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 NO.
DG SECTION RELATED NRC ID NO.
COMMENT RECOMMENDED WORDING DG-1145 DISPOSTION C.II.2.1 C.II.2.1 C.II.2.1 states in a table provided in FSAR Section 14.3, COL applicants should cross-reference the important design information and parameters from these analyses to their treatment (i.e., inclusion or exclusion) in the ITAAC.
This FSAR section 14.3 guidance should be included in C.I.14 and in C.III.1-14.3.
aceept the comment C.II.2.2 C.II.2.1 New nuclear power plants likely will be constructed through the use of modular construction techniques. Since construction modules may be constructed offsite, it may be appropriate for some ITAAC to be performed at the site of manufacturing of the construction modules rather than the reactor site.
Modify the seventh paragraph of this section to indicate that ITAAC testing may include testing of construction modules at the vendors shop. This testing should be distinguished from type tests, in that type tests are not necessarily performed on the components to be installed in the plant, whereas tests of construction modules would be for the modules that will actually be installed in the plant.
disagree - although some components may be manufactured offsite, the as-bulit configuration will follow installation at the site. Inspections or tests performed at the vendor may be incorporated into ITAAC but would not be considered the final as-built condition to be used to close an ITAAC C.II.2.3 C.II.2.2 The 10th paragraph says that ITAAC should not reference the COLA, while the 3d paragraph says ITAAC should reference the FSAR portion of the COLA.
Modify the 3d sentence in the 10th paragraph as follows: Except in the case where no design certification is referenced and no separate ITAAC design 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 top-level design information that pertains to the principal performance characteristics and safety functions of the SSCs. A design feature may be site-specific and unique, and yet have little or no safety function. A design feature does not warrant greater consideration for inclusion in an ITAAC, merely because it is unique or site-specific.
Delete bullet #1 to "Carefully consider design-specific and unique features of the facility for inclusion in ITAAC.
no change - bullet is to consider, understood that not all new items are ITAAC - criteria is same in terms of developing ITAAC C.II.2.5 C.II.2.1 Bullets As indicated earlier in DG-1145, ITAAC should be reserved for top-level design information that pertains to the principal performance characteristics and safety functions of the SSCs.
Not all resolutions of USIs/GSIs, NRC bulletins and generic letters, and operating experience rise to that level. For certain designs, the resolution of a particular generic issue may have little or no safety significance. Therefore, similar to other information, the determination which resolutions should be included in ITAAC should be based upon a graded approach, depending upon the significance of the resolution to safety.
Delete Bullet #3 to Ensure that ITAAC reflect the resolutions of technically relevant USIs/GSIs, NRC generic correspondence such as bulletins and generic letters; and relevant industry operating experience.
In the alternative, modify the language to refer to safety significant resolutions rather than resolutions of technically relevant
[issues]
no change - bullet is to consider, understood that not all items related to generic issues would be ITAAC - criteria is same in terms of developing ITAAC C.II.2.6 C.II.2.1 Bullets Typo Last bullet should modified as follows Systems SSCs for which there is no discernable no change - SSC maintained to capture systems and structures C.II.2.7 C.II.2.1.1 New nuclear power plants likely will be constructed through the use of modular construction techniques. Since construction modules may be constructed offsite, it may be appropriate for some ITAAC to be performed at the site of manufacturing of the construction modules rather than the reactor site.
Modify the definition of as-built to include construction SSCs/modules at the vendors shop that are intended for installation at the reactor in question.
No change - see comment 2
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 description of Tier 1. Tier 1 is not intended to summarize the FSAR. Instead, as indicated in Section C.II.2.1 of DG-1145, Tier 1 is the top-level design information from the FSAR.
In the definition of Design Description, delete the last sentence, which states that Tier 1 information is a summation of the detailed design information in the FSAR.
accept - delete definition for design description
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 deleted. The use and definition of the two similar terms, Design Description and ITAAC Design Description, are confusing and problematic. Design Description is a term that is commonly used in both ITAAC and non-ITAAC contexts. It may be helpful to define the term "Tier 1 Design Description."
