B. Baseline Inspection Scoping Matrices:
Project-specific sampling of construction areas.
C. Availability Based Inspection:
Periodic site inspections throughout construction Options Considered:
Key Decision #1: Inspection Scoping (Concept)
Key Decision Point #1:
How is inspection scope determined?
21
- Program should allow flexibility for technology-based solutions for efficiency gains.
- Inspection scoping should be applicable to parts 52 (using ITAAC) and 50 (without ITAAC). For plants licensed under Part 52, sufficient inclusion of independent inspection of ITAAC performance provides documentation to support licensing decision.
- The NRC should apply the appropriate amount (number of inspections) and type (technical expertise) of resources to inspection to verify quality of SSCs supporting FSFs. This may include flexibility to perform inspections under the vendor inspection program, under a construction inspection program, or a combination of both.
Considerations (continued)
22 Option A: Specific SSC and ITAAC Targeting
==
Description:==
An expert panel ranks SSCs and ITAAC in order of safety importance and risk of deficiencies occurring and going undetected/corrected prior to operations. Activities that rank above an established threshold are targeted for inspection.
Note: This was the inspection scoping method used for inspection of the AP1000 projects. The NRC AP1000 lessons learned report (ML23325A202) states that this method resulted in inefficiencies (i.e., chasing samples).
Key Decision #1: Inspection Scoping (Concept)
23 Option B: Baseline Inspection Scoping Matrices define a project-specific sampling of construction areas.
==
Description:==
An expert panel identifies SSCs and ITAAC that are important to fulfillment of the FSFs. A matrix is created to define the baseline inspection program, which includes key risk information and number of samples proposed for each construction area. Inspection samples are then selected using a risk-informed, performance-based methodology, similar to the ROP.
Key Decision #1: Inspection Scoping (Concept)
Inspection Scoping Matrix - Conceptual Example 24
25 Option C: Availability based Inspection via periodic site inspections throughout construction.
==
Description:==
Teams of multi-disciplinary inspectors perform regularly scheduled inspections and choose samples based on available construction activity during the period.
Key Decision #1: Inspection Scoping (Concept)
Key Decision #1: Inspection Scoping (Concept) 26 Option Requiring Further Development:
Option B: Inspection Scoping Matrix provides the most efficient method to provide the information necessary to make a licensing decision to operate.
Option A: SSC/
ITAAC Targeting Option B: Baseline Inspection Scoping Matrices Option C: Availability Based Inspection More Specific/
Less Flexible Less Specific/
More Flexible
27 Stakeholder Engagement Point
Key Decision Point #2:
How should we scope safety-significant activities occurring at manufacturing facilities?
28
- Inspection should be results driven and performance based (e.g., quality focused and prioritizes observing performance versus reviewing paperwork)
- In some deployment models, significant portions of safety-significant construction will occur in a factory.
- Restricting inspection scope to a specific location (i.e., on-site) would result in variations to inspection scoping for different models. Reactor quality relies on work at manufacturing facilities and on-site construction and the ratio of manufacturing/on-site construction is design specific.
Considerations
ARCOP Draft Terminology 29 On-Site: The site of the reactor plants final installation. (i.e., the site where the reactor is licensed to be installed and ultimately operated).
Manufacturers Smaller reactor plant sizes may allow complete, or nearly complete reactor plants to be assembled in a factory setting.
The term manufacturer generically to refer to these factory settings Work equivalent to final installation of most safety-related or nonsafety-related, risk significant SSCs Manufacturers may, or may not, have a Manufacturing License (ML)
There may not be a manufacturer associated with every project.
Traditional Vendors are suppliers of components and services (to manufacturers or on-site). Traditional vendors will remain in the existing NRC vendor inspection program.
Example Advanced Reactor Scenarios
% OF RISK-SIGNIFICANT CONSTRUCTION ACTIVITY AVAILABLE FOR INSPECTION BY LOCATION BASED ON PLANT DESIGN ATTRIBUTES 80%
10%
10%
60%
30%
10%
10%
90%
Micro Reactors Small modular reactors Large reactors Onsite Manufacturing Facility Traditional Vendor 30 Note: These percentages are estimated and provided for illustration purposes only.
