ML20057D521

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LIC-210, Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection
ML20057D521
Person / Time
Issue date: 03/31/2020
From: Renee Taylor
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
Christopher Welch, NRR/VPO 301-415-7000
References
LIC-210, Y020190128
Download: ML20057D521 (35)
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Text

OFFICE OF NUCLEAR REACTOR REGULATION LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection Volume 200 Licensing Support Approved By:

Robert M. Taylor Date Approved:

March 31, 2020 Effective Date:

April 6, 2020 Certification Date:

April 6, 2025 Responsible Organization: VPO Primary

Contact:

Christopher Welch Christopher.Welch@nrc.gov 301-415-7000 Summary: This Office Instruction (OI) provides the instructions, and associated methodology, to prioritize (i.e., Target) inspection resources for performing ITAAC inspections per Manual Chapter 2503, Construction Inspection Program: Inspections of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Related Work. Additionally, this OI rescinds NRO-REG-102, Prioritization of Inspections, Tests, Analyses, and Acceptance Criteria for Inspection.

Training:

NRR staff assigned to prioritize ITAAC ADAMS Accession Number: ML20057D521 TABLE OF CONTENTS

1.

POLICY............................................................................................................................. 2

2.

OBJECTIVES.................................................................................................................... 2

3.

BACKGROUND................................................................................................................ 2

4.

BASIC REQUIREMENTS................................................................................................. 5

5.

RESPONSIBILITIES AND AUTHORITIES...................................................................... 10

6.

PERFORMANCE MEASURES....................................................................................... 10

7.

PRIMARY CONTACT..................................................................................................... 10

8.

RESPONSIBLE ORGANIZATION................................................................................... 10

9.

EFFECTIVE DATE.......................................................................................................... 10

10.

CERTIFICATION DATE.................................................................................................. 10

11.

REFERENCES................................................................................................................ 11

Office Instruction: LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection Dated: March 31, 2020 Accession No: ML20057D521

  • via email NRR-071 To receive a copy of this document, indicate in the box: "C" = Copy without enclosures E" = Copy with enclosures "N" = No copy OFFICE NRR/VPO NRR/VPO OGC/NLO NRR/DRMA NRR/DD NAME CWelch VHall MASpencer TGorham RTaylor DATE 2/20/2020 2/28/2020 3/2/2020 3/30/2020 3/31/2020 OFFICIAL RECORD COPY

NRR Office Instruction LIC 210 Page 2 of 11

1. POLICY The baseline inspection program shall provide a sufficient basis to support the finding, in accordance with 10 CFR 52.103(g), that the acceptance criteria in a combined license (COL) are met; and develop confidence in the licensees programmatic controls. Inspections of the licensees performance of inspections, tests, analyses, and acceptance criteria (ITAAC) are conducted to provide confidence that licensees ITAAC completion and verification processes are effective and provide reasonable assurance that licensee ITAAC closure and post-closure notifications are sufficient and accurate.
2. OBJECTIVES Provide an efficient, effective and structured method to select the ITAAC for inspection, while allowing for the Nuclear Regulatory Commission (NRC) judgment in its implementation. To optimize NRC resources and inspection planning while providing reasonable assurance that no significant construction flaw goes undetected.
3. BACKGROUND The prioritization process classifies and groups the ITAAC into families to facilitate ITAAC inspection sampling within each family. ITAAC are classified based on (1) the activities performed to implement it, and/or (2) its acceptance criterion. The ITAAC Matrix (see Appendix B) was developed as an inspection tool for this purpose.

The ITAAC Matrix establishes a logical way to group the ITAAC into families for inspection sampling purposes, but it does not provide directions on what ITAAC to inspect. The ITAAC are grouped by selecting the single best combination of a matrix column (i.e., construction program) and a matrix row (i.e., construction process or system, structure, or component) that best covers the ITAACs construction activities. For example, all ITAAC for the as-built inspection of instrumentation and control components will be binned in the matrix family [A10]

formed by the intersection of column (A) and row (10). The use of the ITAAC Matrix provides a consistent framework for developing the inspection program for each new or advanced reactor design and establishes a sound, efficient, inspection sampling approach. Because the ITAAC within a family are similar, an equivalent licensee performance can be expected for each of them.

The first step involves rank-ordering the ITAAC based upon certain defined attributes [see Appendix C] that makes one ITAAC more or less important to inspect. The defined attributes are (1) safety significance, (2) propensity for making errors, (3) construction and testing experience, (4) the opportunity to verify ITAAC completion by other means, and (5)

Licensee (Applicant) oversight. Each attribute is weighted based on its importance in achieving the overall objective of detecting significant construction flaws.

Licensee (Applicant) oversight is unknown at the time of initial ITAAC prioritization and was felt to be too subjective. Therefore, it was decided to not use the attribute during the prioritization process. Each ITAAC thus is assigned a rank of 3 for the oversight value. This effectively removes any impact from the attribute on the algorithms output.

NRR Office Instruction LIC 210 Page 3 of 11 To assign weights to the attributes, the staff uses the Analytic Hierarchy Process (AHP), a hierarchal method of pair wise comparisons in which expert preferences among the attributes are converted into numerical weights. The assigned weights and utility values of the attributes are assumed to never change and are applicable to all certified reactor designs (see Figure 1 and Example 1).

Figure 1 The Dynamic Prioritization Process Using the Analytic Hierarchy Process (AHP)

Attribute Utility Scale Rating Safety Significance Propensity of Making Errors Construction and Testing Experience Opportunity to Verify by Other Means Licensee Oversight 5

1 1

1 1

NA 4

0.606 0.656 0.663 0.594 NA 3

0.213 0.313 0.325 0.188 0.263 2

0.106 0.156 0.163 0.094 NA 1

0 0

0 0

NA ATTRIBUTE:

WEIGHTED VALUE:

Safety Significance 0.33 Propensity of Making Errors 0.05 Construction and Testing Experience 0.09 Opportunity to Verify by Other Means 0.19 Licensee Oversight 0.34

NRR Office Instruction LIC 210 Page 4 of 11 Example 1 AP1000 ITAAC No.