Define a single term, ITAAC Design Description, to mean the equivalent of Tier 1 Design Description when no design certification is referenced, and 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 means the top level design information that pertains to the principal performance characteristics and safety functions of SSCs. This information 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 may choose to provide ITAAC Design Description in a document separate from the FSAR or directly in the FSAR. ITAAC Design Description may, at a minimum, consist only of tables and figures that are referenced in the ITAAC.
accept - delete definition for design description
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.9 (cont'd)
C.II.2.1.1 W hether presented in a separate document or included in the FSAR, ITAAC Design Description is the proper term to describe the top-level design information referenced in ITAAC when a certified design is not referenced.
C.II.2.10 C.II.2.1.1 Clarify definition of Design Requirement/Commitment.
Modify the 1 sentence of the st definition as follows: "Design Requirement/Commitment means the specific that portion of the detailed design information provided in the COL application that is verified by ITAAC."
disagree - keep language "portion of detailed.."
but deleted second sentence C.II.2.11 C.II.2.1.1 As literally worded, the definition of Exists would require an SSC to satisfy all of the provisions in the FSAR (without regard to safety significance). The wording should be changed to indicate that the SSC must satisfy the Design Requirement/Commitment in the ITAAC, which will identify the top-level design information applicable to the SSC.
Change the definition of Exists to state as follows: Exists means that the item is present and meets the Design Requirement/Commitment.
accept - deleted definition of exists C.II.2.12 C.II.2.1.1 As literally worded, the definition of Functional Arrangement would require a system to satisfy all of the design descriptions in the FSAR (without regard to safety significance). The wording should be changed to indicate that the system must satisfy the Design Requirement/Commitment in the ITAAC, which will identify the top-level design information applicable to the system.
Change the definition of Functional Arrangement to delete the reference to system design description and instead refer to the Design Requirement/Commitment.
partially accept - changed definition to be
....described in the ITAAC design description and as shown in the figures
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 more closely track the language in proposed 10 CFR 52.80.
Change the definition of ITAAC to state as follows: ITAAC means the inspections, tests, and analyses, including those applicable to emergency 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 performed and the acceptance criteria met, the facility has been constructed and will operate in conformity with the combined license, the provisions of the Atomic Energy Act, and the NRCs regulations.
accept - deleted definition of ITAAC C.II.2.14 C.II.2.1.1 As literally worded, the definition of Physical Arrangement would require a structure to satisfy all of the design descriptions in the FSAR (without regard to safety significance). The wording should be changed to indicate that the structure must satisfy the Design Requirement/Commitment in the ITAAC, which will identify the top-level design information applicable to the structure.
Change the definition of Physical Arrangement to delete the reference to design description and instead refer to the Design Requirement/Commitment.
partially accept - changed definition to be
....described in the ITAAC design description and as shown in the figures
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 recognized, ITAAC are not needed or appropriate for the QA Additionally, with respect to codes and standards, not all codes and standards are sufficiently important to rise to the level of top level design information. Therefore, it is not appropriate in general to have ITAAC that verify implementation of codes and standards in general.
Delete Bullet (20) codes and standards (GDC 1).
W hy do these bullets start from (13)?
partially accept - deleted reference to GDC 1 but kept listed item of codes and standards (as they relate to verifying as-built conforms to applicable codes and standards)
C.II.2.16 C.II.2.2.2 The 2 bullet under the heading Pressure Boundary Integrity nd should be changed to be consistent with the ITAAC for the existing design certifications and clarifies the scope of the NDE to be performed under the ITAAC.
Modify the second bullet to insert the words for welds after NDE.
accept C.II.2.17 C.II.2.2.2 Determining load combinations is a detailed design function and is not appropriate for inclusion in the ITAAC. Instead, ITAAC should focus on verification of the adequacy of the as-built plant (which occurs through the other bullets under the heading Normal Loads, pertaining to as-built stress reconciliation reports).
Delete the first bullet under the heading Normal Loads, which states that ITAAC should verify that normal and accident loads have been appropriately combined.
partially accept - language to reflect that reconcilation of as-built to design will verify normal and accident loads.....
C.II.2.18 C.II.2.2.2 The 3d bullet under the heading Normal Loads should be changed to clarify that the ITAAC in question pertain to ASME stress reports, not all ASME reports.