Example Advanced Reactor Scenarios
% OF RISK-SIGNIFICANT CONSTRUCTION ACTIVITY AVAILABLE FOR INSPECTION BY LOCATION BASED ON PLANT DESIGN ATTRIBUTES Onsite Manufacturing Facility Traditional Vendor 31 Licensee Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Licensee Vendor Vendor Vendor Manufacturer Vendor Vendor Vendor Vendor Vendor
32 A. Off-site activities not covered under construction oversight.
B. Hybrid Vendor Model (AP1000)
C. Integrated Baseline Inspection Scoping Matrix Options Key Decision #2:
Manufacturer Inspection Scoping (Concept)
33
==
Description:==
- Vendor inspection only for off-site
- ARCOP inspection only for on-site Notes: This option may a require significant increase in the vendor inspection program and may create inequities in oversight for different deployment models.
Option A: Divide inspection programs between off-site and on-site Key Decision #2:
Manufacturer Inspection Scoping (Concept)
34
==
Description:==
Vendor inspections supplemented with construction inspectors for targeted risk-informed inspections.
Option B: Hybrid vendor model (AP1000)
Key Decision #2:
Manufacturer Inspection Scoping (Concept)
35
==
Description:==
Inspection scoping matrix includes all manufacturing and on-site activities that have significant impact on safety. ARCOP applies to all activities in the matrix.
Traditional vendors continue to be inspected under VIP.
Option C: Integrated Baseline Inspection Scoping Matrix Key Decision #2:
Manufacturer Inspection Scoping (Concept)
Key Decision #2:
Manufacturer Inspection Scoping (Concept) 36 Option Requiring Further Development:
Option C: Integrated Baseline Inspection Scoping Matrix :
- provides appropriate inspection scope for assembly of reactor modules independent of location, and
- provides a consistent regulatory approach for advanced reactor construction projects.
37 Stakeholder Engagement Point
Key Decision Point #3:
How can we best structure finding significance determination to reflect risk during construction?
38
Significance Determination (including more-than-minor determination) for construction oversight should appropriately characterize finding significance based on risk to operations and should be comparable to risk thresholds in ROP (source: SRM-SECY-10-0140).
Determining the significance of findings should not be overly complex as to require extensive NRC infrastructure to execute, or extensive licensee time and resources to support (AP1000 Lesson Learned).
Considerations
Key Decision #3: Significance Determination (Concept) 39 A. Finding significance is assigned based on potential impact to FSFs during reactor operations using a qualitative SDP.
B.
Design specific SDPs, including quantitative measures (such as RAW scores) when appropriate, used to inform finding significance.
C.
Traditional enforcement significance/enforcement (ref. section 6.5 of the NRC Enforcement Policy)
Options
Key Decision #3: Significance Determination (Concept) 40 Option A: Finding significance is assigned based on potential impact to FSF during reactor operations using a qualitative SDP applicable to all designs.
Specific criteria for each category are under development.
Finding Safety or Security Significance Criteria Yellow Substantial potential impact on FSFs during operations White Low-to-moderate potential impact on FSFs during operations Green Very Low potential impact on FSFs during operations Minor No potential impact to FSFs during operations
Key Decision #3: Significance Determination (Concept) 41 Option B: Design specific SDPs, including quantitative measures (such as RAW scores) when appropriate, are used to inform finding significance.
==
Description:==
Similar to AP1000 SDP Risk Importance derived from PRA information.
SSC Risk Importance Quality of Construction
Key Decision #3: Significance Determination (Concept) 42 Option C: Traditional enforcement significance/enforcement The staff would use broad categories described in section 6.5 of the NRC Enforcement Policy to disposition construction inspection findings and use those severity levels to determine NRC response.
Key Decision #3: Significance Determination (Concept) 43 Option Requiring Further Development:
Option A: The qualitative significance table based on potential impact FSFs during operations:
- inherently risk-informed and technology-inclusive
- does not rely on PRA information, which may not be available for some projects at the onset of construction.
Other Proposals - Finding Significance (Concept) 44 Significance of QAP Breakdown Self Identified Construction Noncompliance (SCN) time Deficiency self-identified and corrected No Exposure Time = No Potential Consequence Reactor Operation Begins Deficiency occurs Deficiency occurs time NRC Identified Reactor Operation Begins QAP Backstop Low Potential Consequence NRC Identified Noncompliance Minor Significance Very Low (Green)
Significance QAP = Quality Assurance Program
45 Stakeholder Engagement Point
Key Decision Point #4:
How should we disposition findings that occur at manufacturing facilities?