Error Propensity

(.05)

Const. and Testing Exp.

(.09)

Verify by Other Means

(.19)

Licensee Oversight

(.34)

Safety Significance

(.33)

ITAAC Rank Table 1 B

V MV B

V MV B

V MV B

MV 3.3.2a.i 3

3 2

4 1

1 5

2 2

3 5

0.659 2.2.3.9a.1 2

4 2

3 1

1 4

1 1

3 4

0.431 To calculate the ITAACs Rank, convert each attributes baseline (B) and mapped value (MV) to its utility value per Appendix B, Table B-1, Attribute Utility Scale [see below].

ITAAC No.

Error Propensity Const. and Testing Exp Verify by Other Means Licensee Oversight Safety Significance ITAAC Rank Utility Value B

MV B

M V

B MV B

MV 3.3.2a.i 0.313 0.156 0.663 0

1 0.094 0.263 1

0.659 2.2.3.9a.1 0.156 0.156 0.325 0

0.594 0

0.263 0.606 0.431 For the first three attributes, subtract the utility values for the mapped value (MV) rank from its baseline (B) rank and multiply the output by the applicable weighting factor in Table B-2. For the two remaining attributes, multiply their associated utility value by the applicable weighting factor. Sum the obtained values of each attribute to obtain the ITAACs rank value.

ITAAC No.

Error Propensity Const. and Testing Exp.

Verify by Other Means Licensee Oversight Safety Significance ITAAC Rank 3.3.2a.i (0.313-0.156)(.05)

(0.663-0)(.09) (1-.094)(.19)

(0.263)(.34)

(1)(0.33) 0.659 2.2.3.9a.1 (0.156-0.156)(.05)

(0.325-0)(.09) (0.594-0)(.19)

(0.263)(.34)

(0.606)(0.33) 0.431 An ITAACs rank provides insight about both the value of inspecting that ITAAC, in comparison with every other ITAAC, and the assurance gained that a significant construction flaw will not go undetected. Considering the limited NRC inspection resources, only a limited number of ITAAC within an ITAAC family will be targeted for inspection. The targeted ITAAC represent those that will provide the highest value of inspection.

NRR Office Instruction LIC 210 Page 5 of 11 The second step includes a portfolio perspective (or coverage check) for all ITAAC. This assures a diverse set of ITAAC are targeted for inspection such that the target sample is representative of the entire ITAAC universe (i.e., all construction programs and processes) for a specific design. It allows selecting at least one ITAAC from each ITAAC family for inspection, irrespective of whether its rank dictates it, and that as many of the potential ITAAC families be populated with ITAAC as is supported by the types of ITAAC available and the matrix classifications.

Populating the matrix for a given design control document need only be accomplished once.

Management, however, based on its discretion and the extent of changes made to a design or to incorporate lessons learned during construction, may opt to re-populate the matrix and reprioritize the ITAAC at some later time. Management, at its discretion, may add to or remove ITAAC from a site(s) targeted ITAAC list to address a particular need or feedback from ongoing construction projects. In the interim, the ITAAC Matrix should be updated following each revision to a certified design or license amendment in accordance with Appendix D.

Site specific ITAAC identified in a COL or limited work authorization (LWA) may be ranked in accordance with Appendix E and subsequently added to the ITAAC Matrix population to generate a complete ITAAC Matrix for a particular COL.

Security and emergency preparedness (EP) ITAAC are selected for inspection (targeted) based on judgement of the subject matter experts in the Office of Nuclear Security and Incident Response (NSIR). Therefore, security and EP ITAAC are excluded from the ITAAC prioritization (i.e., targeting) process. Placement of the security and EP ITAAC within the ITAAC Matrix is limited to placement within their respective rows (17 & 18).

All design acceptance criteria (DAC) ITAAC are required to be inspected (i.e. targeted), and therefore they too are excluded from the prioritization (i.e., targeting) process.

Inspection Manual Chapter 2506, Construction Reactor Oversight Process General Guidance and Basis Document (Ref. 1) and the Technical Report on the Prioritization of the Inspection Resources for Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) (Ref. 2) may be referred to for additional background information and details associated with the prioritization process.

4. BASIC REQUIREMENTS A. Determine the Targeted ITAAC for a Given Design
1. Populate the ITAAC Matrix a) Convene an expert panel. Table 1 provides a protocol for overall conduct of the expert panel.

b) For each ITAAC, using Appendix B, determine the family that best represents the ITAAC activities, while considering the goal of adequate coverage of all types of ITAAC families. Each ITAAC can only be assigned to a single matrix block (i.e., one alpha-numeric designator).

NRR Office Instruction LIC 210 Page 6 of 11 c) Record each ITAAC number and its alpha-numeric family designator [e.g., (A10)] in Table 2.

d) Enter the ITAAC Matrix information into the ITAAC Prioritization Tool computer program database.

2. Rank-Order the ITAAC Note: The higher the value of the rank of an attribute or an ITAAC for that attribute the greater impact it has on determining an ITAACs final rank. A possible ranking of 1 to 5 would mean that 5 would be most significant.
a. Safety Significance
1. Convene an expert panel. One panel member shall have been involved in the probabilistic risk assessment (PRA) review of the design certification. Table 1 provides a protocol for overall conduct of the expert panel.
2. Based on research and discussion of the available design, engineering, and risk information, establish a rank of perceived safety significance for each ITAAC, as follows:

(a)

Rank the safety significance of each system with ITAAC (on a scale of 1 to 5, with 1 being least and 5 being most). Record the system (SYS) results in Table 2; (b)

Rank how important or significant each ITAAC is (on a scale of 1 to 3, with 1 being low, 2 being medium, and 3 being high) in assuring the proper performance or functioning of the system. Record the ITAAC results in Table 2; and (c)

Add the system rank (1 to 5) to the individual ITAAC rank (1 to 3). Map the resulting sum for each ITAAC, using the table below, to determine the combined value (CV) for its safety significance. Record the CV results for each ITAAC in Table 2.

