ML24129A075
| ML24129A075 | |
| Person / Time | |
|---|---|
| Issue date: | 05/08/2024 |
| From: | O'Bryan P Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML24129A075 (1) | |
Text
NRC Advanced Reactor Construction Oversight Process (ARCOP) 1 Vogtle Units 1-4 Photo Credit: Georgia Power Stakeholder Workshop Series
Introduction and Guidelines 2
Workshop #3
Planned Workshop Sessions 3
Session 1, February 28 and March 20, 2024:
Introduction to NRC Advanced Reactor Construction Oversight, and the ARCOP Framework.
Session 2, April 3, 2024:
Inspection Scoping Session 3, May 22, 2024:
Enforcement Session 4, Date:
Assessment, Feedback/Wrap Up
4 Workshop #3 Agenda 9:00 a.m. - 12:00 p.m. (Hybrid Session)
- Recap from Previous Workshops
- Overview of Enforcement Process
- Proposed Concept-Significance Determination Process 12:00 p.m. - 1:30 p.m.
Lunch Break 1:30 p.m. - 4:00 p.m. (In-Person Only*)
Facilitated Small Group Exercises-Issue Screening and Significance Determination
- Note: A summary of the results of the small group exercises will be presented at the next workshop.
Purpose and Desired Outcome 5
Discuss the objectives & conceptual framework for the Advanced Reactor Construction Oversight Process.
Initiate dialogue with stakeholders and the public about the ARCOP options.
Consider perspectives on the various ARCOP options being considered.
Why ARCOP?
6 A scalable risk-informed oversight program that:
Adapts to all advanced reactor technologies.
Accounts for different licensing pathways under 10 CFR Parts 50, 52, and future Part 53.
Applies lessons learned from AP1000 and other nuclear construction projects.
Adjusts for factory manufacturing and shorter expected construction timelines.
Workshop Session #1 Recap:
Conceptual ARCOP Framework 7
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 SECURITY AND SAFEGUARDS 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 SECURITY PROGRAMS Draft Concept
8
- 1: Inspection Scoping
- 2: Inspection of Manufacturers
- 4: Dispositioning Manufacturer Inspection Findings Workshop Session #1 Recap Key Decision Points:
Workshop Session #2 Recap:
Inspection Scoping & Planning Matrix 9
Inspection Scoping and Planning Matrices support NRC inspection planning, focus inspections on the most risk significant SSCs (ITAAC), and identify SSCs with the greatest value of inspection for identifying a construction or manufacturing flaw.
Inspection Matrices are not part of the licensing process.
We plan to seek input on the Matrices during final development.
Draft Concept
Workshop Session #2 Recap:
Inspection Scoping & Planning Matrix 10 Design Specific Matrix for each unique design a.
Inspection Areas applicable to the design (columns) b.
Risk-significant SSCs (SR & NSRST/RTNSS) (rows) c.
ITAAC (when applicable-Part 52) d.
Risk Importance - Design (PRA, engineering judgement) e.
Risk Importance-Construction (ConE/OE, engineering judgement) f.
Minimum & Maximum sample ranges Once developed the design specific matrix is used to develop project specific matrices.
Operational Programs and Security are currently not included in the matrix.
Draft Concept
Workshop Session #2 Recap:
Inspection Scoping Matrix (example) 11 Safety Function SSCs Rick Importance Design (RID)
RID Basis Risk Importance Construction (RIC)
RIC Basis Structures and Buildings Mechanical Components Reactor and Internals Equipment Qualifications (other than ASME)
ASME Instrumentation and Control Minimum Inspection Area Samples Required 7
12 3
10 8
5 Maximum Inspection Area Samples 10 15 6
13 11 8
Fundamental Safety Functions:
- Reactivity Control
- Radionuclide Retention Water Storage Tanks High PRA HR FSF Medium complex X
Steam Separators Medium PRA HR FSF Medium complex X
X Passive float valves High PRA HR FSF Medium complex X
X Dual wall leak barrier - leak detection system High PRA HR FSF High FOAK X
Water level monitor-tank control system High PRA HR FSF High ConE X
Vessel High Medium FOAK X
X Core barrel High High complex X
Software Lifecycle High High (Installation) complex X
Field sensors High High ConE/
complex X
Reactor trip system High High ConE X
Shutdown Elements High Primary DK path High FOAK X
Reactor Coolant High Medium complex Spent Fuel Storage Rack High High ConE/
complex X
Rx Bldg. Foundation High High ConE X
Rx Bldg. Structural elements High Medium FOAK X
Draft Concept
Workshop Session #3 Discussion Topics 12 Dispositioning Issues:
How can we best structure significance determination to reflect risk during construction?