46
- A significant amount of safety-significant fabrication and testing that was once performed on-site may be performed by manufacturers.
- Currently available enforcement tools include:
o Non-Cited Violations (NCVs) and Notices of Violations (NOVs) for permit holders, licensees, licensed manufacturers, and applicable regulations for non-licensed manufacturers (e.g., Part 21) o Notices of Nonconformances (NONs) for noncompliances with indirectly imposed requirements (i.e. contractual obligations) for non-licensed manufacturers and vendors Considerations
47 Options A. Apply the traditional vendor enforcement process to non-licensed manufacturers and apply the ARCOP enforcement process to ML holders.
B. Use existing enforcement tools. For findings identified at a manufacturing facility, screen for risk significance.
C. Create new risk-informed enforcement tool for manufacturers.
Key Decision #4:
Dispositioning Manufacturer Findings (Concept)
48 Option A: Apply the traditional vendor enforcement process to non-licensed manufacturers and apply the ARCOP enforcement process to ML holders (risk-informed significance).
==
Description:==
The traditional non-licensee enforcement process uses NONs, NCVs and NOVs.
License holders and construction permit holders do not use NONs.
Key Decision #4:
Dispositioning Manufacturer Findings (Concept)
Key Decision #4:
Dispositioning Manufacturer Findings (Concept) 49 Option B: Apply ARCOP significance process to all manufacturers but use existing enforcement tools.
==
Description:==
This option would risk inform all manufacturer findings using the ARCOP SDP, regardless of licensing status. This allows the ARCOP to transparently and predictably respond to findings. Note, because NONs are administrative actions, this would require separately assessing significance of NONs that occur at manufacturers and documenting NRC follow-up in separate correspondence.
Key Decision #4:
Dispositioning Manufacturer Findings (Concept) 50 Option C: Create new enforcement tool for manufacturers.
==
Description:==
Develop a new risk-informed enforcement tool for manufacturers (both licensed and non-licensed).
Key Decision #4:
Dispositioning Manufacturer Findings (Concept) 51 Option Requiring Further Development:
Option B: Apply ARCOP significance process to all manufacturers but keep existing enforcement tools
- provides a means of consistently determining appropriate NRC response using risk information
- addresses safety-significant issues at both manufacturing facilities and on-site.
52 Stakeholder Engagement Point
53 oTo arrive at an objective assessment of a licensees/permit holder/manufacturer effectiveness in assuring construction quality through the evaluation of the inspection history, enforcement history, allegations, and safety culture.
oTo provide guidance for making timely and predictable decisions regarding appropriate agency actions.
oTo provide a method for informing licensees and the public of the results of the NRCs assessment results.
Key Decision #5:
How to assess inspection results?
Considerations (objectives of NRC Assessment)
54 Key Decision #5:
How to assess inspection results?
Overall Project Quality Assessment for Operating License Issuance or 10 CFR 52.103(g) finding Monitor Onsite Construction Quality through Licensee Performance Monitor Reactor/Module Quality through Manufacturer Performance Continuous Assessment
- 1. Baseline Inspection Program Adjustment
Onsite Construction Inspection (from Project-Specific Matrix)
Offsite Manufacturer Inspection (from Project-Specific Matrix)
Vendors Vendor Inspection Plan Vendor Oversight Advanced Reactor Construction Action Matrix
- 3. Supplemental Inspection
- 4. Design-Specific Matrix Update Conceptual Framework
Key Decision #5: Assessment (Concept) 55 Options A. Traditional Action Matrix concept for each project (combines manufacturers and applicants/licensees)
B. Traditional Action Matrix concept for each manufacturer and licensee/applicant (separately)
C. Construction Response Table describes licensee and NRC response to specific finding types and significance.
Option A: Traditional Action Matrix concept for each project (manufacturers and applicants/licensees combined)
==
Description:==
Similar to an AP1000 construction action matrix Integrated Project Quality Draft Construction Action Matrix 56 Key Decision #5: Assessment (Concept)
57 Option B: Traditional Action Matrix concept for each manufacturer and licensee/applicant (separately)
==
Description:==
Manufacturer and permit/COL holder are assessed separately, but a combined assessment of project quality is used to inform licensing decision.
Manufacturer Draft Construction Action Matrix CP/COL Holder Draft Construction Action Matrix Key Decision #5: Assessment (Concept)
Option C: Construction Response Table describes licensee and NRC response to specific finding types and significance.