Sum of the System and ITAAC Safety Significance Rankings Safety Significance Combined Value (CV) 8 5

7 4

6 3

5 2

4, 3, or 2 1

3. Enter the safety significance CV for each ITAAC into the ITAAC Prioritization Tool computer program database.

NRR Office Instruction LIC 210 Page 7 of 11

b. Value of Inspection
1. Convene an expert panel comprised of three groups, with each group being comprised of three individuals. Table 1 provides a protocol for overall conduct of the expert panel.
2. Assign each group one of the following attributes:

propensity of making errors; construction and testing experience; or opportunity to verify by other means.

3. Provide to each group the baseline question, from Table 3, for their assigned attribute. The corresponding value of inspection question, from Table 4, should not be divulged or provided to the groups at this time.
4. Each group, with discussion and consensus on the number representing the best response for its baseline question, establish a ranking (on a scale of 1 to 5, with 1 being least and 5 being most) for the baseline question for each ITAAC. Record the baseline question ranking (B) for each ITAAC in Table 2.
5. Collect the baseline questions and responses from each group. This material is not to be available to the groups when answering the value of inspection question.
6. Provide to each group the corresponding value of inspection question, from Table 4, for their assigned attribute. The groups are not to have access to the prior questions and their results.
7. Each group, with discussion and consensus on the number representing the best response for its value of inspection question, establish a ranking (on a scale of 1 to 5, with 1 being least and 5 being most) for the value-of-inspection question for each ITAAC. Record the value-of-inspection rank (V) for each ITAAC in Table 2.
8. Using the table and instructions provided below, determine the mapped value-of-inspection rank (MV) for each ITAAC. Record the mapped value (MV) for each ITAAC in Table 2.

NRR Office Instruction LIC 210 Page 8 of 11 The value-of-inspection for each ITAAC is determined based on the values assigned to each ITAACs baseline question (B) and its value-of-inspection question (V). For any particular ITAAC, for example, if a numerical rating of 3 were assigned to its baseline ranking (B), the upper limit that could be assigned to the mapped value-of-inspection (MV) would also be 3. Convert the expert panel responses into the ITAACs mapped value-of-inspection (MV) as shown below:

Baseline Question Rank (B)

Value-of-Inspection Question Rank (V)

Value-of-Inspection Mapped Ranking (MV) 1 1, 2, 3, 4, or 5 1

2 4 or 5 2

2 1, 2, or 3 1

3 5

3 3

3 or 4 2

3 1 or 2 1

4 5

4 4

4 3

4 3

2 4

1 or 2 1

5 5

5 5

4 4

5 3

3 5

2 2

5 1

1

9. For each ITAAC, enter the baseline ranking (B) and its associated, value-of-inspection mapped ranking (MV) into the ITAAC Prioritization Tool computer program database.
c. Value of Licensee Oversight For each ITAAC, enter the default value (3) for licensee oversight into the ITAAC Prioritization Tool computer program database.
3. Determine the Targeted ITAAC The targeted ITAAC for the AP1000 and ABWR reactor plant designs include those ITAAC with an ITAAC Rank > 0.4. For any other designs, the value of this threshold must be specifically determined and vetted for that specific design. The vetting process must ensure adequate inspection coverage of the ITAAC families while maintaining NRC inspection resource loading at a reasonable and achievable level.

The targeted ITAAC represent those ITAAC that provide the highest value of inspection results for the committed NRC efforts. These ITAAC targets establish a minimum inspection sample, based upon the organization of the ITAAC into matrix families, which

NRR Office Instruction LIC 210 Page 9 of 11 permits the direct inspection results to be extrapolated to the entire set of ITAAC, including those that only received a review of the licensees ITAAC closure notification as outlined in Appendix F. Thus, the processes and programs used to construct the plant (and complete the ITAAC) can be independently checked and assessed through the conduct of inspections of an informed ITAAC sample, sized to be reasonably achievable with available NRC resources.

Determine the ITAAC Rank at which ITAAC will be targeted for inspection, as follows:

1. Obtain the results and supporting documents from prior prioritization efforts. This information may assist in the prioritization process for the new design.
2. Obtain the ITAAC Prioritization Tool computer program results showing each ITAACs Rank. The desired report lists the ITAAC by family and by Rank within each family.
3. Based on judgment, results from prior prioritizations, and program goals, select the ITAAC Rank that provides sufficient inspection coverage of the ITAAC and the construction programs and processes.
4. Estimate the inspection hours required to inspect each of the proposed targeted ITAAC and compute the total number of inspection hours required.
5. In an iterative process repeat steps three and four, as necessary to determine the optimal ITAAC Rank for selecting the targeted ITAAC. Attempt to balance the need to ensure adequate inspection coverage while maintaining NRC inspection resource loading at a reasonable and achievable level. To this end, discretion may be applied to limit the number of targeted ITAAC in any one family while increasing the number of targeted ITAAC in another family. (Program goals are identified in IMC-2506.)
6. Identify the ITAAC in each family Targeted for inspection based on the above process.
a.

If no ITAAC are targeted within a matrix family, evaluate if at least one of the higher ranked ITAAC within that family should be selected (i.e.,

targeted) for inspection. In making this determination, the staff should ensure that adequate inspection coverage is provided over the full range of construction processes and programs and construction inspection procedures. Consider the following:

1.