How do we disposition findings at manufacturing facilities?
NRC Enforcement Policy 13 Enforcement supports the NRCs mission to ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment.
Adequate protection is presumptively assured by compliance with NRC requirements. Compliance with NRC requirements provides reasonable assurance to the NRC and the public that safety and security are being maintained.
Application of this Policy ensures associated enforcement actions properly reflect the safety or security significance of such violations.
Enforcement Policy (Contd) 14 Consistent with this objective, the Enforcement Policy endeavors to do the following:
Deter noncompliance by emphasizing the importance of compliance with NRC requirements.
Encourage prompt identification and prompt comprehensive correction of violations of NRC requirements.
Enforcement Policy:
Applicability 15 Applies to all NRC licensees and applicants, to various categories of nonlicensees, and to individual employees of licensed and nonlicensed entities involved in NRC-regulated activities. These include, but are not limited to the following:
- a. organizations and individuals holding NRC licenses
- b. license applicants
- c. contractors and subcontractors to NRC licensees
- d. holders of and applicants for various NRC approvals
- e. vendors supplying safety-related components to licensees
Enforcement Process 16 The Enforcement Policy directs that the assessment, disposition, and subsequent NRC action related to inspection findings identified at power reactors under construction are determined by construction oversight process inspection manual chapters.
Enforcement Process 17 The enforcement process has the following steps:
First, violations & noncompliances must be identified.
Next, NRC must assess the severity or significance of the violation.
Finally, the NRC must disposition the violation or noncompliance.
Throughout the process, an organization or individual subject to an NRC enforcement action has multiple opportunities to provide input.
Enforcement Dispositions 18 Minor Violation or Noncompliance Non-cited Violation (NCV)
Civil Penalty (CP)
Orders Demand for Information (DFI)
Administrative Actions:
Confirmatory Action Letter (CAL)
Notice of Nonconformance (NON)
Notice of Deviation (NOD)
Significance Determination (AP1000 Lessons Learned) 19 Determining the significance of findings should not be:
overly complex time-consuming require extensive resources Significance Determination (including more-than-minor determination) for construction oversight should appropriately characterize finding significance based on risk to operations.
SDP Significance Levels Red - have high safety or security significance Yellow - have substantial safety or security significance White - have low-to-moderate safety or security significance Green - have very low safety or security significance Minor - less significant than Green. They do not warrant enforcement action and are not normally documented in inspection reports. However, minor violations must be corrected.
20
New Terms for Construction (Proposed) 21 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 Quality Assurance Program (QAP)
Backstop Low Potential Consequence NRC Identified Noncompliance Minor Significance Very Low (Green)
Significance Draft Concepts - This is not formal NRC Policy
Significance Determination Options Considered 22 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 Draft Concept
Proposed Qualitative Significance Determination Process 23 Option A: A Findings significance is assigned based on the potential impact to the FSFs during reactor operations using a qualitative SDP applicable to all designs.
ARCOP proposes not to use RED.
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 Draft Concept
Proposed Qualitative Significance Determination Process (Contd) 24 Finding Significance Findings Impact on SSCs Green
- a. The finding, if left uncorrected, would reasonably be expected to result in the loss of one system, train, or design features ability to fulfill a Fundamental Safety Function (FSF),
and another system, train, or design feature is credited for fulfilling that FSF; or
- b. The finding is associated with an issue where the manufacture, fabrication, placement, erection, installation, or modification of the hardware associated with the SSC has not begun; or Draft Concept
Proposed Qualitative Significance Determination Process (Contd) 25 Finding Significance Findings Impact on SSCs Green
- c. There is a quality assurance program (QAP) backstop for the deficiency associated with the finding; or
- d. The finding is associated with a hazard protection feature and is not a significant QAP breakdown (see Appendix F); or
- e. It can be demonstrated with reasonable assurance that the design function of the SSC would not be impaired by the deficiency.
