RIS 2008-05, Updated NRC Regulatory Issue Summary 2008-05, Revision 1: Lessons Learned to Improve Inspections, Tests, Analyses, and Acceptance Criteria Submittal
| ML102500244 | |
| Person / Time | |
|---|---|
| Issue date: | 09/23/2010 |
| Revision: | 1 |
| From: | Mcginty T, Tracy M Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| Cheung C, NRO/DCIP, 301-415-2043 | |
| References | |
| RIS-08-005, Rev 1 | |
| Preceding documents: |
|
| Download: ML102500244 (11) | |
ML102500244 UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
WASHINGTON, DC 20555-0001
September 23, 2010
NRC REGULATORY ISSUE SUMMARY 2008-05, REVISION 1, LESSONS LEARNED TO IMPROVE INSPECTIONS, TESTS,
ANALYSES, AND ACCEPTANCE CRITERIA SUBMITTAL
ADDRESSEES
All holders of or applicants for a power reactor early site permit (ESP), combined license (COL),
standard design certification (DC), standard design approval, or manufacturing license under Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to communicate good practices associated with the quality, clarity, and inspectability of inspections, tests, analyses, and acceptance criteria (ITAAC) submitted as part of applications for ESPs, standard DCs, or COLs. This RIS also recommends that applicants, vendors, and the NRC maintain complete and consistent ITAAC lists.
Addressees
should consider incorporating these practices into their applications to provide for a more efficient inspection and ITAAC
closure process. No specific action or written response is required.
RIS 2008-05, Revision 1, expands on issues that were identified in RIS 2008-05, Lessons Learned to Improve Inspections, Tests, Analyses, and Acceptance Criteria Submittal, dated February 27, 2008 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML073190162), and incorporates several new issues. Additional information appears in Regulatory Guide (RG) 1.215, Guidance for ITAAC Closure under 10 CFR Part 52 (ADAMS Accession No. ML091480076), which endorses the methodologies described in the industry guidance document Nuclear Energy Institute (NEI) 08-01, Industry Guideline for the ITAAC Closure Process under 10 CFR Part 52, Revision 3, issued January 2009 (ADAMS
Accession No. ML090270415).
BACKGROUND
As required by 10 CFR Part 52, applicants for ESPs, standard DCs, or COLs must submit, among other information, the proposed ITAAC that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses (ITA) are performed and the acceptance criteria are met, the facility has been constructed and will be operated in conformity with the license, the provisions of the Atomic Energy Act of 1954, as amended, and the Commissions rules and regulations. Following issuance of a COL, a licensee completes the ITAAC in the license during construction and submits notification letters to the NRC in
RIS 2008-05, Rev. 1 accordance with 10 CFR 52.99, Inspection during Construction. The NRC verifies closure of all ITAAC through direct inspection or other methods, such as oversight of the licensees ITAAC
completion, closure, and approval processes.
SUMMARY OF ISSUE
S
On the basis of a review of recent ITAAC submittals to the NRC, the staff has identified five general categories in which ITAAC submittals could be improved: (1) ITAAC format and content, (2) ITAAC nomenclature and language, (3) ITAAC focus, logic, and practicality,
(4) ITAAC standardization and consistency, and (5) ITAAC scope.
ITAAC FORMAT AND CONTENT
Applicants should consider using a consistent system to identify and number individual ITAAC within their applications. Although past submittals have typically used an alphanumeric system, some submittals used dashes or separate paragraphs with no labels in the body of the text to specify separate ITAAC requirements. In other submittals, the alphanumeric designations were not consistently aligned for the applicable ITAAC tables. Use of a standard and consistent ITAAC identification system will facilitate ITAAC closure activities.
Applicants should consider a standard methodology for identifying and organizing the structures, systems, and components (SSCs) associated with an ITAAC to enable a more efficient inspection and ITAAC closure process. For example, if an applicant chooses to organize SSCs in a tabular format (as opposed to system drawings), it could group instrumentation-related components (e.g., sensors) separately from mechanical components. The applicant could also list mechanical components, or a group of components that are likely to be close together, in similar categories (e.g., pumps, valves).
