ML14031A159

NEI 08 01 Revision 5 Comments - 2014-01-30

ML14031A159
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/23/2014
From:	Steven Bloom NRC/NRO/DCIP/CITB
To:	Bell R Nuclear Energy Institute
Bloom S, NRO/DCIP/IGCB, 415-2431
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ML14031A195	List: ML14031A159 ML14031A160
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Download: ML14031A159 (20)

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Number Comment Explanation 1.0 On page 2, add All ITAAC Complete Notification to the list This is editorial and at the bottom and also list guidance for the content of does not affect the ITAAC Post Closure Notifications. staffs ability to endorse NEI 08-01.

3.0 On page 6, 1st paragraph: The title of the SRP section This is editorial and should not be abbreviated; it should be Inspections, Tests, does not affect the Analyses, and Acceptance Criteria. staffs ability to endorse NEI 08-01.

3.1 On page 7, 3rd paragraph: 1st line, revise NRC to the This is editorial and NRC. (Was comment 3.2) does not affect the staffs ability to endorse NEI 08-01.

3.2 On page 11, first full paragraphChange to read as follows: This is editorial and The NRC may, if necessary, delay its closure verification does not affect the for a non-targeted ITAAC until at least some ITAAC staffs ability to inspections have been completed for targeted ITAAC in a endorse NEI 08-01.

particular ITAAC family to confirm that the licensees performance within that ITAAC family is satisfactory.

3.3 On page 11, second full paragraph, first sentence -Change This is editorial and to read as follows: After verifying that the prescribed does not affect the inspections, tests, and analyses in the ITAAC have been staffs ability to performed and the acceptance criteria met, the NRC will endorse NEI 08-01.

issue notices of its verification of the successful completion of those inspections, tests, and analyses at appropriate intervals.

3.4 On page 11, third full paragraph, second sentence This is editorial and Change to read as follows: If the NRC verifies after an does not affect the ITAAC Closure Notification has been submitted that an staffs ability to ITAAC was, in fact, not met, the licensee would be subject endorse NEI 08-01.

to an ITAAC Finding if verified by subsequent NRC inspections.

4.0 On page 22, sentence above 4.1, there are 2 words in. This is editorial and does not affect the staffs ability to endorse NEI 08-01.

5.0 On page 26, first two linesChange to read as follows: This is editorial and Completion Packages is available to support efficient NRC does not affect the ITAAC inspections. staffs ability to endorse NEI 08-01.

6.0 On page 27, second full paragraph, fifth sentence This is editorial and Change to read as follows: The ICN should also be does not affect the written with the expectation that the reader is staffs ability to someone who is appropriately informed about and endorse NEI 08-01.

familiar with applicable NRC regulations, licensing requirements and technical and/or engineering concepts related to ITAAC.

1 Enclosure

7.0 On page 29, 1st paragraph in Section 7.0, last sentence: Staff may add a Recommend removing the sentence because the validity of clarification on the timing this sentence depends on the timing of the issuance of the of the notice of intended notice of intended operation. operation to RG 1.215.

7.1 On page 30, 4th paragraph, 2nd sentence: To illustrate the This is editorial and does use of the template for ITAAC-specific attachments, an not affect the staffs example of an Uncompleted ITAAC Notifications for ability to endorse NEI specific Remove the s after Notifications. 08-01.

8.0 On page 33, paragraph above Section 8.2: ITAAC are only This is editorial and does in effect until fuel load so this needs to be taken into not affect the staffs account. (This was NRC staff comment 8.1 in a previous ability to endorse NEI round of comments - industry stated they modified the 08-01.

paragraph, but the paragraph was not modified). Please add as proposed in Attachment 2 to the July 18, 2013, NEI 08-01, Revision 5 submittal: To support the Section 52.103(g) finding, the licensee is responsible..

9.0 On page 39, top of the page, it appears that the following After further sentence was removed from the previous version, In these consideration, the staff cases, the ITAAC should specify that system tests were has determined that the performed at other than the final installed location. The language in Section 9.1 staff believes that the sentence should be restored, and is sufficient as is.

revised as, In these cases, the ICN should specify that Section 9.7 covers cases system tests were performed at other than the final installed where system tests were location. performed at other than the final location and the plant design did not specifically provide for testing to be performed at a module fabrication or other manufacturing facility.

D-1 On page D1-1 in the ITAAC Determination BasisAfter the Not necessary, since this first sentence, add the following sentence: For partial template is for a submittals, it will be stated here what portions of the complete ICN, not a ITAAC were completed. partial ICN. Sufficient guidance on partial ICNs is given elsewhere.

