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UNITED STATES NUCLEAR REGULATORY COMMISSION e
o WASHINGTON, D. C. 20$55 g
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April 27, 1990 I
t NOTE T0: Stephen G. Burns, OCM/KC FROM:
James L. Blaha, A0/0EDO
SUBJECT:
R0WDEN POINT PAPER Attached is the Mark Rowden point paper Jim Sniezek referred to at the Technical Assistants meeting.
W' Ja es L. Blaha, A0/0EDO
Attachment:
As stated J. Gray /
cc:
J. Guttmann J. Scarborough M. Lopez-Otin SECY DGC J. Tyler
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DE&EI 3/13/90 J
MEMORANDUM TO:
Joe Quirk
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FROM:
Marc Rowden RE:
Part 52 Level of Detail Requirements DATE:
March 12, 1990 This memorandum examines the issue of the requisite level of detail for a design certification application.
The memorandums (1) summarizes the relevant provisions of Part 52, and the explanatory statements by the commission accompanying its issuance (2) reviews the development of these same provisions to shed light on the positions considered by the NRC and either rejected or accepted; and (3) provides a suggested framework for future discussions with the NRC on this issue.
I We are independently preparing a level of detail appendix for inclusion in the NUMARC working group's ITAAC report.
1.
Pa rt 52 Reauirements section 52.47(a) (2) provides as follows:
The [ design certification) application must contain a level of design information sufficient to enable the Commission to judge the applicant's proposed means of assuring that construction conforms to the design and to reach a final conclusion on all safety questions associated with the design before the certification is granted. _The information submitted for e desian certification must include perrormance readirements ano Bijian information sufficientiv detailed to permit
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_the creparation of aCCSDtence and inspection _
requirements by the NRc. and procurement _
_ specifications and construction and insta11atinn__
J specifications ov an soolicant.
The Commission will
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'rwguire, prior to design certification, that 1
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.-- i Jnformation normally contained in certain procurement specifications and construction and installation
' specifications be completed and ava1T&b W for auait if sucn inrormation in==a== mary f or the _. commission so maxe its safety determination.
The foregoing is further explained as follows in the accompanying Part 52 Statements of Consideration:
In addition, an essentially complete design is_a (emian that has noen rina11ses to sneyiTit that
.procurament specifications ana construcElon and_
installation moecnfications can me 50mplet W ald made available for audnt if it is setermined that thTey_7 hie'~
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required for Commission review in eGGOYdince with l
requiremen Ctof 552.47 (a).
Procut*ement speciTiratfD7Fa
'would have to acentify the equipment and material performance requirements and include the necessary codes, standards, and other acceptance and performance criteria to which the equipment and materials will be fabricated and tested.
Construction and installation specifications would have to identify the criteria and
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methods by which systems, structures and components are erected or installed in the facility and include acceptance, performance, inspection, and testing requirements and criteria.
II. Anelvina Part 52 Level of Detail cuidanea on their face, the above quoted provisions lead to the following basic conclusions:
1.
As a primary requirement, the level of design information to be contained in a DC application must be
" sufficient to enable the Commission to judge the applicant's proposed means of assuring that construction conforms to the design and to reach a final conclusion on all safety questions associated with the design before the certification is j
j granted,' (i.e., must be sufficient to satisfy safety review j
and ITAAC needs).
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' 2.
While the foregoing should be read in the context of other relevant NRC guidance (such as the Standard Review Plan and Reg Guide 1.70), the quoted statement seemingly affords a considerable degree of staff discretion as to the level of design detail which an applicant may be required to submit.
However, the two sentences immediately following in 5 52.47 (a) (2) qualify the parameters for exercise of that discretion.
Thus, ES2.47(a)(2) goes on to state: "The information submitted for a design certification must include performance requirements and design information sufficiently detailed to normit the prep (aration of acceptance and inspection
% f ewW %s fee. pen hv of3 requirements by the NRC, an3 procurement s)ecifications and construction and installation specifications by an applicant."
(Emphasis added)
Part 52 thus makes it clear that the D.C.
applicant DBAA REL submit procurement specifications and construction and installation specifications but need submit only such informa?. ion which would " permit" their preparation.
This conclusion is reinforced, and the potential further steps explained, by the final sentence in 552.47(a), which states that "the Commission will reeuire, prior to design certification, that information normally contained in certain procurement specifications and construction and installation specifications be comnleted and available for audit if such l
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information is necessary for the Commission to make its safety determination." (Emphasis added)$!