==
Description:==
Focus on quality issues and their resolution with standard response table for findings.
58 Key Decision #5: Assessment (Concept)
RESULTS GREEN INSPECTION FINDING WHITE INSPECTION FINDING YELLOW INSPECTION FINDING UNACCEPTABLE QUALITY*
- see section xyz for guidance
RESPONSE
APPLIED TO EACH LICENSEE OR NON-LICENSEE FINDING Regulatory Engagement Meeting None Branch Chief (BC) or Division Director(DD)
Deputy Regional Administrator or designee meet with senior management Executive Director for Operations or designee meet with senior management Enforcement Action Recipient
Response
Corrective Action Program Root cause evaluation and correctiveaction Rootcause evaluation and correctiveaction Performance Improvement Plan with NRC Oversight.
NRC Inspection Baseline Inspection Supplemental Inspection (IP 1) and evaluation for additional baseline inspection(s) in area(s) of concern.
Supplemental Inspection (IP 2) and evaluation for additional baseline inspection(s) in area(s) of concern.
Possible Order/
Confirmatory Action Letter. Supplemental team inspection (IP 3). Evaluation for expanded baseline inspections.
COMMS Inspection Report or Letter Branch Chief review/sign inspection report. IR posted on public website.
DD review/sign inspection report (w/ inspection plan).
IR posted on public website.
DRA review/sign inspection report (w/ inspection plan). IR posted on public website.
RA or EDO review/sign assessment letter.
(w/ inspection plan). Letter posted on public website.
Consider public meeting.
Option C: Draft Construction Response Table 59 Key Decision #5: Assessment (Concept)
60 Option Requiring Further Development:
Option C: Construction Response Table because:
- Relatively simpler to understand and implement.
- Does not comingle licensee and non-licensee, or manufacturer and on-site inspection findings.
- Eliminates the need to have quarterly, semi-annual, or annual assessment periods to determine the proper NRC response.
Key Decision #5: Assessment (Concept)
61 Stakeholder Engagement Point
2024
- Engage external stakeholders
- Continue to Engage Commission
- Issue program guidance 2025
- Issue guidance (contd)
- Training 2023
- Developed vision
- Developed information SECY
- Internal Communication
- Translated vision into inspection concepts through development of Draft Inspection Manual Chapters 2026 2027
- Construction projected to begin on lead projects ARCOP Development Timeline 62 ARCOP Development Timeline
Planned Workshop Sessions 63 Session 1, February 24, 2024:
Introduction to NRC Advanced Reactor Construction Oversight, and the ARCOP (draft) Framework.
Session 2, Date TBD:
Inspection Scoping Session 3, Date TBD:
Enforcement and Assessment Session 4, Date TBD:
Follow up discussions
ARCOP Points of Contact 64 Phil OBryan, Project Lead Engineer, NRR/DANU Phil.Obryan@nrc.gov Kevin Roche, Project Manager, NRR/DANU Kevin.Roche@nrc.gov Jon Greives, Project Supervisor, R1/DORS Jonathan.Greives@nrc.gov Mo Shams, Management Sponsor and Division Director, NRR/DANU Mohamed.Shams@nrc.gov
NRC on Social Media Twitter: https://twitter.com/nrcgov Facebook: https://www.facebook.com/nrcgov/
Instagram: https://www.instagram.com/nrcgov/
YouTube: https://www.youtube.com/user/NRCgov Flickr: https://www.flickr.com/photos/nrcgov/sets LinkedIn: https://www.linkedin.com/company/u-s--nuclear-regulatory-commission/
GovDelivery: https://service.govdelivery.com/accounts/USNRC/subscriber/new 65
Feedback on this Public Meeting https://feedback.nrc.gov/pmfs/feedback/form?meetingcode=20240179 66
Closing Remarks 67
Acronyms 68 ARCOP Advanced Reactor Construction Oversight Program COL Combined Operating License ConE Construction Experience CP Construction Permit ESP Early Site Permit FSF Fundamental Safety Function ITAAC Inspection, Test, Analysis, and Acceptance Criteria LWA Limited Work Authorization ML Manufacturing License NCV Non-cited Violation NON Notice of Nonconformance NOV Notice of Violation OpE Operating Experience QAP Quality Assurance Program RAW Risk Achievement Worth SCN Self Identified Construction Noncompliance SDP Significance Determination Process SSC Structure, System, or Component
69 End of Workshop #1