ML070390289
| ML070390289 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/2007 |
| From: | William Reckley NRC/NRO/DNRL/NGIF |
| To: | |
| References | |
| DG-1145, RG-1.206 | |
| Download: ML070390289 (18) | |
Text
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 COMMENT DG SECTION RELATED COMMENT RECOMMENDED WORDING DG-1145 DISPOSTION NO. NRC ID NO.
C.II.2.1 C.II.2.1 C.II.2.1 states in a table provided in FSAR Section 14.3, COL This FSAR section 14.3 guidance aceept the com m ent applicants should cross-reference the im portant design should be included in C.I.14 and inform ation and param eters from these analyses to their treatm ent in C.III.1-14.3.
(i.e., inclusion or exclusion) in the ITAAC.
C.II.2.2 C.II.2.1 New nuclear power plants likely will be constructed through the Modify the seventh paragraph of disagree - although som e com ponents m ay be use of m odular construction techniques. Since construction this section to indicate that ITAAC m anufactured offsite, the as-bulit configuration m odules m ay be constructed offsite, it m ay be appropriate for testing m ay include testing of will follow installation at the site. Inspections or som e ITAAC to be perform ed at the site of m anufacturing of the construction m odules at the tests perform ed at the vendor m ay be construction modules rather than the reactor site. vendors shop. This testing incorporated into ITAAC but would not be should be distinguished from considered the final as-built condition to be type tests, in that type tests are used to close an ITAAC not necessarily perform ed on the com ponents to be installed in the plant, whereas tests of construction m odules would be for the m odules that will actually be installed in the plant.
C.II.2.3 C.II.2.2 The 10th paragraph says that ITAAC should not reference the Modify the 3d sentence in the 10th paragraph as follows: Except in the case COLA, while the 3d paragraph says ITAAC should reference the where no design certification is referenced and no separate ITAAC design FSAR portion of the COLA. descriptions are developed, the ITAAC should not reference the [COLA]....
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.4 C.II.2.3 As indicated earlier in DG-1145, ITAAC should be reserved for Delete bullet #1 to "Carefully no change - bullet is to consider, understood top-level design inform ation that pertains to the principal consider design-specific and that not all new item s are ITAAC - criteria is perform ance characteristics and safety functions of the SSCs. A unique features of the facility for sam e in term s of developing ITAAC design feature m ay be site-specific and unique, and yet have little inclusion in ITAAC.
or no safety function. A design feature does not warrant greater consideration for inclusion in an ITAAC, m erely because it is unique or site-specific.
C.II.2.5 C.II.2.1 As indicated earlier in DG-1145, ITAAC should be reserved for Delete Bullet #3 to Ensure that no change - bullet is to consider, understood Bullets top-level design inform ation that pertains to the principal ITAAC reflect the resolutions of that not all item s related to generic issues perform ance characteristics and safety functions of the SSCs. technically relevant USIs/GSIs, would be ITAAC - criteria is sam e in term s of Not all resolutions of USIs/GSIs, NRC bulletins and generic NRC generic correspondence developing ITAAC letters, and operating experience rise to that level. For certain such as bulletins and generic designs, the resolution of a particular generic issue m ay have little letters; and relevant industry or no safety significance. Therefore, sim ilar to other inform ation, operating experience.