On page D1-2 in the ITAAC Determination Basis, first partial This is editorial and does paragraph, second sentenceChange as follows: If there not affect the staffs are multiple ITAAC associated with a given Design ability to endorse NEI Commitment, licensees should so state and should identify 08-01.

the specific purpose and scope of the particular ITAAC that was closed by the licensee.

On page D1-2 in Determination Basis, fourth full paragraph, Not necessary, since this last sentence.After the last sentence add the following: template is for a For partial ICNs, there will be no concluding statement until complete ICN, not a the final ICN covering the entire ITAAC is submitted. partial ICN. Sufficient guidance on partial ICNs 2

is given elsewhere.

On page D1-3 in the ITAAC Finding Review section, third This is editorial and does sentenceChange to read as follows: Alternatively, the ICN not affect the staffs will provide a justification for why the NRC may issue its ability to endorse NEI Section 52.99 determination of successful ITAAC completion 08-01.

despite the existence of uncompleted corrective actions.

On page D1-3, last sentence in the ITAAC Completion Not necessary, since this Statement--- Add the following sentence after the last template is for a sentence: This will not be required in a partial ICN. complete ICN, not a partial ICN. Sufficient guidance on partial ICNs is given elsewhere.

On page D1-4, under ReferencesChange item 3 as Staff will add clarification follows: Relevant inspection or test or analysis procedure. to RG 1.215.

On page D1-4, under ReferencesAdd item 5 as follows: Not necessary, since Relevant ICN for another associated ITAAC. unless the ICN a references a different ICN, there are no other relevant ICNs. The identification of a relevant ICN in the references section is a situation-specific matter that need not be addressed in the general template.

D-2 On page D2-1, this ICN is composed of thirteen ITAAC The staff is unable to (numbers 799 - 811 in the Vogtle and Summer COLs), for endorse this ICN which separate ICNs must be submitted to the NRC. Please example as written.

revise this ICN to only show one of the thirteen ITAAC which Section 6.0 specifies that are incorporated in this example. an ICN is required for each individual ITAAC; therefore, one ICN needs to be written for one of the ITAAC contained within this example. In addition, the Determination Basis does not adequately specify how the Acceptance Criteria were met, specifically, the numerical distances. In the template D-1, it states that for those ITAAC where the acceptance criteria 3

contain a numerical value(s), the IDB should provide the numerical results; this example does not contain this level of detail.

On page D2-3, 4th paragraph under ITAAC Determination This is editorial and does Basis: Raceway completion and cable route were not affect the staffs validated. ability to endorse NEI 08-01.

On page D2-4, 2nd paragraph: Those separation distances This is editorial and does less than those specified by the ITAAC criteria and not not affect the staffs provided with enclosed raceways or barriers have been ability to endorse NEI analyzed and determined to be satisfactory. The Cable 08-01.

Separation Final Report (Reference 3) is available for NRC inspection at the {Licensee} site.

D-3 On page D3-1, Subject line should state Completion of {Site Staff will add a Name and Unit #} consistent with most of the other ICNs. clarification to RG 1.215.

When the licenses are issued, the ITAAC will be contained in an appendix to the COL, which is the appropriate reference in an ICN since it is possible that the site-specific ITAAC could represent a departure from the DCD ITAAC.

To the extent that industry wishes to identify the ITAAC in the ICN example as coming from a particular technology, the Appendix D-3 header already performs this function. This is a generic comment for ICNs that identify vendor technology in the subject line.

On page D3-1, ITAAC Determination Basis, first paragraph, This is editorial and does second sentence: Why is ASTM E119 identified as not affect the staffs (Reference 2) when it is not listed in the references? ability to endorse NEI 08-01.

Page D3-1, end of first paragraph and beginning of 2nd Not necessary, since paragraph discusses a nationally recognized testing individuals familiar with laboratory (NRTL), but does not specify which laboratory this topic would and therefore, the NRC is not sure what listed and design understand the requirements are being referenced. associated NRTLs for this ITAAC.

D-4 On page D4-2, 1st paragraph, 2nd sentence: Revise to state This is editorial and does The tests were designed to verify that each of the two not affect the staffs CAMS Class 1E radiation monitoring channels in each of the ability to endorse NEI two divisions met the design commitments. 08-01.

On page D4-2, 2nd paragraph, 2nd sentence: Revise to state Not necessary, since the The design and installation of CAMS related equipment ICN states that the maintained the independence in accordance with ITAAC was complete Regulatory Guide 1.75 (Reference 4) as identified using Regulatory Guide 1.75.