Draft Concept
Proposed Qualitative Significance Determination Process (Contd) 26 Finding Significance Findings Impact on SSCs White
- a. The finding, if left uncorrected, would reasonably be expected to result in the loss of two or more systems, trains, or design features ability to fulfill one or more FSFs, and other systems, trains, or design features can be credited in fulfilling the FSFs; or
- b. The finding is not adequately addressed by the significance criteria in this table, and screens as white using appendix F of this IMC.
Draft Concept
Proposed Qualitative Significance Determination Process (Contd) 27 Finding Significance Findings Impact on SSCs Yellow
- a. The finding, if left uncorrected, would reasonably be expected to result in the loss of a FSF because no systems, trains, or design features can be credited for fulfilling the FSF; or
- b. The finding is not adequately addressed by the significance criteria in this table, and screens as yellow using appendix F of this IMC.
Draft Concept
28 Questions/Break
Advanced Reactor Construction Oversight Process (ARCOP)
Workshop 3 - Enforcement/Significance Determination Exercise Portion
Enforcement/Significant Determination Exercise Agenda
- Issue Dispositioning Process - Flowcharts
- Minor and More than Minor (MTM) Significance
- Findings - Significance Determination Process (SDP) for Structures, Systems, and Components (SSCs)
- (Afternoon) Group analyses of construction examples using ARCOP processes
- (Afternoon/Follow-up workshop) Results Insights 30 Draft Concept
NRC Inspection Issue Dispositioning (Proposed)
Initial Screening Flow Chart for Issues of Concern (Proposed)
Traditional enforcement in not covered in this workshop Y
Y N
The noncompliance is an NRC-identified or self-revealing finding Willfulness is not covered in this workshop.
More than Minor?
Y N
N Potentially Involves Willfulness
?
Issue of Concern Non-Compliance
?
No finding Performance Deficiency?
Y N
No finding No finding ARCOP Path N
Go to licensee or Non-licensee flow chart Follow both paths Traditional Enforcement Path 31 Draft Concept
Initial Screening of Inspection Issues of Concern (Proposed)
Issue of Concern A well-defined observation or collection of observations that may have a bearing on safety or security and warrants further inspection, screening, evaluation, or regulatory action.
32 Draft Concept Y
Y N
The noncompliance is an NRC-identified or self-revealing finding Willfulness not covered in this workshop.
More than Minor
?
Y N
N Involves Willfulness
?
Issue of Concern Non-Compliance
?
No finding Performance Deficiency?
Y N
No finding No finding N
Go to Licensee or Non-licensee flow chart Y
Traditional enforcement in not covered in this workshop Traditional Enforcement Path Follow both paths ARCOP Path
Initial Screening of Inspection Issues of Concern (Proposed)
Noncompliance A failure to adhere to a requirement or commitment.
Legally binding requirements include regulations, license conditions, and NRC Orders.
Non-legally binding commitments include self-imposed requirements to establish and maintain quality or requirements specified in procurement contracts..
33 Draft Concept Y
Y N
The noncompliance is an NRC-identified or self-revealing finding Willfulness not covered in this workshop.
More than Minor
?
Y N
N Involves Willfulness
?
Issue of Concern Non-Compliance
?
No finding Performance Deficiency?
Y N
No finding No finding N
Go to Licensee or Non-licensee flow chart Y
Traditional enforcement in not covered in this workshop Traditional Enforcement Path Follow both paths ARCOP Path
Initial Screening of Inspection Issues of Concern (Proposed)
Performance Deficiency The noncompliance was reasonably within the licensees ability to foresee and correct and should have been prevented.
