ML091490692
| ML091490692 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/12/2009 |
| From: | Nuclear Energy Institute |
| To: | Office of New Reactors |
| Shared Package | |
| ML091490694 | List: |
| References | |
| DG-1204 | |
| Download: ML091490692 (7) | |
Text
Industry Comments on DG-1204, Guidance for ITAAC Closure DG Section/
Paragraph/Sentence Comment Proposed Resolution B.1 Development of Industry Clarify that ITAAC closure letters will be Revise the referenced sentence as follows:
Guideline Document NEI 08- submitted for all ITAAC identified in the COL.
01 ITAAC closure letters must be submitted for all ITAAC for which the NRC has not made a finding Second paragraph, bottom of that the acceptance criteria have been met in page 2 accordance with 10 CFR 52.97(2).
ITAAC closure letters must be submitted for all ITAAC.
B.2. Guidelines on ITAAC The last sentence could be interpreted as Delete the last sentence of the referenced Closure Development and incorporating explanatory information in paragraph so it reads as follows:
Documentation in NEI 08-01 Section 3.1.4 into the definition of as-built.
Section 3.1.4 is not part of the definition but Section 2 of NEI 08-01 provides a list of Third paragraph, middle of page rather provides supporting information for definitions for terminology used in the guide.
- 4. how licensees will need to close some of the Some of these definitions will reappear in other ITAACs. documents such as combined license Section 2 of NEI 08-01 provides applications, design certification applications, a list of definitions for While suitable as guidance, the language in and other supporting documents.
terminology used in the guide. Section 3.1.4, e.g., where inspection or Some of these definitions will test is impractical after installation, is not Alternatively, revise the last sentence as follows:
reappear in other documents appropriate to include in the definition of as-such as operating license built. To better convey the meaning of the term as-applications, design certification built, Section 3.1.4 of NEI 08-01 provides applications, and other Therefore, the third sentence should be further explanation of the intent of the definition supporting documents. Therefore, deleted. as identified below.
it is important that the full meaning of the definition be In the second sentence, operating license preserved. applications should be replaced by combined license applications.
1 May 12, 2009
Industry Comments on DG-1204, Guidance for ITAAC Closure DG Section/
Paragraph/Sentence Comment Proposed Resolution B.2. Guidelines on ITAAC The phrasing every effort should be made Replace the fourth paragraph with:
Closure Development and is vague and subject to interpretation. This Documentation in NEI 08-01 paragraph should be revised to be consistent Inspections, tests, and analyses of ITAAC SSCs with the acknowledgement that there may be should be performed in the as-built condition.
Fourth paragraph, bottom of some cases where final, in-place inspections Section 3.1.4 of NEI 08-01 acknowledges that it page 4, top of page 5. are impractical. may be impractical to perform some inspections and testing after installation in the plant. In The additional information those cases, it may be appropriate to perform included in Section 3.1.4 of NEI inspections or tests prior to final installation 08-01 places a restraint on the (e.g., measuring an interior dimension prior to use of other than final in-place final assembly of a valve).
inspections used to satisfy the prescribed inspections, tests, and analyses for ITAAC closure. The intent of the additional language in Section 3.1.4 is to limit the use of those DG-1204, Page 5 inspections to instances when the final in-place inspection is impractical. An acceptable example could be the use of a record of inspection of an interior diameter measurement before final assembly of a valve completed at a vendor location.
Every effort should be made by the licensee to complete the prescribed inspections, tests, and analyses in the SSCs at the final constructed location, or as-built.
2 May 12, 2009
Industry Comments on DG-1204, Guidance for ITAAC Closure DG Section/
Paragraph/Sentence Comment Proposed Resolution B.2. Guidelines on ITAAC NRC should reference SECY 06-0114, which Revise the referenced sentence as follows:
Closure Development and documents the commissions agreement to Documentation in NEI 08-01 use a single proprietary determination for the As described in SECY 06-0114, the NRC will construction schedule and its updates, over consider any licensee claims that the submitted Sixth paragraph, middle of page the entire life of the construction project. schedule is proprietary and should be withheld
- 5. from public release under the Freedom of Information Act and 10 CFR 2.390 (Ref. 15).
The NRC will consider any licensee claims that the submitted schedule is proprietary and should be withheld from public release under the Freedom of Information Act and 10 CFR 2.390 (Ref. 15).
B.2. Guidelines on ITAAC This sentence could be stated more strongly. Revise the referenced sentence as follows:
Closure Development and Documentation in NEI 08-01 The NRC expects the notification of ITAAC completion to contain more information than just Ninth paragraph, bottom of page a simple statement that the licensee has
- 5. completed the ITAAC and has met the acceptance criteria.
