As documented in a January 5, 2012 memorandum, the NRC is conducting a Construction Reactor Oversight Process (cROP) assessment and enforcement pilot to apply the proposed new construction assessment and enforcement programs described in Commission paper SECY-10-0140, "Options for Revising the Construction Reactor Oversight Process Assessment Program." See an overview of the cROP and the new assessment and enforcement programs.
The pilot program will be a 12-month effort beginning on January 1, 2012 and will be conducted and evaluated in accordance with the guidance in the "Construction Reactor Oversight Process (cROP) Assessment and Enforcement Programs Pilot" document. Subsequent to the successful completion of the pilot program, pilot plants will continue under the new assessment and enforcement programs unless major changes to the proposed assessment and enforcement programs are needed. In that case, significant changes needed will be implemented following conclusion of the pilot for the subsequent assessment cycle.
The pilot will be conducted at Vogtle Electric Generating Plant Units 3 and 4 and Virgil C. Summer Units 2 and 3. The pilot will also be conducted at any additional plants for which a Limited Work Authorization and/or a Combined License have been issued and there is sufficient activity occurring for any assessment to be meaningful.
The staff developed the following draft IMC versions for use during the pilot:
- IMC 0613P - Power Reactor Construction Inspection Reports - Pilot
- IMC 2505P - Periodic Assessment of Construction Inspection Program Results - Pilot
- IMC 2519P - Construction Significance Determination Process - Pilot
The pilot plants will be inspected by the NRC under the risk-informed baseline construction inspection program described in IMC 2506, "Construction Reactor Oversight Process General Guidance and Basis Document". Inspection results will screened and documented in accordance with the guidance in IMC 0613P. The significance of findings will be determined using the construction significance determination process described in IMC 2519P. Performance will be assessed using the guidance in IMC 2505P. Enforcement actions will be taken in accordance with Enforcement Guidance Memorandum (EGM) 11-06, "Enforcement Actions Related to the Construction Reactor Oversight Process." Each unit at a construction site will be assessed separately based on the findings that are associated with the respective unit (note: similar to the Reactor Oversight Process (ROP), findings can be applicable to both units).
The pilot plants will be discussed as part of the April 2013 agency action review meeting (AARM) process. At the AARM screening meetings, the pilot plant performance review and discussion of agency action will be based on the inspection findings as applied to the construction action matrix in IMC 2505P. The guidance in IMC 2505P will be used to determine which pilot plants, if any, need to be discussed further at the AARM.
cROP Pilot Program Evaluation
In accordance with Commission direction, the staff developed new construction assessment and enforcement programs and tested the new programs during a pilot conducted during CY 2012 at Vogtle and Sumer. As part of the pilot program evaluation, the staff will be soliciting internal and external stakeholder feedback through surveys. The external survey, cROP External Stakeholder Survey (pdf or docx), will be conducted via a Federal Register Notice which will detail the feedback process and include the survey developed to solicit external feedback. The staff will use a similar survey to solicit internal feedback. The result of the cROP pilot program including comments received from the surveys were discussed with the ACRS on February 7, 2013. In April 2013, the staff plans to issue a cROP self-assessment Commission paper including a summary of the pilot program results and recommendations for its improvement.