the determ ination which resolutions should be included in ITAAC In the alternative, m odify the should be based upon a graded approach, depending upon the language to refer to safety significance of the resolution to safety. significant resolutions rather than resolutions of technically relevant
[issues]
C.II.2.6 C.II.2.1 Typo Last bullet should m odified as no change - SSC m aintained to capture Bullets follows System s SSCs for which system s and structures there is no discernable C.II.2.7 C.II.2.1.1 New nuclear power plants likely will be constructed through the Modify the definition of as-built No change - see com m ent 2 use of m odular construction techniques. Since construction to include construction m odules m ay be constructed offsite, it m ay be appropriate for SSCs/m odules at the vendors som e ITAAC to be perform ed at the site of m anufacturing of the shop that are intended for construction m odules rather than the reactor site. installation at the reactor in question.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.8 C.II.2.1.1 The definition of Design Description includes an inaccurate In the definition of Design accept - delete definition for design description description of Tier 1. Tier 1 is not intended to sum m arize the Description, delete the last FSAR. Instead, as indicated in Section C.II.2.1 of DG-1145, Tier 1 sentence, which states that Tier 1 is the top-level design inform ation from the FSAR. inform ation is a sum m ation of the detailed design inform ation in the FSAR.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.9 C.II.2.1.1 The term "Design Description" is not needed and should be Define a single term , ITAAC accept - delete definition for design description deleted. The use and definition of the two sim ilar term s, Design Design Description, to m ean the Description and ITAAC Design Description, are confusing and equivalent of Tier 1 Design problem atic. Design Description is a term that is com m only Description when no design used in both ITAAC and non-ITAAC contexts. It m ay be helpful to certification is referenced, and define the term "Tier 1 Design Description." provide two alternatives for presenting ITAAC Design Description in COLAs, as follows:
ITAAC Design Description for a COL application that does not reference a design certification m eans the top level design inform ation that pertains to the principal perform ance characteristics and safety functions of SSCs. This inform ation is equivalent to Tier 1 Design Description for certified designs (see appendices to 10 CFR Part 52 for definitions associated with certified designs).
COL applicants m ay choose to provide ITAAC Design Description in a docum ent separate from the FSAR or directly in the FSAR. ITAAC Design Description m ay, at a m inim um , consist only of tables and figures that are referenced in the ITAAC.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.9 C.II.2.1.1 W hether presented in a separate docum ent or included in the FSAR, ITAAC (cont'd) Design Description is the proper term to describe the top-level design inform ation referenced in ITAAC when a certified design is not referenced.
C.II.2.10 C.II.2.1.1 Clarify definition of Design Requirem ent/Com m itm ent. Modify the 1 st sentence of the disagree - keep language "portion of detailed.."
definition as follows: "Design but deleted second sentence Requirem ent/Com m itm ent m eans the specific that portion of the detailed design inform ation provided in the COL application that is verified by ITAAC."
C.II.2.11 C.II.2.1.1 As literally worded, the definition of Exists would require an SSC Change the definition of Exists accept - deleted definition of exists to satisfy all of the provisions in the FSAR (without regard to to state as follows: Exists safety significance). The wording should be changed to indicate m eans that the item is present that the SSC m ust satisfy the Design Requirem ent/Com m itm ent in and m eets the Design the ITAAC, which will identify the top-level design inform ation Requirem ent/Com m itm ent.
applicable to the SSC.
C.II.2.12 C.II.2.1.1 As literally worded, the definition of Functional Arrangem ent would Change the definition of partially accept - changed definition to be require a system to satisfy all of the design descriptions in the Functional Arrangem ent to delete ....described in the ITAAC design description FSAR (without regard to safety significance). The wording should the reference to system design and as shown in the figures be changed to indicate that the system m ust satisfy the Design description and instead refer to Requirem ent/Com m itm ent in the ITAAC, which will identify the the Design top-level design inform ation applicable to the system . Requirem ent/Com m itm ent.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.13 C.II.2.1.1 The definition of ITAAC should m ore closely track the language in Change the definition of ITAAC to accept - deleted definition of ITAAC proposed 10 CFR 52.80. state as follows: ITAAC m eans the inspections, tests, and analyses, including those applicable to em ergency planning, that the licensee shall perform , and the acceptance criteria which are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are perform ed and the acceptance criteria m et, the facility has been constructed and will operate in conform ity with the com bined license, the provisions of the Atom ic Energy Act, and the NRCs regulations.
C.II.2.14 C.II.2.1.1 As literally worded, the definition of Physical Arrangem ent would Change the definition of Physical partially accept - changed definition to be require a structure to satisfy all of the design descriptions in the Arrangem ent to delete the ....described in the ITAAC design description FSAR (without regard to safety significance). The wording should reference to design description and as shown in the figures be changed to indicate that the structure m ust satisfy the Design and instead refer to the Design Requirem ent/Com m itm ent in the ITAAC, which will identify the Requirem ent/Com m itm ent.
top-level design inform ation applicable to the structure.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.15 C.II.2.2.2 GDC 1 pertains to quality assurance (QA). As the NRC has long Delete Bullet (20) codes and partially accept - deleted reference to GDC 1 recognized, ITAAC are not needed or appropriate for the QA standards (GDC 1). but kept listed item of codes and standards (as they relate to verifying as-built conform s to Additionally, with respect to codes and standards, not all codes W hy do these bullets start from applicable codes and standards) and standards are sufficiently im portant to rise to the level of top (13)?
level design inform ation. Therefore, it is not appropriate in general to have ITAAC that verify im plem entation of codes and standards in general.
