ML24227B033
| ML24227B033 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/2024 |
| From: | Kevin Roche NRC/NRR/DANU/UAL2 |
| To: | Stephen Philpott NRC/NRR/DANU/UAL2 |
| Roche K | |
| References | |
| Download: ML24227B033 (1) | |
Text
MEMORANDUM TO:
Stephen S. Philpott, Chief (Acting)
Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Kevin M. Roche, Project Manager /RA/
Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JULY 17, 2024 - ADVANCED REACTOR CONSTRUCTION OVERSIGHT PROCESS PUBLIC WORKSHOP #4 Meeting Information:
Public Meeting Notice Agencywide Documents Access and Management System (ADAMS) Accession No.: ML24185A087 Presentation Slides ADAMS Accession No.: ML24190A146 Meeting Attendees: See the enclosure for a list of meeting attendees.
CONTACT:
Kevin Roche, NRR/DANU (301) 415-1554 August 26, 2024
S. Philpott Meeting Summary:
The U.S. Nuclear Regulatory Commission (NRC) staff conducted the meeting in accordance with NRC Management Directive 3.5, Attendance at NRC Staff-Sponsored Meetings (ADAMS Accession No. ML21180A271). The main points of discussion during the meeting included:
On July 17, 2024, the NRC staff conducted the fourth of a series of workshops discussing the advanced reactor construction oversight process (ARCOP). This workshop included discussions of possible ARCOP assessment options, the prior tabletop exercises that the staff held in-person with stakeholders, and topics/questions from the previous three workshops.
This meeting along with the others were information meetings with question-and-answer sessions. The workshops were held on the following days and discussed the following topics:
Workshop 1 - February 28, 2024 (and finished on March 20, 2024) - Introduction and overview of potential options for the various ARCOP elements.
Public Meeting Notice ADAMS Accession No.: ML24058A197, and ML24067A292 Presentation Slides ADAMS Accession No.: ML24046A154 Workshop 2 - April 3, 2024 - Performance monitoring and baseline inspection scoping.
Public Meeting Notice ADAMS Accession No.: ML24082A114 Presentation Slides ADAMS Accession No.: ML24081A308 Workshop 3 - May 22, 2024 - Recapped previous workshops, the NRC Enforcement Policy, potential options for the ARCOP significance determination process, and held table-top exercises using possible guidance to determine the significance of example inspection issues.
Public Meeting Notice ADAMS Accession No.: ML24129A079 Presentation Slides ADAMS Accession No.: ML24129A075 In-person Participant Handout ADAMS Accession No.: ML24163A042 In-person NRC facilitator handout ADAMS Accession No.: ML24163A041 For Workshop 4, the staff collected and developed a list of common questions and themes that stakeholders brought up during the previous meetings. These can be found in Enclosure 2.
Please note, these answers are preliminary, were intended to clarify draft concepts presented during the previous workshops, and do not constitute a regulatory decision.
The NRC made no regulatory decisions during this meeting.
Enclosures:
- 1. List of Meeting Attendees
S. Philpott 2. Questions from previous meetings cc:
Advanced Reactor Stakeholder Meeting for the NRC Advanced Reactor Rulemaking and Guidance Development for the NRC via GovDelivery
NRR-106 OFFICE NRR/DANU/UAL2/PM NRR/DANU/UAL2 RII/DCO/DD NAME KRoche POBryan NCoovert DATE 8/14/2024 8/15/2024 8/15/2024 OFFICE RI/DORS/PB4/BC NRR/DANU/UAL2/BC NRR/DANU/UAL2/PM NAME JGreives SPhilpott KRoche DATE 8/18/2024 8/26/2024 8/26/2024 List of Meeting Attendees ADVANCED REACTOR CONSTRUCTION OVERSIGHT PROCESS PUBLIC WORKSHOP #4*
July 17, 2024 Name Organization Billy Gleaves NRC Charles Murray NRC Christopher Welch NRC Darrell Neal NRC George Khouri NRC James Gaslevic NRC Jonathan Greives NRC Justin Fuller NRC Kevin Roche NRC Nicole Coovert NRC Phil OBryan NRC Qin Pan NRC Robert Mathis NRC Sean Gallagher NRC Amir Afzali Public Andrew Porter Public Brazos Fitch Public Bruce Greer Public Eiric Oesterle Public Farshit Shahrokhi Public Glenn Neises Public Hyosook Jung Public Jacob Robertson Public Jana Bergman Public Jeff Public John Biersdorf Public Jon Facemire Public Leigh Lloveras Public Mory Diané Public Neil Herman Public Nik Krainchich Public Patrick Donnelly Public Paul Coco Public Pete Okrasa Public Rani Franovich Public Rob Burg Public Sarah Gibboney Public Siavash Dorvash Public Spencer Toohill Public Steven Pope Public Thomas Basso Public Timothy Williamson Public Tom Kozak Public
- Attendance list based on Microsoft Teams Participant list. This list does not include individuals that connected via phone.