34 Draft Concept Y
Y The noncompliance is an NRC-identified or self-revealing finding Willfulness not covered in this workshop.
More than Minor
?
Y N
N Involves Willfulness
?
Issue of Concern Non-Compliance
?
No finding Performance Deficiency?
Y N
No finding No finding N
Go to Licensee or Non-licensee flow chart Y
Traditional enforcement in not covered in this workshop Traditional Enforcement Path Follow both paths ARCOP Path
Initial Screening of Inspection Issues of Concern (Proposed)
Minor/More than Minor Noncompliances that are less significant than green findings.
Minor/MTM criteria are discussed later in this presentation.
35 Draft Concept Y
Y The noncompliance is an NRC-identified or self-revealing finding Willfulness not covered in this workshop.
More than Minor
?
Y N
N Involves Willfulness
?
Issue of Concern Non-Compliance
?
No finding Performance Deficiency?
Y N
No finding No finding N
Go to Licensee or Non-licensee flow chart Y
Traditional enforcement in not covered in this workshop Traditional Enforcement Path Follow both paths ARCOP Path
Initial Screening of Inspection Issues of Concern (Proposed)
At this point in screening, the noncompliance meets the conditions for documentation (i.e., the noncompliance is a finding).
36 Draft Concept Y
Y The noncompliance is an NRC-identified or self-revealing finding Willfulness not covered in this workshop.
More than Minor
?
Y N
N Involves Willfulness
?
Issue of Concern Non-Compliance
?
No finding Performance Deficiency?
Y N
No finding No finding N
Go to Licensee or Non-licensee flow chart Y
Traditional enforcement in not covered in this workshop Traditional Enforcement Path Follow both paths ARCOP Path
Dispositioning Licensee* Findings (Proposed)
Green Finding?
Y N
Noncited violation?
N Legally binding requirement
?
NRC-Identified or self-revealed licensee finding.
Y Screen finding significance N
Enter the SERP Process Y
Noncited Violation (NCV)
A violation is associated with the finding Go to next flowchart Enforcement Discretion Apply?
Y N
Document in accordance with the Enforcement Policy A violation is not associated with the finding
- Licensees include applicants and holders of a Limited Work Authorization (LWA), Construction Permit (CP), Combined License (COL), or Manufacturing License (ML) 37 Draft Concept
Dispositioning Licensee* Findings (Proposed)
Legally binding requirements
- Regulations
- License conditions
- NRC Orders.
Non-legally binding requirements Self-imposed requirements to establish and maintain quality Green Finding?
Y N
Noncited Violation
?
N Legally binding requirement
?
NRC-Identified or self-revealed licensee finding.
Y Screen finding significance N
Enter the SERP Process Y
Noncited Violation (NCV)
A violation is associated with the finding Go to next flowchart Enforcement Discretion Apply?
Y N
Document in accordance with the Enforcement Policy 38 Draft Concept
Dispositioning Licensee* Findings (Proposed)
Enforcement discretion The NRC may exercise judgment and discretion in determining the severity levels of violations and the appropriate enforcement actions to be taken.
This may include escalation or mitigation of enforcement actions.
See section 3 of the NRC Enforcement Policy for additional guidance.
Green Finding?
Y N
Noncited Violation
?
N Legally binding requirement
?
NRC-Identified or self-revealed licensee finding.
Y Screen finding significance N
Enter the SERP Process Y
Noncited Violation (NCV)
A violation is associated with the finding Go to next flowchart Enforcement Discretion Apply?
Y N
Document in accordance with the Enforcement Policy 39 Draft Concept
Dispositioning Licensee* Findings (Proposed)
Green Finding?
Y N
Noncited Violation?
N Legally binding requirement
?
NRC-Identified or self-revealed licensee finding.
Y Screen finding significance N
Enter the SERP Process Y
Noncited Violation (NCV)
A violation is associated with the finding Go to next flowchart Enforcement Discretion Apply?