Modify the third bullet to refer to ASME Code-required stress reports.
accept C.II.2.19 C.II.2.2.2 Determining load combinations is a detailed design function and is not appropriate for inclusion in the ITAAC. Instead, ITAAC should focus on verification of the adequacy of the as-built plant (which occurs through the other bullets under the heading Seismic Loads pertaining to as-built stress reconciliation reports).
Under the heading Seismic Loads, delete the first bullet, which states that ITAAC should verify that structures and systems have been designed for seismic loads.
partially accept - language to reflect that reconcilation of as-built to design will verify seismic loads.....
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.20 C.II.2.2, Sec. 14.3.2 This section contains numerous statements similar to COL applicants should provide ITAAC to reconcile the as-built plant with the structural design basis. Reconciliation between as-built configuration and structural analysis is neither performed nor required unless there is a deviation from the design drawings used in the analysis. As-built configurations are checked against design drawings to verify compliance with the design basis. There is no regulatory basis for this requirement and it is not consistent with precedent (none of the existing certified designs have these ITAAC). This comment is also applicable to draft SRP Section 14.3.2.
This section should be revised to remove all statements that imply a requirement for as-built reconciliation with analysis and replace it with reconciliation of as-built configuration with design drawings.
disagree - reconcilation to ensure as-built to design basis. Reconciliation may involve various levels of effort but will ultimately verify as-built to design.
C.II.2.21 C.II.2.2.2 The 4 bullet under the heading Seismic Loads, should be th changed to clarify that the ITAAC in question pertain to ASME stress reports, not all ASME reports.
Modify the fourth bullet to refer to ASME Code-required stress reports.
accept C.II.2.22 C.II.2.2.2 Under the heading Seismic Loads, to the extent that the 6th bullet is intended to refer to safety-related buildings, the ITAAC is inappropriate because safety-related buildings are designed to withstand seismic events without collapse.
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.
Under the heading Seismic Loads, delete the sixth bullet related to the collapse of buildings.
accept (addressed by next bullet in list)
C.II.2.23 C.II.2.2.2 Determining load combinations is a detailed design function and is not appropriate for inclusion in the ITAAC. Instead, ITAAC should focus on verification of the adequacy of the as-built plant (which occurs through the other bullets under the heading related to the Suppression Pool pertaining to as-built stress reconciliation reports).
Under the heading related to the Suppression Pool, delete the first bullet, which states that ITAAC should verify that structures and systems have been designed for hydrodynamic loads.
disagree - reconcilation to ensure as-built to design basis. Reconciliation may involve various levels of effort but will ultimately verify as-built to design.
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 bullet under the heading related to the Suppression Pool th should be changed to clarify that the ITAAC in question pertain to ASME stress reports, not all ASME reports.
Modify the fourth bullet to refer to ASME Code-required stress reports.
accept C.II.2.25 C.II.2.2.2 Determining load is a detailed design function and is not appropriate for inclusion in the ITAAC. Instead, ITAAC should focus on verification of the adequacy of the as-built plant (which occurs through the other bullets under the heading Flood, W ind, etc., pertaining to as-built stress reconciliation reports).
Under the heading Flood, W ind, etc, delete the first bullet which states that ITAAC should verify that structures and systems have been designed for natural phenomena loads.
disagree - reconcilation to ensure as-built to design basis. Reconciliation may involve various levels of effort but will ultimately verify as-built to design.
C.II.2.26 C.II.2.2.2 The 3d bullet under the heading Pipe Break makes no sense as written. RPVs are not postulated to experience LOCAs. Perhaps the reference to RPVs should be to the reactor coolant pressure boundary, or reactor coolant system.
Delete the third bullet related to reactor pressure vessel (RPV)
LOCA analysis.
accept - changed to RCS C.II.2.27 C.II.2.2.2 This topic of Codes and Standards is redundant of the bullets under the other headings and therefore should be deleted.
Delete the heading and bullet related to Codes and Standards.
disagree - part of verification will also ensure required documentation 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 under the other headings and therefore should be deleted.
Delete the heading and bullets related to As-Built Reconciliation.
disagree - section and bullets maintained C.II.2.29 C.II.2.2.2 Consistent with the practice for the ITAAC for the existing design certifications, a single ITAAC may address the as-built stress reconciliation for all loads applicable to a system, rather than having a separate ITAAC for each load.