Thus, in contrast to current FSAR praction, this indicates that considerably less information is envisioned to be supplied at the D.C. application stage than at the stage of an FSAR at the time of OL issuance, where procurement specifications and construction and installation specifications have been prepared and are available for NRC review.
3.
The foregoing conclusions are further supported by the explanation in the Commission's Part 52 Statements of Consideration.
That background explanation states that the design submitted must be " finalized to the point that j
procurement specifications and construction and installation specifications can be comoisted and made availabia for audit if it is deternined that thev are resuired for Commission review."
In such case, the " specifications" made available for audit would not be those which a plant constructor would issue in final forar rather, the procurement specifications "would have to identify the equipment and material performance
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Compare these Part 52 provisions and their explanation with the analogous provisions in the ABWR LRBt "The degree of l
design detail necessary for providing an essentially complete desip is to be that detail that in muitable for ebtainina seecific eeulement er construction hida and to demonstrate conformance to the design safety limits and criteria".
The underscored language also appears in the AIF report on NPP standardization issuad in November of 1986.
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i requirements and include the necessary codes, standards and 1
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other acceptance criteria and performance criteria to which the equipment and materials will be fabricated and tested.
i Construction and installation specifications would have to identify the criteria and methods by which systems, structures j
and components are erected or installed in the facility and include acceptance, performance, inspection, and testing requirements and criteria." 54 F.R. 15382.
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That the Commission did not intend to go beyond the foregoing as respects level of design detail is underscored by j
examining the Part 52 positions recommended by the ACRS and the
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NRC staff, which the Commission rejected in adopting the final l
Part 52 issuance. 'The Commission did not adopt the i
j recommendation of the ACRS that the required level of detail go bevond that which is necessary to " permit the preparation of i
i procurement specifications and construction and installation l
specifications", and require that "this large body of l
information [be) available in final form, i.e., the procurement 1
l specifications and the construction and installation f
specifications" themselves. (ACRS Part 52 comment letter of l
January 19, 1989).
Similarly, the Commission did not adopt the proposal of the Executive Director for Operations that i
552.47(a)(2) be expanded to include the following sentence:
"Before the design is approved, it must be finalized to the i
point that procurement specifications and construction and I
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- t installation specifications Ara completed and available for i
audit."
(raphasis added)
Rather, in response to an objecting i
combustion Engineering comment, the commission included in the final rule the sentence which now appears in $52.47(a) (2):
"The commission will require, prior to design certification, i
that information normally contained in certain procurement specifications and construction and installation specifications a
be completed and available for audit if such information is necessary for the Commission to make its safety determination."
The foregoing is tantamount to the commission rejecting the i
l position that the amount of design detail submitted or available at the time ef D.C.
issuance must be equivalent to the amount of design detkil which, under current Part 50 licensing practice, is submitted in a FSAR or available at the time of OL issuance.
III. Succested Framework for Further Staff Discussions As I understand it, GE believes that its ABWR submission is consistent with the principles set forth herein, the further guidance contained in the Standard Review Plan and Reg Guide 1.70.
Moreover, the level of design detail available for staff review relative to the ABWR meets or exceeds the level of detail found acceptable by the staff in support of the GESSAR Final Design Approval.
In principle, that should be enough.
Nonetheless, it was evident to me from Tom Murley's repeated statements at the ITAAC briefing on March 9, that he and his
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staff want considerably more in the way of design detail --
i either in the application docket or (more likely) prepared by GE and available for audit in the Company's files.
He related this to ITAAC needs, but placed even greater emphasis en the staff's willingness and ability to sign off." definitively" on future use of a certified design without substantially more detailed information than D.C. applicants have submitted thus far.
Prior to SE attempting to satisfy this generalized staff "need", however, additional discussions with Murley and his staff should take place to better define (1) what GE can provide and (2) what NRC is prepared to accept.
In discussing the design detail question with the staff, it
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is inevitable that comparisons and contrasts will be made with current Part 50 licensing practice. ' The amount of design detail either contained in modern FSARs or available at the time of an OL issuance is a tempting comparison to make with either the amount of information in the ABWR/SSAR or that which is otherwise available for review (i.e., audit).
However tempting, this comparison is inappropriate.
First, the FSAR documents what actually has been constructed.
The SSAR states what will be constructed.
Material and component procurement has substantially occurred at the time the FSAR is amended to support an OL issuance.
As previously discussed, this level of detail was expressly rejected by the commission in promulgating Part 52.