4

On page D4-2, 3rd paragraph from the bottom states Cable Not necessary, since the routing within cabinets was Can the ICN discuss the relationship is relationship between the cabinet, divisions and channels? adequately described in How many cabinets make up a division and/or how many the ICN.

channels are in a division?

On page D4-2, why is there no reference to electrical Not necessary, since isolation as stated in the ITAAC 3b? If electrical isolation ITAAC was completed was not required, it should be so stated. using physical separation.

D-5 On page D5-2, in the 3rd bullet, spell out SRV. This is editorial and does not affect the staffs ability to endorse NEI 08-01.

On page D5-2, why does the ITAAC Determination Basis not Not necessary, since define what is Class 1, 2, and 3 piping? individuals familiar with this topic would understand the definition of Class 1, 2, and 3 piping.

On page D5-2, is the specificity offered in this ICN for ASME Not necessary, because references consistent with other ICN examples? citing the specific ASME section is not necessary; however, it could be beneficial, as a reference for the staff, for the ICN to cite the specific ASME Code section.

D-6 Page D6-3,

References:

Global comment - the numbers This is editorial and does should not be italicized. not affect the staffs ability to endorse NEI 08-01.

D-7 On page D7-1, ITAAC Determination Basis, 2nd sentence: This is editorial and does This ITAAC was completed when the piping identified in not affect the staffs Table 2.1.22 (Attachment A), which is encompassed within ability to endorse NEI the respective piping system(s) Code Symbol N-Stamp and 08-01.

the corresponding piping system(s) Code N-5 Data Report Form(s) ABC (Reference 2), was completed. This seems to indicate that the piping was completed, please revise to say installed.

On page D7-1, ITAAC Determination Basis, 3rd sentence: Not necessary, since the Are all these type of NDE tests conducted for each weld or ASME Code specifies only some of them? which types of NDE are needed for pressure boundary welds.

D-8 Under ITAAC Determination Basis, please specify if the Not necessary, since the 5

methodology was approved by the NRC. methodology is in accordance with the ANSI standard.

On page D8-2, why is it not stated here what is meant by Not necessary, since the loop inaccuracies, response testing, and maintenance or referenced ANSI replacement of instrumentation in regard to the methodology standard defines these for determining setpoints? terms.

References are incorrect in the 1st full paragraph on page The staff is unable to D8-2. endorse this ICN example as written.

There are several instances where the explanation of the method for completing the ITAAC consists of referring to a reference number, where the reference is clearly incorrect. For example, on page D8-2, the first full paragraph, contains Reference 1, as one of the references for the inspections for the PMS setpoints and calculating instrument and loop uncertainty setpoints.

However, Reference 1 is NEI 08-01, and therefore the ICN incorrectly refers to the appropriate references. Such errors would not allow the NRC staff to complete its verification review.

D-9 Under ITAAC Determination Basis, specify the number of Not necessary, since the locations/structures which were inspected? ITAAC deals with the ability of the structures to withstand design basis loads and not the measurement of the thickness.

On page D9-2, ITAAC Determination Basis, fifth paragraph, This is editorial and does first sentence: Should not the codes and standards referred not affect the staffs to here be stated and referenced? ability to endorse NEI 08-01.

D-10 On page D10-2, 2nd paragraph: Twice the paragraph says This is editorial and does quality program, should this not state quality assurance not affect the staffs 6

program? ability to endorse NEI 08-01.

On page D10-2, ITAAC Determination Basis - Why is there Not necessary, since the no mention here of the fact that this ITAAC verifies that there ICN does discuss the are controls for the design of both safety related and non- controls for the design of safety related SSCs in accordance with the QA programs of safety and non-safety each? related SSCs.

D-12 Under ITAAC Statement, where is the Design This is editorial and does Commitment? not affect the staffs ability to endorse NEI 08-01, EP ITAAC are written differently.

On page D12-3 for ITAAC 2.3-1.8.1.5 under ResultsWhy Not necessary, because does the result state that backup power supply was tested the licensees activities when this ITAAC is only for an inspection? encompassed the required inspection and ensured that the backup power supply was available as required by the acceptance criteria.

On page D12-3, last sentence: Should not say Offsite The staff is unable to Support Center, but should say onsite operations support endorse this ICN center? example as written. The ITAAC describes the emergency facilities as being onsite; however, the conclusion statement for the ICN stating that the acceptance criteria were met discusses an offsite facility.

