ML101450192
| ML101450192 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/2010 |
| From: | Mcginty T, Tracy G Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| Cheung C, NRO/DCIP, 301-415-2043 | |
| References | |
| RIS-08-005, Rev 1 | |
| Download: ML101450192 (11) | |
See also: RIS 2008-05
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
WASHINGTON, DC 20555-0001
DRAFT
NRC REGULATORY ISSUE SUMMARY 2008-05, REVISION 1,
LESSONS LEARNED TO IMPROVE INSPECTIONS, TESTS,
ANALYSES, AND ACCEPTANCE CRITERIA SUBMITTAL
ADDRESSEES
All holders of or applicants for a power reactor early site permit (ESP), combined license (COL),
standard design certification (DC), standard design approval, or manufacturing license under
Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and
Approvals for Nuclear Power Plants.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to communicate good practices associated with the quality, clarity, and inspectability of
inspections, tests, analyses, and acceptance criteria (ITAAC) submitted as part of applications
for ESPs, standard DCs, or COLs. This RIS also recommends that applicants, vendors, and the
NRC maintain complete and consistent ITAAC lists. Addressees should consider incorporating
these practices into their applications to provide for a more efficient inspection and ITAAC
closure process. No specific action or written response is required.
RIS 2008-05, Revision 1, expands on issues that were identified in RIS 2008-05, Lessons
Learned to Improve Inspections, Tests, Analyses, and Acceptance Criteria, dated February 27,
2008 (Agencywide Documents Access and Management System (ADAMS) Accession
No. ML073190162), and incorporates several new issues. Additional information appears in
Regulatory Guide (RG) 1.215, Guidance for ITAAC Closure under 10 CFR Part 52 (ADAMS
Accession No. ML091480076), which endorses the methodologies described in the industry
guidance document Nuclear Energy Institute (NEI) 08-01, Industry Guideline for the ITAAC
Closure Process under 10 CFR Part 52, Revision 3, issued January 2009 (ADAMS Accession
No. ML090270415).
BACKGROUND
As required by 10 CFR Part 52, applicants for ESPs, standard DCs, or COLs 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 are 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 COL, a licensee completes the
RIS 2008-05, Rev. 1
Page 2 of 10
ITAAC in the license during construction and submits notification letters to the NRC in
accordance with 10 CFR 52.99, Inspection during Construction. The NRC 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
On the basis of a review of recent ITAAC submittals to the NRC, the staff has identified five
general categories in which ITAAC submittals could be improved: (1) ITAAC format and
content, (2) ITAAC nomenclature and language, (3) ITAAC focus, logic, and practicality,
(4) ITAAC standardization and consistency, and (5) ITAAC scope.
ITAAC FORMAT AND CONTENT
Applicants should consider using a consistent system to identify and number individual
ITAAC within their applications. Although past submittals have typically used an
alphanumeric system, some submittals used dashes or separate paragraphs with no
labels in the body of the text to specify separate ITAAC requirements. In other
submittals, the alphanumeric designations were not consistently aligned for the
applicable ITAAC tables. Use of a standard and consistent ITAAC identification system
will facilitate ITAAC closure activities.
Applicants should consider a standard methodology for identifying and organizing the
structures, systems, and components (SSCs) associated with an ITAAC to enable a
more efficient inspection and ITAAC closure process. For example, if an applicant
chooses to organize SSCs in a tabular format (as opposed to system drawings), it could
group instrumentation-related components (e.g., sensors) separately from mechanical
components. The applicant could also list mechanical components, or a group of
components that are likely to be close together, in similar categories (e.g., pumps,
valves).
Applicants should avoid the integration of several different engineering or construction
areas into a single ITAAC. For example, one applicant put all of the American Society of
Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements and the
pipe break analyses for all of the plants piping into only two ITAAC. In another instance,
an applicants definition for a systems basic configuration included five separate
engineering and construction processes, the applicability of which had to be interpreted
to determine the required ITAAC for each. In both cases, the ITAAC were ill-defined and
unwieldy.
