ML25226A119

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Arcop Workshop 6 Presentation 8/26/25
ML25226A119
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NRC Advanced Reactor Construction Oversight Program (ARCOP) 1 Vogtle Units 1-4 Photo Credit: Georgia Power ARCOP Stakeholder Workshop Series Presentation ADAMS Accession #: ML25226A119

2 Jonathan Greives, Director Division of Advanced Reactors and Non-power Production and Utilization Facilities (DANU)

Office of Nuclear Reactor Regulation (NRR)

Welcome

Advanced Reactor Construction Oversight DRAFT Guidance DRAFT INSPECTION MANUAL CHAPTERS (IMCs) 3 ARCOP Workshop #6

4 ARCOP Workshop #6 NRC Staff

5 Workshop #6 Agenda

1. Recap of Previous Workshops
2. Draft Inspection Manual Chapter Content

6 Previous Workshops

  • Session 1: Introduction to ARCOP, and the ARCOP Framework (2/28/24 & 3/20/24) (ML24078A063)

(5/22/24) (ML24177A120)

  • Session 5: Quality Assurance Program (QAP) Programmatic Inspections and Assessing Safety Culture (12/10/24) (ML25002A037)

7 ARCOP Framework Quality of Reactor Plant Construction Security and Safeguards Operational Readiness Operational Programs Public Health and Safety Associated with Future Nuclear Reactor Operation Heat Removal FSF*

Radionuclide Retention FSF*

Security Programs Reactivity Control FSF*

NRC Mission Strategic Performance Areas Cornerstones of Safety

  • Fundamental Safety Function (FSF)

8

  • IMC 2573, INSPECTION OF THE ADVANCED POWER REACTOR QUALITY OF REACTOR PLANT CONSTRUCTION STRATEGIC PERFORMANCE AREA ML25210A581
  • IMC 2574, INSPECTION OF THE ADVANCED POWER REACTOR OPERATIONAL READINESS STRATEGIC PERFORMANCE AREA ML25210A582 Draft ARCOP IMCs

9

  • IMC 2571, DISPOSITIONING ADVANCED POWER REACTOR CONSTRUCTION NONCOMPLIANCES
  • IMC 2572, ASSESSMENT PROGRAM FOR ADVANCED REACTOR CONSTRUCTION PROJECTS
  • IMC 2573, INSPECTION OF THE ADVANCED POWER REACTOR QUALITY OF REACTOR PLANT CONSTRUCTION STRATEGIC PERFORMANCE AREA
  • IMC 2574, INSPECTION OF THE ADVANCED POWER REACTOR OPERATIONAL READINESS STRATEGIC PERFORMANCE AREA Draft ARCOP IMCs

10

- Defines ARCOP terms

- Provides short history of NRC advanced reactor activities

- Describes the ARCOP framework

- Describes the elements of NRC Oversight (Performance Monitoring, Dispositioning Noncompliances, Performance Assessment)

IMC 2570 Contents

11 New NRC oversight terms used in ARCOP include:

1. Advanced Reactor - includes all microreactors, small module reactors, and large LWRs with advanced or inherent safety features (e.g., AP-1000).
2. Project Vendor - a non-licensed facility that fabricates nearly complete reactor plants, or significant parts of safety-significant system modules.
3. Audit - a program review (operational or security) prior to its implementation.

Note: a program review after its implementation is an inspection.

4. Inspection Scoping Matrix - Defines the baseline inspection scope for each construction project.

IMC 2570 Contents

12 New ARCOP Definitions (cont):

5. QAP Backstop - a planned activity meant to detect deficiencies associated with a finding.
6. Self-identified Construction Noncompliance (SCN) - self-identified noncompliances that are corrected (or in process of correction) per the QAP procedures without NRC intervention.
7. Finding Response Table - a table that determines NRC actions and expected licensee actions for NRC enforcement actions.