C.II.2.16 C.II.2.2.2 The 2 nd bullet under the heading Pressure Boundary Integrity Modify the second bullet to insert accept should be changed to be consistent with the ITAAC for the the words for welds after NDE.
existing design certifications and clarifies the scope of the NDE to be perform ed under the ITAAC.
C.II.2.17 C.II.2.2.2 Determ ining load com binations is a detailed design function and is Delete the first bullet under the partially accept - language to reflect that not appropriate for inclusion in the ITAAC. Instead, ITAAC should heading Norm al Loads, which reconcilation of as-built to design will verify focus on verification of the adequacy of the as-built plant (which states that ITAAC should verify norm al and accident loads.....
occurs through the other bullets under the heading Norm al Loads, that norm al and accident loads pertaining to as-built stress reconciliation reports). have been appropriately com bined.
C.II.2.18 C.II.2.2.2 The 3d bullet under the heading Norm al Loads should be changed Modify the third bullet to refer to accept to clarify that the ITAAC in question pertain to ASME stress ASME Code-required stress reports, not all ASME reports. reports.
C.II.2.19 C.II.2.2.2 Determ ining load com binations is a detailed design function and is Under the heading Seism ic partially accept - language to reflect that not appropriate for inclusion in the ITAAC. Instead, ITAAC should Loads, delete the first bullet, reconcilation of as-built to design will verify focus on verification of the adequacy of the as-built plant (which which states that ITAAC should seism ic loads.....
occurs through the other bullets under the heading Seism ic Loads verify that structures and system s pertaining to as-built stress reconciliation reports). have been designed for seism ic loads.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.20 C.II.2.2, This section contains num erous statem ents sim ilar to COL This section should be revised to disagree - reconcilation to ensure as-built to Sec. 14.3.2 applicants should provide ITAAC to reconcile the as-built plant rem ove all statem ents that im ply design basis. Reconciliation m ay involve with the structural design basis. Reconciliation between as-built a requirem ent for as-built various levels of effort but will ultim ately verify configuration and structural analysis is neither perform ed nor reconciliation with analysis and as-built to design.
required unless there is a deviation from the design drawings used replace it with reconciliation of as-in the analysis. As-built configurations are checked against built configuration with design design drawings to verify com pliance with the design basis. There drawings.
is no regulatory basis for this requirem ent and it is not consistent with precedent (none of the existing certified designs have these ITAAC). This com m ent is also applicable to draft SRP Section 14.3.2.
C.II.2.21 C.II.2.2.2 The 4 th bullet under the heading Seism ic Loads, should be Modify the fourth bullet to refer to accept changed to clarify that the ITAAC in question pertain to ASME ASME Code-required stress stress reports, not all ASME reports. reports.
C.II.2.22 C.II.2.2.2 Under the heading Seism ic Loads, to the extent that the 6th bullet Under the heading Seism ic accept (addressed by next bullet in list) is intended to refer to safety-related buildings, the ITAAC is Loads, delete the sixth bullet inappropriate because safety-related buildings are designed to related to the collapse of withstand seism ic events without collapse. buildings.
To the extent that this bullet is intended to refer to non-safety-related buildings, the subject is addressed by the seventh bullet and is therefore redundant.
C.II.2.23 C.II.2.2.2 Determ ining load com binations is a detailed design function and is Under the heading related to the disagree - reconcilation to ensure as-built to not appropriate for inclusion in the ITAAC. Instead, ITAAC should Suppression Pool, delete the first design basis. Reconciliation m ay involve focus on verification of the adequacy of the as-built plant (which bullet, which states that ITAAC various levels of effort but will ultim ately verify occurs through the other bullets under the heading related to the should verify that structures and as-built to design.
