ML24163A041
| ML24163A041 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/2024 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML24163A041 (1) | |
Text
AECOP Workshop #3 NRC Facilitator Handout - Scenarios and Solutions
Questions to stimulate conversation (if needed):
- 1. Was your result consistent with the NRC s result? If not, why?
- 2. Are there technology-specific considerations that might change the outcomes?
- 3. Is the process reasonably easy to understand and execute? If not, why?
- 4. Do you think the ARCOP SDP process provides reasonable results? If not, why?
- 5. Do you have any suggestions to improve the process?
1 Group activity - Example Scenario 1 (For demonstration purpose only)
No PD
While walking down the salt processing system in the reactor building of a MSR project, an NRC inspector observes damage to a system pipe. That portion of the reactor building has not been completed (no roof ) and the inspector is aware of a severe weather event that occurred 2 days ago at the site. The licensee informs the NRC inspector that they intend to walkdown all the SSCs that were potentially affected by the weather event, but they hadnt walked down that portion of the reactor building yet. The NRC inspector reviews work requests generated after the weather event and observes that there is an open work request to walkdown the reactor building for potential damage to SSCs.
Extra information:
- The salt processing system piping is a SR radionuclide boundary, and the deficiency affects its ASME qualification.
- Exact cause of the damage is unknown but appears to be storm-re l ate d
- It is reasonable that the licensee has not walked down the room yet. With no immediate safety concern, they could wait a long time to do it. It should be documented in the work-flow system or CAP if not performed promptly.
Alternate Scenarios:
- What if they didnt have a planned action to identify?
- What if they completed their action to walkdown, but missed this degradation? 2 Scenario 1 Flowchart (For demonstration purpose only)
Potentially Y Issue of Involves W illfulness is not covered Concern W illfulness in this workshop.
?
N
Non-Y Traditional Enforcement Path Traditional enforcement in Compliance Follow both not covered in this
? paths workshop
N
N
ARCOP Path No finding
The noncompliance Go to Y More Y licensee or Performance than is an NRC-identified Non-Deficiency? Minor? or self-revealing licensee flow finding chart
N N
No finding No finding
3 Group activity - Example Scenario 2 (For demonstration purpose only)
Minor - SCN:
While reviewing condition reports (CAP entries) as part of an auxiliary heat removal system inspection, an NRC inspector reviews a condition report that documents an error in a work procedure that led to 4 nonconforming welds in system piping. The NRC inspector also noted that corrective actions were complete for 2 of the 4 welds (grind out weld and reweld) but not the other 2 welds. Those corrective actions are marked as pending further evaluation in the CAP database.
Extra information:
- There is also a completed corrective action to correct the procedural error, which was completed, and the CA fixed the problem adequately.
- No other welds were performed with the procedure.
- The pending further evaluation action in the CAP is assigned to the engineering department with no due date - but this isnt really a problem because the action is assigned a reasonable priority in the CAP to schedule and repair.
- The system is NSRST. The welds are required to be ASME qualified. The system is credited for DID for heat removal for several LBEs.
4 Scenario 2 Flowchart (For demonstration purpose only)
Potentially Y Issue of Involves W illfulness is not covered Concern W illfulness in this workshop.
?
N
Non-Y Traditional Enforcement Path Traditional enforcement in Compliance Follow both not covered in this
? paths workshop
N
N
ARCOP Path No finding
The noncompliance Go to Y More Y licensee or Performance than is an NRC-identified Non-Deficiency? Minor? or self-revealing licensee flow finding chart
N N
No finding No finding
5 Scenario 2 Flowchart (For demonstration purpose only)
Noncompliance with Self-identified Y The noncompliance is Self-identified Construction Noncompliances (SCNs)
Performance Construction minor.
Deficiency Noncompliance?
- 1. The noncompliance is self-identified (not NRC-N identified or self-revealing), and
Y The noncompliance is More than minor more than minor. 2. The noncompliance must be in a facility-approved impact on SSC? Continue screening. QAP process for correction when evaluated by NRC inspectors, as defined by facility-approved QAP N procedures. This may include:
More than minor Y - Entry into an QAP work -flow process or corrective impact on Op. action program.
Readiness?
- Proper timing and tracking of planned corrective N actions so that the noncompliance will not adversely impact reactor operations.
More than minor Y impact on - If corrective actions are complete, the corrective Security or actions are adequate.
Safeguards?
N Note: NRC-identified weaknesses with corrective actions are processed as separate noncompliances.
The noncompliance is minor.