Add a paragraph at the end of this section to state that ITAAC for the various topics discussed in this section may be combined into one or more ITAAC, and that a separate ITAAC is not needed for each topic.
accept - will add paragraph that an inspection can address more than one topic - also that ITAAC to be developed to support construction activities/schedules such that applicants may propose multiple ITAAC for some items
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 appropriate for, verification of classifications. Instead, ITAAC are intended to verify that the as-built plant has certain design features and functions.
Modify the statement preceding the second series of bullets in this section to delete reference to verifying piping and component "classification."
The ITAAC should verify that the piping components and systems have been fabricated in accordance with the proper Code class requirements. Code classification is part of the initial design certification. The ITAAC merely confirms that fabricated components meets its classification. (P. Higgins, SPW B)
C.II.2.31 C.II.2.2.3 It will not always be possible to simulate design basis conditions in the plant. Therefore, in some cases, it will be necessary to perform an analysis that extrapolates the results of tests at actual conditions to determine whether the MOVs will be able to perform their functions at design basis conditions.
Modify the last bullet of this section to indicate that the capability of installed MOVs at design basis conditions should be verify by in-situ testing and analysis.
Modify the last bullet of this section to indicate that the capability of installed pumps, valves, and dynamic restraints at design basis conditions should be verified by in-situ testing and functional design and qualification records.
(T. Scarbrough, CPTB)
C.II.2.32 C.II.2.2.3, Sec. 14.3.3 This section requires as-built analyses to be performed. See above comment on C.II.2.2.2, Section 14.3.2 concerning as-built reconciliation. As-built reconciliation is performed by confirmation that the as-built configuration conforms to the design drawings.
Structural analyses are only revised if necessary to reconcile deviations that are identified. If the design uses LBB methods there should be an ITAAC developed to require that a report exists and concludes that the material properties in the certified material test reports are consistent with the material properties assumed in the LBB analysis.
This section should be revised to remove all statements that stipulate the structural analyses have to be revised to verify as-built configuration. The bullet on LBB reconciliation should be revised to reflect that the only input needed is the certified material test reports.
ITAAC should be developed to require the existence of a report, which documents the results of an as-built reconciliation confirming that the piping systems have been built in accordance with the ASME Code Certified stress report. (P. Higgins, SPW B)
C.II.2.33 C.II.2.2.4 As a general rule, ITAAC are not intended to, and are not appropriate for, verification of classifications. Instead, ITAAC are intended to verify that the as-built plant has certain design features and functions.
Delete Item # 2 under the last bullet, which indicates that ITAAC should be developed to verify seismic and code classification.
The NRC staff does not agree. The ITAAC are itended not only to verify that the as-built plant has certain design features and functions, but also to verify that the as-built features, structures, systems, and components meet the seismic 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 meaningful. Not all numeric performance values need to be verified. Instead, only the top-level performance values need to be verified.
Delete Item # 9 under the last bullet, which states that ITAAC should verify numeric performance values.
The NRC staff agrees that Tier 1 information should include top level design features and performance standards. Rather than deleting Item #9 as recommended, the last bullet will be revised for clarification as the following: "ITAAC should be developed to verify the top level design aspects of reactor systems listed below:" (P. Higgins, SPW B)
C.II.2.35 C.II.2.2.5 Some of the topics listed do not relate to the as-built plant, but instead pertain to the licensing analyses that will be reviewed and approved by the NRC in the COL proceeding (e.g., identification of design basis events; minimum criteria for manual initiation and control of protective actions; single failure criterion). Such topics are not appropriate subjects for ITAAC, as indicated by Attachment A.II.10 of DG-1145.
Some of the topics listed pertain more to operation than the design of the as-built plant (e.g., repair; control of access).
Such topics are not appropriate subjects for ITAAC.
Consistent with the principal that ITAAC pertain only to the top-level design and performance requirements, delete or substantially reduce items 2-33 related to verification of each section of IEEE 603.
disagree - I&C discussions reflect DAC used in existing DCDs and therefore design acceptance criteria is appropriate C.II.2.35 (cont'd)
C.II.2.2.5 Much of the information listed in this paragraph is not top-level information and/or not principal performance characteristics and safety functions of the SSCs (e.g., capability for test and calibration; maintenance bypasses). Therefore, in accordance with the principles in Section C.II.1 of DG-1145, such topics are not appropriate for ITAAC.
