ML20030B356

IMC 2503 Construction Inspection Program: Inspections of Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) Related Work

ML20030B356
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Issue date:	03/04/2020
From:	Michael Webb NRC/NRR/VPOB
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NRC INSPECTION MANUAL VPO INSPECTION MANUAL CHAPTER 2503 CONSTRUCTION INSPECTION PROGRAM:

INSPECTIONS OF INSPECTIONS, TESTS, ANALYSES AND ACCEPTANCE CRITERIA (ITAAC)

RELATED WORK

TABLE OF CONTENTS 2503-01 PURPOSES ......................................................................................................... 1 2503-02 OBJECTIVES ...................................................................................................... 1 2503-03 DEFINITIONS ...................................................................................................... 1 2503-04 RESPONSIBILITIES AND AUTHORITIES ........................................................... 1 2503-05 REQUIREMENTS ................................................................................................ 2 05.01 ITAAC-related Construction Inspection ......................................................... 2 05.02 Inspection Planning ....................................................................................... 2 05.03 Inspection Results ......................................................................................... 3

a. Categories of ITAAC Inspection Results ............................................... 3

b. Assessment of Inspection Results ........................................................ 3 05.04 Enforcement.................................................................................................. 3 2503-06 GUIDANCE .......................................................................................................... 3 06.01 General ......................................................................................................... 3 06.02 ITAAC Inspection Overview .......................................................................... 4 06.03 Implementation ............................................................................................. 4 06.04 Process for the Modification of the ITAAC Target Set ................................... 6 Appendix A: IMC 2503 INSPECTION PROCEDURES ................................................. AppA-1 Appendix B: The ITAAC Matrix..................................................................................... AppB-1 Attachment 1: Revision History for IMC 2503 ................................................................. Att1-1 Issue Date: 03/04/20 i 2503

CONSTRUCTION INSPECTION PROGRAM:

INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA (ITAAC) 2503-01 PURPOSES 01.01 To specify the policy used for the NRCs inspection of the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) of a combined license (COL) or Limited Work Authorization (LWA).

01.02 To provide guidance for inspections intended to support the determination, in accordance with Title 10 of the Code of Federal Regulations Part 52, Section 103(g) (10 CFR 52.103(g)), that the acceptance criteria in the combined license have been met.

2503-02 OBJECTIVES 02.01 To provide guidance to inspectors on inspection of ITAAC-related work activities.

02.02 To provide a sufficient basis to support the determination in accordance with 10 CFR 52.103(g) that the acceptance criteria in a combined license have been met.

2503-03 DEFINITIONS 03.01 Definitions can be found in Manual Chapter 2506.

2503-04 RESPONSIBILITIES AND AUTHORITIES 04.01 Office of Nuclear Reactor Regulation (NRR). The Director, NRR, has responsibility for:

a. Providing the overall direction of the construction inspection program and directing the development and implementation of policies, programs and procedures for the construction inspection program.

b. Providing inspector resources to support and augment regional inspector resources assigned to construction projects.

c. Making the recommendation to the Commission regarding a determination pursuant to 10 CFR 52.103(g) that the acceptance criteria have been successfully completed.

Issue Date: 03/04/20 1 2503

04.02 Region II Office. The Regional Administrator has responsibility for:

a. Supporting the finding required by 10 CFR 52.103(g) by informing the Director, NRR, on the licensees completion of the ITAAC, the plants readiness to load fuel, and the overall readiness for operation.

04.03 Region II Construction Inspection Staff. The Region II staff has responsibility for:

a. Implementing the construction inspection program and documenting inspection findings.

b. Providing NRR with the status of inspections related to specific ITAAC.

c. Coordinating the development of the site inspection plans.

d. Ensuring that the necessary inspection record is maintained in the Construction Inspection Program Information Management System (CIPIMS) for determination of satisfactory ITAAC completion.

e. Integrating all the inspection findings to develop an overall assessment of licensee performance as described in IMC 2505, Periodic Assessment of Construction Inspection Program Results.

04.04 Vogtle Project Office (VPO) Staff. The VPO Staff has responsibility for:

a. Administering and monitoring the execution of the construction inspection program.

b. Ensuring the requisite inspection procedures are maintained current and accurate.

c. Maintaining and ensuring the accuracy of CIPIMS.

d. Publishing notices in the Federal Register of the successful completion of ITAAC in accordance with 10 CFR 52.99.