Y N
Document in accordance with the Enforcement Policy Significance Screening The finding is assigned a significance color:
Green: Very Low Safety or Security Significance White: Low to Moderate Safety or Security Significance Yellow: Substantial Safety or Security Significance Red: High Safety or Security Significance (Not applicable to ARCOP findings -
Proposed) 40 Draft Concept
Dispositioning Licensee* Findings (Proposed)
Green Finding?
Y N
Noncited Violation
?
N Legally binding requirement
?
NRC-Identified or self-revealed licensee finding.
Y Screen finding significance N
Enter the SERP Process Y
Noncited Violation (NCV)
A violation is associated with the finding Go to next flowchart Enforcement Discretion Apply?
Y N
Document in accordance with the Enforcement Policy Significance Enforcement Review Panel (SERP)
A SERP consists of NRC managers, inspectors and enforcement specialists. The SERP reviews all findings initially screening as greater than green (GTG).
41 Draft Concept
Dispositioning Licensee* Findings (Proposed)
Noncited Violation (NCV) vs.
Notices of Violation (NOV)
NOV: Written notice of violation requiring a written response describing violation reasons, completed and planned corrective actions, expected date of compliance.
NCV: Normally used in lieu of Green NOVs if the licensees corrective action program has been inspected and found to meet regulatory guidance, industry standards, or both.
Does not require a written response.
Green Finding?
Y N
Noncited Violation
?
N Legally binding requirement
?
NRC-Identified or self-revealed licensee finding.
Y Screen finding significance N
Enter the SERP Process Y
Noncited Violation (NCV)
A violation is associated with the finding Go to next flowchart Enforcement Discretion Apply?
Y N
Document in accordance with the Enforcement Policy 42 Draft Concept
Green Finding
?
CAP reviewed and effective
?
N Y
N Enter the SERP Process Y
Document as an NOD Document as a FIN From Previous flowchart Screen finding significance A violation is not associated with the finding Dispositioning Licensee* Findings - No Violation (Proposed) 43 Draft Concept
Green Finding?
CAP reviewed and effective?
N Y
N Enter the SERP Process Y
Document as an NOD Document as a FIN From Previous flowchart Screen finding significance A violation is not associated with the finding Dispositioning Licensee* Findings - No Violation (Proposed)
Licensee non-violation path The noncompliance is not a violation but has MTM impact on safety or security.
44 Draft Concept
Green Finding
?
CAP reviewed and effective
?
N Y
N Enter the SERP Process Y
Document as an NOD Document as a FIN From Previous flowchart Screen finding significance A violation is not associated with the finding Dispositioning Licensee* Findings - No Violation (Proposed)
Significance Screening Uses the same screening criteria used for violations.
Findings initially screened as GTG are reviewed by a SERP.
45 Draft Concept
Green Finding
?
CAP reviewed and effective?
N Y
N Enter the SERP Process Y
Document as an NOD Document as a FIN From Previous flowchart Screen finding significance A violation is not associated with the finding Dispositioning Licensee* Findings - No Violation (Proposed)
Corrective Action Program (CAP)
Reviewed?
A Notice of Deviation (NOD) requires a written response like the response required for NOVs.
A Finding (FIN) does not require a written response.
46 Draft Concept
Initial Screening Flow Chart for Issues of Concern (Proposed) 47 Draft Concept Traditional enforcement in not covered in this workshop Y
Y N
The noncompliance is an NRC-identified or self-revealing finding Willfulness is not covered in this workshop.
More than Minor?
Y N
N Potentially Involves Willfulness
?
Issue of Concern Non-Compliance
?
No finding Performance Deficiency?
Y N
No finding No finding ARCOP Path N
Go to licensee or Non-licensee flow chart Follow both paths Traditional Enforcement Path
Dispositioning Non-Licensee Manufacturer* Findings (Proposed)
NRC-identified or self-revealed non-licensee finding Document as a Notice of Nonconformance (NON) to the manufacturer From the initial screening flow chart
- Non-Licensee Manufacturers: The ARCOP noncompliance dispositioning process is only used for non-licensed manufacturer noncompliances (and not other non-licensed suppliers/vendors).
Enforcement Process 48 Draft Concept Note: all manufacturer NONs are assessed for potential follow-up inspection.