D-13 On page D13-1, in purpose paragraph: Spell out GDCS. These are editorial and do not affect the staffs On page D13-1, ITAAC Determination Basis: Spell out ability to endorse NEI RPV. 08-01.

On page D13-2, first paragraph, 2nd sentence -This ITAAC Not necessary, since the is for testing however it is stated that visual checks were visual check was made which is an inspection. What is the testing element of necessary to complete this ITAAC? the test and verify the acceptance criteria.

On page D13-2, ITAAC Finding Review: Global comment, This is editorial and does be consistent with This review identified X ITAAC findings, not affect the staffs listed below: The X should be written as{X}. ability to endorse NEI 08-01.

D-15 Under ITA and Acceptance Criteria, need to specify, not just It is not necessary to reference, Tier 1 information. address any of these 7

comments because this Under ITAAC Determination Basis, you need to summarize is a reference ITAAC, the methodology used, and the results. and the completion of the referenced ITAAC is On page D15-1, ITAAC Determination Basis - Would it not all that is required.

be better to have chosen ITAAC Item 7 of Table 2.2.1-3 to show the ICN for containment isolation instead of the ICN for reference ITAAC Item 8.a of Table 2.2.3-4 (from the Subject line)?

D-16 On page D16-1, ITAAC Determination Basis, first The staff is unable to sentenceWhy does this sentence refer to ITAAC Table endorse this ICN 2.3.3-2 instead of ITAAC Table 2.1.1-2 (from Subject line)? example as written. The Determination Basis refers to Tier 1 Table 2.3.3-2, which does not exist and which is not the correct reference to find the key dimensions and acceptable variations of the as-built RPV. The Determination Basis should refer to the Table 2.1.1-2.

On page D16-2, 2nd paragraph: Revise the sentence to add The staff is unable to the preposition of {Licensee} Procedure XYZ, Material endorse this ICN Receipt, (Reference 3), establishes and governs the process example as written. The used for performing and documenting receipt inspections of sentence without the components such as the RPV delivered to the site. word of creates confusion to the staff and the intent of the sentence would not necessarily be clear to a reasonable person.

On page D16-2, since inspections were at a vendor location The staff is unable to instead of the as-built location, why is there no technical endorse this ICN justification provided in the ICN or a reference in the ICN to example as written.

a standard technical justification in NEI 08-01? Page 38 of the NEI guidance (Section 9) states The ITAAC Completion Package and the ITAAC Closure Notification description of as-built ITA performed on SSCs at other than the final installed location should identify the applicable generic technical justification(s) provided in Sections 9.1 8

- 9.6. This ICN does not identify the applicable technical justification, while Example D-100 does.

D-17 On page D17-2, since inspections were at a vendor location The staff is unable to instead of the as-built location, why is there no technical endorse this ICN justification provided in the ICN or a reference in the ICN to example as written.

a standard technical justification in NEI 08-01? Page 38 of the NEI guidance (Section 9) states The ITAAC Completion Package and the ITAAC Closure Notification description of as-built ITA performed on SSCs at other than the final installed location should identify the applicable generic technical justification(s) provided in Sections 9.1

- 9.6. This ICN does not identify the applicable technical justification, while Example D-100 does.

D-18 On page D18-1, ITAAC Determination Basis, the 1st This is editorial and does sentence says engineering; is this the department or does not affect the staffs it mean something else? ability to endorse NEI 08-01.

D-21 Under ITAAC Determination Basis, discuss what tasks are The staff is unable to necessary. endorse this ICN example as written. The ICN states that the procedure addresses tasks which are performed to determine that adequate security facilities and equipment support the Security Plan. In order for the NRC staff to complete its verification review, the ICN needs to be revised to discuss what tasks are necessary to perform the ITA.

D-28 Under the purpose paragraph: Global comment, when Staff will add a referring to a Table, it should not be to the DCD but to the clarification to RG 1.215.

COL.

9

Under ITAAC Determination Basis, specify the pressure Not necessary, since the and the results of the hydrostatic testing, possibly in a table. hydrostatic test was performed in accordance with ASME Code Section III.

On page D28-2, under ITAAC Determination Basis, 1st Not necessary, since paragraph: Are the N-5 Data Reports part of the ASME individuals familiar with Code report? this topic would understand the different ASME reports.

On page D28-2, under ITAAC Determination Basis, 2nd Not necessary, since paragraph: What is the difference between the purpose of individuals familiar with the Code Data Report (Reference 2) and the Hydrostatic this topic would Testing Report for each ASME component? The difference understand the definition should be stated and the purpose of each indicated. of Class 1, 2, and 3 piping.