2503-05 REQUIREMENTS 05.01 ITAAC-related Construction Inspection. The NRC staff will perform the inspections listed in Appendix A to evaluate the licensees ITAAC-related construction activities.

05.02 Inspection Planning. The staff shall develop and maintain an inspection plan to verify that it is successfully performing ITAAC-related construction activities. This plan shall include, as a minimum, the baseline targeted ITAAC inspection requirements for the selected certified reactor design, as modified per Section 06.04, Process for the Modification of the ITAAC Target Set. The plan shall provide the level of detail necessary to determine the general time-frame in which each occurrence of an inspection procedure is to take place.

a. Use the licensees construction schedule to identify when key activities will be available for inspection.

b. The overall schedule will incorporate all of the planned inspection activities for the planned period of construction. Use the overall construction inspection schedule for Issue Date: 03/04/20 2 2503

planning of inspection resources (i.e., ensuring the required inspection skills or engineering disciplines are available when required).

c. Consider bundling ITAAC with the same or similar design commitments and inspections, tests, and analyses (ITA) during the inspection planning process to maximize efficiency and use of NRC inspection resources.

05.03 Inspection Results. NRC inspections of ITAAC-related work result in the early identification and resolution of problems, their root causes, and generic implications. Document inspection observations and inspection results in accordance with IMC 0613, Power Reactor Construction Inspection Reports.

The staff will use CIPIMS to link inspection results to the docket, the inspection report, and the specific ITAAC.

a. Categories of ITAAC Inspection Results. Because of their potential for affecting the NRCs verification of successful ITAAC completion, inspection findings will be categorized to reflect their impact on ITAAC. The documentation requirements for the different types of inspection results are described in IMC 0613.

b. Assessment of Inspection Results. NRC will periodically review inspection results to determine if it should change the level of inspection effort. The review of inspection results will focus on two factors: (1) the implementation of specific construction activities as documented in the inspection history; and (2) the implementation of the licensees corrective action program. This approach will ensure that any deficiencies that have been identified by the licensee or NRC have been adequately addressed by the licensees QA program and have resulted in effective corrective actions. The NRCs confidence in the licensees construction activities is directly related to its confidence in the quality assurance program. IMC 2505 further defines this process.

05.04 Enforcement. During the construction period, the agency will process identified violations of NRC regulations and conditions of the COL in accordance with the cROP process and the Commissions Enforcement Policy, NUREG-1600, General Statement of Policy and Procedures for NRC Enforcement Actions.

2503-06 GUIDANCE 06.01 General. When licensing a plant under 10 CFR Part 52, the Commission is required by 10 CFR 52.97(b)(1) to identify within the combined license, the inspections, tests, and analyses; including those applicable to emergency planning that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to Issue Date: 03/04/20 3 2503

provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Atomic Energy Act, and the Commissions rules and regulations.

In addition, pursuant to 10 CFR 52.103(g), the Commission shall find that the acceptance criteria (AC) in the combined license are met, prior to allowing the facility to operate. The Commission, in the Staff Requirements Memorandum (SRM) for SECY-13-0033, delegated the responsibility for the 10 CFR 52.103(g) finding to the staff.

Successful completion of the ITAAC is the responsibility of the licensee. The NRC will use inspections of construction activities to independently verify that the licensee successfully carries out construction activities and identifies and corrects deficiencies which may have an impact on the ITAAC or other construction activities. The results of the construction inspection program implemented through this manual chapter will form the basis of the staffs recommendation to the Commissions determination, in accordance with 10 CFR 52.103(g), of whether the acceptance criteria have been met.

06.02 ITAAC Inspection Overview. The NRC may begin ITAAC inspection according to this Manual Chapter when a licensee is issued a COL or an LWA that contains ITAAC. Since many of the ITAAC are oriented towards system completion, they may not be completed until construction is nearly complete. Therefore, the staff intends to implement an ITAAC inspection approach which will require NRC inspectors to observe ITAAC-related construction activities as they are performed.

The NRC has developed a framework to prioritize the ITAAC and facilitate efficient inspections.

This framework is structured to integrate complementary inspection activities that evaluate the licensees control of the construction processes. Central to the NRCs inspection program for construction under 10 CFR Part 52 is the ITAAC Matrix which provides a means for ensuring adequate inspection coverage of ITAAC inspections. The matrix will be populated with the ITAAC applicable to each certified design as described in Appendix B to this manual chapter.

