ML073190162
| ML073190162 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/2008 |
| From: | Michael Case NRC/NRR/ADRO/DPR |
| To: | Tracy G Division of Construction Inspection and Operational Programs |
| References | |
| RIS-08-005 | |
| Download: ML073190162 (6) | |
See also: RIS 2008-05
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
WASHINGTON, DC 20555-0001
February 27, 2008
NRC REGULATORY ISSUE SUMMARY 2008-05
LESSONS LEARNED TO IMPROVE INSPECTIONS, TESTS,
ANALYSES, AND ACCEPTANCE CRITERIA SUBMITTAL
ADDRESSEES
The U.S. Nuclear Regulatory Commission (NRC) applicants for early site permits, design
certifications, or combined licenses to construct and operate nuclear power plants under
Title 10, Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, of Title 10
of the Code of Federal Regulations (10 CFR) Part 52.
INTENT
The intent of this regulatory issue summary (RIS) is to communicate to addressees the good
practices for submitting inspections, tests, analyses, and acceptance criteria (ITAAC) as part of
their applications for early site permits, standard design certifications, or combined licenses.
Applicants should consider incorporating these lessons learned into their applications to provide
for a more efficient inspection and ITAAC closure process. No specific action or written
response is required.
BACKGROUND
As required by 10 CFR Part 52, applicants for early site permits, standard design certifications,
or combined licenses must submit, among other information, the proposed ITAAC that are
necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and
analyses (ITA) are performed and the acceptance criteria met, the facility has been constructed
and will be operated in conformity with the license, the provisions of the Atomic Energy Act of
1954, as amended, and the Commissions rules and regulations. Following issuance of a
combined license, a licensee completes the ITAAC contained in the combined license during
construction and submits notification letters to the NRC in accordance with 10 CFR 52.99,
Inspection during Construction. The NRC subsequently verifies closure of all ITAAC through
direct inspection or other methods, such as oversight of the licensees ITAAC completion,
closure, and approval processes.
SUMMARY OF ISSUES
Based on the review of recent ITAAC submittals to the NRC, the staff has identified four general
categories in which ITAAC submittals could be improved. These areas include (1)
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ITAAC format and content, (2) ITAAC nomenclature and language, (3) ITAAC focus, logic, and
practicality, and (4) ITAAC standardization and review.
ITAAC FORMAT AND CONTENT
Applicants should consider using a consistent system to identify and number individual
ITAAC within their applications. While an alphanumeric system has generally been used
in past submittals, in some cases dashes or separate paragraphs with no labels were
used in the body of the text to specify separate ITAAC requirements. In other cases, the
alphanumeric designations were not consistently aligned for the applicable ITAAC table
requirements. Use of a standard and consistent ITAAC identification system will
minimize confusion.
Applicants should consider a standard methodology for identifying and organizing the
structures, systems, and components (SSCs) associated with an ITAAC to allow for a
more efficient inspection and ITAAC closure process. For instance, if an applicant
chooses to organize SSCs in a tabular format (as opposed to system drawings), they
could organize instrumentation-related components (e.g., sensors) separately from
mechanical components. Additionally, the applicant could list mechanical components,
or a group of components that are likely to be closed together, in similar categories (e.g.,
pumps, valves).
Applicants should consider avoiding the integration of several different engineering or
construction areas into a single ITAAC. In one case, an applicant included all of the
American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code
requirements and pipe break analyses for all the plants piping into two ITAAC. In
another instance, an applicants definition for a systems basic configuration included
five separate engineering and construction processes, but only two ITAAC were
associated with them.
ITAAC NOMENCLATURE AND LANGUAGE
All terms used in an ITAAC should clearly be defined. For example:
-
It is unclear whether an applicant using the terms design reports and reports
in an ITAAC involving ASME Code piping and welding intends the ASME Code
definition for design report and data report or its own definition for these
terms.
-
In one instance, the term as-installed was frequently used but not defined.
Apparently this term was used as a substitute for the term as-built, which was
defined.
If applicants use terms such as interfacing systems, control room features, minimum
set, seismic structure, equipment qualification, fast-closing valves, and rapid
depressurization, they should clearly define them. For instance, the term equipment
qualification, if not clearly defined, could be associated with the specific requirements
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for environmental qualification delineated in 10 CFR 50.49, Environmental Qualification
of Electric Equipment Important to Safety for Nuclear Power Plants.
The use of the conjunction and/or is generally not appropriate.
If applicants use the phrase, a report exists and concludes that..., they should consider
specifying the scope and the type of report. For example, they should explain whether
the scope of the report includes the design, the as-built construction (as reconciled with
the design), or any other information.
Applicants should be consistent in the use of specific technical terms (e.g., the terms
pressure test and hydrostatic pressure test are interchanged; similarly, internal
pressure and design pressure are used in the same ITAAC). Applicants should also
take care not to confuse the preoperational conditions with the applicable operation
modes in situations involving testing.