COL applicants should consider aggregating into one complete ITAAC list all of the
ITAAC contained in both the certified design and the COL. Because this complete
ITAAC list would include all ITAAC applicable to a specific COL, it would function as a
master list that could be referenced by both the NRC and the applicant (or licensee)
throughout construction until the Commission makes a 10 CFR 52.103(g) finding.
RIS 2008-05, Rev. 1
Page 3 of 10
As a complementary measure to the development of a consistent ITAAC identification
system and an ITAAC master list, both DC and COL applicants should consider
establishing a logical process for handling, identifying, and referencing ITAAC revisions.
If a design control document (DCD) revision or COL change adds to or renumbers the
existing ITAAC, the applicant should link all new ITAAC to the existing ITAAC they
originated from through their alphanumeric designations. This renumbering protocol
would facilitate the closure of any new ITAAC by correlating available information with
the planned inspection activities for the ITAAC already approved. Both licensee and
NRC inspection processes would then be able to efficiently coordinate existing
inspection results and conclusions with the revised ITAAC.
ITAAC NOMENCLATURE AND LANGUAGE
Applicants should clearly define all terms used in an ITAAC. The following are examples
of confusion caused by undefined terms:
-
It was unclear whether an applicant using the terms design reports and
reports in an ITAAC involving ASME Code piping and welding intended the
ASME Code definition for design report and data report or its own definition
for these terms.
-
An applicant frequently used the term as-installed but did not define it. The
applicant was using this term as a substitute for as-built, which it did define.
Substitution of undefined but similar terms for as-built is not recommended.
Even when the applicable DCD defines ITAAC terms and phrases, applicants should
ensure that such ITAAC word usage is consistent with industry-accepted guidance. For
example, Section 8.6 of NEI 08-01, Guidance for Inspections, Tests or Analyses
Performed at Other Than Final Installed Location, as endorsed by NRC RG 1.215,
discusses several examples of the already defined term, as-built, in the context of how
an as-built condition can be correctly interpreted in various ITAAC applications.
Applicants should specifically consider this guidance (not only in Section 8.6, but also
elsewhere in NEI 08-01) when developing ITAAC to submit for approval.
If applicants use such terms as interfacing systems, control room features, minimum
set, seismic structure, equipment qualification, physical separation, fast-closing
valves, and rapid depressurization, they should clearly define themor at least
quantify the adjectives usedfor inspection purposes. For example, the term
equipment qualification, if not clearly defined, could be associated with the specific
requirements for environmental qualification (EQ) given in 10 CFR 50.49,
Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power
Plants.
Use of the conjunction and/or is never appropriate.
If applicants use the phrase a report exists and concludes that... they should specify
the scope, the type of report and how report generation is controlled. For example, the
RIS 2008-05, Rev. 1
Page 4 of 10
applicant should explain whether the scope of the report includes the design, the as-built
construction (as reconciled with the design), or any other information. This is not
necessary for reports generated in accordance with the ASME Code, as the Code itself
governs the creation of such reports.
Applicants should use specific technical terms consistently. For example, the terms
pressure test and hydrostatic pressure test are often inappropriately interchanged;
similarly, internal pressure and design pressure are used synonymously in the same
ITAAC to mean the same thing. Applicants should also take care not to confuse the
preoperational conditions with the applicable operation modes in situations involving
testing.
Applicants should avoid subjective terms, such as inclined sufficiently, acceptable
level, and adequate thickness. These terms call for interpretation to understand the
ITAAC INSPECTION FOCUS, LOGIC, AND PRACTICALITY
Applicants should avoid applying a single ITAAC to a large area of construction or to
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 example, if a single ITAAC includes 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 simpler ITAAC 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), it
may be possible to justify inspection or testing at the remote location. It may also be
possible for applicants to develop ITA that can be performed at the remote location.