Workshop 4 Questions and Answers (Q&As)
A reminder that the concepts that were discussed in public workshops, and summarized, below, are draft. The final framework and concepts are under development and subject to change. As such, these Q&As are reflective of the draft concepts that were presented in those workshops and answers are intended to clarify some of those concepts. Q&As are not intended to convey any regulatory positions.
The staff intends to share these high-level concepts with the Commission and are in the process of defining these concepts in more detail in draft Inspection Manual Chapters (IMCs) and inspection procedures (IPs). Note that in addition to these Q&As, several comments were received during workshops that are being considered for enhancements to detailed inspection guidance. The staff remains fully committed to keeping stakeholders informed of our progress.
Separately, the staff are still developing high-level concepts for other key topics (e.g., inspection of operational programs, assessment of safety culture) and will communicate our progress in those areas as well.
General How will the fundamental safety functions (FSFs) be used in ARCOP and how does this relate to systems, structures, and components (SSCs) classification in the license application?
The fundamental safety functions are intended to be used to support inspection scoping and planning, and to disposition inspection findings. The FSFs are applicable to all reactor designs and would allow us to create a generic process for construction oversight of multiple reactor designs. The proposed use of FSFs in ARCOP will have no impact on the classification of SSCs in a license application.
The Inspection Scoping Matrix and Significance Determination Process are tools the staff is considering to use to prioritize inspections and establish safety-significance of inspection findings. ARCOP is an oversight process and does not impact the licensing process. As noted in slides 13-15 of the Workshop 1 presentation (ML24046A154), the FSFs are 1) Heat removal, 2) Reactivity Control, and 3) Radionuclide Retention.
What are the meanings of the words manufacturer and vendor in the ARCOP lexicon?
The intent of these terms in ARCOP is to distinguish between the locations and the entities performing work. Historically, construction has occurred on the site where the reactor plant is intended to be operated and is conducted under the responsibility of a licensee as a combined license (COL) or a construction permit (CP) holder. New deployment models presented by the industry include significant increases in factory fabrication away from the site, including manufacture of complete or nearly complete nuclear power or reactor modules. The terms Manufacturer and Vendors were described in Slide 6 of the Workshop 2 presentation (ML24081A308).
The term Manufacturer, as used in ARCOP concepts, refers to entities performing work
2 off-site (at a location where the reactor plant is not intended to be permanently operated). The manufacturer may be a licensee, a license applicant, or a non-licensee that performs work activities that traditionally would have occurred on-site by a licensee or their contractors. Manufacturers are expected to assemble complete plants off-site in factories, under a manufacturing license, or may complete significant portions of reactor modules for small modular reactors (SMRs). While activities performed by manufacturers are being considered for inspection under the construction oversight program within the baseline inspection scoping matrix, this is not to say that those entities are performing construction as defined in 10 CFR 50.2. The ARCOP intends to scope those activities within the inspection program that are important to meeting the ARCOP objective.
Vendors/suppliers refers to traditional vendors/suppliers who provide engineering services, components, and to some degree modules; they are not typically NRC licensees, and they will continue to be inspected under the vendor inspection program.
Can performance indicators be used in ARCOP?
The staff does not currently plan to develop performance indicators (PIs) for the same reasons they were not used in construction reactor oversight program (cROP), which was documented in SECY-09-0113 (ML091970152). One of the primary reasons cited by industry (in Nuclear Energy Institute (NEI) letter dated 12/5/2008, ML092080426) and SECY-09-0113, was lack of historical data from which to benchmark and derive risk informed thresholds of construction performance important to safety.
However, their use could be revisited in the future. For example, as industry progresses from deployment of first-of-a-kind technologies and moves into factory fabrication for multiple subsequent units (nth-of-a-kind), performance indicators with risk informed thresholds could potentially be identified to allow for the efficient monitoring of performance.
Does the NRC plan to interface with other countries to increase efficiency? How?
The staff plans to leverage relationships with other countries to further develop our understanding of their approaches to advanced reactor regulation, and to gain efficiencies in our oversight process where possible.
3 Inspection What is the difference between a Design versus Project-specific inspection scoping matrix? How will the licensee be engaged during matrix development?
The concept being considered under ARCOP would create a design matrix for each specific design. The matrix would initially be developed using the standard design approval application (SDAA), design certification application, or COL/CP application for first-of-a-kind plants without a standard design application, and any other available design information. When a specific licensee submits an application, the design matrix can then be used to create a project-specific inspection scoping matrix that will incorporate any site or project specific components or inspection, tests, analysis, and acceptance criteria (ITAAC), as applicable. Slides 36-47 in the Workshop 2 presentation (ML24081A308) walk through an example of developing a generic baseline inspection scoping matrix.
Staff engagement with applicants/licensees/designers throughout matrix development is key to ensuring the matrices are accurate and reflect the important SSCs of the design and risk insights.
How are inspection areas determined and how will non-safety related systems be scoped into construction inspection?