Suppression Pool pertaining to as-built stress reconciliation system s have been designed for reports). hydrodynam ic loads.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.24 C.II.2.2.2 The 4 th bullet under the heading related to the Suppression Pool Modify the fourth bullet to refer to accept should be changed to clarify that the ITAAC in question pertain to ASME Code-required stress ASME stress reports, not all ASME reports. reports.
C.II.2.25 C.II.2.2.2 Determ ining load is a detailed design function and is not Under the heading Flood, W ind, disagree - reconcilation to ensure as-built to appropriate for inclusion in the ITAAC. Instead, ITAAC should etc, delete the first bullet which design basis. Reconciliation m ay involve focus on verification of the adequacy of the as-built plant (which states that ITAAC should verify various levels of effort but will ultim ately verify occurs through the other bullets under the heading Flood, W ind, that structures and system s have as-built to design.
etc., pertaining to as-built stress reconciliation reports). been designed for natural phenom ena loads.
C.II.2.26 C.II.2.2.2 The 3d bullet under the heading Pipe Break m akes no sense as Delete the third bullet related to accept - changed to RCS written. RPVs are not postulated to experience LOCAs. Perhaps reactor pressure vessel (RPV) the reference to RPVs should be to the reactor coolant pressure LOCA analysis.
boundary, or reactor coolant system .
C.II.2.27 C.II.2.2.2 This topic of Codes and Standards is redundant of the bullets Delete the heading and bullet disagree - part of verification will also ensure under the other headings and therefore should be deleted. related to Codes and Standards. required docum entation of applicable codes and standards C.II.2.28 C.II.2.2.2 This topic of As-Built Reconciliation is redundant of the bullets Delete the heading and bullets disagree - section and bullets m aintained under the other headings and therefore should be deleted. related to As-Built Reconciliation.
C.II.2.29 C.II.2.2.2 Consistent with the practice for the ITAAC for the existing design Add a paragraph at the end of accept - will add paragraph that an inspection certifications, a single ITAAC m ay address the as-built stress this section to state that ITAAC can address m ore than one topic - also that reconciliation for all loads applicable to a system , rather than for the various topics discussed in ITAAC to be developed to support construction having a separate ITAAC for each load. this section m ay be com bined into activities/schedules such that applicants m ay one or m ore ITAAC, and that a propose m ultiple ITAAC for som e item s separate ITAAC is not needed for each topic.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.30 C.II.2.2.3 As a general rule, ITAAC are not intended to, and are not Modify the statem ent preceding The ITAAC should verify that the piping appropriate for, verification of classifications. Instead, ITAAC are the second series of bullets in this com ponents and system s have been fabricated intended to verify that the as-built plant has certain design section to delete reference to in accordance with the proper Code class features and functions. verifying piping and com ponent requirem ents. Code classification is part of the "classification." initial design certification. The ITAAC m erely confirm s that fabricated com ponents m eets its classification. (P. Higgins, SPW B)
C.II.2.31 C.II.2.2.3 It will not always be possible to sim ulate design basis conditions in Modify the last bullet of this Modify the last bullet of this section to indicate the plant. Therefore, in som e cases, it will be necessary to section to indicate that the that the capability of installed pum ps, valves, perform an analysis that extrapolates the results of tests at actual capability of installed MOVs at and dynam ic restraints at design basis conditions to determ ine whether the MOVs will be able to perform design basis conditions should be conditions should be verified by in-situ testing their functions at design basis conditions. verify by in-situ testing and and functional design and qualification records.
analysis. (T. Scarbrough, CPTB)
C.II.2.32 C.II.2.2.3, This section requires as-built analyses to be perform ed. See This section should be revised to ITAAC should be developed to require the Sec. 14.3.3 above com m ent on C.II.2.2.2, Section 14.3.2 concerning as-built rem ove all statem ents that existence of a report, which docum ents the reconciliation. As-built reconciliation is perform ed by confirm ation stipulate the structural analyses results of an as-built reconciliation confirm ing that the as-built configuration conform s to the design drawings. have to be revised to verify as- that the piping system s have been built in Structural analyses are only revised if necessary to reconcile built configuration. The bullet on accordance with the ASME Code Certified deviations that are identified. If the design uses LBB m ethods LBB reconciliation should be stress report. (P. Higgins, SPW B) there should be an ITAAC developed to require that a report exists revised to reflect that the only and concludes that the m aterial properties in the certified m aterial input needed is the certified test reports are consistent with the m aterial properties assum ed in m aterial test reports.
the LBB analysis.
