ML24163A042

Arcop Ws 3 Exercise Participant Handout

ML24163A042
Person / Time
Issue date:	06/11/2024
From:	Office of Nuclear Reactor Regulation
To:
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Download: ML24163A042 (1)

Text

Advanced Reactor Construction Oversight Process (ARCOP)

Workshop #3 Draft Material for External Participants

1 Group activity - Example Scenario 1 (For demonstration purpose only)

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.

Screening Result:

Notes:

2 Group activity - Example Scenario 2 (For demonstration purpose only)

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.

Screening Result:

Notes:

3 Group activity - Example Scenario 3 (For demonstration purpose only)

While comparing 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.

Screening Result:

Notes:

4 Group activity - Example Scenario 4 (For demonstration purpose only)

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).

Screening Result:

Notes:

5 Group activity - Example Scenario 5 (For demonstration purpose only)

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.

Screening Result:

Notes:

6 Group activity - Example Scenario 6 (For demonstration purpose only)

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).

Screening Result:

Notes:

7 Group activity - Example Scenario 7 (For demonstration purpose only)

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.

Screening Result:

Notes:

8 Issue Screening Flowchart (DRAFT)

Issue of Potentially Y W illfulness is not covered Concern Involves in this workshop.

W illfulness?

N

Y Traditional enforcement in Non- Follow both Traditional Enforcement Path not covered in this Compliance? paths workshop

N

N

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

9 Minor/More-than-Minor Screening Flowchart (DRAFT)

Noncompliance with Self-identified Y Performance Construction The noncompliance is 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 Operational Readiness?

N

More than minor Y impact on Security or Safeguards?

N

The noncompliance is minor

10 Dispositioning Licensee Findings - Flowchart (DRAFT)

NRC- Identified or self-revealing 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 Y Noncited Green Noncited Violation Go to Finding? violation? (NCV)

next flowchart N N

Enter the Notice of SERP Process Violation (NOV) 11 Dispositioning Non-Licensee Findings Flowchart (DRAFT)

From the NRC- identified or Document as a Notice initial of Nonconformance Note: all screening self-revealing non- licensee (NON) to the manufacturer NONs flow chart finding manufacturer are assessed for potential follow-up inspection.

Enforcement Process

12 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..

13 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.

14 Significance Determination (DRAFT)

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. 15 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.

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