On page D28-2, under ITAAC Determination Basis, 2nd The staff is unable to paragraph: Last sentence says The pressure testing endorse this ICN (hydrostatic or pneumatic) results of the . The ITAAC is example as written. The for a hydrostatic test, therefore it cannot be performed as a pressure testing cannot pneumatic test. be performed using pneumatic methods, only as a hydrostatic test.

Page D28-4, the top of the page is very confusing, because This is editorial and does it lists 2 Attachments. not affect the staffs ability to endorse NEI 08-01.

In addition, the Table should not refer to the DCD but to the Staff will add a license. clarification to RG 1.215.

D-29 On Page D29-1, under ITAAC Determination Basis: This is editorial and does Global comment, you need to be consistent that information not affect the staffs to be included should be in { }. ability to endorse NEI 08-01.

On page D29-2, under ITAAC Determination Basis, 2nd Not necessary, since paragraph - Each component listed in Tier 1 Table 2.3.61 individuals familiar with as ASME Code Section III was fabricated in accordance with this topic would the DCD and the ASME BPVC Section III requirements. In understand the ASME addition, does each of these components have a Design requirements.

Specification which is required by ASME Code Section III?

If a Design Specification is required, is this also described in the Design Report referred to in this ITAAC Determination Basis?

Not necessary, since 10

On page D29-2, under ITAAC Determination Basis: What individuals familiar with is the purpose of the reconciliation process referred to for this topic would piping systems in connection with the ASME Code Section understand the ASME III components contained within each of those piping requirements.

systems? Are not the components finalized in terms of fabrication before the reconciliation process takes place?

On page D29-2, 2nd paragraph: What are the differences Not necessary, since between the individual component ASME Section III Code individuals familiar with Data Reports and the ASME Section III N-5 Code Data this topic would Report(s) ABC which are discussed, related to the understand the ASME fabrication and design of the components, in the ITAAC requirements.

Determination Basis? Should these differences be called out and explained?

On page D29-3rd paragraph: Spell out QA. This is editorial and does not affect the staffs ability to endorse NEI 08-01.

D-30 On page D30-1, ITAAC Determination Basis, specify the Staff will add a article of ASME, if possible. clarification to RG 1.215.

Citing the specific ASME section is not necessary; however, it could be beneficial, as a reference for the staff, for the ICN to cite the specific ASME Code section.

On page D30-2, ITAAC Determination Basis, what elements Not necessary, since the of the weld did the NDE verify? ASME Code specifies which types of NDE are needed for pressure boundary welds and what the NDE will detect.

D-31 On page D31-2, ITAAC Determination Basis: Specify the Not necessary, since the pressure and results of the hydrostatic test, possibly in a hydrostatic test was table and through the use of a diagram. performed in accordance with ASME Code Section III.

D-32 On page D32-2, ITAAC Determination Basis, 2nd paragraph, This is editorial and does 1st sentence: Add the word bounding in the following part not affect the staffs combination of bounding type tests and analyses. ability to endorse NEI 08-01.

D-33 On page D33-2, ITAAC Determination Basis, 2nd paragraph, This is editorial and does 2nd sentence: Add the words under conditions in the not affect the staffs following part the prescribed tests under conditions where ability to endorse NEI the 08-01.

Under ITAAC Determination Basis, in the 3rd paragraph, Not necessary since the 11

specify what types of faults were tested. In the last ICN discusses the tests paragraph, specify/list which isolation devices prevent being performed per credible faults. In addition, the 1st sentence say that the IEEE 384. If the testing most severe credible faults injected however, the of the isolation devices acceptance criteria says prevent credible faults therefore, was demonstrated under this implies all faults. the most severe credible fault and the isolation devices passed, then this is a bounding scenario and encompasses all credible faults discussed in IEEE 384.

The description discusses isolation barrier devices, should This is editorial and does this be isolation devices? not affect the staffs ability to endorse NEI 08-01.

On page D33-2 in the first and third paragraphsThe first Not necessary, since the paragraph refers to isolation barrier components (relay information is contained isolation and inductive isolation (transformer coupled)), and in the AP1000 DCD and the third paragraph refers to fiber optic links. What is the associated technical connection between the isolation types referred to in the first reports.

and third paragraphs and should not that be indicated here?