Site specific ITAAC will be added to the matrix population once they have been identified.

The approach to ITAAC inspection will require inspectors to evaluate the acceptability of ITAAC-related processes. The NRC will perform sampling-type inspections of ITAAC-related activities to verify that the licensee is performing the activities successfully. The selection of the ITAAC for each design to receive direct inspection will be based on a prioritization process used to determine overall inspection value.

When the licensee notifies the NRC that an ITAAC is complete, they will also identify the bases for the ITAAC completion. NRC reviews of the licensees ITAAC closure notification, as well as any NRC inspection history for that ITAAC, will determine if the licensees ITAAC closure notification and its associated bases are satisfactory.

06.03 Implementation. The inspection program is intended to provide the framework for managing the inspection effort. How often each inspection procedure should be performed during the construction period, and when each inspection procedure occurrence should be performed will be determined during development and periodic update of the site-specific inspection plan.

Inspectors are encouraged to pursue any safety or risk significant concern. However, inspectors must identify the inspection procedure used to perform inspection activities and to Issue Date: 03/04/20 4 2503

accurately record this information and the inspection results, so they can be incorporated into CIPIMS.

Regional managers responsible for the construction inspection program shall periodically review inspection results to monitor progress on the inspection plan. Changes to the inspection plan, discussed in Section 05.03b, should be considered during periodic assessment of licensee performance per IMC 2505.

The primary objectives of the construction inspection program are: (1) to prevent a significant construction flaw from going undetected and (2) to provide a sufficient basis to support the staffs determination that the licensee performed the inspections, tests, and analyses and met the acceptance criteria.

The staff shall implement an ITAAC inspection approach primarily based on observing ITAAC-related construction activities as they are performed in-situ. However, due to the nature and the fluidity of construction schedules, the staff must remain flexible in how and when it conducts ITAAC inspections. To maximize effective use of inspection resources, staff should discuss the use of the following inspection alternatives with their inspection team leader, branch chief, or senior resident inspector.

a. ITAAC bundling: One tool useful in providing greater inspection flexibility is ITAAC bundling. ITAAC bundling is the process by which ITAAC with similar design commitments or inspections, tests, and analyses, are grouped together under one or more inspection plans to reduce the overall inspection effort including the number of inspections and inspection samples necessary to verify with reasonable assurance that the licensee has performed the inspections, tests, and analyses and met the acceptance criteria for all ITAAC within that bundle.

Ideally at least one inspection sample from each ITAAC within the bundle should be completed; however, this is not a requirement. The staffs ability to sign off a targeted ITAAC for which no direct inspection sample was completed is based on the completed inspections of the licensees program, processes and procedures related to that ITAAC and coupled with the results of the completed inspection samples from the other ITAAC within the bundle.

As with any targeted ITAAC, inspections should attempt to cover the various shifts and work crews performing the related work. Examples where ITAAC bundling would be beneficial include: structural and shielding ITAAC related to wall and floor thickness, the structural reconciliation ITAAC, seismic and environmental qualification ITAAC, ASME ITAAC, and the ITAAC related to the separation requirements for electrical cables and cable trays. Other ITAAC highly suitable for bundling are those ITAAC from the design control document (DCD) with the same design commitment that have been broken out into discrete ITAAC within the COL.

b. Crediting Inspection of Non-Targeted ITAAC: Inspection of a non-targeted ITAAC may be performed in leu of a targeted ITAAC inspection sample when a change in the licensees schedule might challenge the inspection schedule. When implementing this Issue Date: 03/04/20 5 2503

alternative, the inspector must ensure the licensees performance on the non-targeted ITAAC activity provides meaningful insight with respect to the licensees ability to meet the design commitment and perform the inspections, tests, and or analyses for the targeted ITAAC in question.

For example, a welding inspection on an ASME Section III piping system is planned for a targeted ITAAC, but due to a change in schedule the targeted sample is no longer available; however, a similar weld on ASME Section III piping for a non-targeted ITAAC is available during that on-site inspection and is on schedule. The inspection of this non-targeted ITAAC which has the same design commitment, ITA and AC would clearly provide the same insights with respect to licensee welding and NDE performance that the targeted ITAAC would have provided.

c. To maximize inspection efficiency and provide a more complete review of the ITAACs acceptance criteria, staff may perform a sample of direct inspections of the licensees performance of the ITA coupled with the subsequent review of the completed quality assurance records. This may be particularly useful for ITAAC that require repeated performance of the ITA and or have large amounts of data associated with the acceptance criteria.

