Construction Reactor Oversight Process (cROP)
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Process Description
Overview - The cROP is described in detail in IMC 2506, "Construction Reactor Oversight Process General Guidance and Basis Document," and at the Detailed cROP Description page. The cROP is implemented when an applicant announces its intent to submit an application pursuant to Part 52 for an early site permit (ESP), a limited work authorization (LWA), and/or a combined construction permit and operating license (COL). The cROP will remain in effect until regulatory oversight for the plant is transitioned to the Reactor Oversight Process (ROP).
The degree to which the cROP is implemented depends on the application/license status and the amount of ongoing activities that are associated with applications/licenses. For instance, only inspections pursuant to IMC 2501, "Construction Inspection Program: Early Site Permit (ESP)," may be necessary in the case where an applicant only requests an ESP. On the other hand, if the NRC issues a COL, and there is sufficient activity occurring, all aspects of the cROP will be implemented.
In developing the cROP, many aspects of the ROP, such as the inspection program, assessment process, and enforcement policy were considered. Elements of the cROP include developing and maintaining programs in the areas of: construction inspection, construction assessment, enforcement, allegations, construction experience, inspections, tests, analyses, and acceptance criteria (ITAAC) closure verification, vendor inspection, and the transition to operations. Coordination of these activities requires that the cROP also consider the ability of the NRC to effectively plan and schedule the conduct of these activities by having sufficient resources available when needed (planning and budgeting).
A description of the construction assessment program was provided to the Commission in SECY-08-0155, "Update on the Development of the Construction Inspection Program for New Reactor Construction under 10 CFR Part 52," dated October 17, 2008. On December 5, 2008, the Commission issued SRM M081022, which directed the staff to reconsider the construction assessment process as presented in IMC 2505 and propose policy options to the Commission. The Commission further directed that the staff proposal should address the inclusion in the construction oversight process of objective elements such as construction program performance indicators (PIs) and significance determination processes (SDPs) analogous to those used in the ROP.
In response to SRM M081022, NRO, other program offices, and the regional offices formed an interoffice working group to develop construction assessment program options for Commission consideration, which were documented in Commission Paper SECY-2010-0140, "Options For Revising The Construction Reactor Oversight Process Assessment Program." In SRM-SECY-10-0140, the Commission approved the staff's recommended option to develop a construction assessment program that includes a regulatory framework, the use of a construction significance determination process (SDP) to determine the significance of findings identified during the construction inspection program (CIP), and the use of a construction action matrix (CAM) to determine the appropriate NRC response to findings.
The staff developed a new cROP assessment program as directed by the Commission and began a yearlong pilot of the program at Vogtle Units 3 and 4 on January 1, 2012 and Summer Units 2 and 3 on March 30, 2012. As part of the new assessment program, the NRC transitioned to an annual assessment cycle. The annual assessment cycle consists of a mid-cycle review for the period of January 1, 2012 through June 30, 2012, and an end-of-cycle review for the period of January 1, 2012 through December 31, 2012.
Inputs to the Assessment Process - The NRC evaluates plant performance by analyzing inspection findings resulting from NRC's inspection program. After a violation is identified, the NRC assesses its significance. In the initial assessment and enforcement programs, severity levels were assigned to violations which generally reflected the assessment of the significance of a violation. During the pilot of the new assessment program, the construction significance determination process will be used to assign significance to findings.
NRC Inspection Findings for each plant are documented in inspection reports in accordance with IMC 0613, "Documenting 10 CFR Part 52 Construction and Test Inspections." In addition to determining the significance of each inspection finding, the NRC will also consider the underlying weaknesses in areas important to safety culture by assigning a construction cross-cutting aspect to a finding if warranted. A construction substantive cross-cutting issue (cSCCI) will be associated with multiple findings that have the same cross-cutting component aspect. The NRC will use cSCCIs to communicate to the licensee weaknesses identified in a construction site safety culture. It will be expected that licensees evaluate the findings in these areas to identify the cause(s) for the weakness and implement appropriate actions to improve the construction site performance.
NRC Response to Plant Performance - In the initial assessment program, the NRC assessed plant performance continuously, and communicated its assessment of plant performance in semi-annual performance review (SPR) assessment letters to licensees. The SPR assessment letters contained a proposed inspection plan for the next six months of construction. The SPR assessment letters are posted on this web site as they become available. More detailed information on the NRC's assessment process is available in IMC 2505, "Periodic Assessment of Construction Inspection Program Results." In the new assessment process, the NRC communicates performance results in mid-cycle and end-of-cycle review letters to the licensees.
The NRC determines its regulatory response in accordance with a Construction Action Matrix that provides for a range of actions commensurate with the significance of the inspection results. The Construction Action Matrix is intended to provide consistent, predictable, understandable agency responses to licensee performance. The actions of the matrix are graded such that the NRC becomes more engaged as licensee performance declines. One basic tenet of the cROP was that a licensee's corrective action program should be relied upon to correct identified issues that do not result in exceeding a performance threshold. So for a plant that has all of its inspection findings characterized as green, the NRC will implement its baseline inspection program, typically consisting of approximately 30,000 hours over the course of the construction project. For plants that have finding(s) greater than green or an cSCCI, the NRC will perform additional inspections beyond the baseline program and initiate other actions commensurate with the safety significance of the issues.
Construction Action Matrix Deviations. IMC 2505 recognizes that there may be rare instances in which the regulatory actions dictated by the Construction Action Matrix may not be appropriate. In these instances, the Agency may deviate from the Construction Action Matrix to either increase or decrease Agency action when approved by the Executive Director for Operations. The Construction Action Matrix Deviations page provides a listing of Construction Action Matrix deviations.
Plant Assessment & Results
Individual Plant Performance Summaries - Performance information is summarized for each plant and sorted by the six cornerstones of safety. This information can be viewed by selecting the plant name below. For each plant, the current Construction Action Matrix designation is displayed along with a summary of NRC inspection findings. Links are also provided to NRC assessment letters, inspection plans, and inspection reports.
Performance Summaries - Based on the latest applicable inspection findings, the current Construction Action Matrix designation for each plant is available in the Construction Action Matrix Summary. The Construction Action Matrix Summary provides a matrix of the four columns with the plants listed within their applicable column. In addition, the List of Construction Inspection Reports includes links to all NRC reports documenting cROP-related inspection results and the List of Construction Assessment Reports and Inspection Plans includes links to all NRC performance assessment reports and associated inspection plans for the next six months. Finally, the Construction Substantive Cross Cutting Issues Summary page lists the plants that have an open construction substantive cross cutting issue.
Historical Performance - Historical snapshots of plant construction performance from previous quarters as displayed on the web since the inception of the cROP are also available on the cROP Historical Performance from Previous Quarters page. These include pdf files of the construction action matrix summary and the cSCCI summary for all plants that are under construction.
Program Evaluations and Stakeholder Feedback - The NRC staff plans to conduct annual cROP self-assessments. The initial cROP self-assessment was completed for calendar year 2011 and was documented in SECY 12-0059, "Construction Reactor Oversight Process Self-Assessment for Calendar Year 2011," dated April 16, 2012. As part of the self-assessment program, the staff plans to obtain external stakeholder input regarding cROP effectiveness, and to conduct internal surveys to solicit and analyze stakeholder feedback from NRC staff.
Watts Bar Unit 2 Oversight - The NRC is conducting additional oversight inspections of the reactivation of Watts Bar Unit 2. Until the unit fully transitions under the Reactor Oversight Process (ROP), information regarding this multi-year project can be accessed at Watts Bar Unit 2 Reactivation.