(The industry guidance document, NEI 08-01, discusses modular construction, as well
as a consistent approach to the use of as-built terminology.)
Applicants should consider the timing and sequence of construction activities in the
development of related ITAAC. Breaking an ITAAC into pieces that can be completed in
the early and mid-stages of construction would help alleviate the surge in ITAAC closure
activities at the end of the process.
Applicants should develop ITAAC that require direct inspection of construction as it
occurs, rather than review of postconstruction records. For example, a design
RIS 2008-05, Rev. 1
Page 5 of 10
commitment that indicates certain buildings are constructed of reinforced concrete or are
prestressed is inconsistent with an ITA that specifies an inspection of the construction
records. The ITA should be an inspection of the actual construction to ensure the use of
reinforced concrete or prestressing as required. ITAAC inspections are intended to
physically confirm the attribute being checked. An inspection of documentation is
actually a record check, not a physical verification of the SSC attributes of concern.
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 example, the design commitment indicated that the piping
was designed and constructed in accordance with the ASME Code, but the acceptance
criteria only required the existence of design reports (which would not normally
encompass construction quality) for as-built piping. In another example, the design
commitment indicated that each standby diesel generator was sized to accommodate
expected loads, but the acceptance criteria only required the generator to provide power
at generator terminal rated voltage and frequency when at rated load. To validate the
design commitment, the applicant would first need to determine the electrical loads
presented by equipment credited in the safety analysis (e.g., by analyses or testing) and
then conduct a test to verify that the procured diesel generator could adequately supply
these loads.
Applicants should ensure that the ITA match the associated acceptance criteria. The
NRC staff has observed instances in which the ITA was inappropriate for determining
that the acceptance criteria had been satisfied. In one example, the ITA required an
inspection of a makeup water system. Although three separate acceptance criteria were
associated with this one ITA inspection, only two of the criteria were actually inspections;
the third criterion specified a flow rate, which is a test result and not an inspection
criterion. Below are three additional examples illustrating mismatches between ITA and
acceptance criteria.
- Example 1
Design Commitment
Inspection, Tests,
Analyses
Acceptance Criteria
The XYZ system has an
available volumesized
to contain approximately
400 percent of the full-
core debris.
Inspections of the as-built
system will be conducted.
The as-built XYZ system is
sized to contain 350-450
percent of the full-core
debris.
The inspection is appropriate for determining the volume of the XYZ system.
However, an inspection alone is not capable of determining whether the
measured volume can contain 350-450 percent of full-core debris, because this
amount of material has either not been determined or is not defined for the
inspection.
RIS 2008-05, Rev. 1
Page 6 of 10
- Example 2
Design Commitment
Inspection, Tests,
Analyses
Acceptance Criteria
All low-pressure coolant
injection piping and
componentsare
designed to withstand
full reactor pressure.
Inspection of the as-built
low-pressure coolant
injection pipingwill be
performed.
The as-built low-pressure
coolant injection piping and
componentsare designed
to withstand full reactor
pressure.
The inspection of piping and components can determine whether they were
installed in accordance with design. In addition to the inspection, an analyses or
test would be needed to determine whether the as-built piping and components
meet the approved design. Additionally, the applicant needs to quantify the term
full reactor pressure in the acceptance criteria.
- Example 3
Design Commitment
Inspection, Tests,
Analyses
Acceptance Criteria
Level instruments with
adequate operating
ranges are provided for
the spent fuel pool.
Inspections of the ABC
System will be conducted to
verify that level instruments
with adequate operating
ranges are provided for the
spent fuel pool.
The as-built ABC System
provides spent fuel pool
level instrumentation with
adequate operating ranges.
Pool instruments accurately
indicate pool level over
ranges.
Although an inspection is capable of checking the proper pool level range, an
inspection alone cannot determine the accuracy of the specified instrumentation.