C.II.2.33 C.II.2.2.4 As a general rule, ITAAC are not intended to, and are not Delete Item # 2 under the last The NRC staff does not agree. The ITAAC are appropriate for, verification of classifications. Instead, ITAAC are bullet, which indicates that ITAAC itended not only to verify that the as-built plant intended to verify that the as-built plant has certain design should be developed to verify has certain design features and functions, but features and functions. seism ic and code classification. also to verify that the as-built features, structures, system s, and com ponents m eet the seism ic and ASME code classifification.
Therefore, Item #2 should be retained. (P.
Higgins, SPW B)
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.34 C.II.2.2.4 Item # 9 under the last bullet is too vague to be m eaningful. Not Delete Item # 9 under the last The NRC staff agrees that Tier 1 inform ation all num eric perform ance values need to be verified. Instead, only bullet, which states that ITAAC should include top level design features and the top-level perform ance values need to be verified. should verify num eric perform ance standards. Rather than deleting perform ance values. Item #9 as recom m ended, the last bullet will be revised for clarification as the following: "ITAAC should be developed to verify the top level design aspects of reactor system s listed below:" (P. Higgins, SPW B)
C.II.2.35 C.II.2.2.5 Som e of the topics listed do not relate to the as-built plant, but Consistent with the principal that disagree - I&C discussions reflect DAC used in instead pertain to the licensing analyses that will be reviewed and ITAAC pertain only to the top- existing DCDs and therefore design acceptance approved by the NRC in the COL proceeding (e.g., identification level design and perform ance criteria is appropriate of design basis events; m inim um criteria for m anual initiation andrequirem ents, delete or control of protective actions; single failure criterion). Such substantially reduce item s 2-33 topics are not appropriate subjects for ITAAC, as indicated by related to verification of each Attachm ent A.II.10 of DG-1145. section of IEEE 603.
Som e of the topics listed pertain m ore to operation than the design of the as-built plant (e.g., repair; control of access).
Such topics are not appropriate subjects for ITAAC.
C.II.2.35 C.II.2.2.5 Much of the inform ation listed in this paragraph is not top-level see above disagree - I&C discussions reflect DAC used in (cont'd) inform ation and/or not principal perform ance characteristics and existing DCDs and therefore design acceptance safety functions of the SSCs (e.g., capability for test and criteria is appropriate calibration; m aintenance bypasses). Therefore, in accordance with the principles in Section C.II.1 of DG-1145, such topics are not appropriate for ITAAC.
Furtherm ore, the inform ation requested in this section is not necessary for ITAAC as evidenced by the ITAAC for the existing design certifications (which are by definition adequate for COL).
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.36 C.II.2.2.5 This paragraph m erely lists the relevant GDC and provides no Delete or substantially reduce disagree - I&C discussions reflect DAC used in useful inform ation regarding the content of the ITAAC that are Item s 34-46 in this section related existing DCDs and therefore design acceptance needed to verify the GDC. In this regard, the ITAAC for the to the GDC. criteria is appropriate existing design certification are not developed or structured on a GDC-by-GDC basis. Instead, they were developed and structured on a system -by-system basis. DG-1145 should reflect such a structure.
C.II.2.37 C.II.2.2.5 As indicated in SECY-05-197 and the associated Staff Under Item s 48-50, delete the disagree - reference is not applicant operating Requirem ents Mem orandum , ITAAC are not appropriate for references to plans that do not program s but is related to software operational program s. pertain to design and construction developm ent (e.g., m aintenance, training, operations, start-up tests).
C.II.2.38 C.II.2.2.6 Most non-safety-related system s either have no safety function or Modify Item 10 of this section to The NRC staff agrees with the com m ent.
m inor safety functions. Therefore, it would be inappropriate to indicate that ITAAC should verify require ITAAC related to the electrical power for such system s. the functional arrangem ent of Instead, such ITAAC should be lim ited to those non-safety-related electrical power for non-safety system s that have significant safety functions. system s to the extent that those system s perform a significant safety function.