D-35 On page D35-1, the Design Commitment discusses lightning Not necessary, since the protection; however, the ITAAC Determination Basis does topic is contained in not discuss any lightning protection system. another ITAAC On page D35-2, ITAAC Determination Basis: The Not necessary, since a inspection verifies visual observations of connections of voltage check is not equipment grounding system. Should there not also be a needed per RG 1.204 voltage test to verify the voltage for each equipment and IEEE standards.

enclosure, metal structure, metallic tank, ground bus of switchgear assembly, load center, motor control center, and control cabinet being grounded is at ground potential and not above it, similar to the resistance verification?

On page D35-2, ITAAC Determination Basis, 2nd paragraph, The staff is unable to 2nd sentence: The equipment grounding system connects endorse this ICN to the station grounding grid via XX discreet connection example as written. The The word is misspelled, should be discrete. word discreet is defined, among other things: unobtrusive; unnoticeable. The staff believes that the word should be discrete, which means:

constituting a separate entity or individually distinct.

12

This is editorial and does not affect the staffs Also, put the XX into {XX}. ability to endorse NEI 08-01.

D-39 On page D39-1, ITAAC Determination Basis: The Not necessary, since the description states that the components exist in the ICN specifies the component location, and the table only specifies a building. methodology used for The locations should be more specific to perform their the inspections and that intended function. these inspections verify that the installed radiation monitors have the appropriate nominal detection range to provide indication of unusual radiological events For Steam Generator Blowdown and Main Steam Line there Not necessary, since the are two different monitors in the same building, they cannot ICN specifies the be at the same location in that building in order to serve their methodology used for intended purposes. Even providing an elevation level would the inspections and that be more specific. these inspections verify that the installed radiation monitors have the appropriate nominal detection range to provide indication of unusual radiological events.

D-40 On page D40-1, ITAAC Determination Basis, 2nd paragraph: Not necessary, since the Are the controls for Automatic Depressurization System requested information (ADS) Stage 4 Manual Actuation Controls on the Primary goes beyond the scope Dedicated Safety Panel fixed controls or virtual controls? of the ITAAC.

That should be indicated along with how many or all the controls that can make this actuation.

D-41 On page D41-2, ITAAC Determination Basis: Specify dc or Not necessary, since the ac for number of amps. requested information goes beyond the scope of the ITAAC.

Specify the results in a table. Not necessary, since the acceptance criteria of the ITAAC does not contain a numerical value; therefore, this information is not needed to verify that the ITAAC has been completed.

13

D-42 On page D42-1, ITAAC Determination Basis: Change This is editorial and does telephone page to telephone/page. not affect the staffs ability to endorse NEI 08-01.

On page D42-1, ITAAC Determination Basis, last sentence: This is editorial and does Please add (Manual zone initiation and Stored (speed dial) not affect the staffs zone initiation) after two parts. ability to endorse NEI 08-01.

On page D42-2, Manual zone initiation: What is meant by Not necessary, since alarm tone? alarm tone is sufficiently clear to demonstrate completion of the ITAAC.

This is editorial and does On page D42-2, Stored (speed dial) zone initiation: Change not affect the staffs Inspection was performed..: to Inspections were ability to endorse NEI performed... 08-01.

D-44 On page D44-2, 2nd paragraph: What parts of QME-1-2007 Staff will add a (Reference 7) are used in connection with this ICN example clarification to RG 1.215.

and qualification of valves for seismic purposes? Citing the specific QME-1-2007 section is not necessary; however it could be beneficial, as a reference for the staff for the ICN to cite the specific QME-1-2007 section.

On page D44-2, ITAAC Determination Basis: Specify the Article of ASME Code. Staff will add a clarification to RG 1.215.

Citing the specific ASME section is not necessary; however, it could be beneficial, as a reference for the staff, for the ICN to cite the specific ASME Code section.

In the 5th paragraph, specify the method used; remove the i.e. in the brackets. Not necessary, since i.e. specifically indicates that the methods following the i.e. were used and these methods encompass the entirety of the ITAAC.

D-45 On page D45-2, ITAAC Determination Basis, in the 4th Not necessary, since the paragraph, please add a table to specify the attached table contains 14

make/model/serial number used for verification. the Tag Number for each component which demonstrates that the as-built installed components are the same as the seismically qualified components.

Therefore, the make, model and serial number are not needed to verify completion of the ITAAC.

D-46 On page D46-2, first paragraphIs functional capability only Not necessary, since the to withstand the effects of earthquakes, or also for other design commitment design basis events? Crimping of pipe could be caused by defines the scope of the other design basis events also. Under ITAAC ITAAC as the SSC being Determination Basis, the 1st paragraph discusses the designed to withstand effects of earthquakes. What about other level C and D combined normal and events mentioned in Table 3.9-11 of Tier 2 of the AP1000 seismic design basis DCD? loads and the requested information goes beyond this scope.