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.The more appropriate point of departure for SSAR comparison L
j is the PSAR. - Under Part 50,'the PSAR provides the level of 1
i design detail and other assurances that are exacted from an j
opplicant prior to the staff's authorising commencement of l
construction.
A construction permittee is permitted to 1
initiate construction with an approved conceptual design and a
the staff can impose additional requirements either through the
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backfit process or, more practically, in the course of making I
its reasonable assurance findings at the time of OL issuance.
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Under Part 52 the staff is provided far greater detail i
prior to design certification.
Although there is a heightened i
standard under Part 52 for the staff to impose a change, prior to certifying a Gesign the NRC will have reviewed an i
essentially complete design at the level of performance requirements (and in many instances beyond), will have reviewed the ITAAC, and will be able to assure appropriate interfaces in I
greater detail at the time of col issuance.
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In casting the discussion with the Staff in this context,
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l GE will be able to emphasize all the additional information it has submitted beyond the traditional PBAR.
In contrast, if the discussion is cast in the context of comparison with the modern
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FSAR, GE will be in the position of explaining how much 1ess detail it has provided.
After you have reviewed this memorendum. it would be useful to have a telephone conference with Jay Outierrez and me.
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l PART 52 LEVEL OF DETAIL REQUIREMENTS i
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SECTION 52.47(a)(2)
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The (design certification) application must contain a j
level of design information sufficient to enable th'e' Commission to judge the applicant's proposed means of 4
j assuring that construction conforms to the design and to reach a final conclusion on all safety questions i
associated with the design before the certification is granted. 4he information submitted for a desion
. certification must include performance recuirements j
and design infor=ation suf ficiently detailed to Dermit 4
_t n e preparation of ecceptance and inanection requirements by the Nac, and procurement j
_ specifications and construction and installation i
specifications by an applicant.
The commission will i
prior to design certification, that require, ion normally contained in certain procurament informat specifications and construction and installation j
specifications be-completed and available for audit if such information is necessary for the commission to j
maXe its safety determination.
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l PART 52 STATEMENTS OF CONSIDERATION i
3 In addition, an essentially complete design is a design that has been rinalizac to the point that procure =ent spectrications and construction and I
installation specifications can be completed and made
_available for audit if it is determined that they are required for co==1ssion review in accordance with the
_ requirements of iS2.4?(a).
Procurement specifications l
would have to identify the equipment and material performance requirements and include the necessary t
codes, standards, and other acceptance and performance 5
j criteria to which the equipment and materials will be fabricated and tested.
Construction and installation
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specifications would have to identify the criteria and 4
methods by which systems, structures and components are erected or installed in the facility and include i
acceptance, performance, inspection, and testing j
requirements and criteria.
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SUPPORT SAFETY REVIEW AND ITAAC PREPARATION 1
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1 LRB COMPLETENESS OF DESIGN O DEGREE OF DESIGN DETAIL NECESSARY FOR PROVIDING AN ESSENTIALLY COMPLETE DESIGN IS THAT DETAIL SUITABLE FOR:
- OBTAINING SPECIFIC EQUIPMENT OR CONSTRUCTION BID'S
- DEMONSTRATING CONFORMANCE TO THE DESIGN SAFETY LIMITS AND CRITERIA
- DEFINING THOSE RELATED TESTS, INSPECTIONS, ANALYSES, AND i
ACCEPTANCE CRITERIA THAT ARE NECESSARY TO ASSURE THAT THE DESIGNS ARE PROPERLY IMPLEMENTED IN THE PLANT
- - CURRENTLY BEING DEVELOPED FOR ABWR 0 IN LIMITED CASES WHERE DESIGN INFORMATION IN NOT AVAILABLE, INFORMATION IS PROVIDED ON METHODS, PROCEDURES, AND l
PERFORMANCE CRITERIA.