IMC 2570 Contents

13 IMC 2570 Contents - ARCOP Overview

14

  • IMC 2571, DISPOSITIONING ADVANCED POWER REACTOR CONSTRUCTION NONCOMPLIANCES
  • IMC 2572, ASSESSMENT PROGRAM FOR ADVANCED REACTOR CONSTRUCTION PROJECTS
  • IMC 2573, INSPECTION OF THE ADVANCED POWER REACTOR QUALITY OF REACTOR PLANT CONSTRUCTION STRATEGIC PERFORMANCE AREA
  • IMC 2574, INSPECTION OF THE ADVANCED POWER REACTOR OPERATIONAL READINESS STRATEGIC PERFORMANCE AREA IMC Contents

15 IMC 2571 Contents

  • Initial screening of Noncompliances
  • Minor/MTM Criteria
  • Guidance for use of different enforcement mechanisms (i.e., finding dispositioning)
  • Significance and Enforcement Review Panel (SERP) guidance

16 IMC 2571 - Initial Screening

17 IMC 2571 - Minor/MTM Criteria

18

1. Does the noncompliance prevent a safety-significant SSC from performing its safety-significant function or make its functionality indeterminate?
2. Does the noncompliance prevent meeting an ITAAC acceptance criterion, and does the noncompliance prevent a safety-significant SSC from performing its safety-significant function, or make its functionality indeterminate?
3. Does the noncompliance invalidate the results of an Inspection, Test, or Analysis described in an ITAAC? (this applies to previously completed ITAAC)

IMC 2571 - Minor/MTM Criteria for SSCs

19 Yellow The finding, if left uncorrected, would result in the inability to fulfill multiple FSFs1.

Or The findings significance cannot be adequately screened using other criteria in this table and has screened as Yellow using Attachment 62.

White The finding, if left uncorrected, would result in the inability to fulfill one FSF1 Or The findings significance cannot be adequately screened using other criteria in this table and has screened as White using Attachment 62.

Green

a. The finding, if left uncorrected, would result in the loss of safety-significant functions of one or more SSCs, but all FSFs are fulfilled; 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
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 only; or
e. The findings significance cannot be adequately screened using other criteria in this table and has screened as Green using Attachment 62 IMC 2571 - ARCOP SSC Finding Significance Determination

20

  • IMC 2571, DISPOSITIONING ADVANCED POWER REACTOR CONSTRUCTION NONCOMPLIANCES
  • IMC 2572, ASSESSMENT PROGRAM FOR ADVANCED REACTOR CONSTRUCTION PROJECTS
  • IMC 2573, INSPECTION OF THE ADVANCED POWER REACTOR QUALITY OF REACTOR PLANT CONSTRUCTION STRATEGIC PERFORMANCE AREA
  • IMC 2574, INSPECTION OF THE ADVANCED POWER REACTOR OPERATIONAL READINESS STRATEGIC PERFORMANCE AREA IMC Contents

21 IMC 2572 Contents

  • 3 types of ARCOP assessments
1. Continuous assessment
2. Escalated enforcement finding assessment
3. Final assessment prior to operations

22 ARCOP Assessment

23 Finding Response Table RESULTS GREEN INSPECTION FINDING WHITE INSPECTION FINDING YELLOW INSPECTION FINDING

RESPONSE

APPLIED TO EACH FINDING Regulatory Engagement Meeting None Branch chief or division director Regional Administrator or designee meets with senior management Recipient Response Corrective Action Program Causal evaluation and corrective actions NRC Response Baseline Inspection Supplemental Inspection Evaluation for additional baseline inspection(s) in area(s) of concern COMMUNICATIONS Inspection Report Posted on Public Website Branch Chief review and signature Division Director review and signature Regional Administrator review and signature

24

  • IMC 2571, DISPOSITIONING ADVANCED POWER REACTOR CONSTRUCTION NONCOMPLIANCES
  • IMC 2572, ASSESSMENT PROGRAM FOR ADVANCED REACTOR CONSTRUCTION PROJECTS
  • IMC 2573, INSPECTION OF THE ADVANCED POWER REACTOR QUALITY OF REACTOR PLANT CONSTRUCTION STRATEGIC PERFORMANCE AREA
  • IMC 2574, INSPECTION OF THE ADVANCED POWER REACTOR OPERATIONAL READINESS STRATEGIC PERFORMANCE AREA IMC Contents

25 IMC 2573 Contents

  • Guidance for developing design-specific and project-specific scoping baseline inspections.
  • Nth-of-a-kind (NOAK) vs. first-of-a-kind (FOAK) reactor inspection scoping

26 IMC 2573 Contents SSC(s)

Fundamental Safety Function1 Design Risk Characterization (RID)

Construction Risk Characterization (RIC)

Reactor Plant System Safety Class2 Individual Columns for each Inspection Area applicable to the Adv. Reactor Design3, Location Factory (F)

Site (S)

Both (FS)

(RC) (HR) (RR)

(H)

(M)

(L)

Basis (H)

(M)

(L)

Basis INSPECTION PROCEDURES4 75001 and 75001.XX MINIMUM INSPECTION SAMPLES5 MAXIMUM INSPECTION SAMPLES5 Generic Design-Specific Matrix

27 ARCOP Inspection Scope Scalability 0

5000 10000 15000 20000 25000 Microreactor Test Reactor SMR 1 SMR 2 SMR 3 AP1000 (ARCOP)

Vogtle 3 (cROP)

Reactor Designs Inspection Scope Efficiency gains from cROP Lessons Learned Efficiency gains from ARCOP Methodology Vogtle 3 - cROP

28 IMC 2573 Inspection Scope Scalability - NOAK Onsite Construction Considerations (FOAK to NOAK)

- Unit specific baseline inspection program adjustments will be made based on oversight experience.