Do other targeted ITAAC provide adequate representative inspection coverage?

2.

Is the scope of the quality process or program adequately covered by other targeted ITAAC inspections?

3.

Do other targeted ITAAC invoke the associated inspection procedures?

4.

If the ITAAC is not targeted for inspection, is there still reasonable assurance that a significant flaw or failure to meet an acceptance criterion would not go undetected?

NRR Office Instruction LIC 210 Page 10 of 11

b.

Document by memorandum the results of the prioritization process. In an attachment to the memorandum, identify for each ITAAC: the ITAAC number (when applicable include the ITAACs COL index number), the associated ITAAC Family, and if it has been targeted for inspection.

B. Determine the Targeted ITAAC for ITAAC Revisions Update the targeted ITAAC list following revision to the design control document, COL, or LWA in accordance with Appendix D.

C. Determine the Targeted ITAAC for Site-Specific ITAAC Identify the site-specific targeted ITAAC for an LWA or COL in accordance with Appendix E.

5. RESPONSIBILITIES AND AUTHORITIES Director NRR: Shall ensure sufficient resources are available to effectively implement the ITAAC prioritization process review.

Branch Chief: Shall ensure sufficient staff are qualified to effectively prioritize (i.e., target)

ITAAC for inspection.

Staff: should implement the targeting process pursuant to the instructions within this Office Instruction.

6. PERFORMANCE MEASURES None
7. PRIMARY CONTACT Christopher Welch Christopher.Welch@nrc.gov 301-415-7000
8. RESPONSIBLE ORGANIZATION VPO
9. EFFECTIVE DATE April 6, 2020
10. CERTIFICATION DATE April 6, 2025

NRR Office Instruction LIC 210 Page 11 of 11

11. REFERENCES
1. Inspection Manual Chapter 2506, Construction Reactor Oversight Process General Guidance and Basis Document
2. Technical Report on the Prioritization of Inspection Resources for Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) (ADAMS Accession No. ML060740006)
3. Inspection Manual Chapter 2503, Construction Inspection Program: Inspections of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Related Work
4. SECY-08-0117, Staff Approach to Verify Closure of Inspections, Tests, Analyses, and Acceptance Criteria and to Implement Title 10 CFR 52.99, Inspection During Construction, and Related Portion of 10 CFR 52.103(g) on the Commission Finding (ADAMS Accession No. ML081050362)
5. SECY-07-047, Staff Approach to Verifying the Closure of Inspections, Tests, Analyses, and Acceptance Criteria Through a Sample-Based Inspection Program (ADAMS Accession No. ML070430501)

Enclosures:

1.

Appendix A - Change History

2.

Table 1 - ITAAC Expert Panel Guidelines

3.

Table 2 - ITAAC Prioritization Data

4.

Table 3 - Baseline Question

5.

Table 4 - Value of Inspection Question

6.

Appendix B - The ITAAC Matrix

7.

Appendix C - ITAAC Attributes

8.

Appendix D - Prioritization of ITAAC Revisions

9.

Appendix E - Site Specific ITAAC Prioritization

10. Appendix F - ITAAC Inspection Protocol

Appendix A Change History Office Instruction LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection LIC-210 - Change History Date Description of Changes Method Used to Announce and Distribute Training 03/31/2020 This Office Instruction (OI) provides the instructions, and associated methodology, to prioritize (i.e., Target) inspection resources for performing ITAAC inspections per Manual Chapter 2503, Construction Inspection Program:

Inspections of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Related Work.

Additionally, this OI rescinds NRO-REG-102, Prioritization of Inspections, Tests, Analyses, and Acceptance Criteria for Inspection.

E-mail to all NRR staff None

Table 1 ITAAC Expert Panel Guidelines Expert panel: Generally, consists of three experienced NRC personnel with some combination of expertise in inspection, plant construction, reactor risk, and project licensing, including relevant plant design and ITAAC experience or knowledge. Each panel member should have a working knowledge of Appendix B and the ITAAC Matrix (including its associated notes).

It may be appropriate to develop design-specific rules for each expert panel - document them.

Start with consensus before trying other decision-making (e.g., voting, averaging) processes. [Note: It may be necessary to use more efficient processes if time becomes a factor.]

Use the full number range (i.e., 1 to 5). [A narrow range defeats the purpose of determining which ITAAC should be targeted for inspection.]

If necessary, make a reasonable assumption as to how the question relates to an ITAAC; then decide on the number response. [There are no N/A answers.]

Be consistent in answering the same question across all ITAAC, but let collective judgment, tempered by logic, rule.

Use the reference material sparingly (i.e., as really needed). Expertise is based upon your experience, not research!

Consider the Design Commitment (the what), checked by the ITA (the how determined) to arrive at the AC (the why acceptable).

Think generically - flaws, errors, and defects all constitute those ITA results that dont meet the AC.

Make a decision. Be consistent.

Think generically. Use the Matrix notes.

Distribute the ITAAC as widely throughout the families as consistency and logic allow Logic should rule where the notes dont apply Establish a Prioritization Scheme (either from notes or panel consensus)

Look for keywords and at system IDs

Table 2 ITAAC Prioritization Data Individual data tables customized for the activity being performed by the expert panel may be used to gather raw data. This table may subsequently be completed once all information has been captured.

Sheet of ITAAC NUMBER ITAAC Matrix Family SAFETY SIGNIFICANCE (SYS) (ITAAC)

(CV)

ERROR PROPENSITY (B)

(V)

(MV)

CONSTRUCTION AND TESTING EXPERIENCE (B)

(V)

(MV)

VERIFICATION BY OTHER MEANS (B)

(V)

(MV)

Table 3 Baseline Questions:

ITAAC Attribute:

Baseline Question (Q1):

Verification by other means:

What is the likelihood that construction defects, or other evidence that this specific inspection, test, analysis, and acceptance criteria (ITAACs) acceptance criteria have not been met, will remain undetected throughout the fabrication, installation, or testing processes?