Furthermore, the information 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).
see above disagree - I&C discussions reflect DAC used in existing DCDs and therefore design acceptance criteria is appropriate
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 merely lists the relevant GDC and provides no useful information regarding the content of the ITAAC that are needed to verify the GDC. In this regard, the ITAAC for the 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.
Delete or substantially reduce Items 34-46 in this section related to the GDC.
disagree - I&C discussions reflect DAC used in existing DCDs and therefore design acceptance criteria is appropriate C.II.2.37 C.II.2.2.5 As indicated in SECY-05-197 and the associated Staff Requirements Memorandum, ITAAC are not appropriate for operational programs.
Under Items 48-50, delete the references to plans that do not pertain to design and construction (e.g., maintenance, training, operations, start-up tests).
disagree - reference is not applicant operating programs but is related to software development C.II.2.38 C.II.2.2.6 Most non-safety-related systems either have no safety function or minor safety functions. Therefore, it would be inappropriate to require ITAAC related to the electrical power for such systems.
Instead, such ITAAC should be limited to those non-safety-related systems that have significant safety functions.
Modify Item 10 of this section to indicate that ITAAC should verify the functional arrangement of electrical power for non-safety systems to the extent that those systems perform a significant safety function.
The NRC staff agrees with the comment.
C.II.2.39 C.II.2.2.7 As a general rule, ITAAC are not intended to, and are not appropriate for, verification of classifications. Instead, ITAAC are intended to verify that the as-built plant has certain design features and functions.
Delete Item #3 under the last bullet in this section, which indicates that ITAAC should be developed to verify seismic and code classification.
The NRC staff does not fully agree with the comment. In some instances, design classification is closely related to the safety function of the system. The text of the last bullet should the changed to read, "Commensurate with the importance of the design attribute to safety, ITAAC should be developed to verify the following design attributes for plant systems.".
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 meaningful. Not all numeric performance values need to be verified. Instead, only the top-level performance values need to be verified.
Delete Item #10 under the last bullet in this section which states that ITAAC should verify numeric performance values.
The NRC staff agrees with the comment in that only higher level numeric performance values need to be specified. Therefore, the text of the last bullet should be changed to read, "Commensurate with the importance of the design attribute to safety, ITAAC should be developed to verify the following design attributes for plant systems."
C.II.2.41 C.II.2.2.7, Sec. 14.3.7 Some of the discussion in this section specifies ITAAC for as-built reconciliation with analyses. As noted in the comments above, the as-built reconciliation is not performed with analyses, it is performed with the design drawings.
This section should be revised to remove reference to performing as-built reconciliation with analyses and replace it with as-built reconciliation with design drawings.
The NRC staff disagrees with the comment.
During design certification, all important aspects of analyses have not typically been translated into analyses. Therefore, the ITAAC must verify all important attributes of the design analysis are satisfied by the as-built configuration.
C.II.2.42 C.II.2.2.8 Equipment leakage is a relatively minor detail that is not appropriate for ITAAC (which pertain to top-level information). In this regard, the ITAAC for the existing design certifications do not in general address equipment leakage characteristics (except for a few significant leakage issues, such as integrated containment leakage).
Delete the fourth bullet in this section pertaining to equipment leakage characteristics.
under review C.II.2.43 C.II.2.2.8 The ITAAC for the existing design certification do not require that radiation protection equipment be environmental qualified (except as necessary to satisfy 10 CFR 50.49).
Modify the fifth bullet in this section pertaining to environmental qualification of radiation protection equipment.
The scope of the ITAAC should be limited to that equipment that needs to be qualified under 10 CFR 50.49.
under review
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 systems and will evaluate offsite releases to verify that the limits in Part 190 are met. The ITAAC should not be focused on reverification of compliance with Part 190. Instead, the ITAAC should be focused on verification of the important design features and functions of the liquid and gaseous radwaste that were the basis for the analyses in the application.
Modify the ninth bullet of this section to delete the reference to 40 CFR Part 190. Instead, ITAAC should require verification of the important design features and functions of the liquid and gaseous radwaste systems.
under review C.II.2.45 C.II.2.2.8 The ITAAC should focus on the important design features and performance characteristics relied upon in the accident evaluations. ITAAC should not be established to re-verify analytical assumptions such as delay times.