For example, inspection of a selected sample of surveys may be coupled with the review of the results from the entire survey; inspection of the licensees performance of a test on several components (e.g., valve stroke tests, containment penetration leak tests) may be performed followed by a review of the completed procedure test results for the associated ITAAC.

d. Should changes in the licensees schedule result in the performance of a targeted ITAAC not receiving direct inspection of the ITA, staff may review the completed quality assurance records to complete the targeted ITAAC inspection.

e. ITAAC Closure verification: Inspectors may also consider reviewing the licensees principle closure packages for completed ITAAC in accordance with IP 40600, Licensee Program for Managing Inspections, Tests, Analyses, And Acceptance Criteria (ITAAC)

Closure.

06.04 Process for the Modification of the ITAAC Target Set. The ITAAC prioritization process should be adaptive. When modifying the set of targeted ITAAC, staff should consider lessons learned, inspection history, and NRC inspection resource requirements. The staff should ensure the baseline inspection program (BIP), after the proposed changes, continues to provide reasonable assurance that a significant construction flaw does not go undetected and a sufficient basis to support the staffs determination that the licensee performed the inspections, tests, and analyses and met the acceptance criteria.

This section does not apply to inspections of additional ITAAC based on plant assessments, extent of condition reviews, or for other cause. It also does not apply to the addition and deletion of targeted ITAAC through the license amendment process, which is handled in Office Instruction NRO-REG-102, Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection.

Issue Date: 03/04/20 6 2503

To optimize inspection resource use, the staff un-targeted ITAAC that had low risk and low inspection value. This included un-targeted EP ITAAC that were redundant to activities that the staff already inspect (i.e., EP exercise). The Commission directed that Design Acceptance Criteria (DAC) ITAAC be inspected and were therefore not un-targeted.

For any modification to the targeted ITAAC set, VPO staff will perform a review of the proposed change. The review shall consider the impact on inspection coverage on the ITAAC Matrix, the value of inspection (i.e., prioritization rank), and the following screening questions. Though any ITAAC may be untargeted with Director approval, the staff should not un-target ITAAC with a high value of inspection or that fail to answer yes to the screening questions. The staff shall document a basis for each ITAAC untargeted using Table D-1 in Appendix D of NRO-REG-102.

a. If a targeted ITAAC is not performed, do other targeted ITAAC provide adequate, representative inspection coverage?

b. If a targeted ITAAC inspection is not performed, is the scope of the quality process or program represented by that ITAAC adequately covered by other targeted ITAAC inspections?

c. If a targeted ITAAC inspection is not performed, do other targeted ITAAC invoke the associated inspection procedures.

d. If a targeted ITAAC inspection is not performed, is there a high likelihood that a significant flaw or failure to meet an acceptance criterion would go undetected?

e. If a targeted ITAAC inspection is not performed, is the ITAACs inspection value below or at the lower end of the target cutoff (if not ranked does it have low safety significance)?

f. If a targeted ITAAC inspection related to security or emergency preparedness is not performed, did NSIR agree to un-target it?

The staff should conduct this review using an appropriate panel of experts. Upon completion of its review, the expert panel shall provide the changes to the targeted ITAAC set via memo to the VPO and DCO Office Directors.

END Appendix A: IMC 2503 Inspection Procedures Appendix B: The ITAAC Matrix : Revision History for IMC 2503 Issue Date: 03/04/20 7 2503