6 Group activity - Example Scenario 3 (For demonstration purpose only)
Green - Hazards:
While reviewing seismic design requirements for the safety related portion of the reactor building, an NRC inspector notes that part of the north wall rebar configuration does not match the design drawing. In response to the NRC inspector s observation, the licensee repaired the nonconformance which required substantive rework.
Extra information:
- The design drawing is correct.
- The configuration issue did not affect the ability of the wall to hold its own weight but did affect the seismic qualification or tornado protection.
- No use-as-is analysis was performed to assess the impact of the defect.
- The error in the north wall is traced back to a human performance issue with craft workers.
- The north wall is the first rebar placed in the reactor building; no other SR walls have been constructed.
- The problems effect on the ability of the wall to resist a DBE is unknown (no detailed analysis was performed). Note: no analysis should be required as the nonconformance was repaired. The issue was screened to green due to the limited scope ( i.e, lack of a significant QAP breakdown).
7 Scenario 3 Flowchart (For demonstration purpose only)
Potentially Y Issue of Involves W illfulness is not covered Concern W illfulness in this workshop.
?
N
Non-Y Traditional Enforcement Path Traditional enforcement in Compliance Follow both not covered in this
? paths workshop
N
N
ARCOP Path No finding
The noncompliance Go to Y More Y licensee or Performance than is an NRC-identified Non-Deficiency? Minor? or self-revealing licensee flow finding chart
N N
No finding No finding
8 Scenario 3 Flowchart (For demonstration purpose only)
Noncompliance with Self-identified Y The noncompliance is Performance Construction minor. a. Does the performance deficiency represent an Deficiency Noncompliance? adverse condition that rendered the quality of a risk-
N significant or safety -related SSC unacceptable or indeterminate, and requires substantive corrective Y The noncompliance is action?
More than minor more than minor.
impact on SSC? Continue screening.
- b. Does the noncompliance represent an irretrievable N loss or inadequate documentation of a quality assurance record; or a record-keeping issue that
More than minor Y could preclude the licensee from demonstrating impact on Op. adequacy of quality or from properly evaluating risk-Readiness?
significant or safety -related activities?
N c. Does the noncompliance prevent the licensee from
More than minor Y meeting an ITAAC Design Commitment or approved impact on Technical Specification?
Security or Safeguards? d. Does the noncompliance invalidate the performance
N of an Inspection, Test, or Analysis described in an
The noncompliance is ITAAC?
minor.
9 Dispositioning Licensee Findings (Proposed)
Scenario 3 Flowchart NRC-Identified or (For demonstration purpose only)
self-revealed licensee finding.
Legally Y A violation is Enforcement Y Document in binding associated with Discretion accordance with the requirement the finding Apply? Enforcem ent Policy
?
N N
A violation is Screen finding not associated significance with the finding
Y Noncited Y Noncited Green violation Violation Go to Finding? ? (NCV)
next flowchart N N
Enter the Notice of SERP Process Violation (NOV)
10 Scenario 3 (For demonstration purpose only)
Significance of Finding Findings Impact on SSCs Red Not applicable to ARCOP findings.
- 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 Yellow
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as yellow using Appendix F of this IMC.
- a. The finding, if left uncorrected, would reasonably be expected to result in t he 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 fulfillin g White the FSFs; or
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as white using Appendix F of this IMC.
- 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 begun; or Green c. There is a quality assurance program (QAP) backstop 3 for the deficiency associated with the finding; or
- d. The finding is associated with a hazard protection feature 4 and does not potentially represent a significant quality assurance program breakdown 5; or
- e. It is demonstrated with reasonable assurance that the design function of the SSC would not be impaired by the deficiency.
See table notes 11 Group activity - Example Scenario 4 (For demonstration purpose only)
Green - Loss of a system/train/design feature:
During an NRC inspection, the inspector noted that an orifice in a reactor cavity cooling system pipe was smaller than others in the system (1 of 2 trains affected). The NRC inspector also noted that the orifice size was in accordance with the design drawing. However, the PSAR states that the design flow of ___ is needed for the line, and the design calculations for pipe flow assume a larger orifice (the same size as installed in the other line).
Extra information:
- There are 2 redundant sets of reactor cavity cooling pipes/standpipes. Only 1 set/train is affected.
- The reactor cavity cooling system is the SR system credited for the HR FSF for most LBEs.
- The design drawing error appears to be isolated (no other errors were identified). The licensee initiated a CR to determine the cause of the error after the NRC inspector's observation.
- The calculations were not reperformed with the smaller orifice to see if flow would have been sufficient with the wrong orifice installed. Instead, the licensee has elected to replace the orifice and revise the design drawing to be consistent with the PSAR. Note: should get to green without the analysis (criterion a.)