Some form of testing or analyses is likely required to validate the pool instrument
accuracy noted in the acceptance criteria.
ITAAC STANDARDIZATION AND CONSISTENCY
Applicants should ensure consistency in ITAAC designations within their applications.
For example, a count of the ITA designations identified 33 ITAAC, but a count of the
acceptance criteria designations identified 38 ITAAC. Such an inconsistent ITAAC count
could result in problems not only during verification and inspection activities, but also
when the ITAAC are closed and the notification letters are submitted in accordance with
Applicants should ensure that ITAAC references exist and provide appropriate
information. For example, a design commitment and acceptance criteria indicated that
controls exist in the main control room, but did not specify nor provide enough
information about what actual controls must exist. Either a list of controls or a reference
RIS 2008-05, Rev. 1
Page 7 of 10
to a list would have provided the necessary information. Applicants should ensure that
the ITAAC verify the design commitment. If the existence and the functionality of the
controls are to be validated, the ITAAC should clearly state that requirement. (However,
functionality can only be verified by a test.)
Applicants should ensure that ITAAC agree with Tier 1 information. For example, the
Tier 1 definition of an EQ required type tests, or type tests and analyses, but the
associated ITA for EQ required type tests, analyses, or a combination of type tests and
analyses. This would appear to inappropriately allow analyses alone to validate the EQ.
Applicants should ensure that ITAAC agree with Tier 2 information. For example, the
acceptance criteria for one ITAAC specified that a certain valve will open within
0.89 seconds, but the Tier 2 design parameter for this valve identified a maximum of
0.7 seconds.
ITAAC SCOPE
Applicants should ensure that ITAAC are written in a clear and objective manner. In
some cases, applicants have expanded the scope of individual ITAAC in a way that
diminished the ITAACs objectivity and promoted a lack of clarity about what the ITAAC
required. Some examples follow that illustrate the generic problem of expanding the
scope of an ITAACs objectivity beyond what was intended.
-
An applicant attempted to expand the ITAAC for functional arrangement of a
system beyond the definition of functional arrangement as a physical
arrangement of SSCs to include several testing, qualification, and analytical
attributes. In this case, an ITAAC intended to be verified by an objective
inspection of the as-built system was inappropriately transformed into a catch-all
for a diverse set of technical attributes. In some cases, these separate attributes
(e.g., separate tests, physical measurements, analytical results) justified their
own unique ITAAC. This was a case where the objectivity of a simple ITAAC
was lost because its scope was inappropriately expanded.
-
Other ITAAC have used terminology that the applicant defined differently than
the NRC, thus expanding the scope of the defined term. For example, the
applicant defined the word exists using part of the definition presented in
Standard Review Plan Section 14.3, Inspections, Tests, Analyses, and
Acceptance Criteria, issued March 2007, of NUREG-0800, Standard Review
Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, which
states, the term exists, when used in the acceptance criteria, means that the
term is present and meets the design description. Unfortunately, the second
part of the section is not quoted by the applicant, which states that, "detailed
supporting information on what should be present is contained in
thestandard safety analysis report. This clarifying sentence implies that what
should be present is something that can be seen to be inspected. Several
criteria described in the design description (e.g., EQ, seismic qualification, design
attributes, and, most importantly, functionality) cannot be seen. Therefore, the
RIS 2008-05, Rev. 1
Page 8 of 10
scope of any ITAAC using the term "exists" might be inappropriately expected to
include attributes (like functionality in accordance with the design) that cannot be
validated by only an inspection that something exists. This is another case in
which an objective ITAAC may be improperly expanded to include the scope of
attributes that cannot be verified by the inspection. Below is an example of an
ITAAC that illustrates improper use of the term exist.
Design Commitment
Inspection, Tests,
Analyses
Acceptance Criteria
Controls exist in the
Main Control Room.
Tests will be performed for
the existence of control
signals from the Main
Control Room.