C.II.2.39 C.II.2.2.7 As a general rule, ITAAC are not intended to, and are not Delete Item #3 under the last The NRC staff does not fully agree with the appropriate for, verification of classifications. Instead, ITAAC are bullet in this section, which com m ent. In som e instances, design intended to verify that the as-built plant has certain design indicates that ITAAC should be classification is closely related to the safety features and functions. developed to verify seism ic and function of the system . The text of the last bullet code classification. should the changed to read, "Com m ensurate with the im portance of the design attribute to safety, ITAAC should be developed to verify the following design attributes for plant system s.".
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.40 C.II.2.2.7 Item 10 is too vague to be m eaningful. Not all num eric Delete Item #10 under the last The NRC staff agrees with the com m ent in that perform ance values need to be verified. Instead, only the top- bullet in this section which states only higher level num eric perform ance values level perform ance values need to be verified. that ITAAC should verify num eric need to be specified. Therefore, the text of the perform ance values. last bullet should be changed to read, "Com m ensurate with the im portance of the design attribute to safety, ITAAC should be developed to verify the following design attributes for plant system s."
C.II.2.41 C.II.2.2.7, Som e of the discussion in this section specifies ITAAC for as-built This section should be revised to The NRC staff disagrees with the com m ent.
Sec. 14.3.7 reconciliation with analyses. As noted in the com m ents above, rem ove reference to perform ing During design certification, all im portant aspects the as-built reconciliation is not perform ed with analyses, it is as-built reconciliation with of analyses have not typically been translated perform ed with the design drawings. analyses and replace it with as- into analyses. Therefore, the ITAAC m ust verify built reconciliation with design all im portant attributes of the design analysis drawings. are satisfied by the as-built configuration.
C.II.2.42 C.II.2.2.8 Equipm ent leakage is a relatively m inor detail that is not Delete the fourth bullet in this under review appropriate for ITAAC (which pertain to top-level inform ation). In section pertaining to equipm ent this regard, the ITAAC for the existing design certifications do not leakage characteristics.
in general address equipm ent leakage characteristics (except for a few significant leakage issues, such as integrated containm ent leakage).
C.II.2.43 C.II.2.2.8 The ITAAC for the existing design certification do not require that Modify the fifth bullet in this under review radiation protection equipm ent be environm ental qualified (except section pertaining to as necessary to satisfy 10 CFR 50.49). environm ental qualification of radiation protection equipm ent.
The scope of the ITAAC should be lim ited to that equipm ent that needs to be qualified under 10 CFR 50.49.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.44 C.II.2.2.8 The application will describe the liquid and gaseous radwaste Modify the ninth bullet of this under review system s and will evaluate offsite releases to verify that the lim its in section to delete the reference to Part 190 are m et. The ITAAC should not be focused on 40 CFR Part 190. Instead, reverification of com pliance with Part 190. Instead, the ITAAC ITAAC should require verification should be focused on verification of the im portant design features of the im portant design features and functions of the liquid and gaseous radwaste that were the and functions of the liquid and basis for the analyses in the application. gaseous radwaste system s.
C.II.2.45 C.II.2.2.8 The ITAAC should focus on the im portant design features and In the last bullet in this section, under review perform ance characteristics relied upon in the accident delete the parenthetical statem ent evaluations. ITAAC should not be established to re-verify that references issues such as analytical assum ptions such as delay tim es. m axim um delay tim e, m axim um tim e for drawing negative pressure, etc.
C.II.2.46 C.II.2.2.9 The ITAAC for the existing design certification, and the generic Delete the bullets that pertain to under review em ergency ITAAC accepted by the NRC in Section C.I.13 of DG- hum an factors engineering (HFE) 1145, do not address HFE for the TSC or EOF. Such inform ation for the technical support center does not rise to top-level inform ation. (TSC) and em ergency operations facility (EOF).
C.II.2.47 C.II.2.2.11 The ITAAC for the existing design certifications provide for a Modify the last bullet in this The NRC staff does not agree with the CILRT rather than individual valve leakage tests. Lim iting the section to indicate that ITAAC com m ent. Valve leak rate test are required by ITAAC to the CILRT is appropriate, because safety is ensure if the should include a containm ent regulation and should rem ain part of the ITAAC.
integrated leakage is acceptable. integrated leak rate test (CILRT),
rather than tests of individual valve leakage.