12 Scenario 4 Flowchart (For demonstration purpose only)
Potentially Y Issue of Involves W illfulness is not covered Concern W illfulness in this workshop.
?
N
Non-Y Traditional Enforcement Path Traditional enforcement in Compliance Follow both not covered in this
? paths workshop
N
N
ARCOP Path No finding
The noncompliance Go to Y More Y licensee or Performance than is an NRC-identified Non-Deficiency? Minor? or self-revealing licensee flow finding chart
N N
No finding No finding
13 Scenario 4 Flowchart (For demonstration purpose only)
Noncompliance with Self-identified Y The noncompliance is Performance Construction minor. a. Does the performance deficiency represent an Deficiency Noncompliance?
adverse condition that rendered the quality of a risk-N significant or safety -related SSC unacceptable or Y indeterminate, and requires substantive corrective More than minor The noncompliance is action?
impact on SSC? more than minor.
Continue screening. b. Does the noncompliance represent an irretrievable
N loss or inadequate documentation of a quality assurance record; or a record-keeping issue that More than minor Y could preclude the licensee from demonstrating impact on Op. adequacy of quality or from properly evaluating risk-Readiness?
significant or safety -related activities?
N
- c. Does the noncompliance prevent the licensee from
More than minor Y meeting an ITAAC Design Commitment or approved impact on Technical Specification?
Security or Safeguards?
- d. Does the noncompliance invalidate the performance N of an Inspection, Test, or Analysis described in an
The noncompliance is ITAAC?
minor.
14 Dispositioning Licensee Findings (Proposed)
Scenario 4 Flowchart NRC-Identified or (For demonstration purpose only) self-revealed licensee finding.
Legally Y A violation is Enforcement Y Document in binding associated with Discretion accordance with the requirement the finding Apply? Enforcem ent Policy
?
N N
A violation is Screen finding not associated significance with the finding
Y Noncited Y Noncited Green violation Violation Go to Finding? ? (NCV)
next flowchart N N
Enter the Notice of SERP Process Violation (NOV)
15 Scenario 4 (For demonstration purpose only)
Significance of Finding Findings Impact on SSCs Red Not applicable to ARCOP findings.
- 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 Yellow
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as yellow using Appendix F of this IMC.
- a. The finding, if left uncorrected, would reasonably be expected to result in t he 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 fulfillin g White the FSFs; or
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as white using Appendix F of this IMC.
- 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 begun; or Green c. There is a quality assurance program (QAP) backstop 3 for the deficiency associated with the finding; or
- d. The finding is associated with a hazard protection feature 4 and does not potentially represent a significant quality assurance program breakdown 5; or
- e. It is demonstrated with reasonable assurance that the design function of the SSC would not be impaired by the deficiency.
See table notes 16 Group activity - Example Scenario 5 (For demonstration purpose only)
White - Loss of multiple systems/trains/design features:
During a review of measurement and test equipment (M&TE) records, an NRC inspector noted that a differential pressure instrument was not calibrated within its required periodicity as defined by the site M&TE program QA procedures. The inspector also noted that the instrument was used during pre-operational tests of the Boron Injection System and the system was turned over to operations.
Extra Information:
- The affected instruments were used on both (2 of 2) boron injection line tests and were used to adjust flow in the line.
- Flow was adjusted during both pre-op tests to lower flow as indicated on the instrument.
- When the instrument calibration was rechecked, the instrument was significantly inaccurate in the non-conservative direction.
- The test was subsequently reperformed and the as-found flows were significantly lower than required by the design calcs.
Alternate Scenarios:
- What if pre-operational testing had not yet been performed, which represents a reasonable opportunity for the licensee to identify and correct prior to operations (e. g., QAP Backstop would screen to Green). 17 Scenario 5 Flowchart (For demonstration purpose only)
Potentially Y Issue of Involves W illfulness is not covered Concern W illfulness in this workshop.
?
N
Non-Y Traditional Enforcement Path Traditional enforcement in Compliance Follow both not covered in this
? paths workshop
N
N
ARCOP Path No finding
The noncompliance Go to Y More Y licensee or Performance than is an NRC-identified Non-Deficiency? Minor? or self-revealing licensee flow finding chart
N N
No finding No finding
18 Scenario 5 Flowchart (For demonstration purpose only)
Noncompliance with Self-identified Y The noncompliance is Performance Construction minor.
Deficiency Noncompliance?
- a. Does the performance deficiency represent an N adverse condition that rendered the quality of a risk-
Y significant or safety -related SSC unacceptable or More than minor The noncompliance is indeterminate, and requires substantive corrective impact on SSC? more than minor.