In the last bullet in this section, delete the parenthetical statement that references issues such as maximum delay time, maximum time for drawing negative pressure, etc.
under review C.II.2.46 C.II.2.2.9 The ITAAC for the existing design certification, and the generic emergency ITAAC accepted by the NRC in Section C.I.13 of DG-1145, do not address HFE for the TSC or EOF. Such information does not rise to top-level information.
Delete the bullets that pertain to human factors engineering (HFE) for the technical support center (TSC) and emergency operations facility (EOF).
under review C.II.2.47 C.II.2.2.11 The ITAAC for the existing design certifications provide for a CILRT rather than individual valve leakage tests. Limiting the ITAAC to the CILRT is appropriate, because safety is ensure if the integrated leakage is acceptable.
Modify the last bullet in this section to indicate that ITAAC should include a containment integrated leak rate test (CILRT),
rather than tests of individual valve leakage.
The NRC staff does not agree with the comment. Valve leak rate test are required by regulation and should remain part of the ITAAC.
C.II.2.48 Table C.II.2-1 SAMPLE ITAAC FORMAT The ITAAC for the existing design certifications only require NDE for ASME welds, not NDE for all ASME components.
In ITAAC # 2 in this table, change the word components to welds.
The NRC staff does not agree. In ITAAC #2 of Table C.II.2-1, it is not appropriate to change the word "components" to "welds", because in addition to welds, NDE is also required for components 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 equipment qualification, not whether there may be EQ documentation problems. In this regard, the ITAAC for the existing design certifications do not contain requirements to verify that the EQ documentation satisfies all of the requirements in 10 CFR 50.49.
Delete the sentence pertaining to equipment qualification (EQ) documentation. 50.49 documentation requirements should be addressed in DG-1145, Section C.I.3.11.
The NRC staff does not agree with the comment.
C.II.2.50 C.II.2; Appendix A.I.A.11 Accessibility is not top-level design information that pertains to the principal performance characteristics and safety functions of the SSCs. The ITAAC for the existing design certifications do not in general address accessibility.
Delete this section, which pertains to accessibility to perform ISI and IST.
The NRC staff does not agree, the referenced section that pertains to accessibility should not be deleted. Accessibility is one of the essential component design requirements to peform ISI and IST. This accessibility requirement may not fully addressed in the design certification documents, because at this early stage detailed designs of the components may not be available. However, if is not too late to discuss and implement this accessibility requirement during the final design stage of the components and, therefore, it is prudent to include this requirement 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 CILRT rather than individual valve leakage tests. Such provisions are appropriate, because safety is assured if the integrated leakage is acceptable.
Modify this section to indicate that ITAAC should include a containment integrated leak (CILRT) rate test (rather than tests of individual valve leakage).
preliminary - ITAAC tp be maintained for CIV leak tests and not only on IRLT
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.52 C.II.2; Attachment A on I&C Systems In general, this Attachment would require extremely detailed design information to be included in the ITAAC, without regard to its safety significance. For example, there is no basis for including cabinet layout and wiring in the ITAAC - - inclusion of such information in the ITAAC would be entirely inconsistent with the ITAAC for other types of systems, which do not contain such details. Similarly, much of the information sought by this Attachment (e.g., single failure analysis) will need to be included in the application and approved by the NRC - - there is no reason (and it would be inconsistent with the entire purpose of ITAAC, which is focused on as-built SSCs) to reverify that design analysis as part of ITAAC.
The comments applicable to Section C.II.2.2.5 are equally applicable to this Attachment.
This entire attachment should be deleted.
The NRC staff does not agree; the Attachment A on I&C System should not be deleted. DG Section C.II.2: Attachment A on I&C System specify the COL application to address the compliance with 10 CFR 50.55a(h), "Criteria for Protection Systems for Nuclear Generating Stations." 10 CFR 50.55a(h) requires protection systems to meet the requirements of IEEE Std 603-1991. Appropriate ITAAC acceptance criteria to verify the COL applicant's commitment in compliance with REGULATION is the top-level information for ITAAC.