C.II.2.48 Table C.II.2-1 SAMPLE The ITAAC for the existing design certifications only require NDE In ITAAC # 2 in this table, change The NRC staff does not agree. In ITAAC #2 of ITAAC FORMAT for ASME welds, not NDE for all ASME com ponents. the word com ponents to Table C.II.2-1, it is not appropriate to change welds. the word "com ponents" to "welds", because in addition to welds, NDE is also required for com ponents such as studs, bolts, and inner surface radius.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.49 C.II.2; Appendix A.I.A.10 The ITAAC should focus on the results of type tests for equipm ent Delete the sentence pertaining to The NRC staff does not agree with the qualification, not whether there m ay be EQ docum entation equipm ent qualification (EQ) com m ent.
problem s. In this regard, the ITAAC for the existing design docum entation. 50.49 certifications do not contain requirem ents to verify that the EQ docum entation requirem ents docum entation satisfies all of the requirem ents in 10 CFR 50.49. should be addressed in DG-1145, Section C.I.3.11.
C.II.2.50 C.II.2; Appendix A.I.A.11 Accessibility is not top-level design inform ation that pertains to Delete this section, which The NRC staff does not agree, the referenced the principal perform ance characteristics and safety functions of pertains to accessibility to section that pertains to accessibility should not the SSCs. The ITAAC for the existing design certifications do not perform ISI and IST. be deleted. Accessibility is one of the essential in general address accessibility. com ponent design requirem ents to peform ISI and IST. This accessibility requirem ent m ay not fully addressed in the design certification docum ents, because at this early stage detailed designs of the com ponents m ay not be available. However, if is not too late to discuss and im plem ent this accessibility requirem ent during the final design stage of the com ponents and, therefore, it is prudent to include this requirem ent in ITAAC for verification.
C.II.2.51 C.II.2; Appendix A.I.B.11 The ITAAC for the existing design certifications provide for a Modify this section to indicate that prelim inary - ITAAC tp be m aintained for CIV CILRT rather than individual valve leakage tests. Such provisions ITAAC should include a leak tests and not only on IRLT are appropriate, because safety is assured if the integrated containm ent integrated leak leakage is acceptable. (CILRT) rate test (rather than tests of individual valve leakage).
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.52 C.II.2; Attachm ent A on In general, this Attachm ent would require extrem ely detailed The com m ents applicable to The NRC staff does not agree; the Attachm ent I&C System s design inform ation to be included in the ITAAC, without regard to Section C.II.2.2.5 are equally A on I&C System should not be deleted. DG its safety significance. For exam ple, there is no basis for including applicable to this Attachm ent. Section C.II.2: Attachm ent A on I&C System cabinet layout and wiring in the ITAAC - - inclusion of such This entire attachm ent should be specify the COL application to address the inform ation in the ITAAC would be entirely inconsistent with the deleted. com pliance with 10 CFR 50.55a(h), "Criteria for ITAAC for other types of system s, which do not contain such Protection System s for Nuclear Generating details. Sim ilarly, m uch of the inform ation sought by this Stations." 10 CFR 50.55a(h) requires protection Attachm ent (e.g., single failure analysis) will need to be included system s to m eet the requirem ents of IEEE Std in the application and approved by the NRC - - there is no reason 603-1991. Appropriate ITAAC acceptance (and it would be inconsistent with the entire purpose of ITAAC, criteria to verify the COL applicant's which is focused on as-built SSCs) to reverify that design analysis com m itm ent in com pliance with REGULATION as part of ITAAC. is the top-level inform ation for ITAAC.