(e.g., a component or system flaw may not be identified by other licensee process controls or verified by other means before the plant goes into operation)

Propensity for error:

To what degree does the complexity or difficulty in the performance of the engineering/construction/testing/inspection activities associated with this ITAAC contribute to the likelihood that errors will be made during fabrication, installation, or testing?

(e.g., the propensity for errors may be higher during the conduct of special processes, for example requiring qualification, than in the performance of simpler, more routine construction activities)

Construction and testing experience:

What would be the level of concern for a lack of prior design or construction experience (including the possibility of insufficient training) associated with performance of this ITAAC activity?

(e.g., the ITAAC may involve a unique, first-of-a-kind [FOAK] activity; or the industry experience with performance of this ITAAC might not be well known or established)

Table 4 Value of Inspection Questions:

ITAAC Attribute:

Value of Inspection Question (Q2):

Verification by other means What level of confidence would there be that no significant, hidden flaws would result from the performance of this specific inspection, test, analysis, and acceptance criteria (ITAAC), if the Nuclear Regulatory Commission (NRC) provided no inspection to the ITAAC activity while it was in progress?

Propensity for error If no NRC inspection were applied to this ITAAC, what level of trust would be maintained that the associated tasks/activities would be performed without difficulty or error?

Construction and testing experience What degree of assurance would exist that industry personnel could routinely and repetitively perform such tasks without problems in meeting the acceptance criteria, if the NRC provided no inspection oversight of this ITAAC activity?

B-1 Appendix B The ITAAC Matrix Office Instruction LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection BACKGROUND: The goal of inspections conducted under IMC-2503 is to verify licensee compliance with all 10 CFR Part 52 requirements for inspections, tests, analyses, and acceptance criteria (ITAAC), 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 Nuclear Regulatory Commission (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 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 A-1.

OVERVIEW: The matrix is considered both an inspection methodology (creating inspection samples),

as well as an inspection planning tool. As a planning tool, the ITAAC Matrix identifies the 25 core inspection procedures (IPs) that comprise a comprehensive set of construction programs and systems, structures, and components (SSCs) or processes, the activities for which the NRC believes encompass those combine license (COL) holder activities supporting the quality construction of a nuclear power plant. A review of the six column titles and the nineteen row titles identifies the six generic construction programs and nineteen SSCs or processes, respectively, which comprise the ITAAC matrix. The SSCs are construction products because they are installed or formed by construction activities during the building of a nuclear plant, and the processes are used to evaluate some performance-based aspect of the as-built SSCs.

Each row IP will be used to inspect activities associated with an ITAAC for design, construction, installation, composition, integrity, evaluation, or functionality of an SSC. A row IP not only addresses those construction activities directly involved with an ITAACs implementation in achieving and/or evaluating an SSCs as-built state, but also those peripheral construction activities indirectly involved in order to evaluate the totality of a licensees performance in completing the ITAAC. Each column IP will be used to inspect in-progress construction activities and their results for an ITAAC as oversight over a licensees construction program to determine if its programmatic controls support performance of construction activities in accordance with the construction programs guidelines.

B-2 POPULATING THE ITAAC MATRIX: ITAAC are subjectively assigned to one of the matrix blocks created by the intersection of a column and a row. Each block is referred to as an ITAAC family because it is a grouping of similar ITAAC with specific characteristics.

Figure B-1 ITAAC MATRIX A) As-Built Inspection B) Welding C) Const Testing D) Opn Testing E) Qual Criteria F) Design

/Fab Req

01) Foundations

& Buildings A01 B01 C01 D01 E01 F01

02) Struc Conc A02 B02 C02 D02 E02 F02
03) Piping A03 B03 C03 D03 E03 F03
04) Pipe Spt &

Restraints A04 B04 C04 D04 E04 F04

05) RPV & Intls A05 B05 C05 D05 E05 F05
06) Mech Comp A06 B06 C06 D06 E06 F06
07) Valves A07 B07 C07 D07 E07 F07
08) Elec Comp &

Systems A08 B08 C08 D08 E08 F08

09) Elec Cable A09 B09 C09 D09 E09 F09
10) I&C Comp &

Systems A10 B10 C10 D10 E10 F10

11) Containment Integrity & Pens A11 B11 C11 D11 E11 F11
12) HVAC A12 B12 C12 D12 E12 F12
13) Eqp Handling

& Fuel Racks A13 B13 C13 D13 E13 F13

14) Complex Sys w/ Multi-Comp A14 B14 C14 D14 E14 F14
15) Fire Prot 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 Prot A19 B19 C19 D19 E19 F19

B-3 Matrix Notes:

Column categories [A thru F]: Interdisciplinary Nuclear Regulatory Commission (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.

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]), then 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., American Society of Mechanical Engineers (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; weld 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, including quality acceptance tests (e.g., concrete testing or simulated signal testing to confirm Class 1E division boundaries), baseline data checks (e.g., preservice inspection (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 (EQ) in a harsh environment or in analyzing seismic response, as well as for other similar 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

B-4 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, which would include any Design Acceptance Criteria (DAC) associated with a particular facility design.

[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 results 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 (1) 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].

(2) 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 embedments, anchors, anchorages, water barriers that are installed before or after the concrete placement, and structural grout. Any items that are installed in the formwork (e.g., 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).

B-5 (3) 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 better fit (14) for Complex Systems w/ Multiple Components.

(4) 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.

(5) Reactor Pressure Vessel (RPV) & Internals: While the reactor pressure vessel (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 categorized on the I&C line (10).

(6) 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). This category 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).

(7)

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 line (11), Containment Integrity &

Penetrations.