Appendix A: IMC 2503 INSPECTION PROCEDURES IP 65001 - ITAAC Inspections 65001.01 - Foundations and Buildings 65001.02 - Installation of Structural Concrete 65001.03 - Installation of Piping 65001.04 - Installation of Pipe Supports & Restraints 65001.05 - Installation of Reactor Pressure Vessel and Internals 65001.06 - Installation of Mechanical Components 65001.07 - Installation of Valves 65001.08 - Installation of Electrical Components and Systems 65001.09 - Installation of Electrical and Fiber Optic Cable 65001.10 - Installation of Instrument Components and Systems 65001.11 - Containment Integrity and Containment Penetrations 65001.11A - Containment Structural Integrity Test 65001.12 - Installation of Heating, Ventilating, and Air Conditioning Systems 65001.13 - Installation of Load Handling Equipment and Fuel Racks 65001.14 - Installation of Complex Systems with Multiple Components 65001.15 - Installation of Fire Protection Equipment 65001.16 - Engineering 65001.17 - Security (For Official Use Only - Security-related Information) 65001.18 - Emergency Planning ITAAC 65001.19 - Radiation Monitoring Components and Systems 65001.20 - Safety-related Piping DAC 65001.21 - Pipe Rupture Hazards Analysis Design Acceptance Criteria (DAC) 65001.22 - Digital Instrumentation and Control (DI&C) System/Software (DAC) 65001.23 - Human Factors Engineering Integrated System Validation 65001. A - As-Built Attributes for Structures, Systems, and Components 65001. B - Welding Program 65001. C - Construction Test Program 65001. D - Operational Testing Program 65001. E - Qualification Program 65001. F - Design and Fabrication Requirements Issue Date: 03/04/20 AppA-1 2503

Appendix B: The ITAAC Matrix BACKGROUND: The goal of inspections conducted under IMC 2503 is to verify licensee compliance with all 10 CFR Part 52 ITAAC requirements, as well as other relevant NRC regulations, using an integrated inspection and review strategy.

The ITAAC inspection philosophy contained in IMC 2503 recognizes that several ITAAC are expected to be closely related, thereby providing the NRC with the opportunity to evaluate a family of ITAAC based upon an examination of some representative ITAAC within the family.

Such an inspection approach would allow for the efficient use of NRC inspection resources for evaluation of the construction processes that result in the ITAAC completion.

OBJECTIVE: A framework was developed by the NRC to manage ITAAC inspections, while recognizing the need for a sampling-inspection approach. This framework was structured to integrate inspection activities that evaluate the licensees control of the construction processes into the NRC inspection program. Central to the NRCs CIP for construction under 10 CFR Part 52 is a tool that provides a coherent approach to the coverage and completion of the ITAAC related inspections. This tool is called the ITAAC Matrix and is shown in Figure 1.

OVERVIEW: The ITAAC Matrix provides a means for assigning each ITAAC into a matrix block referred to as an ITAAC family. Each family represents a combination of ITAAC characteristics related to the successful ITAAC completion.

The IPs for the 19 Matrix rows provide guidance on the inspection of specific technical disciplines, while the IPs for the six Matrix columns discuss those inspection criteria that crosscut disciplinary boundaries. The 25 IPs developed to address all Matrix categories provide a template for ITAAC inspections, as well as inspection of the licensees control of the construction processes. This facilitates the process of inspecting the selected sample of ITAAC, but also ensures adequate coverage of all construction disciplines. For example, all ITAAC within a specific plant design that discuss instrumentation and control (I&C) components and systems and specific as-built inspection criteria would be binned in the matrix block formed at the intersection of row (10) and column (A).

POPULATING THE ITAAC MATRIX: Each ITAAC for a specific design is evaluated and assigned to the appropriate family by selecting the appropriate combination of row and column.

Site specific ITAAC will also be added to the population once they have been identified.

a. An NRC expert panel reviews all the ITAAC for each design. An expert panel will generally consist of a minimum of three NRC personnel with some combination of expertise in plant construction, reactor risk, and project licensing, including some relevant plant design and ITAAC experience.

b. The expert panel will review each of the ITAAC and will place it in one of the families of the ITAAC Matrix.

c. Once the expert panel determines where in the Matrix each of the ITAAC for a particular design should be placed, all facilities constructed with that particular design will use that ITAAC Matrix.

Issue Date: 03/04/20 AppB-1 2503

This use of a single ITAAC Matrix format provides a consistent framework for developing the inspection programs for each of the different reactors that are licensed and built under 10 CFR Part 52. This also ensures consistency in the inspection program within any specific design.

DESIGN ACCEPTANCE CRITERIA (DAC): Inspection Procedures 65001.20 through 65001.23 are special purpose procedures for inspection of DAC-related ITAAC. There is no correlation between these procedures and the ITAAC Matrix.