C.II.2.52 C.II.2; Attachm ent A on In general, this attachm ent does nothing m ore than repeat the see above see above (cont'd) I&C System s requirem ents of IEEE 603, the GDC, and SRP. The attachm ent does not distinguish between design inform ation that needs to be reviewed and approved as part of the application, and as-built attributes that should be verified by ITAAC. Furtherm ore, this attachm ent m akes no attem pt to distinguish between top-level inform ation on the principal perform ance characteristics and safety functions that are appropriate for verification by ITAAC, and detailed design inform ation that is not appropriate for ITAAC. As a result, this attachm ent is not consistent with the principles that the NRC has established for developm ent of ITAAC, and provides incorrect guidance for ITAAC. As a result, this attachm ent (in its current form and substance) should be deleted in its entirety.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.53 C.II.2, Appendix C.II.2-A, Item C seeks subm ittal of the Software Test Plan. There is no This section should be revised to The NRC staff does not agree. Regulatory I&C and Control regulatory basis for this requirem ent. The Software Test Plan is rem ove the Software Test Plan. Guide 1.170, "Software Test Docum entation for System s,Section II, not m entioned in BTP-14. Digital Com puter Software used in Safety ITAAC: System s of Nuclear Power Plants", endorse the requirem ents contained in IEEE Std. 826-1983, "IEEE Standard for Software Test Docum entation". The updated BTP 7-14 has included the software test plan.
C.II.2.54 C.II.2; Attachm ent A on Not all recom m endations in Regulatory Guides warrant treatm ent The first sentence of this The NRC staff partially agrees with the Electrical System s; in ITAAC. For exam ple, som e recom m endations sim ply call for paragraph should be m odified to com m ent. The sentence should read, Paragraph A.9 analyses to be included in an application, but do not pertain to indicate that the "Regulatory Guides (RGs) which have specific perform ance characteristics or safety functions. In other cases, recom m endations in Regulatory recom m endations (all of the RG the Regulatory Guides contain recom m endations that pertain to Guides should be verified through recom m endations m ay not need Tier 1 detailed design inform ation that does not rise to the level of top- ITAAC, to the extent that they treatm ent). Here m ay be an area that Tier 1 level inform ation. Therefore, only those recom m endations in represent top-level inform ation on treatm ent captures the design aspect Regulatory Guides that represent top-level inform ation on the the principal perform ance addressed by the RG."
principal perform ance characteristics and safety functions should characteristics and safety be included in the ITAAC. functions.
C.II.2.55 C.II.2; Attachm ent A on Not all new design features warrant treatm ent in ITAAC. For The first sentence of this The NRC staff agrees with the com m ent. The Electrical System s; exam ple, som e new design features m ay be non-safety-related paragraph should be m odified to sentence should read, "New features in the Paragraph A.12 and have no significant safety function. Therefore, only those new indicate that new design features design (all of the new features m ay not need design features that represent top-level inform ation on the should be verified through ITAAC, Tier 1 treatm ent). For exam ple, on the ABW R principal perform ance characteristics and safety functions should to the extent that they represent this includes the m ain generator breaker for be included in the ITAAC. top-level inform ation on the back feed purposes; and the potential for principal perform ance harm onics introduced by the new RIPs, MFW characteristics and safety pum p speed controllers and its potential effects functions. on the Class 1E equipm ent.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.56 C.II.2; Attachm ent A on Most of the dim ensions requested by this paragraph are not Delete this paragraph, which disagree - ITAAC for dim ensions to rem ain for Building Structures; critical to safety and should not be em bedded in the ITAAC. In requires ITAAC for building structures Paragraph I.3 general, a licensee should be able to change these dim ensions, dim ensions. In the alternative, without seeking prior NRC approval. However, if the dim ensions lim it this paragraph to a few key are in the ITAAC, they cannot be changed without NRC approval. critical dim ensions.
In this regard, the NRC certified the ABW R design, without requiring that the dim ensions be verified by ITAAC (as provided in the footnote to ABW R Tier 1, Section 2.15.10). Although such inform ation was required for the ITAAC for the AP1000, we recom m end that the NRC reconsider that position and only require ITAAC for those key dim ensions that cannot change without significant im plications for safety. In this regard, we believe that it is appropriate to specify a wall thickness for protection against external floods as provided in paragraph II.3 of the Attachm ent, and are not recom m ending any change to that provision.
C.II.2.57 C.II.2 Sentence 2 of paragraph 4 states that COLAs m ust include Modify sentence to be consistent Disagree that wording needs to be changed.
physical security ITAAC, in the sam e way that COLAs m ust with new Appendix C.II.2.C and ITAAC to be developed for physical security include EP ITAAC. However, EP ITAAC are unique in the way Appendix I response C.III.7-2 they are called out in the regulation as required.