Dispositioning Non-Licensee Manufacturer Findings (Proposed)
Notice of Nonconformance (NON)
A NON is a written notice to a non-licensed manufacturer describing its failure to meet commitments related to NRC activities. The commitments are normally contained in contract requirements and are not direct violations of regulations.
E.g., Licensees establish a contract with a manufacturer to fabricate safety-related components using a QA program that complies with 10 CFR 50, appendix B.
NRC-identified or self-revealed non-licensee finding Document as a Notice of Nonconformanc e (NON) to the manufacturer From the initial screening flow chart Note: all manufacturer NONs are assessed for potential follow-up inspection.
Enforcement Process 49 Draft Concept
Minor/More than Minor Determinations (Proposed)
Y Y
N Noncompliance with Performance Deficiency More than minor impact on SSC?
The noncompliance is more than minor.
Continue screening.
Y N
More than minor impact on Security or Safeguards?
N The noncompliance is minor.
Self-identified Construction Noncompliance
?
The noncompliance is minor.
Y N
More than minor impact on Op.
Readiness?
50 Draft Concept
Minor/More than Minor Determinations (Proposed)
Y Y
N Noncompliance with Performance Deficiency More than minor impact on SSC?
More than minor impact on Op.
Readiness?
The noncompliance is more than minor.
Continue screening.
Y N
More than minor impact on Security or Safeguards?
N The noncompliance is minor.
Self-identified Construction Noncompliance
?
The noncompliance is minor.
Y N
Self-identified Construction Noncompliances (SCNs)
- 1. The noncompliance is self-identified (not NRC-identified or self-revealing), and
- 2. The noncompliance must be in a facility-approved QAP process for correction when evaluated by NRC inspectors, as defined by facility-approved QAP procedures. This may include:
- Entry into an QAP work-flow process or corrective action program.
- Proper timing and tracking of planned corrective actions so that the noncompliance will not adversely impact reactor operations.
- If corrective actions are complete, the corrective actions are adequate.
Note: NRC-identified weaknesses with corrective actions are processed as separate noncompliances.
51 Draft Concept
Minor/More than Minor Determinations (Proposed)
Y Y
N Noncompliance with Performance Deficiency The noncompliance is more than minor.
Continue screening.
Y N
More than minor impact on Security or Safeguards?
N The noncompliance is minor.
Self-identified Construction Noncompliance
?
Y The noncompliance is minor.
N More than minor impact on SSC?
More than minor impact on Op.
Readiness?
a.
Does the performance deficiency represent an adverse condition that rendered the quality of a risk-significant or safety-related SSC unacceptable or indeterminate, and requires substantive corrective action?
b.
Does the noncompliance represent an irretrievable loss or inadequate documentation of a quality assurance record; or a record-keeping issue that could preclude the licensee from demonstrating adequacy of quality or from properly evaluating risk-significant or safety-related activities?
c.
Does the noncompliance prevent the licensee from meeting an ITAAC Design Commitment or approved Technical Specification?
d.
Does the noncompliance invalidate the performance of an Inspection, Test, or Analysis described in an ITAAC?
52 Draft Concept
Minor/More than Minor Determinations (Proposed)
Y Y
N Noncompliance with Performance Deficiency The noncompliance is more than minor.
Continue screening.
Y N
More than minor impact on Security or Safeguards?
N The noncompliance is minor.
Self-identified Construction Noncompliance
?
Y The noncompliance is minor.
N More than minor impact on SSC?
More than minor impact on Op.
Readiness?
ARCOP is not proposing to make substantive changes to the minor/MTM criteria for operational programs or safeguards and security, and that information will not be covered in this workshop.
53 Draft Concept
SSC Noncompliance Significance Determination Process Table (Proposed)
Significance of Finding Findings Impact on SSCs Red Not applicable to ARCOP findings.
Yellow
- a. The finding, if left uncorrected, would reasonably be expected to result in the loss of a fundamental safety function (FSF)1 because no systems, trains, or design features are credited for fulfilling the FSF; or.
- b. The finding is not adequately addressed by the significance criteria in this table2, and screens as yellow using Appendix F of this IMC.