Issue Date: 03/04/20 AppB-2 2503

Figure 1: THE ITAAC MATRIX A) As-Built B) Welding C)Construction D) Operational E) Qual F) Design &

Insp Testing Testing Criteria Fabrication 01)Foundations & A01 B01 C01 D01 E01 F01 Buildings 02)Structural A02 B02 C02 D02 E03 F02 Concrete 03)Piping A03 B03 C03 D03 E03 F03 04)Pipe Supports A04 B04 C04 D04 E04 F04

& Restraints 05)RPV & A05 B05 C05 D05 E05 F05 Internals 06)Mechanical A06 B06 C06 D06 E06 F06 Components 07)Valves A07 B07 C07 D07 E07 F07 08)Elec Comp & A08 B08 C08 D08 E08 F08 Systems 09)Electrical A09 B09 C09 D09 E09 F09 Cables 10)I&C Comp & A10 B10 C10 D10 E10 F10 Systems 11)Containment A11 B11 C11 D11 E11 F11 Integrity &

Penetrations 12)HVAC A12 B12 C12 D12 E12 F12 13)Eqp Handle & A13 B13 C13 D13 E13 F13 Fuel Racks 14)Complex Sys A14 B14 C14 D14 E14 F14 w/ Multi-Comp 15)Fire Protection A15 B15 C15 D15 E15 F15 16)Engineering A16 B16 C16 D16 E16 F16 17)Security A17 B17 C17 D17 E17 F17 18)EP A18 B18 C18 D18 E18 F18

19) Rad A19 B19 C19 D19 E19 F19 Protection

- Column Categories [A thru F]: Interdisciplinary NRC inspection activities that represent common ITAAC attributes. An NRC inspection procedure (IP) will correspond to each column category.

- Row Categories [1 thru 19]: Construction processes & resulting products (e.g., SSC) that relate to a unique discipline, with an IP corresponding to each row category.

Issue Date: 03/04/20 AppB-3 2503

ITAAC MATRIX NOTES:

Column Classification

[A] As-Built Inspection comprises the functional/physical arrangement series of ITAAC, to include checks for location, alignment, dimensions, sizing, and measurements, and may include functional checks, unless related to testing (which would be covered by [C] or [D]) or a design report/analysis (which would be covered by [F]). Simple calculations (e.g., a screen area or tank volume) that can be made from field measurements or sizing estimates would be covered here based upon the dimensional checks; however, more complex calculations, even if field measurements are involved, would better be categorized in [F]. If a single ITAAC involves both as-built information, like a physical or dimensional check, and other criteria, like those for an operational test [D] or design analyses/calculations [F], the [D] or [F] categories, as applicable, would take preference over this as-built [A] category. Also, checking that a meter or display is located properly (e.g., is on the Main Control Board) would be categorized here [A], while reading the meter or retrieving data from the display as part of an operational test would better be categorized in [D].

[B] Welding comprises those ITAAC which address any welding process, whether code referenced (e.g., ASME piping) or oriented to other processes (e.g., structural steel or electrical supports). This category also includes those ITAAC which address or provide criteria for weld quality, e.g. the requirements for the nondestructive examination (NDE) of welds. Additionally, activities and programs related to the welding process (e.g., welder training, testing, and certification; welding procedure qualification; NDE personnel and procedure qualification; other weld testing activities) are all included in this welding [B] category.

[C] Construction Testing includes specific ITAAC tests that are associated with the quality of component fabrication and construction activities, to include quality acceptance tests (e.g.,

concrete testing or simulated signal testing to confirm Class 1E division boundaries), baseline data checks (e.g., PSI), and field-work completion testing (e.g., hydros) or any other similar construction testing activities. In-process field testing of individual pieces of equipment would be covered here, while the construction-complete, pre-operational test phases leading to integrated system testing would better be categorized in [D]. However, the testing (e.g., type tests) of equipment for qualification in a harsh environment (EQ) or in analyzing seismic response, as well as for other like programmatic qualification criteria, should be covered by

[E], as described in note (E) below.

[D] Operational Testing involves testing activities that check component and system function by measuring operational parameters (e.g., flow requirements) and/or validating operational performance acceptance criteria (e.g., component actuation with signal inputs or similar pre-op testing). Such tests might be performed on a single component, an individual system, or a complex, integrated system. Similarly, as with Construction Testing above, type tests and equipment qualification should be covered by [E].

[E] Qualification Criteria includes seismic qualification, environmental qualification (EQ) and other ITAAC qualification programs and any related program attributes that are oriented toward broad design criteria versus the specific test parameters of [C] or [D]. The characteristics of such programs as the Design Reliability Assurance Program (DRAP) might be considered here.

