ML20024J477
| ML20024J477 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1994 |
| From: | Stewart Magruder Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9410180287 | |
| Download: ML20024J477 (6) | |
Text
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UNITED STATES l
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j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20555-0001
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October 5, 1994 APPLICANT: NdCLEAR ENERGY INSTITUTE (NEI)
PROJECT:
CONSTRUCTION INSPECTION PROGRAM
SUBJECT:
PUBLIC MEETING OF SEPTEMBER 14, 1994, REGARDING CONSTRUCTION INSPECTION AND VERIFICATION UNDER PART 52 0F TITLE 10 0F THE CODE OF FEDERAL REGULATIONS (10 CFR)
On September 14, 1994, a public meeting was held at the U.S. Nuclear Regulatory Commission (NRC) headquarters offices in Rockville, Maryland, between representatives of the NEI and the NRC. provides a list of attendees.
The purpose of the meeting was to exchange views on the new construction inspection program and inspections, tests, analyses, and acceptance criteria (ITAAC) verificat' ion under 10 CFR Part 52.
The draft Commission paper, "ITAAC Verification and Construction Inspection Under 10 CFR Part 52," which had previously been provided to the public, was the main topic of discussion. is the hand-out material presented by NEI at the meeting.
The meeting provided an opportunity for (1) the industry to ask questions 4
about the staff's thoughts and intentions and (2) the staff to clarify its statements in the paper.
No final industry or staff positions were presented and no commitments were made at the meeting.
The first topic of discursion was the timing of completion of ITAAC.
The industry raised a concern that it appeared that the majority of the sign-offs would not come until the end of the construction process.
The staff explained that since the ITAAC are system-based, they could not be signed off until the system was completed. The staff emphasized that an ITAAC could not be signed off by the staff until the licensee had first verified that it was complete.
The sign-as-you-go (SAYGO) process was discussed next.
The staff explained that its objective for the construction inspection program is to provide lots of data points to support NRC conclusions regarding plant construction, and a SAYG0 process could effectively be implemented in conjunction with the inspection program at a const-
- ion site.
The group discussed whether individual line items in the ! J,AC could be signed off.
The consensus of the group was that they could.
On a related topic, the staff stated that they intend to provide regular notices in the Federal Reaister when inspection reports are published.
t Next, the industry raised concerns about some of the terminology used in the r
draft paper.
Soecifically, they objected to the use of the terms " compound 2,
ITAAC" and "100% walkdown." During a lengthy discussion, the industry
/
explained the reasons for their concerns.
The staff agreed to re-examine the l
use of the terms in the final version of the paper.
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. The final topic of discussion was the role of Quality Assurance (QA) in the construction process and the relationship between the licensee's QA process and ITAAC verification.
The staff pointed out that one of the primary means the construction inspection program will use to determine that a plant is built in accordance with its certified design and combined license conditions will be to validate the effectiveness of the licensee's QA process.
The group reached the consensus that licensee and NRC confidence in a licensee's QA process will be essential to final verification that ITAAC requirements have been satisfied. Additionally, it was clarified that individual construction deficiencies identified by a QA process would impact final ITAAC verification only if, after evaluation of the deficiencies, it was found that ITAAC acceptance criteria were not met.
For example, the discovery of a problem with the calibration of a gauge used in verifying a system ITAAC would constitute a QA deficiency requiring correction in accordance with the requirements of 10 CFR Part 50, Appendix B, but it would not necessarily affect the determination that the ITAAC was satisfactorily completed.
The industry expressed their appreciation for the opportunity to discuss these issues with the staff in a working-level meeting.
The staff agreed with the industry that more meetings on these topics would be helpful before a new nuclear plant is built in the United States.
M [. N Stewart L. Magrude, Project Manager Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/ enclosures:
See next page j
P r
. October 5, 1994 The final topic of discussion was the role of Quality Assurance (QA) in the construction process and the relationship between the licensee's QA process and ITAAC verification..The staff pointed out that one of the primary means the construction inspection program will use to determine that a plant is built in accordance with its certified design and combined license conditions will be to validate the effectiveness of the licensee's QA process.