C.II.2.52 (cont'd)
C.II.2; Attachment A on I&C Systems In general, this attachment does nothing more than repeat the requirements of IEEE 603, the GDC, and SRP. The attachment does not distinguish between design information that needs to be reviewed and approved as part of the application, and as-built attributes that should be verified by ITAAC. Furthermore, this attachment makes no attempt to distinguish between top-level information on the principal performance characteristics and safety functions that are appropriate for verification by ITAAC, and detailed design information that is not appropriate for ITAAC. As a result, this attachment is not consistent with the principles that the NRC has established for development of ITAAC, and provides incorrect guidance for ITAAC. As a result, this attachment (in its current form and substance) should be deleted in its entirety.
see above see above
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, I&C and Control Systems,Section II, ITAAC:
Item C seeks submittal of the Software Test Plan. There is no regulatory basis for this requirement. The Software Test Plan is not mentioned in BTP-14.
This section should be revised to remove the Software Test Plan.
The NRC staff does not agree. Regulatory Guide 1.170, "Software Test Documentation for Digital Computer Software used in Safety Systems of Nuclear Power Plants", endorse the requirements contained in IEEE Std. 826-1983, "IEEE Standard for Software Test Documentation". The updated BTP 7-14 has included the software test plan.
C.II.2.54 C.II.2; Attachment A on Electrical Systems; Paragraph A.9 Not all recommendations in Regulatory Guides warrant treatment in ITAAC. For example, some recommendations simply call for analyses to be included in an application, but do not pertain to performance characteristics or safety functions. In other cases, the Regulatory Guides contain recommendations that pertain to detailed design information that does not rise to the level of top-level information. Therefore, only those recommendations in Regulatory Guides that represent top-level information on the principal performance characteristics and safety functions should be included in the ITAAC.
The first sentence of this paragraph should be modified to indicate that the recommendations in Regulatory Guides should be verified through ITAAC, to the extent that they represent top-level information on the principal performance characteristics and safety functions.
The NRC staff partially agrees with the comment. The sentence should read, "Regulatory Guides (RGs) which have specific recommendations (all of the RG recommendations may not need Tier 1 treatment). Here may be an area that Tier 1 treatment captures the design aspect addressed by the RG."
C.II.2.55 C.II.2; Attachment A on Electrical Systems; Paragraph A.12 Not all new design features warrant treatment in ITAAC. For example, some new design features may be non-safety-related and have no significant safety function. Therefore, only those new design features that represent top-level information on the principal performance characteristics and safety functions should be included in the ITAAC.
The first sentence of this paragraph should be modified to indicate that new design features should be verified through ITAAC, to the extent that they represent top-level information on the principal performance characteristics and safety functions.
The NRC staff agrees with the comment. The sentence should read, "New features in the design (all of the new features may not need Tier 1 treatment). For example, on the ABW R this includes the main generator breaker for back feed purposes; and the potential for harmonics introduced by the new RIPs, MFW pump speed controllers and its potential effects on the Class 1E equipment.
PRELIMINARY ASSESSMENT OF COMMENTS ON DG-1145 TO SUPPORT PUBLIC MEETING ON FEBRUARY 13, 2007 C.II.2.56 C.II.2; Attachment A on Building Structures; Paragraph I.3 Most of the dimensions requested by this paragraph are not critical to safety and should not be embedded in the ITAAC. In general, a licensee should be able to change these dimensions, without seeking prior NRC approval. However, if the dimensions are in the ITAAC, they cannot be changed without NRC approval.
In this regard, the NRC certified the ABW R design, without requiring that the dimensions be verified by ITAAC (as provided in the footnote to ABW R Tier 1, Section 2.15.10). Although such information was required for the ITAAC for the AP1000, we recommend that the NRC reconsider that position and only require ITAAC for those key dimensions that cannot change without significant implications 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 Attachment, and are not recommending any change to that provision.
Delete this paragraph, which requires ITAAC for building dimensions. In the alternative, limit this paragraph to a few key critical dimensions.
disagree - ITAAC for dimensions to remain for structures C.II.2.57 C.II.2 Sentence 2 of paragraph 4 states that COLAs must include physical security ITAAC, in the same way that COLAs must include EP ITAAC. However, EP ITAAC are unique in the way they are called out in the regulation as required.
Modify sentence to be consistent with new Appendix C.II.2.C and Appendix I response C.III.7-2 Disagree that wording needs to be changed.
ITAAC to be developed for physical security