(8) Electrical Components & 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 line (11).

(9) Electrical Cable: Involves all cable and includes the raceways (e.g., conduit, cable tray) in which it is run, and the raceway supports (e.g., Unistrut), unless they are part of the building structural steel (01) or pipe supports (04).

(10) I&C 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

B-6 (MCR) would be covered here. However, low-voltage instrument cable is covered under (09),

Electrical 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 Structural Concrete (02) and the electrical penetration assemblies are considered Electrical Components (08).

(12) Heating, Ventilating & Air Conditioning: [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) Equipment Handling and Fuel Racks: Includes the components involved with equipment handling and movement (e.g., polar crane), fuel movement (e.g., 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 process 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),

the engineering category (line 16) would apply. Similarly, the engineering category may be the best fit for design issues (e.g., seismic) and more subjective areas (e.g., human reliability analysis) that cross disciplinary boundaries, are engineering oriented, and difficult to categorize on any other line.

B-7 (17) Security and (18) Emergency Planning (EP): Are separate lines to cover the systems, processes, and programs related to these activities.

(18) Radiological Protection: 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 line (19).

C-1 Appendix C ITAAC Attributes Office Instruction LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection In November 2005, an expert panel of the Nuclear Regulatory Commission (NRC) managers with extensive nuclear construction and NRC inspection experience was convened to weight each of the five inspection, test, analysis, and acceptance criteria (ITAAC) attributes identified below. The expert panel then chose utility values for the level of inspection related to each attribute. This attribute weighting and utility selection process is part of the Analytic Hierarchy Process, which is an integral part of the ITAAC prioritization process. The results of this expert panel were provided as input to the algorithm that establishes the basis for the subsequent evaluation of the ITAAC against each of the five attributes. This weighting and utility process, performed for the five preselected attributes below, will apply to any reactor design; therefore, these expert panel deliberations do not have to be repeated. The values established by the expert panel for the utility scale values and weights for each attribute are provided in Table C-1 and Table C-2 respectively.

Safety Significance - This is highly dependent on the type and nature of the structure system, and component (SSC) included in the ITAAC. For example, instrumentation components and their particular failure modes may be modeled in the probabilistic risk assessment (PRA) for which the Birnbaum measure provides an indication of the conditional significance of degraded item performance. If an SSC is not modeled in the PRA, this attribute can be assessed for it in terms of the safety significance of the PRA success paths that it supports. The expert panel shall reduce subjectivity involved in rating an ITAAC for this attribute by using documented PRA resources when available. That information is available in the NRC staff self-evaluation report and Tier 2, Chapter 19 of the design control document. Individual PRA insights in those documents can be used in identifying significant PRA success paths.

Propensity of Making Errors - The degree of propensity to, or ease of, making errors in the process of fabrication, installation, or testing depends on the complexity or inherent difficulty of an activity. For example, a bimetallic weld on the reactor vessel safe end should be more difficult than welding structural steel for a seismic pipe support.

The degree of training or certification or experience required of the doer such as a Level III nondestructive examination technician is an indicator of a tasks complexity.

This typically is also related to the concept of a special process which has requirements associated with it per 10 CFR 50, Appendix B. This attribute may contribute to procedural, equipment, human, and inherent aspects of the probability of a flaw.

C-2 Definition of Baseline Impact Level Options for Constructed Scales:

High =

A high probability of error in the process or activity as a result of its very difficult or irregular-nature Medium =

A medium probability of error in the process or activity as a result of its less difficult or irregular-nature Low =

A small probability of error in process or activity as a result of its simplistic or routine-nature.

Construction and Testing Experience - This is a measure of the level of experience that the company or testing team has in (1) a first of a kind activity or (2) the subject activity or nuclear field or (3) the quality assurance requirements or strict adherence to procedural controls. This includes whether there is a history of quality or other performance deficiencies associated with the activity and whether the activity is for a new technology, new technique, industry standard, or known problem area.

This attribute could contribute to human and inherent aspects of the probability of a flaw.

Definition of Baseline Impact Level Options for Constructed Scales:

High =

Limited or no experience with the activity or known to be problematic for the industry Medium =

Increased experience with the activity or possibly problematic for the industry Low =

Vast experience with the activity or not problematic for the industry.

Opportunity to Verify by Other Means - The degree to which the activity can be verified at different times by other inspections or by other functional, pre-operational, or performance tests. For example, the lack of access to piping or cables once buried, coatings inside tanks once permanently sealed, or to other SSCs due to physical interferences that are time dependent. The preference is to inspect or test when afforded the best opportunity. This attribute could contribute to the procedural and inherent aspects of the probability of a flaw, as well as the ability of the licensee to detect the flaw, when associated with the sequencing of the construction program. For example, an ITAAC that verifies the rebar in prefabricated, reinforced concrete would be given a high impact level for this attribute because of the limited opportunity to inspect it.

C-3 Conversely, when two ITAAC tests are available with each able to completely test certain pumps and valves, this attribute would be given a low impact level.

Definition of Baseline Impact Level Options for Constructed Scales:

High =

No or limited opportunity to verify the activity to any degree by other means Medium =

Opportunity to partially verify the activity by other means.

Low =

Opportunity to completely verify the activity by other means Note that for a fabrication ITAAC, a High impact level indicates that there is no other means to check the correctness of the fabrication, a Medium impact level indicates that the other means is only moderately effective at checking the fabrication, and a Low impact level indicates the other means is very effective at checking the fabrication. A High impact level may be given if an analysis is the only means to identify a potential flaw except duplicating the abnormal stress levels assumed in the analysis which is not feasible for as-built installation. A seismic calculation is an example. A Low impact level for this attribute may mean that a test in addition to an analysis could easily discover the flaw during normal operation.

Licensee (or applicant) Oversight Attention - Not Used.