D-47 On page D47-2, ITAAC Determination Basis, 2nd This comment is paragraph: What design conditions? addressed in the 4th comment below.

For QME-1-2007, specify what article. Staff will add clarification to RG 1.215. Citing the specific QME-1-2007 section is not necessary; however it could be beneficial, as a reference for the staff, for the ICN to cite the specific QME-1-2007 section.

Explain where the listing of tests was obtained; QME-1-2007 Not necessary, since all does not discuss all of these tests. of the tests are discussed in QME 2007.

What is the connection between these tests and the The staff is unable to completion of this ITAAC? Should not that be stated in the endorse this ICN ITAAC Determination Basis. example as written. The listing of the tests in the ICN implies that all of the tests were performed on all of the valves; however, this is incorrect. In addition, the description should identify items such as 15

the functional qualification report and application report required by ASME QME-1-2007 for NRC review.

The ICN should indicate whether the specific MOVs were qualified by direct testing, application of a test-based methodology, or extrapolation from other MOV tests.

On page D47-2, ITAAC Determination Basis, paragraph The staff is unable to after bullets: The sentence that states, Note that no end- endorse this ICN loading qualification should be revised to state that end- example as written. The loading valve testing for QME-1-2007 was done per the ICN should indicate function of the valve whether the specific valves are closed to isolate blowdown flow conditions, or opened to blow down the RCS. If either of these conditions are met, then end-loading valve qualification is required.

ASME QME-1-2007 did not anticipate an AP1000 design that opens valves (such as 14-inch ADS squib valves) to blow down the RCS. Valves that operate under blowdown conditions must satisfy end-loading qualification.

On page D47-2, ITAAC Determination Basis: Where and The staff is unable to what is Attachment A. endorse this ICN example as written. The last paragraph, refers to Attachment A identifying the Equipment Qualification Document Packages; however, there is no Attachment A in the ICN example.

Provide an example of Attachment A.

D-48 Under ITAAC Determination Basis, 4th paragraph, specify Not necessary, since the 16

the make, model and serial number in Attachment A. attached table contains the Tag Number for each component which demonstrates that the as-built installed components are the same as the previously qualified components.

Therefore the make, model and serial number are not needed to verify completion of the ITAAC.

D-50 On page D50-2, second full paragraph - The factors that Not necessary, since the weigh in determining the UA of a heat exchanger should be requested information presented here in appropriate detail with respect to how goes beyond the scope these factors affect the UA. of the ITAAC.

D-52 On page D52-2, first paragraph - Provide some detail Not necessary, since regarding what the Integrated System Validation was to individuals familiar with accomplish in regard to Human Factors Engineering (HFE) this topic would devices and what determined whether it was successfully understand that the ISV completed? In the last sentence, it states provided an process and the appropriate ISV test bed... What does the term necessary information is appropriate mean? already included in the Validation Plan which the staff has previously approved.

Also, add a reference to the HFE verification and validation Not necessary, since the implementation plan. ICN already references this plan.

D-53 On page D53-2, second paragraph - If the plant control Not necessary, since system (PLS) controls this valve, use its system acronym or there is only one plant other descriptor to identify which PLS. control system.

D-54 Under ITAAC Determination Basis, 1st paragraph, specify Not necessary since the the test load because that must be compared to the ICN discusses the tested acceptance criteria. load.

On page D54-1, ITAAC Determination Basis, 2nd paragraph Not necessary, since the

- It should be stated what crane is being tested and whether information in the ICN the load testing applies to only the hoist. specifies that the polar crane and main hoist were tested.

On page D54-1, ITAAC Determination Basis, 2nd paragraph Not necessary, since the

- Are both NUREG-0554 Section 8.2 (Reference 4), and ICN states that both the ASME NOG-1 (Reference 5) required for this testing? Are documents are used and both referenced as such in the AP 1000 DCD Tier 1 and 2? individuals familiar with Which takes precedence? this topic would understand that these are sufficient methods to 17

complete the ITAAC.

On page D54-1, ITAAC Determination Basis, 2nd paragraph Not necessary, since the

- Is there any time limit for holding the load? If it is only NOG referenced by the momentarily, it should be so stated. If it is until load stops ICN discusses how the any motion, that should be stated. test was performed.

D-100 Under ITAAC Determination Basis, 1. Surface coatings, Not necessary, since as there is no mention about coatings not transporting. the ICN is written, the density requirement is met and a transport analysis is therefore not required.