- Adjustments will be implemented via the project-specific scoping matrix.

Manufacturer Considerations (FOAK to NOAK)

- Project specific inspection scoping adjustments will be made via project-specific scoping matrix for first units.

- Time-based inspection baseline will be implemented when manufacturer demonstrates consistent quality.

29 Discussion

30

  • IMC 2571, DISPOSITIONING ADVANCED POWER REACTOR CONSTRUCTION NONCOMPLIANCES
  • IMC 2572, ASSESSMENT PROGRAM FOR ADVANCED REACTOR CONSTRUCTION PROJECTS
  • IMC 2573, INSPECTION OF THE ADVANCED POWER REACTOR QUALITY OF REACTOR PLANT CONSTRUCTION STRATEGIC PERFORMANCE AREA
  • IMC 2574, INSPECTION OF THE ADVANCED POWER REACTOR OPERATIONAL READINESS STRATEGIC PERFORMANCE AREA IMC Contents

31 IMC 2574 - Content

  • Discusses Program Audits vs. Program Inspections under ARCOP
  • Provides guidance for developing site-specific operational readiness inspection and audit plans.
  • Describes RIPB program audit and inspection scoping.

32 IMC 2574 - Content ARCOP Program Audits vs. Program Inspections Audits: - NRC reviews of programs prior to the program implementation.

- NRC enforcement does not apply to audits.

- Audit reports will contain observations.

- Failure to address significant weaknesses identified in audits may impact a projects transition to operations.

Inspections:-

NRC reviews of programs after program implementation.

- NRC enforcement applies.

- Inspection reports may contain violations.

- Significant violations may impact a projects transition to operations until they are resolved/closed.

33 Operational Program Oversight Efficiency Gains

1. Elimination of redundant inspections - SSC qualification programs will be inspected as part of regular SSC vertical slice inspections.

Examples: PSI/ISI, PST/IST, EQ, RV material surveillance, CLRT, MOV

2. RIPB scoping methodology for other programs.

34 Operational Program Inspection and Audit Scoping Can the NRC be reasonably assured of safety (Risk-Informed) without evaluating the OP during construction?

Consider not performing an inspection or audit of the OP during construction Is there a performance-based inspection or audit opportunity during construction?

If risk supports, consider not performing an inspection or audit of the OP during construction Consider lessons learned from past performance and perform an inspection or audit of the OP during construction.

No Yes Yes No

Future IMC 2203 Advanced Reactor Security Program Oversight 33 Project-Specific Scoping Licensing basis serves as the foundation for audits and inspections to ensure they align with regulatory requirements (Part 50, 52, or 53) and commitments establish ed during the licensing process.

Risk-Informed Audit and inspection samples are reviewed based on security significance to focus resources on areas that pose greatest potential risk to public health and safety, and to identify where additional resources may be warranted.

Performance-Based Inspectors have flexibility to adjust sample size based on performance.

Co-located units and fleetwide programs will have the opportunity to also receive credit for samples and flexibility to adjust audit size based on performance.

36 Path Forward

  • Finalize IMCs 2570 thru 2574 and associated IPs.
  • Finalize IMC 2203, Security Inspection Program for Advanced Power Reactor Construction.
  • Develop ARCOP IMC for inspection report content (in progress in conjunction with AIMS development)
  • Develop ARCOP inspection procedures (in progress).
  • Continue to coordinate with current applicants to develop project-specific inspection scoping.

37 Discussion

38 End of Workshop Points of Contact Jon Greives, Director Office of Nuclear Reactor Regulation (NRR)

Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU)

Jonathan.Greives@NRC.GOV Mike Wentzel, Chief NRR/DANU/Advanced Reactor Policy Branch (UARP)

Michael.Wentzel@NRC.GOV Phil OBryan, ARCOP Project Lead Engineer NRR/DANU/UARP Phil.OBryan@NRC.GOV

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