ITAAC INSPECTION FOCUS, LOGIC, AND PRACTICALITY
Applicants should avoid applying a single ITAAC to a large area of construction or
activities that are likely to be widely separated in time. Large-scoped ITAAC create
problems with verification activities and with the timing of construction and other
requisite inspections.
Applicants should consider breaking ITAAC with a large number of SSCs into areas of
construction. For instance, if an ITAAC envelops construction from the basemat to the
top of containment and applies to several different buildings, the large area and scope
create difficulties not only in tracking the applicable SSCs, but also in connecting the
interdependent nature (e.g., seismic) of the applicable structures. Breaking a large
single ITAAC into several areas will make the ITAAC closure process more efficient.
Applicants that envision using modular construction should consider the impact of these
activities in developing their ITAAC. For example, the inspection of as-built SSCs
implies that as-built refers to the completion of construction at the final location at the
plant site. However, if a module is fabricated at a remote location (e.g., a shipyard), the
individual components within the module (e.g., a pipe support) would be in their final
locations, even if the module had not yet been transported to the site. Such
considerations will facilitate ITAAC inspections and timely closures.
Applicants should consider the timing and sequence of construction activities in the
development of related ITAAC. Breaking the ITAAC into pieces that can be completed
in the early and mid-stages of construction would help alleviate the backlog of ITAAC
closure activities at the end of the process.
Applicants should ensure that design commitments and ITAAC are consistent. It is
important for the language and details of the ITAAC to comport with the language of the
design commitment. In one case, the design commitment indicates that the piping is
designed and constructed in accordance with the ASME Code, but the acceptance
criteria only require the existence of design reports (which would not normally
encompass construction quality) for as-built piping.
Applicants should ensure that the ITA and the associated acceptance criteria match. In
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one case, the ITA required an inspection of a makeup water system. While three
separate acceptance criteria were associated with this one ITA inspection, only two of
the criteria were inspections; the third criterion specified a flow rate, which is a test
result and not an inspection criterion.
ITAAC STANDARDIZATION AND REVIEW
Applicants should ensure consistency in ITAAC designations within their applications. In
one case, a count of the ITA designations identified 33 ITAAC, while a count of the
acceptance criteria designations identified a total of 38 ITAAC. Such an inconsistent
ITAAC count could result in problems not only during the conduct of verification and
inspection activities, but also when the ITAAC are closed and the notification letters, in
accordance with 10 CFR 52.99, are submitted.
BACKFIT DISCUSSION
This RIS requires no action or written response and is, therefore, not a backfit under
10 CFR 50.109, Backfitting. Consequently, the NRC staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal Register
because the RIS is informational and does not represent a departure from current regulatory
requirements.
CONGRESSIONAL REVIEW ACT
The NRC has determined that this action is not a rule under the Congressional Review Act.
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain information collections and, therefore, is not subject to the
requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.).
Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid Office of Management and Budget control number.
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CONTACT
This RIS requires no specific action or written response. Please direct any questions about this
matter to the technical contact listed below.
/RA/
/RA/
Michael Case, Director
Glenn Tracy, Director
Division of Policy and Rulemaking
Division of Construction Inspection and
Office of Nuclear Reactor Regulation
Operational Programs
Office of New Reactors
Technical Contact:
(301) 415-6616
oty@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site,
http://www.nrc.gov, under Electronic Reading Room/Document Collections
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CONTACT
This RIS requires no specific action or written response. Please direct any questions about this matter
to the technical contact listed below.
/RA/
/RA/
Michael Case, Director
Glenn Tracy, Director
Division of Policy and Rulemaking
Division of Construction Inspection and
Office of Nuclear Reactor Regulation
Operational Programs
Office of New Reactors
Technical Contact:
(301) 415-6616
oty@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov,
under Electronic Reading Room/Document Collections.
OFFICE CCIB:DCIP:NRO Tech Ed.
TL:CCIB:DCIP:NRO
BC:CCIB:DCIP:NRO D:DORL:NRR
NAME
OTabatabai
HChange
RLaura
RRasmussen
CHaney
DATE
1/23/08
1/18/08
2/5/08
2/5/08
2/4/08
OFFICE D:DIRS:NRR
D:DNRL:NRO
D:DPR:NSIR
DD:DCI:R-II
D:OE
NAME
FBrown
TBergman
MLeach
COgle
CCarpenter
DATE
2/5/08
2/8/08
2/4/08
2/1/08
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OGC (CRA)
D:PMDA:NRO
OIS
LA:PGCB:NRR
NAME
JRund
SHamrick
BGusak
GTrussel
CHawes
DATE
2/12/08
2/12/08
1/25/08
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OFFICE PM:PGCB:NRR
BC:PGCB:NRR
D:DCIP:NRO
D:DPR:NRR
NAME
AMarkley
MMurphy
GTracy
MCase
DATE
02/20/08
2/26/08
2/26/08
2/26/08