Issue Date: 03/04/20 AppB-4 2503

[F] Design/Fabrication Requirements cover those ITAAC that refer to Code (e.g., ASME) requirements for the fabrication of material and components or discuss the adequacy of design by reference to analyses, calculations, bounding condition checks, functional assessments, engineering evaluations and other design reports. However, if Welding is the primary fabrication process, this is better categorized in [B]. If construction or operational Testing result in design parameters/measurements, this is better categorized in [C] or [D]. Also, if the design analyses involve programmatic Qualification Criteria (e.g., seismic), this would be better categorized in [E]. Where a report exists, or the functional capabilities of the system/components are analyzed, to confirm compliance with general Code requirements versus specific test results or programmatic qualification criteria, it should be covered here under [F].

Row Classification (01) Foundations & Buildings include geo-technical (e.g., rock) investigation, civil surveying, elevation grading, pre-construction preparations (e.g., mudmats) and site layout, including the arrangement of buildings and structures; except that the Containment, as a separate Building, is covered by line (11) while its Foundation is covered here with all site foundations. This category also includes the building framework, like the structural steel and bolting materials.

However, any ITAAC discussing the details of construction of the buildings that are more specifically defined by other Matrix rows will be classified by that process (i.e., Structural Concrete (02) for concrete buildings, Mechanical Components (06) for large metal tanks, or Engineering (16) for generic design criteria (e.g., seismic) of buildings, like the nuclear island).

(02) Structural Concrete includes all the materials (e.g., cement and rebar) and processes (e.g., concrete batch mixing and delivery) that result in a steel reinforced concrete placement, as well as embedded devices, anchors, anchorages, water barriers that are installed before or after the concrete placement, and structural grout. Any items that are installed in the formwork (for example, anchor bolts that are embedded in the concrete when placed) are covered by this line item, while items that are subsequently attached to finished concrete are covered by other functional categories; for example, concrete expansion anchors, which are known to provide piping support or electrical raceway support, are covered under lines (04) and (09) respectively.

For work on placed and finished concrete, where the ultimate function is unknown (e.g.,

expansion anchors for general supports), such activities are covered here under (02).

(03) Piping includes all piping, whether safety-related or not, and covers all ASME classes including the reactor coolant pressure boundary, as well as piping referenced in other codes (e.g., B31.1). ITAAC that describe systems that deliver fluid flow through piping as the major function, as well as the pressure boundary function (e.g., the pressure rating verified by hydrostatic testing) of such systems, are best categorized here. However, if the system functions and test acceptance criteria are more complex, involving diverse component interactions, the ITAAC might be a better fit for Complex Systems w/ Multiple Components (14).

Issue Date: 03/04/20 AppB-5 2503

(04) Pipe Supports & Restraints apply to all classes of piping and all types of supports (e.g.,

snubbers, struts, anchors, and guides) and pipe whip restraints. The seismic adequacy of piping systems would likely be applied here in (04). However, if the ITAAC focuses on the seismic qualification of a unique component (e.g., a pump) instead of the piping system, Mechanical Components (06) would be most appropriate line for categorization.

(05) Reactor Pressure Vessel (RPV) and Internals While the RPV may be considered a mechanical component or part of a fluid-flow system; it is uniquely covered here, along with the reactor internals. However, any instrumentation internal to the RPV is best characterized under I&C Components & Systems (10).

(06) Mechanical Components include all classes (ASME or non-safety) of equipment (e.g.,

pumps, heat exchangers, strainers, etc.), but not Valves (07) and not HVAC (12). It also includes any mechanical equipment support that is unique (e.g., a steel pedestal) to the component, rather than part of the building structure [e.g., concrete pads with anchor bolts that are part of Structural Concrete (02). Storage tanks that are fabricated metal components would fit here (06), but concrete tanks with only a liner, may best fit under Structural Concrete (02).

(07) Valves regardless of the type of operator (e.g., motor, hydraulic, air, squib, etc.), are considered here as a separate category of mechanical components because of the unique nature in the way they are described in the ITAAC. This category covers all valves, including check valves and any other valves of a similar self-actuating nature. Also, any valve functions related to containment isolation are covered in Containment Integrity & Penetrations (11).

(08) Electrical Components and Systems include all electrical equipment (e.g., diesel generators) and supporting distribution components (e.g., switchgear), except for the cables.

Because of their unique nature, containment electrical penetration assemblies are included here instead of row (11).