In the 1st sentence, personnel confirmed that the This is editorial and does selected The term personnel should be replaced with not affect the staffs the licensee or some other word. ability to endorse NEI 08-01.

2. Component Coatings, 1st paragraph, 1st sentence: specify Not necessary, since the what components. ICN describes the category of components to which the protective coating is applied.

Not necessary, since as Also no mention about coatings not transporting. the ICN is written the density requirement is met and a transport analysis is therefore not required.

3. Caulking, Tags and Signs, 1st sentence, explain what is Not necessary, since the meant by selected material. The 1st paragraph discusses concluding sentence in the tags, signs or caulking and that the selected material section 3 verifies that the being either steel or another material, but the acceptance material for the tags and criteria states that for the tags and signs the material is signs is either steel or either steel or another metal. another metal D-101 Under ITAAC Determination Basis, the 2nd paragraph Not necessary, since the states (following concrete placement). Are there any ICN describes the inspections performed prior to concrete placement? inspections as being performed following concrete placement.

Specify the accuracy of the survey equipment. Not necessary, since the attached table contains the results which provide an indication of the accuracy of the equipment through the use of significant figures.

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Specify the number of inspection points. Not necessary, since the ICN describes the methodology used to identify the location and frequency of inspection points to ensure measurements are representative of the entire section being inspected.

On page D101-2, first full paragraph - Should it not be Not necessary, since the stated here that nuclear island basemat thickness and thicknesses and tolerance will be in accordance with construction drawings tolerance are specified for that purpose? by the attached ITAAC table.

D-102 On page D102-2, first full paragraph - Please explain why Not necessary, since the watertight doors are referenced here since there are none ICN could be written for for this purpose for the AP1000? locations which require watertight doors.

Under ITAAC Determination Basis, specify and explain The staff is unable to what other provisions means. endorse this ICN example as written. In order for the staff to find this example acceptable, please replace other provisions with [provide a list of any other provisions used].

Demo-3 On page Demo 3-1, at the end of the 1st paragraph under The staff is unable to the ITAAC Determination Basis, it was requested at a endorse this ICN Demo February 16, 2012 public meeting to add the following example as written. The sentence: This inspection encompassed all SSCs identified staff during a in the Tier 1 design description, including those in tables and presentation on figures. functional arrangement ITAAC (ADAMS Accession No. ML120440280) provided clarifying language to ensure that this ICN specifically included Tier 1 Design Descriptions, Tier 1 Figures and Tier 1 Tables. This example does not include this language.

E-1 After the last sentence in first paragraph, add the following Staff will add a depending on which is correct. [With this letter, {Licensee} clarification to RG 1.215.

has provided the entire set of notifications for ITAAC that will 19

not be completed 225-days prior to initial fuel load. OR

{Licensee} will at a later date provide additional notifications for ITAAC that will not be completed 225-days prior to initial fuel load.]

E-2 Subject Line - Add "(ITAAC identifier should exactly match This would be a helpful the ITAAC number in the COL)" which is from the Appendix clarification, but does not D-1 template. affect the staffs ability to endorse NEI 08-01.

Design Commitment and Acceptance Criteria are missing a This is editorial and does period after the word source. not affect the staffs ability to endorse NEI 08-01.

App H On page H-3, 4th entry in the table at the top of the page, This is editorial and does change 56 to 5.6 not affect the staffs ability to endorse NEI 08-01.

10 CFR 52.103 Scheduled Fuel Load Notification content: Staff will add a The initial notification should include the anticipated date clarification to RG 1.215.

(270 days in the future) of initial loading of fuel. The updates required by 10 CFR 52.103 should include updates to the anticipated date and the reason for any change, if applicable. In determining the anticipated date, the licensee should use NRC guidance on timeframes for completion of its review and the making of the 10 CFR 52.103(g) finding.

Global Under Finding Review, why is the language different in This is editorial and does various examples notifications, make all of the language the not affect the staffs same, such as Finding or Findings. ability to endorse NEI 08-01.

Under Finding Review, the first sentence starts with the Not necessary, since the fact that the review was done in accordance with plant requested information is procedures for ITAAC completion. Is there only one contained elsewhere in procedure used for all of the ITAAC Finding Reviews? Is the NEI 08-01 and does not procedure referenced anywhere? need to be included in the ICN.

Under ITAAC Completion Statement, the 2nd paragraph Not necessary, since the says that the ITAAC are maintained using approved plant requested information is programs and procedures. Are these always the same? contained elsewhere in Are they referenced anywhere? NEI 08-01 and does not need to be included in the ICN.

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