FOR ABWR THIS INCLUDES:
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- PIPING SYSTEM LAYOUTS
- ELECTRICAL SYSTEM LAYOUTS
- MAJOR CONDUIT LAYOUTS
- CABLE TRAY LAYOUTS O THE SSAR DEFINES MAJOR DESIGN COMPONENTS AND INCLUDES RESU OF SUFFICIENT ENGINEERING TO IDENTIFY:
_ABWR STATUS
- DESIGN BASIS CRITERIA INCLUDED
- ANALYSIS AND DESIGN METHODS INCLUDED
- FUNCTIONAL DESIGN AND PHYSICAL INCLUDED ARRANGEMENT OF AUXILIARY, BOP, AND NSSS SYSTEMS
- PLANT PHYSICAL ARRANGEMENTS SUFFICIENT INCLUDED TO ACCOMMODATE SYSTEM AND COMPONENTS
- FUNCTIONAL AND/OR PERFORMANCE SPECIFI-INCLUDED CATIONS FOR COMPONENTS AND MATERIALS SUFFICIENTLY DETAILED TO BECOME A PART OF ASSOCIATED PROCUREMENT SPECIFICATIONS
- ACCEPTANCE / TEST REQUIREMENTS -
INCLUDED
- RISK ASSESSMENT METHODOLOGY INCLUDED
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l LRB' COMPLETENESS OF DESIGN
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(CONTINUED)
O DESIGN DOCUMENTATION FOR SYSTEMS, STRUCTURES, AND COMPONENTS INCLUDES:
ABWR STATUS
- DESIGN BASIS CRITERIA INCLbDED
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- PLANT GENERAL ARRANGEMENTS OF STRUCTURES
- INCLUDED, AND COMPONENTS, INCLUDING PIPING SYSTEM EXCEPT CRITERIA LAYOUTS FOR PIPING l
LAYOUT
- PROCESS AND INETRUMENTATION DIAGRAME, P E T D ' s T H P,k.W L E D ;
l ELECTRICAL SYSTEM LAYOUTS, AND MAJOR CRITERIA FOR l
CONDUIT AND CABLE TRAY LAYOUTS OTHERS l
- CONTROL LOGIC DIAGRAh5 INCLUDED i
- SYSTEM FUNCTIONAL DESCRIPTIONS AND INCLUDED i
SUPPORTING STUDIES AND AHLAYSES
- COMPONENT AND PROCUREMENT SPECIFICATIONS, SUITABLE DETAIL INCLUDING ACCEPTANCE CRITERIA AND TEST AVAILABLE FOR REQUIREMENTS DEVELOPING SPECS.
- CONSTRUCTION AND INSTALLATION SPECIFI-INCLUDED CATIONS, INCLUDING ACCEPTANCE CitITERIA AND TEST REQUIREMENTS
- PROGRAM FOR THE ASURANCE OF QUALITY INCLUDED
- DESIGN-RELATED ASPECTS FOR THE EMIRGENCY IN PROGRESS PLANS
- SUPPORTING DESIGN DOCUMENTATION SUCN AS INCLUDED SITE ENVELOPE DATA AND CALCULATIONS SUFFICIENT TO SUPPORT THE LEVEL OF DETAIL' HOTED ABOVE
- DESIGN-RELATED ASPECTS OF THE PHYSICAL INCLUDED SECURITY PROGRAM
- AN ALARA RADIATION PROTECTION PLAN INCLUDED (INTERFACE)
-1CCIbENTANALYSES INCLUDED
- TECHNICAL SPECIFICATIONS INCLUDED
- RISK ANALYSIS INCLUDED s
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Vy I.
HIERARCHY OF DESIGN REOUIREMENTS:
RULES AND REGULATIONS STANDARD REVIEW PLAN /BTPs REGULATORY GUIDES / CODES AND STANDARDS l
II.
APPROXIMATE HIERARCHY OF DESIGN DETAIL:
l GENERAL ENGINEERING DESIGN, CONSTRUCTION, AND INSTALLATION SPECIFICATIONS (CIVIL / STRUCTURAL, MECHANICAL, ELECTRICAL, HVAC, I&C)
THESE ARE INDEED GENERAL, USUALLY SETTING FORTH GENERALLY APPLICABLE REQUIREMENTS, INCLUDING TOP TIER DESIGN PERFORMANCE REQUIREMENTS, CODES AND STANDARDS, AND QA/QC REQUIREMENTS.