Each of the above attributes was chosen because they will have a specific influence on the NRC inspection effort as identified below:

Safety Significance: Provides a focus on the most important activities or SSCs from the standpoint of public safety, which may be of particular importance for passive designs.

Propensity of Making Errors: Provides a focus on the most error-prone areas likely to have quality deficiencies and thus a greater likelihood to identify and fix them. Higher complexity or inherent difficulty could lead to a greater probability of a flaw, regardless if the ITAAC has been inspected previously.

Construction and Testing Experience: This influences the inspection due to the lack of demonstrated track record, or the lack of a high-quality construction or performance history by the industry as a whole. By definition, this attribute would most likely be rated High during an initial inspection and only in subsequent inspection would this rating drop to Medium and Low.

Opportunity to Verify by Other Means: This influences the inspection plan by giving an input into whether there is another time or place that the ITAAC can be verified. In other words, this might be the only chance to witness something important or it can be just as completely verified by observing or reviewing another activity at a later date.

C-4 Table C-1 Attribute Utility Scale Rating Safety Signif.

Propensity of Making Errors Construction and Testing Experience Opportunity to Verify by Other Means Licensee (or applicant)

Oversight Attention 5

1 1

1 1

1 4

0.606 0.656 0.663 0.594 0.631 3

0.213 0.313 0.325 0.188 0.263 2

0.106 0.156 0.163 0.094 0.131 1

0 0

0 0

0 Table C-2 Attribute Weights ATTRIBUTE:

WEIGHTED VALUE:

Safety Significance 0.33 Propensity of Making Errors 0.05 Construction and Testing Experience 0.09 Opportunity to Verify by Other Means 0.19 Licensee (or applicant) Oversight Attention 0.34

D-1 Appendix D Prioritization of ITAAC Revisions Office Instruction LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection 1.0 Purpose To provide a simplified and less resource intensive method to update the targeted inspection, test, analysis, and acceptance criteria (ITAAC) list following revision to the Design Control Document (DCD), Combined License (COL), or Limited Work Authorization (LWA) which resulted in ITAAC deletions, ITAAC additions, or content changes to existing ITAAC.

2.0 General Requirements This procedure should be performed by an individual knowledgeable and experienced in the ITAAC prioritization process. The individual shall present his or her targeting determinations to a panel of senior NRR personnel familiar with the ITAAC process for final approval. If there is disagreement, the panel shall vote on the final targeting decision.

The reviewer shall have available the results of the prior expert panels for that DCD or COL [including any prior revisions] indicating the ITAAC rank and whether a particular ITAAC is targeted.

3.0 Specific Requirements

1. Review the DCD, COL, or LWA revision and identify all ITAAC deletions, ITAAC additions, and content changes to existing ITAAC. Record the associated ITAAC number(s) for each change in Table D-1.
2. Categorize and disposition each ITAAC change as follows. Record the results in Table D-1.

a.)

For all ITAAC deletions: determine whether the deleted ITAAC was targeted.

b.)

For all ITAAC additions: evaluate the content and wording of each new ITAAC (noting in particular the system to which it applies, its safety-related nature, and its relation or similarity to ITAAC that have already been prioritized). Based upon analysis and comparison of the existing ITAAC prioritization results, determine whether the new ITAAC should be targeted and which Matrix family it belongs in.

D-2

[For example, ITAAC added to ITAAC tables for safety-related systems where all the existing ITAAC have been targeted or ITAAC that add an additional inspection or test requirement to a specific ITAAC subject area that has been already targeted would likely also be considered a targeted ITAAC. In the converse, if ITAAC are added to a system with low ranking ITAAC that have not been targeted or augment the ITA for an already non-targeted ITAAC, these new ITAAC could be logically determined to all represent ITAAC that should not be targeted.]

c.)

For all ITAAC content changes: Evaluate the nature of the revision to determine if it has significantly altered either the focus or the substance of an ITAAC. If it has not, the ITAAC being evaluated should remain as targeted or not; depending upon its previous ranking.

[Typical changes that revise word usage or descriptions, add to the equipment population, revise the numeric value of an acceptance criterion, or add to the ITA by including a test to supplement an existing inspection would not normally justify changing the status of an ITAAC. However, this is a judgment call made by the reviewer, based upon the experience base and data available for the associated ITAAC set under review.]

3. Present the decisions documented in Table D-1 to a panel of three knowledgeable senior NRR staff members for final approval. If there is disagreement with the recommended action, the panel shall vote on the final targeting decision for the subject ITAAC.
4. Issue a memorandum documenting the process and its results. Update, as required, NRC databases (e.g., CIPIMS and VOICES) and any published targeted ITAAC lists to reflect the latest revision for a DCD or COL, as appropriate.

D-3 TABLE D-1 Prioritization of DCD or COL Revisions Design:

DCD / COL / LWA Revision No.:

ITAAC NUMBER MATRIX BOX CHANGE TYPE (note 1)

TARGETED ITAAC (note 2)

COMMENTS Note 1: Change Type: D - ITAAC Deleted, R - ITAAC Revised, A - ITAAC Added, E-editorial Note 2: T - Targeted ITAAC, NT - Non-Targeted ITAAC SHEET:

of

E-1 Appendix E Site-Specific ITAAC Prioritization Office Instruction LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection 1.0 Purpose To provide a simplified and less resource intensive method to target the site-specific inspections, tests, analyses, and acceptance criteria (ITAAC) within a Combined License (COL) or Limited Work Authorization (LWA).

2.0 General Requirements Flexibility is desired in the resource commitment necessary to target the site-specific ITAAC. Their number and complexity may vary greatly for each site. The process is simplified by the decision to target security and emergency planning ITAAC based on subject matter expert opinion, which are expected to comprise the majority of the site-specific ITAAC. The method chosen shall be approved by management of the Division responsible for ITAAC prioritization.