Applicants should avoid the integration of several different engineering or construction areas into a single ITAAC. For example, one applicant put all of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements and the pipe break analyses for all of the plants piping into only two ITAAC. In another instance, an applicants definition for a systems basic configuration included five separate engineering and construction processes, the applicability of which had to be interpreted to determine the required ITAAC for each. In both cases, the ITAAC were ill-defined and unwieldy.
COL applicants should consider aggregating into one complete ITAAC list all of the ITAAC contained in both the certified design and the COL. Because this complete ITAAC list would include all ITAAC applicable to a specific COL, it would function as a master list that could be referenced by both the NRC and the applicant (or licensee)
throughout construction until the Commission makes a 10 CFR 52.103(g) finding.
As a complementary measure to the development of a consistent ITAAC identification system and an ITAAC master list, both DC and COL applicants should consider
RIS 2008-05, Rev. 1 establishing a logical process for handling, identifying, and referencing ITAAC revisions.
If a design control document (DCD) revision or COL change adds to or renumbers the existing ITAAC, the applicant should link all new ITAAC to the existing ITAAC they originated from through their alphanumeric designations. This renumbering protocol would facilitate the closure of any new ITAAC by correlating available information with the planned inspection activities for the ITAAC already approved. Both licensee and NRC inspection processes would then be able to efficiently coordinate existing inspection results and conclusions with the revised ITAAC.
ITAAC NOMENCLATURE AND LANGUAGE
Applicants should clearly define all terms used in an ITAAC. The following are examples of confusion caused by undefined terms:
-
It was unclear whether an applicant using the terms design reports and reports in an ITAAC involving ASME Code piping and welding intended the ASME Code definition for design report and data report or its own definition for these terms.
-
An applicant frequently used the term as-installed but did not define it. The applicant was using this term as a substitute for as-built, which it did define.
Substitution of undefined but similar terms for as-built is not recommended.
Even when the applicable DCD defines ITAAC terms and phrases, applicants should ensure that such ITAAC word usage is consistent with industry-accepted guidance. For example, Section 8.5 of NEI 08-01, Guidance for Inspections, Tests or Analyses Performed at Other Than Final Installed Location, as endorsed by NRC RG 1.215, discusses several examples of the already defined term, as-built, in the context of how an as-built condition can be correctly interpreted in various ITAAC applications.
Applicants should specifically consider this guidance (not only in Section 8.5, but also elsewhere in NEI 08-01) when developing ITAAC to submit for approval.
If applicants use such terms as interfacing systems, control room features, minimum set, seismic structure, equipment qualification, physical separation, fast-closing valves, and rapid depressurization, they should clearly define themor at least quantify the adjectives usedfor inspection purposes. For example, the term equipment qualification, if not clearly defined, could be associated with the specific requirements for environmental qualification (EQ) given in 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants.
Use of the conjunction and/or is never appropriate.
If applicants use the phrase a report exists and concludes that... they should specify the scope, the type of report and how report generation is controlled. For example, the applicant should explain whether the scope of the report includes the design, the as-built construction (as reconciled with the design), or any other information. This is not
RIS 2008-05, Rev. 1 necessary for reports generated in accordance with the ASME Code, as the Code itself governs the creation of such reports.
Applicants should use specific technical terms consistently. For example, the terms pressure test and hydrostatic pressure test are often inappropriately interchanged;
similarly, internal pressure and design pressure are used synonymously in the same ITAAC to mean the same thing. Applicants should also take care not to confuse the preoperational conditions with the applicable operation modes in situations involving testing.
Applicants should avoid subjective terms, such as inclined sufficiently, acceptable level, and adequate thickness. These terms call for interpretation to understand the ITAAC.
ITAAC INSPECTION FOCUS, LOGIC, AND PRACTICALITY
Applicants should avoid applying a single ITAAC to a large area of construction or to activities that are likely to be widely separated in time. Large-scoped ITAAC create problems with verification activities and with the timing of construction and other requisite inspections.