(09) Electrical and Fiber Optic Cable involves all cable and includes the raceways (e.g.,

conduit, cable tray) in which the cable is run and the raceway supports (e.g., unistrut), unless they are part of the building structural steel (01) or pipe supports (04).

(10) Instrument Components & Systems include sensing instrumentation and actuation control equipment, including the system hardware (e.g., signal process cabinets) and logic process devices, as well as the related signal initiation, control and annunciation checks, e.g., including those for the Main Control Board (MCB). Displays on the MCB and the retrieval of the information from the MCB windows or other panels and cabinets in the main control room (MCR) would be covered here. However, low-voltage instrument cable is covered under Electrical and Fiber Optic Cable, with all other cable.

(11) Containment Integrity & Penetrations involve the Containment structure and boundary, including all aspects of the containment isolation function. Therefore, any containment isolation check (e.g., a valve closure) or integrity criteria (e.g., hatch leakage) are covered here, instead of line (07) for valves or line (06) for mechanical components. However, the containment concrete material and placement is covered by AStructural Concrete@ (02) and the electrical penetration assemblies are considered AElectrical Components@ (08).

Issue Date: 03/04/20 AppB-6 2503

(12) Heating, Ventilating & Air Conditioning Systems (HVAC) involves air distribution and environmental control systems from a functional standpoint, thereby including all mechanical, electrical, and I&C equipment that is directly related to the HVAC function or system performance.

(13) Load Handling Equipment and Fuel Racks includes the components involved with equipment handling and movement (e.g., polar crane), fuel movement (egg., fuel bridges) both inside and outside of containment, and the spent fuel storage racks and related equipment. The fuel itself is not covered here, but rather in line (05) as an internal component.

(14) Complex Systems with Multiple-Components is intended to cover categories that discuss attributes that cross disciplinary boundaries, for example electrical, I&C, and valve response are all connected to the same ITAAC. This would also cover any ITAAC that refer to Tables of equipment, that would fit multiple lines of the Matrix if the components were evaluated separately; for example, a Table that lists valves, mechanical components, and I&C components. This category should be used when the nature of the ITAAC does not lend itself to clear placement in one of the other categories. However, even for complex systems, where the ITAAC focus is specific (e.g., the pressure boundary function of an integrated piping system),

the matrix category (in this example line (03) for piping) that best fits the focal point of the ITAAC should be selected.

(15) Fire Protection includes all related material, equipment, systems, processes, and programs.

(16) Engineering is a separate line to distinguish it as a Aprocess@ separate from the construction activities that result in the SSC and products on the other lines. If design criteria (e.g., flooding analyses) are the dominant focus of an ITAAC (e.g., building room boundaries)

Aengineering@ would apply. Similarly, for design issues (e.g., seismic) and more subjective areas (e.g., human reliability analysis) that cross disciplinary boundaries, are Aengineering@

oriented, and difficult to categorize on any other line, the most applicable categorization may fit here under row (16).

(17) Security and (18) Emergency Planning are separate lines to cover the systems, processes, and programs related to these activities.

(19) Radiation Monitoring Components and Systems includes not only all radiation protection (RP) components and RP system functions, but also those processes and programs related to RP, similar to the way fire protection and security systems and programs fit under lines (15) and (17) respectively. An ITAAC that refers generally to the EP function, which might include radiological protection, is better categorized under line (18); while a more direct reference to RP equipment functionality and the programs that support the use of RP data would fit here under row (19).

Issue Date: 03/04/20 B-7 2503

Attachment 1 Revision History for IMC 2503 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training Required and Closed Feedback Number Issue Date and Completion Form Accession Change Notice Date Number (Pre-Decisional, Non-Public Information)

N/A ML043100008 Initial Issuance None N/A 04/25/06 CN 06-010 N/A ML072681114 Researched for 4 years and found none. None N/A 10/03/07 Revised to reflect program development and CN 07-030 incorporate stakeholder feedback.

N/A ML12110A239 Complete rewrite. Incorporating language to None ML12110A239 07/05/2012 address Design Acceptance Criteria (DAC).

CN 12-012 N/A ML20030B356 Revised to reflect the reunification of the ML20030B556 03/04/20 Office of New Reactors (NRO) and Office of CN 20-013 Nuclear Reactor Regulation (NRR) into NRR, provide additional guidance for ITAAC inspection planning and un-targeting ITAAC, and makes reformatting and editorial corrections.

Issue Date: 03/04/20 Att1-1 2503