The NRC expects that the notification of ITAAC completion to contain more information than just a simple statement that the licensee believes that it has completed the ITAAC and has met the acceptance criteria.
3 May 12, 2009
Industry Comments on DG-1204, Guidance for ITAAC Closure DG Section/
Paragraph/Sentence Comment Proposed Resolution B.2. Guidelines on ITAAC It is not necessary to specify when each Revise the referenced sentence as follows:
Closure Development and inspection, test, or analysis was completed.
Documentation in NEI 08-01 Each inspection, test, or analysis should be detailed to clearly indicate how it was completed Tenth paragraph, top of page 6. and should state its results.
Each inspection, test, or analysis should be detailed to clearly indicate how and when it was completed and should state its results.
B.2. Guidelines on ITAAC It is not necessary to specify when each Revise the referenced sentence as follows:
Closure Development and inspection, test, or analysis was or will be Documentation in NEI 08-01 completed. Each inspection, test, or analysis for both completed and uncompleted portions should be Thirteenth paragraph, bottom of detailed to clearly indicate how it was, or will be, page 6. completed.
Each inspection, test, or analysis for both completed and uncompleted portions should be detailed to clearly indicate how and when it was, or will be, completed.
4 May 12, 2009
Industry Comments on DG-1204, Guidance for ITAAC Closure DG Section/
Paragraph/Sentence Comment Proposed Resolution B.2. Guidelines on ITAAC This statement is understood to be a Revise the referenced sentence as follows:
Closure Development and restatement of NRC regulations on this point.
Documentation in NEI 08-01 As such, the RG should restate Section Section 52.103(g) states, The licensee shall 103(g) (as was done in NEI 08-01, Section not operate the facility until the Commission Fourteenth paragraph, top of 3.1), rather than characterize this makes a finding that the acceptance criteria in page 7. requirement as a staff position using the combined license are met.
language that may be subject to a different The NRC staff position is that the interpretation. Clarification and guidance on licensee must satisfy all of the the meaning of Section 52.103(g) is the acceptance criteria for all ITAAC subject of ongoing discussion.
at the time that Embellishment or interpretation of the the 10 CFR 52.103(g) finding is regulation in this RG would be premature.
made.
B.2. Guidelines on ITAAC This sentence is too open-ended with respect Revise the referenced sentence as follows:
Closure Development and to what additional information may be Documentation in NEI 08-01 necessary in individual ITAAC closeout The staff considers these letters to be examples letters. and anticipates that differing or additional Top of page 8. information, consistent with Section 6 of NEI 08-01 (Guidance on Sufficient Information for The staff considers these letters ITAAC Closure Letters), may be necessary for to be examples and anticipates individual ITAAC letters.
that additional information may be necessary for individual ITAAC letters.
5 May 12, 2009
Industry Comments on DG-1204, Guidance for ITAAC Closure DG Section/
Paragraph/Sentence Comment Proposed Resolution B.2. Guidelines on ITAAC The last sentence presumes a worst case Delete the last sentence. Alternatively, revise it Closure Development and timing for DAC closeout without basis. This to read, because the closeout of the acceptance Documentation in NEI 08-01 sentence is unnecessary anyway because the criteria could be delayed until during plant staffs preference is clear without it. construction.
Sixteenth paragraph, middle of page 7.
Three scenarios exist for the closure of design acceptance criteria, namely, closure through the amendment of the design certification rule, closure through the COL application review process, and closure after COL issuance. The NRC staff prefers closure through the amendment of the design certification rule and closure through the COL application review process, as ways to satisfy and close out the acceptance criteria for those design characteristics because these two scenarios would be completed before construction begins. The staff does not prefer closure after COL issuance, because the closeout of the acceptance criteria could be delayed until the end of plant construction.
6 May 12, 2009
Industry Comments on DG-1204, Guidance for ITAAC Closure DG Section/
Paragraph/Sentence Comment Proposed Resolution C. REGULATORY POSITION The staff may always provide further Delete the sentence guidance at a later date, so this sentence is
- 4. Guidance for Site-Specific unnecessary. Retaining it would raise ITAAC questions about why additional guidance would be needed in light of there being no If necessary, the staff may difference from an ITAAC closure perspective provide further guidance or between design certification and plant-examples for use with respect to specific ITAAC.
such site-specific attributes and characteristics at a later date.
7 May 12, 2009