Applicants should consider breaking ITAAC with a large number of SSCs into areas of construction. For example, if a single ITAAC includes construction from the basemat to the top of containment and applies to several different buildings, the large area and scope create difficulties, not only in tracking the applicable SSCs, but also in connecting the interdependent nature (e.g., seismic) of the applicable structures. Breaking a large single ITAAC into several simpler ITAAC will make the ITAAC closure process more efficient.
Applicants that envision using modular construction should consider the impact of these activities in developing their ITAAC. For example, the inspection of as-built SSCs implies that as-built refers to the completion of construction at the final location at the plant site. However, if a module is fabricated at a remote location (e.g., a shipyard), it may be possible to justify inspection or testing at the remote location. It may also be possible for applicants to develop ITA that can be performed at the remote location.
(The industry guidance document, NEI 08-01, discusses modular construction, as well as a consistent approach to the use of as-built terminology.)
Applicants should consider the timing and sequence of construction activities in the development of related ITAAC. Breaking an ITAAC into pieces that can be completed in the early and mid-stages of construction would help alleviate the surge in ITAAC closure activities at the end of the process.
Applicants should develop ITAAC that specify the construction activity will be completed successfully rather than specifying that the construction records will be reviewed. For example, a design commitment that indicates certain buildings are constructed of reinforced concrete or are prestressed is inconsistent with an ITA that specifies an
RIS 2008-05, Rev. 1 inspection of the construction records. The licensees inspection should verify the actual construction to ensure the use of reinforced concrete or prestressing as required.
ITAAC inspections by licensees are intended to physically confirm the attribute being checked and should not focus solely on inspection of documentation. ITAAC inspections of construction activities may be documented via work package documentation in accordance with the licensees Quality Assurance Program, and such records are expected to be included in the ITAAC completion package.
Applicants should ensure that design commitments and ITAAC are consistent. It is important for the language and details of the ITAAC to comport with the language of the design commitment. In one example, the design commitment indicated that the piping was designed and constructed in accordance with the ASME Code, but the acceptance criteria only required the existence of design reports (which would not normally encompass construction quality) for as-built piping. In another example, the design commitment indicated that each standby diesel generator was sized to accommodate expected loads, but the acceptance criteria only required the generator to provide power at generator terminal rated voltage and frequency when at rated load. To validate the design commitment, the applicant would first need to determine the electrical loads presented by equipment credited in the safety analysis (e.g., by analyses or testing) and then conduct a test to verify that the procured diesel generator could adequately supply these loads.
Applicants should ensure that the ITA match the associated acceptance criteria. The NRC staff has observed instances in which the ITA was inappropriate for determining that the acceptance criteria had been satisfied. In one example, the ITA required an inspection of a makeup water system. Although three separate acceptance criteria were associated with this one ITA inspection, only two of the criteria were actually inspections;
the third criterion specified a flow rate, which is a test result and not an inspection criterion. Below are three additional examples illustrating mismatches between ITA and acceptance criteria.
- Example 1
Design Commitment Inspection, Tests, Analyses Acceptance Criteria The XYZ system has an available volumesized to contain approximately
400 percent of the full- core debris.
Inspections of the as-built system will be conducted.
The as-built XYZ system is sized to contain 350-450
percent of the full-core debris.
The inspection is appropriate for determining the volume of the XYZ system.
However, an inspection alone is not capable of determining whether the measured volume can contain 350-450 percent of full-core debris, because this amount of material has either not been determined or is not defined for the inspection.
RIS 2008-05, Rev. 1 - Example 2
Design Commitment Inspection, Tests, Analyses Acceptance Criteria All low-pressure coolant injection piping and componentsare designed to withstand full reactor pressure.
Inspection of the as-built low-pressure coolant injection pipingwill be performed.
The as-built low-pressure coolant injection piping and componentsare designed to withstand full reactor pressure.