Continue screening. action?
N b. Does the noncompliance represent an irretrievable loss or inadequate documentation of a quality More than minor Y assurance record; or a record-keeping issue that impact on Op. could preclude the licensee from demonstrating Readiness?
adequacy of quality or from properly evaluating risk-N significant or safety -related activities?
More than minor Y c. Does the noncompliance prevent the licensee from impact on meeting an ITAAC Design Commitment or approved Security or Safeguards? Technical Specification?
N d. Does the noncompliance invalidate the performance
The noncompliance is of an Inspection, Test, or Analysis described in an minor.
19 Dispositioning Licensee Findings (Proposed)
Scenario 5 Flowchart NRC-Identified or (For demonstration purpose only)
self-revealed licensee finding.
Legally Y A violation is Enforcement Y Document in binding associated with Discretion accordance with the requirement the finding Apply? Enforcem ent Policy
?
N N
A violation is Screen finding not associated significance with the finding
Y Noncited Y Noncited Green violation Violation Go to Finding? ? (NCV)
next flowchart N N
Enter the Notice of SERP Process Violation (NOV)
20 Scenario 5 (For demonstration purpose only)
Significance of Finding Findings Impact on SSCs Red Not applicable to ARCOP findings.
- 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 Yellow
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as yellow using Appendix F of this IMC.
- a. The finding, if left uncorrected, would reasonably be expected to result in t he 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 fulfillin g White the FSFs; or
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as white using Appendix F of this IMC.
- 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 begun; or Green c. There is a quality assurance program (QAP) backstop 3 for the deficiency associated with the finding; or
- d. The finding is associated with a hazard protection feature 4 and does not potentially represent a significant quality assurance program breakdown 5; or
- e. It is demonstrated with reasonable assurance that the design function of the SSC would not be impaired by the deficiency.
See table notes 21 Group activity - Example Scenario 6 (For demonstration purpose only)
Yellow - Loss of FSF:
NRC inspectors identified a generic setpoint control program problem that resulted in non -conservative setpoints in the reactor protection system. All scram and runback setpoints, and all RPS trains were adversely/non-conservatively affected. Systems had already been turned over to operations (e. g., there was no reasonable opportunity for the licensee to have identified and corrected the issue prior to operations).
Extra Information:
- Reactor protection system is the sole credited (safety -related or NSRST) system to fulfill the reactivity control FSF.
- All setpoints are significantly non-conservative (no analysis can demonstrate safety).
22 Scenario 6 Flowchart (For demonstration purpose only)
Potentially Y Issue of Involves W illfulness is not covered Concern W illfulness in this workshop.
?
N
Non-Y Traditional Enforcement Path Traditional enforcement in Compliance Follow both not covered in this
? paths workshop
N
N
ARCOP Path No finding
The noncompliance Go to Y More Y licensee or Performance than is an NRC-identified Non-Deficiency? Minor? or self-revealing licensee flow finding chart
N N
No finding No finding
23 Scenario 6 Flowchart (For demonstration purpose only)
Noncompliance with Self-identified Y The noncompliance is Performance Construction minor. a. Does the performance deficiency represent an Deficiency Noncompliance?
adverse condition that rendered the quality of a risk-N significant or safety -related SSC unacceptable or indeterminate, and requires substantive corrective Y The noncompliance is action?
More than minor more than minor.
impact on SSC? Continue screening.
- b. Does the noncompliance represent an irretrievable N loss or inadequate documentation of a quality assurance record; or a record-keeping issue that More than minor Y could preclude the licensee from demonstrating impact on Op. adequacy of quality or from properly evaluating risk-Readiness?
significant or safety -related activities?
N c. Does the noncompliance prevent the licensee from
More than minor Y meeting an ITAAC Design Commitment or approved impact on Technical Specification?
Security or Safeguards?
- d. Does the noncompliance invalidate the performance N of an Inspection, Test, or Analysis described in an
The noncompliance is ITAAC?
minor.
24 Dispositioning Licensee Findings (Proposed)
Scenario 6 Flowchart NRC-Identified or (For demonstration purpose only) self-revealed licensee finding.
Legally Y A violation is Enforcement Y Document in binding associated with Discretion accordance with the requirement the finding Apply? Enforcem ent Policy
?
N N
A violation is Screen finding not associated significance with the finding
Y Noncited Y Noncited Green violation Violation Go to Finding? ? (NCV)
next flowchart N N
Enter the Notice of SERP Process Violation (NOV)
25 Scenario 6 (For demonstration purpose only)
Significance of Finding Findings Impact on SSCs Red Not applicable to ARCOP findings.