In the concept being considered for ARCOP, the staff would start developing an inspection scoping matrix by identifying all SSCs that are safety related, non-safety related with special treatment (NSRST), or regulatory treatment of non-safety systems (RTNSS) and entering them into the Inspection Scoping Matrix. Non-safety related (NSR) and non-safety related without special treatment (NST) SSCs would not be entered into the matrix because they are not risk-significant. Some NSR and NST SSCs, such as those related to security, emergency preparedness, or other programs could be inspected as part of operational readiness or security inspections.
Once the staff populates the inspection scoping matrix, they would group SSCs into inspection areas based on design, qualification, performance, and/or quality assurance program (QAP) commonalities. The concept of inspection areas is intended to make the inspections program more efficient by relying more on verification of the QAP for groups of SSCs rather than relying on larger samples of specific SSCs. See Slides 36-47 (specifically slides 40-42) in the Workshop 2 presentation (ML24081A308).
How are Risk Importance measures for design and construction determined and how will they be used for inspection scoping?
As described on Slides 43 and 44 of the Workshop 2 presentation (ML24081A308), for the concept being considered under ARCOP the staff intends to include risk importance measures for design and construction on the inspection scoping matrix for each SSC.
The staff would determine the risk importance measures using available design information, risk insights, construction and operating experience, and engineering judgement where necessary. The risk importance measures are intended to be primarily used to inform inspectors in their selection of specific SSCs to inspect.
4 How will ARCOP adjust the inspection scope when changes are made to the design or probabilistic risk assessment during Title 10 of the Code of Federal Regulation (10 CFR) Part 50 construction?
Under concepts being considered for ARCOP, NRC inspection staff would communicate often with licensees and applicants for construction projects before, during, and after planned inspections. The inspection scoping matrices would be living documents that the staff would update as necessary as changes are made to the plant design. The staff acknowledges that there may be modifications and license amendments throughout construction and would adapt inspections accordingly.
How is the preliminary safety analysis report and/or construction permit (PSAR/CP) application used for construction inspection when design is not final (more applicable to a 10 CFR Part 50 construction project)?
Under concepts being considered for ARCOP, the PSAR/CP would serve as a starting point for inspection planning. However, inspectors will need to coordinate with licensees and applicants to ensure the inspection scope reflects the most up-to-date design information.
How will NRC management control the scope of inspections?
Consistent with all NRC inspection programs, the ARCOP is intended to include decision-making processes that ensure NRC management conducts a review of the program inspection scope, including the inspection scoping matrix. See Slides 24, 31.
32, and 45 of Workshop 2 (ML24082A114) for additional places that NRC management will review/approve various aspects of the inspection program.
How will the NRC prevent inspection scope creep into the nuclear supply chain?
The staff already inspects the supply chain under the vendor inspection program, and the current effort to update reactor construction oversight through development of the ARCOP does not include any proposed revisions to this inspection program. When developing detailed guidance, the staff intends to develop a clear delineation between the vendor inspection scope and the ARCOP inspection scope at facilities where component fabrication and reactor assembly activities are co-located. The staff in the two programs will continue to closely coordinate to ensure maximum efficiency and avoid any duplication of effort. Slide 11 of the Workshop 4 presentation illustrates the relationship between the ARCOP and the vendor inspection program (ML24190A146).
5 Dispositioning Issues Will manufacturers and constructers be given a chance to identify noncompliances before we use enforcement? (i.e., in-situ work findings.)
Performing in-situ inspections are an important part of any NRC oversight process and will be important to the concepts being developed for ARCOP as well. As a result of this, inspection staff could identify a finding prior to the licensee or manufacturer having completed its quality assurance (QA) or quality control (QC) reviews.
However, the staff recognizes the need to consider how the significance of issues is impacted by inspecting work-in-progress versus inspecting completed work activities (including completed QA/QC checks). Under the concepts being considered for ARCOP, the staff is considering the existence of barriers that would prevent deficiencies from going on to operations as mitigators to issue significance. See Slide 21, 25, 54, and 55 of the Workshop 3 presentation (ML24190A146) for more information on QA Backstops.
The staff also acknowledges that inspecting completed work activities may often be preferred since assessment of performance in multiple QAP areas could be assessed and intends to clarify this balance between inspecting in-situ and completed work in detailed guidance.
How are design features credited in the significance determination process (SDP)?
Under the concepts being considered by ARCOP, the term design feature refers to an inherent physical property of a reactor design that is credited for fulfilling one or more FSFs, when appropriate. For example, if a reactor design is not susceptible to a specific accident, then there will be no significance associated with findings that impact SSCs that may mitigate that accident.
How will radionuclide retention FSF be assessed?
Under the concepts being considered for ARCOP, the radionuclide retention FSF could be unique because the significance of an unintentional radionuclide release depends on the magnitude of the release and the radionuclides released. The staff intends to clarify how findings that affect this FSF will be characterized in detailed inspection guidance and will seek further stakeholder engagement to ensure the significance of all findings reflect the risk to public health and safety if the deficiency were to proceed to plant operations.