White
- a. The finding, if left uncorrected, would reasonably be expected to result in the loss of two or more systems, trains, or design features ability to fulfill one or more FSFs, and other systems, trains, or design features are credited in fulfilling the FSFs; or
- b. The finding is not adequately addressed by the significance criteria in this table2, and screens as white using Appendix F of this IMC.
Green
- a. The finding, if left uncorrected, would reasonably be expected to result in the loss of one system, train, or design features ability to fulfill an FSF, and another system, train, or design feature is credited for fulfilling that FSF; or
- b. The finding is associated with an issue where no manufacture, fabrication, placement, erection, installation, or modification of hardware associated with the SSC has not begun; or
- c. There is a quality assurance program (QAP) backstop3 for the deficiency associated with the finding; or
- d. The finding is associated with a hazard protection feature4 and does not potentially represent a significant quality assurance program breakdown5; or
- e. It is demonstrated with reasonable assurance that the design function of the SSC would not be impaired by the deficiency.
54 Draft Concept
Fundamental safety functions (FSFs), as used in ARCOP, are:
Control of Heat Generation (Reactivity and Power Control),
Control of Heat Removal (including reactor and spent fuel decay heat and heat generated from waste stores), and Radionuclide Retention.
Note 2:
Findings not adequately addressed by the significance criteria of the SDP table. When the ARCOP construction significance determination process guidance is not adequate to provide a reasonable estimate of the significance of an inspection finding, the safety significance should ultimately be determined by using engineering judgement and regulatory oversight experience, which is acceptable in a risk-informed process. Appendix F provides guidance to the NRC to apply a consistent process for risk-informed decision making.
Note 3:
Quality assurance program (QAP) backstop. A QAP backstop is a scheduled QAP activity designed to detect SSC deficiencies or noncompliances that are associated with the finding. To give credit for a QAP backstop, the QAP activity must be reasonably defined or contained in a procedure, scheduled prior to the receipt of an operating license (Part 50) or before the 103(g) finding (Part 52), and would reasonably be able to detect the deficiency or noncompliance associated with the finding.
Note 4:
Hazard protection features are those SSCs and design features that mitigate the effects of internal (e.g., fire, internal flooding, internal chemical release) or external (e.g., seismic event, external flooding, severe weather events) hazards.
Note 5:
Use Appendix F of this IMC to determine if an issue should be considered a potentially significant quality assurance program breakdown.
55 Draft Concept
56 Acronyms ARCOP - Advanced Reactor Construction Oversight Process CFR - Code of Federal Regulations ConE - Construction Experience DD - Division Director DRA - Deputy Regional Administrator EDO - Executive Director of Operations FSF - Fundamental Safety Function GTG - Greater than Green IR - Inspection Report ITAAC - Inspections, Tests, Analyses, and Acceptance Criteria MTM - More than Minor NCV-Non-Cited Violation NOD - Notice of Deviation NOV - Notice of Violation NON - Notice of Nonconformance NRC - Nuclear Regulatory Commission NSR - Non-safety Related (no special treatment)
NSRST - Non-safety related special treatment OE - Operating Experience
57 PRA - Probabilistic Risk Assessment RA - Regional Administrator QAP - Quality Assurance Program RAW - Risk Achievement Worth RTNSS - Regulatory Treatment of Non-safety Related Systems ROP - Reactor Oversight Process SCN - Self-identified Construction Noncompliance SDP - Significance Determination Process SL-Severity Level SR - Safety Related SSC - Structures, Systems, and Components Acronyms
Stakeholder Input End of Morning Session 58
Planned Workshop Sessions 59 Session 1, February 28, 2024, and March 20, 2024:
Introduction to NRC Advanced Reactor Construction Oversight, and the ARCOP Framework.
Session 2, April 3, 2024:
Inspection Scoping Session 3, May 22, 2024:
Enforcement Session 4, Date:
Assessment, Feedback/Wrap Up
Feedback on this Public Meeting https://feedback.nrc.gov/pmfs/feedback/form?meetingcode=20240651 60