- 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 Yellow
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as yellow using Appendix F of this IMC.
- a. The finding, if left uncorrected, would reasonably be expected to result in t he 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 fulfillin g White the FSFs; or
- b. The finding is not adequately addressed by the significance criteria in this table 2, and screens as white using Appendix F of this IMC.
- 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 begun; or Green c. There is a quality assurance program (QAP) backstop 3 for the deficiency associated with the finding; or
- d. The finding is associated with a hazard protection feature 4 and does not potentially represent a significant quality assurance program breakdown 5; or
- e. It is demonstrated with reasonable assurance that the design function of the SSC would not be impaired by the deficiency.
See table notes 26 Group activity - Example Scenario 7 (For demonstration purpose only)
Nonconformance:
While reviewing radiographs at the manufacturing facility of a non -licensed manufacturer for the CVCS piping system associated with an SMR, the NRC inspector observed a previously unidentified unacceptable weld indication on the radiograph. The radiograph had already been reviewed/accepted by the manufacturer s NDE personnel.
Extra information:
- The CVCS piping is a SR reactor coolant pressure boundary, and the deficiency affects its ASME qualification.
- The cause and full extent of the weld indication is unknown.
27 Scenario 7 Flowchart (For demonstration purpose only)
Potentially Y Issue of Involves W illfulness is not covered Concern W illfulness in this workshop.
?
N
Non-Y Traditional Enforcement Path Traditional enforcement in Compliance Follow both not covered in this
? paths workshop
N
N
ARCOP Path No finding
The noncompliance Go to Y More Y licensee or Performance than is an NRC-identified Non-Deficiency? Minor? or self-revealing licensee flow finding chart
N N
No finding No finding
28 Scenario 7 Flowchart (For demonstration purpose only)
Noncompliance with Self-identified Y The noncompliance is Performance Construction minor.
Deficiency Noncompliance?
N
Y The noncompliance is More than minor more than minor.
impact on SSC? Continue screening.
N
More than minor Y impact on Op.
Readiness?
N
More than minor Y impact on Security or Safeguards?
N
The noncompliance is minor.
29 Dispositioning Non-Licensee Findings Scenario 7 Flowchart (For demonstration purpose only)
From the NRC-identified or Document as a Notice initial of Nonconformance Note: all screening self-revealed non-licensee (NON) to the manufacturer NONs flow chart finding manufacturer are assessed for potential follow-up inspection.
Enforcement Process
30 Backup Slides
31 Flowchart Instructions (DRAFT)
Issue of Concern Noncompliance Performance Legally Binding Deficiency Requirements A w e l l-defined A failure to adhere to a observation or collection requirement or - Regulations of observations that may commitment. The noncompliance was - License conditions have a bearing on safety reasonably within the - NRC Orders or security and warrants Legally binding licensees ability to foresee further inspection, requirements include and correct and should Non-legally binding screening, evaluation, or regulations, license have been prevented. requirements regulatory action. conditions, and NRC Orders. Self-imposed requirements to establish Non-legally binding and maintain quality commitments include self-imposed requirements to establish and maintain quality or requirements specified in procurement contracts..
32 Flowchart Instructions (Minor/More-than-Minor Screening)
(DRAFT)
Self-identified Construction Noncompliance (SCN) Criteria SSC Issues - Minor Criteria Questions
- 1. The noncompliance is self-identified (not NRC-a. Does the performance deficiency represent an adverse identified or self-revealing), and condition that rendered the quality of a risk-significant or s afet y-related SSC unacceptable or indeterminate, and
- 2. The noncompliance must be in a facility-approved QAP requires substantive corrective action?
process for correction when evaluated by NRC b. Does the noncompliance represent an irretrievable loss inspectors, as defined by facility-approved QAP or inadequate documentation of a quality assurance procedures. This may include: record; or a record-keeping issue that could preclude the
- Entry into an QAP work -flow process or corrective licensee from demonstrating adequacy of quality or from action program. properly evaluating risk-significant or safety-related
- Proper timing and tracking of planned corrective activities?
actions so that the noncompliance will not adversely c. Does the noncompliance prevent the licensee from impact reactor operations. meeting an ITAAC Design Commitment or approved
- If corrective actions are complete, the corrective Technical Specification?
actions are adequate. d. Does the noncompliance invalidate the performance of Note: NRC-identified weaknesses with corrective actions an Inspection, Test, or Analysis described in an ITAAC?
are processed as separate noncompliances.
33 SSC SDP Table Notes (DRAFT)
Note 1: 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.
34