3.0 Specific Requirements Target the site-specific ITAAC using one of the following options. The options are listed in order of preference, based on the most effective utilization of resources.

a. Target the site-specific ITAAC per Appendix D.
b. Target the site-specific ITAAC utilizing expert panels for only two attributes, safety-significance and the ability to verify by other means. Follow the instructions in the main body of this procedure. For the remaining attributes, assume the highest-rank value.
c. Target the site-specific ITAAC per the instructions in the main body of this procedure.

F-1 Appendix F ITAAC Inspection Protocol Office Instruction LIC-210 Prioritization of Inspections, Tests, Analysis, and Acceptance Criteria (ITAAC) for Inspection Title 10 of the Code of Federal Regulations, Section 52.54 Issuance of standard design certification, requires design certifications to include those inspections, tests, analyses, and acceptance criteria (ITAAC) that, when acceptably completed, are necessary and sufficient, within the scope of the certified design, to provide reasonable assurance that the facility has been constructed and will be operated in accordance with the design certification, the Atomic Energy Act of 1954, as amended, and the Nuclear Regulatory Commission (NRC) regulations. The Part 52 Construction Inspection Program (CIP) has adopted an ITAAC inspection sampling strategy that utilizes a Matrix-organized, inspection-value process for prioritizing the ITAAC for NRC Inspection. The ITAAC prioritization methodology uses expert panels and their assessment of certain preselected attributes to rank the value of inspecting the ITAAC for any specific plant design. The result of this prioritization process for a plant referencing a certified design is the identification of specific ITAAC targeted for direct NRC inspection. These ITAAC targets are subject to the following protocol and rules, which should be generically applied to the implementation of IMC-2503 for ITAAC inspections at any facility licensed in accordance with 10 CFR Part 52:

1. The finding that all acceptance criteria are met (reference 10 CFR 52.103(g)) is supported by (1) a review of all ITAAC Closure Notifications (ICNs) and ITAAC post-closure notifications (IPCNs), as supported by independent record checks as necessary, and (2) NRC inspections of selected ITAAC. Direct inspection by the NRC is required for ITAAC targeted by the prioritization methodology endorsed by the CIP. This prioritization methodology is intended to ensure adequate coverage of the ITAAC to support a finding that all acceptance criteria are met.

[Note: The direct inspection of ITAAC entails any work observations, SSC field examinations, records reviews, or related inspection activities that provide an independent NRC verification of a particular ITAAC attribute selected for inspection.

Direct inspection may also include follow-up inspection checks (e.g., confirming that adequate corrective measures were taken for a problem identified during a work observation or checking that a material certification is correct if a conflict is identified in the work control documents).]

0

F-2

2. The targeted ITAAC for the AP1000 and advance boiling-water reactor designs include ITAAC with an ITAAC Rank > 0.4. For any other designs, the value of this threshold will be specifically determined, set and vetted for that specific design. The vetting process ensures adequate coverage exists of the ITAAC families while maintaining NRC inspection resource loading at a reasonable and achievable level.
3. All Design Acceptance Criteria ITAAC are targeted.
4. The targeted ITAAC represent those ITAAC that provide the highest value of inspection results for the committed NRC efforts. These ITAAC targets also establish a minimum inspection sample, based upon the organization of the ITAAC into Matrix families, which permits the direct inspection results to be extrapolated to the entire set of ITAAC, including those that only received a review of the licensees ICN (See protocol point 1). Thus, the processes and programs used to construct the plant (and complete the ITAAC) can be independently checked and assessed through the conduct of inspections of an informed ITAAC sample, sized to be reasonably achievable with available NRC resources.
5. If no ITAAC are targeted within a Matrix family, at least one of the higher ranked ITAAC within that family may be selected for direct inspection, as part of an independent inspection sample to ensure complete coverage of the construction processes and programs.

[Inspection resources can be allocated to non-targeted ITAAC for cause, assessment purposes, or other inspection planning goals. This inspection flexibility is also provided to cover the inspection of ITAAC completed by contractors who otherwise would not receive targeted inspection.]

6. NRC inspection planning should consider that each targeted ITAAC will be the subject of direct inspection by both the row and column inspection procedures (IP) applicable to the Matrix family in which the ITAAC resides.
7. The NRC will continue to perform row and column IPs at any site, as long as the applicable row process or column program is being implemented at that site and until all targeted ITAAC affected by the row or column IP have been inspected. [See also, protocol points 8a and 8b for the impact of assessment on continuing IP implementation.]
8. The NRC Assessment program can impact the ITAAC inspection process in the following ways:
a.

A positive assessment in a construction process area (i.e., a matrix row IP) may allow the suspension of further inspections of the subject process, as long as no targeted ITAAC remain to be inspected for that matrix row.

F-3

b.

A positive assessment in a construction area, affecting any matrix IP implementation, may allow independent inspection samples of the ITAAC to be waived.

c.

A negative assessment of construction activities affecting any particular ITAAC or matrix family may result in the decision to re-run the ITAAC prioritization program algorithm using the appropriate negative weighting numbers for the licensee oversight attribute for that ITAAC family. This will likely result in more targeted ITAAC (i.e., for the AP1000 and ABWR > 0.4 ITAAC rank) that need to receive direct inspection for that family.

d.

The judicious application of NRC assessment of ITAAC inspection results, particularly for negative assessments, requires consideration of the specific licensee controls and contractor programs that yielded the subject findings.

For example, if a negative assessment of a construction activity results in increased inspection targets for a specific family of ITAAC, the responsible NRC personnel should ensure that the targets selected for additional inspection actually represent the problematic contractors work or the scope of construction evidencing the inadequate licensee controls.

The NRC Assessment program is within the purview of NRC management controls and is considered a management review function with the appropriate inspector input.

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