ML24190A146

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Arcop Ws 4 Ppt - Public
ML24190A146
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Issue date: 07/08/2024
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NRC Advanced Reactor Construction Oversight Process (ARCOP) 1 Vogtle Units 1-4 Photo Credit: Georgia Power Stakeholder Workshop Series

Introduction and Guidelines 2

Workshop #4

Planned Workshop Sessions (Meeting Summary ML) 3 Session 1, February 28 and March 20, 2024:

Introduction to NRC Advanced Reactor Construction Oversight, and the ARCOP Framework.

(ML24078A063)

Session 2, April 3, 2024:

Inspection Scoping (ML24123A214)

Session 3, May 22, 2024:

Enforcement and SDP (ML24177A120)

Session 4, July 17, 2024:

Assessment Tabletop Summary Feedback/Wrap Up

Assessment Key Proposals Tabletop Exercise Summary Workshops 1-3 Follow-up Topics 4

Workshop #4 Agenda

Purpose and Desired Outcome 5

Discuss the objectives & conceptual framework for the Advanced Reactor Construction Oversight Process (ARCOP).

Initiate dialogue with stakeholders including the public about the ARCOP options.

Gain perspectives on the various ARCOP options being considered.

NRC guidance discussions are preliminary and are not meant to convey a final regulatory position.

Conceptual ARCOP Framework 6

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

Construction Assessment Objectives 7

1. To arrive at an objective assessment of a licensees/permit holders/manufacturers effectiveness in assuring quality by:

Continuously assessing inspection results and adjusting the inspection program, as necessary; and Adjusting, as appropriate, the scope of the inspection program for subsequent Nth of-a-kind reactors/reactor plants.

This is intended to support a decision to issue an operating license pursuant to 10 CFR 50.57 or to allow operations to commence in accordance with 10 CFR 52.103(g).

Conceptual Framework

Construction Assessment Objectives (continued) 8

2. To provide guidance for making timely decisions regarding appropriate agency actions in a predictable, scrutable, and repeatable manner.
3. To communicate the staffs assessments of the manufacturing and construction quality of the reactor plant to stakeholders and interested members of the public.

Conceptual Framework

Assessment Process 9

  • The Reactor Oversight Process (ROP) is cyclical and runs on an annual basis culminating with the End-of-Cycle (EOC) assessment.
  • Construction is linear in that it has a beginning and end.

Under ARCOP, assessments in each inspection area will be performed on a continuous basis.

  • Inspection reports will provide brief assessment statements for the inspection areas inspected.
  • ARCOP proposes to replace EOC letters and EOC public meetings with an annual report on the state of manufacturing and construction.

Conceptual Framework

Assessment Process (Contd) 10 Public engagements will continue to occur on periodic and as-needed basis.

The annual report will support the Agency Action Review Meeting (AARM).

Conceptual Framework

11 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 COL, CP, LWA, or ESP Holder/Applicant Manufacturer (if applicable)

Onsite Construction Inspection (from Project-Specific Matrix)

Offsite Manufacturer Inspection (from Project-Specific Matrix)

Vendors Vendor Inspection Plan Vendor Oversight Construction Response Table

2. Supplemental Inspections
3. Design-Specific Matrix Update Conceptual Framework ARCOP Assessment Road Map

12 ARCOP Assessment Feedback Mechanisms

1. Baseline Inspection Program Adjustments
2. Supplemental Inspections of Risk-Significant Inspection Issues
3. Design-Specific Inspection Scoping Matrix Update Conceptual Framework

Proposed Options for Feedback Mechanism #2 (Supplemental Inspections) 13 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.

Conceptual Framework

14 Construction Action Matrix Concept Conceptual Framework

RESULTS GREEN INSPECTION FINDING WHITE INSPECTION FINDING YELLOW INSPECTION FINDING UNACCEPTABLE QUALITY*

  • see IMC for guidance

RESPONSE

APPLIED TO EACH LICENSEE OR NON-LICENSEE FINDING Regulatory Engagement Meeting None Branch Chief (BC) or Division Director (DD)

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 Causal evaluation and corrective actions Causal evaluation and corrective actions Performance Improvement Plan with NRC Oversight.

NRC Inspection Baseline Inspection Supplemental Inspection and evaluation for additional baseline inspection(s) in area(s) of concern.

Supplemental Inspection and evaluation for additional baseline inspection(s) in area(s) of concern.

Possible Order/

Confirmatory Action Letter. Supplemental team inspection(s). 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.

RA 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.

15 Construction Response Table Conceptual Framework

16 Option C: Construction Response Table

  • 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.
  • Focuses on the significance of the issue with appropriately scaled response.

Option Requiring Further Development Conceptual Framework

17 Questions/Break

18 Summary Workshop #3 Tabletop Exercise (ML24177A120)

In-person Participant Handout ADAMS Accession No.: ML24163A042 In-person NRC facilitator handout ADAMS Accession No.: ML24163A041 Workshop #4, Part 2

19 Tabletop Exercise Summary The staff noted the following during the exercises:

The unique designs and deployment models will require knowledgeable trained inspectors to ensure that issues are dispositioned consistent with the NRCs principles of good regulation.

While the current fleet of operating reactor licensees is well versed in how inspectors disposition issues, new vendors and licensees would benefit from additional workshops and training to solidify their knowledge and familiarity of the process.

Inspector training and guidance is needed to understand the Part 50 licensing process and how it will impact inspection planning and issue disposition.

Inspector guidance is needed on crediting design features in fulfillment of fundamental safety functions when assessing the risk significance of issues, particularly for those features that are not subject to construction inspection, like fuel design features.

20 NRC Follow-Up on Stakeholder Feedback from Previous Workshops Workshop #4, Part 3

21 Questions

Questions/Comments -

General 22

  • How will the FSFs be used in ARCOP and how does this relate to SSC classification in the license application?
  • What are the meanings of the words construction, manufacturer, and vendor in the ARCOP lexicon?
  • Can performance indicators be used in ARCOP?
  • Do you plan to interface with other countries to increase efficiency? How?

Questions/Comments -

Inspection 23

  • What is the difference between a Design vs Project-specific inspection scoping matrix? How will the licensee be engaged during matrix development?
  • How are inspection areas determined and how will non-safety related systems be scoped into construction inspection?
  • How are Risk Importance measures for Design and Construction determined and how will they be used for inspection scoping?
  • How will ARCOP adjust the inspection scope when changes are made to the design or PRA during part 50 construction?

24

  • How is the PSAR/CP application used for construction inspection when design is not final (Part 50)?
  • How will NRC management control (i.e.,

programmatic control) the scope of inspections?

  • How will the NRC prevent inspection scope creep into the nuclear supply chain?

Questions/Comments -

Inspection (continued)

Questions/Comments -

Dispositioning Issues 25

  • Will manufacturers and constructers be given a chance to identify noncompliances before we use enforcement? (i.e., in-situ work findings.)
  • How are design features credited in the SDP?
  • How will radionuclide retention FSF be assessed?
  • For the SDP, instead of using loss of 1, 2 systems for an FSF, use single, multiple because not all designs have more than a specific
  1. of systems.

Questions/Comments -

Dispositioning Issues (continued) 26

  • The term trains may not be applicable for some designs. Consistent/technology-inclusive language should be used.
  • Need to define substantial corrective action as it is applied to some screening questions.
  • ARCOP SDP should not result in a higher significance level than if the issue were to occur during operations under the ROP.

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 27 ARCOP Development Timeline

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 28

Feedback on this Public Meeting https://feedback.nrc.gov/pmfs/feedback/form?meetingcode=20240894 29

Acronyms 30 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

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