The group reached the consensus that licensee and NRC confidence in a licensee's QA process will be essential to final verification that ITAAC requirements have i
been satisfied. Additionally, it was clarified that individual construction deficiencies identified by a QA process would impact final ITAAC verification only if, after evaluation of the deficiencies, it was found that ITAAC acceptance criteria were not met.
For example, the discovery of a problem 1
with the calibration of a gauge used in verifying a system ITAAC would constitute a QA deficiency requiring correction in accordance with the requirements of 10 CFR Part 50, Appendix B, but it would not necessarily affect the determination that the ITAAC was satisfactorily completed, The industry expressed their appreciation for the opportunity to discuss these issues with the staff in a working-level meeting. The staff agreed with the j
industry that more meetings on these topics would be helpful before a new nuclear plant is built in the United States.
Original signed by Stewart L. Magruder, Project Manager i
Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/ enclosures:
See next page DISTRIBUTION w/ enclosures:
Central File PDST R/F DCrutchfield PDR PMagnanelli SMagruder i
Distribution w/o enclosures:
WRussell/FMiraglia WTravers JCaldwell, 0-12E4 SHoffman, 0-IlF23 RBorchardt FGillespie AHowe, 0-12E4 WDean, 0-17G21 RArchitzel AGody, 0-12E4 JNakoski, 0-12E4 EJordan, T-4D18 JNWilson ACRS (11)
PCastleman, 0-12E4 JMoore, 0-15818 TBoyce lW 0FC:
LA:PDST:ADAR PM:PDST:ADAR SC:PWT:ADAR NAME: PMdcinanelli SMagru M RArchitzel DATE: 10/./94 10/(o/94 10/l//94 0FFICIAL RECORD COPY:
DOCUMENT NAME: MSUMNEl.914
cc:
Mr. Sterling Franks U.S. Department of Energy NE-42 Washington, D.C.
20585 Mr. Steve Goldberg Budget Examiner 725 17th Street, N.W.
Room 8002 Washington, D.C.
20503
i Construction Inspection Program Meeting September 14, 1994 Attendees Hadf ORGANIZATION S. Magruder NRC T. Boyce NRC S. Hoffman NRC J. Wilson NRC S. Brewer American Electric Power W. Ramsey Southern Co.
R. Bell NEI B. George Southern Nuclear J. Nakoski NRC P. Castleman NRC J. Caldwell NRC A. Howe NRC F. Gillespie NRC R. Borchardt NRC
~
t Industry - NRC Staff Meeting on Construction Inspection September 14,1994 Meetime Puy.
Information exchange related to ALWR construction inspection and ITAAC implementation Promote mutual understanding ofindustry and NRC staff perspectives related to ITAAC implementation and provide opportunity for industry input to the NRC staff's formative thinking in this area Obtain clariDeation of aspects of the NRC staffs draft paper, "lTAAC e
VeriGcation and Construction Inspection Under 10 CFR Part $2" Identify further opportunities for industry - NRC staffinteraction in the ALWR construction inspection area Disen*= ion Ouestions i
1.
What is the relationship between the respective implementation of(l)ITAAC, and (2) the construction QA program?
2.
How will the " basic configuration" TTAAC be implemented? What is the role, 1
relative to construction inspection, of the figures in the Tier i design?
3.
What are the NRC staff views regarding use of an ITAAC/S AYGO implementation process that is both discipline-based and system / building-based?
4.
The High Pressure Core Flooder (HPCF) example in the stafPs draft paper contains a provision for 100% walkdown of the as-huilt system as part of the
" Final Inspection" process. What is the naturc/ purpose of this "walkdown" relative to ITAAC?
5.
It appears that, given the focus is ITAAC, the " Inspection Arcas" portion of the IIPCF inspection matrix should correlate with the ten individual ITAAC elements (plus sub-elements) identified in the Tict I material for this system. What is the
.~2fTs intent regarding the HFCF inspection matrix?
j 6.
As a result of the Part 52/ITAAC process, what additional ditTerences from past practices (beyond those that may have been discussed above) are expected in the j
way plants are built and inspected, c.g., enhanced documentation /recortikeeping needs?
ENCLOSURE 2 i