BUILDING / SYSTEM DESIGN SPECIFICATIONS (INCLUDING PERFORMANCE REQUIREMENTS AND MATERIAL SPECIFICATIONS)
ARCHITECTURAL DRAWINGS (BUILDING LAYOUT) k GENERAL ARRANGEMENT DRAWINGS PROCESS FLOW DIAGRAMS, I&C LOOP DIAGRAMS, ELECTRICAL AND I&C
[*o LOGIC DIAGRAMS
[1 h) 0 P& ids (INCL. HVAC), ELECTRICAL ELEMENTARY DRAWINGS, I&C
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ELEMENTARIES
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r'%[w PIPING /HVAC/ CABLE TRAY AND CONDUIT ISOMETRICS, MAJOR COMPONENT INSTALLATION DRAWINGS, ARCHITECTURAL DRAWINGS (STRUCTURAL %
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DETAIL) 3 th g.Q/
PIPING / CABLE TRAY / CONDUIT /HVAC SUPPORT DESIGN DETAIL DRAWINGS, f
6f CABLE PULL SHEETS, ELECTRICAL TE ON DRAWINGS, ELECTRICAL Ljf AND I&C COMPONENT SCHEMATICS, PIPING / MECHANICAL WELD DETAILS, 3
hid CABLE SPLICE DETAILS, AND PIPING, CABLE TRAY, CONDUIT, HVAC DUCT, COMPONENT INSTALLATION DETAIL DRAWINGS glp AS-BUILT (POST-CONSTRUCTION) ARCHITECTURAL, STRUCTURAL, MECHANICAL, ELECTRICAL, I&C, HVAC, DRAWINGS (NOT APPLICABLE TO DESIGN CERTIFICATION).
III. SAMPLE LIST OF PROCEDURES TRANSLATING CONSTRUCTION AND INSTALLATION SPECIFICATIONS -- GENERALLY APPROVED BY THE DESIGNER:
CONSTRUCTION AND INSTALLATION PROCEDURES, INCLUDING REBAR INSTALLATION (TIEING AND CADWELDING), CONCRETE PLACEMENT AND DEAERATION, EMBEDDED BOLT PLACEMENT, STRUCTURAL STEEL ERECTION, MASONRY WALL CONSTRUCTION. EQUIPMENT SETTING, WELDING, SOLDERING,
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l BOLT TORQING, CABLE PULLING, LIFTING AND RIGGING, PROTECTIVE COATING APPLICATION, ROTATING EQUIPMENT ALIGNMENT, ELECTRICAL TERMINATIONS, CABLE TIE WRAP INSTALLATION, LABELING, CABLE SPLICING, SNUBBER INSTALLATION, REBAR CUTTING, EXPANSION ANCHOR INSTALLATION, ETC.
NOTES:
1)
THIS HIERARCHY IS HARDLY EXHAUSTIVE AND TERMINOLOGY VARIES FROM VENDOR /A/E TO VENDOR /A/E.
2)
THE PSAR/FSAR MAY TOUCH ON ALL ASPECTS OF OF THE DESIGN DETAIL HIERARCHY, BUT GENERALLY ONLY SCRATCHES THE SURFACE.
3)
VARIOUS ANALYSES, INCLUDING THE SAFETY ANALYSIS, STRESS ANALYSES, EQ ANALYSES, FIRE PROTECTION ANALYSES ETC. EVOLVE AS THE DESIGN DETAIL IS DEVELOPED.
4)
AS THE DESIGN MATURES, ALL LEVELS OF THE HIERARCHY MAY BE SUBJECT TO MODIFICATION.
5)
DETAILED PROCUREMENT, CONSTRUCTION AND INSTALLATION SPECIFICATIONS EVOLNE WITH THE DESIGN.
6)
BELOW THE DOTTED LINE IN THE HIERARCHY, IT BEGINS TO BE ESSENTIAL (AS APRACTICAL MATTER) THAT YOU KNOW WHAT SPECIFICALLY YOU ARE BUYING FROM WHOM. ADDITIONALLN, YOU MUST GET TO BELOW THE DOTTED LINE IN ORDER TO PREPARE COMPLETE PROCUREMENT SPECIFICATIONS.
7)
IN ORDER TO SATISFY THE OBJECTIVES OF PART 52, IT WOULD APPEAR THAT ALL OF THE LEVELS OF DESIGN DETAIL LISTED ABOVE SHOULD BE INCLUDED IN THE DEFINITION OF "ESSENTIALLN j
COMPLETE DESIGN".
8)
THE SUBSTANTIVE REQUIREMENTS / ACCEPTANCE CRITERIA OF THE INSTALLATION PROCEDURES, SUCH AS THOSE CITED ABOVE, SHOULD BE CAPTURED BY ITAAC.
THEIR ARE QC INSPECTION AND TEST REQUIREMENTS ESTABLISHED IN THE INSTALLATION PROCEDURES THEMSELVES OR IN STAND-ALONE CHECKLISTS TO PROVIDE INDEPENDENT VERIFICATION THAT ALL NECESSARY REQUIREMENTS ARE MET.
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