Controls exist in the Main
Control Room.
The ITAAC should have enough detail to describe what is being verified.
Although the necessary information may be included in the DCD, it is neither
provided in the ITAAC nor provided by reference to any other detailed
information or tables that would adequately support licensee inspection or NRC
verification.
Applicants should ensure that revisions to ITAAC are thoroughly reviewed and the
extent-of-condition fully evaluated and resolved. Applicants should check revisions to
ITAAC for applicability to all related system ITAAC and also for the impact of referenced
SSC table revisions. ITAAC reviews should include verification checks for extent-of-
condition applicability, especially in situations involving ITAAC revisions or ITA activities
that generically apply to similar systems or components.
-
For example, the ITAAC for one system refer to tests of motor-operated valve
(MOV) functions and squib valve functions. The ITAAC references a table
identifying the related valves and their respective functions. However, an ITAAC
for a similar safety-related system that also employs MOVs and squib valves with
active functions refers only to MOV tests and inappropriately neglects the squib
valve tests.
-
In the previous example, the applicant later revised the referenced table to
change the active function of the MOV to none. However, the ITAAC written to
test the operation of the MOV was never deleted. This entire ITAAC was no
longer applicable because there was no active function for the MOVs associated
with this ITAAC.
BACKFIT DISCUSSION
This revised RIS provides addressees information to aid in the submittal of ITAAC as part of
their applications for ESPs, standard DCs, or COLs and does not represent a new or different
NRC staff position on the implementation of 10 CFR Part 52. It does not create or impose any
RIS 2008-05, Rev. 1
Page 9 of 10
new or different applicable NRC staff positions inconsistent with 10 CFR Part 52. It requires no
action or written response beyond what is required in 10 CFR Part 52.
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 was not published in the Federal Register because
this RIS is informational and does not represent a departure from current regulatory
requirements. However, the NRC posted this RIS on the NRC Public Web site for comment 30
days. These comments will be considered before the issuance of this RIS.
CONGRESSIONAL REVIEW ACT
This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. 801-808) and,
therefore, is not subject to the Act.
PAPERWORK REDUCTION ACT STATEMENT
This RIS contains existing information collection requirements that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were approved by the
Office of Management and Budget, approval number 3150-00151.
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.
RIS 2008-05, Rev. 1
Page 10 of 10
CONTACT
This RIS requires no specific action or written response. Please direct any questions about this
matter to the technical contact listed below.
Timothy McGinty, 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) 415-2043
calvin.cheung@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.
Page 10 of 10
CONTACT
This RIS requires no specific action or written response. Please direct any questions about this
matter to the technical contact listed below.
Timothy McGinty, 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) 415-2043
Calvin.Cheung@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.
ADAMS Accession Number: ML101450192
OFFICE
CTSB:DCIP:NRO
Tech Ed.
TL:CTSB:DCIP:NRO
BC:CTSB:DCIP:NRO
OGC (CRA)
NAME
CCheung
KAzasiah
RLaura
MKowal
SCrockett
DATE
5/27/2010
6/18/2010
5/27/2010
5/28/2010
6/17/2010
OFFICE
D:PMDA:NRO
OIS
D:DIRS:NRR
D:DNRL:NRO
NAME
NHilton
BGusack
TDonnell
FBrown
DMatthews
DATE
6/14/2040
5/28/2010
6/7/2010
6/15/2010
6/8/2010
OFFICE
DD:DCI:R-II
D:DORL:NRR
LA:PGCB:NRR
PM:PGCB:NRR
NAME
COgle
JGiitter
MZobler
CHawes CMH
SStuchell
DATE
6/15/2010
6/22/2010
7/19/2010
07/20/2010
/ /
OFFICE
BC:PGCB:NRR
D:DCIP:NRO
D:DPR:NRR
NAME
SRosenberg
GTracy
TMcGinty
DATE
/ /
/ /
/ /