The inspection of piping and components can determine whether they were installed in accordance with design. In addition to the inspection, an analyses or test would be needed to determine whether the as-built piping and components meet the approved design. Additionally, the applicant needs to quantify the term full reactor pressure in the acceptance criteria.
- Example 3
Design Commitment Inspection, Tests, Analyses Acceptance Criteria Level instruments with adequate operating ranges are provided for the spent fuel pool.
Inspections of the ABC
System will be conducted to verify that level instruments with adequate operating ranges are provided for the spent fuel pool.
The as-built ABC System provides spent fuel pool level instrumentation with adequate operating ranges.
Pool instruments accurately indicate pool level over ranges.
Although an inspection is capable of checking the proper pool level range, an inspection alone cannot determine the accuracy of the specified instrumentation.
Some form of testing or analyses is likely required to validate the pool instrument accuracy noted in the acceptance criteria. Additionally, as discussed earlier under ITAAC Nomenclature and Language, the use of the subjective term, adequate operating ranges, should be replaced with more objective language, or a reference to technical details should be added that provides the needed information for adequate ITAAC verification.
ITAAC STANDARDIZATION AND CONSISTENCY
Applicants should ensure consistency in ITAAC designations within their applications.
For example, a count of the ITA designations identified 33 ITAAC, but a count of the acceptance criteria designations identified 38 ITAAC. Such an inconsistent ITAAC count could result in problems not only during verification and inspection activities, but also when the ITAAC are closed and the notification letters are submitted in accordance with
RIS 2008-05, Rev. 1 *
Applicants should ensure that ITAAC references exist and provide appropriate information. For example, a design commitment and acceptance criteria indicated that controls exist in the main control room, but did not specify nor provide enough information about what actual controls must exist. Either a list of controls or a reference to a list would have provided the necessary information. Applicants should ensure that the ITAAC verify the design commitment. If the existence and the functionality of the controls are to be validated, the ITAAC should clearly state that requirement. (However, functionality can only be verified by a test.)
Applicants should ensure that ITAAC agree with Tier 1 information. For example, the Tier 1 definition of an EQ required type tests, or type tests and analyses, but the associated ITA for EQ required type tests, analyses, or a combination of type tests and analyses. This would appear to inappropriately allow analyses alone to validate the EQ.
Applicants should ensure that ITAAC agree with Tier 2 information. For example, the acceptance criteria for one ITAAC specified that a certain valve will open within
0.89 seconds, but the Tier 2 design parameter for this valve identified a maximum of
0.7 seconds.
ITAAC SCOPE
Applicants should ensure that ITAAC are written in a clear and objective manner. In some cases, applicants have expanded the scope of individual ITAAC in a way that diminished the ITAACs objectivity and promoted a lack of clarity about what the ITAAC
required. Some examples follow that illustrate the generic problem of expanding the scope of an ITAACs objectivity beyond what was intended.
-
An applicant attempted to expand the ITAAC for functional arrangement of a system beyond the definition of functional arrangement as a physical arrangement of SSCs to include several testing, qualification, and analytical attributes. In this case, an ITAAC intended to be verified by an objective inspection of the as-built system was inappropriately transformed into a catch-all for a diverse set of technical attributes. In some cases, these separate attributes (e.g., separate tests, physical measurements, analytical results) justified their own unique ITAAC. This was a case where the objectivity of a simple ITAAC
was lost because its scope was inappropriately expanded.
-
Other ITAAC have used terminology that the applicant defined differently than the NRC, thus expanding the scope of the defined term. For example, the applicant defined the word exists using part of the definition presented in Standard Review Plan Section 14.3, Inspections, Tests, Analyses, and Acceptance Criteria, issued March 2007, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, which states, the term exists, when used in the Acceptance Criteria, means that the item is present and meets the design description. Unfortunately, the second part of the section is not quoted by the applicant, which states that, "detailed supporting information on what should be present is contained in
RIS 2008-05, Rev. 1 thestandard safety analysis report. This clarifying sentence implies that what should be present is something that can be seen to be inspected. Several criteria described in the design description (e.g., EQ, seismic qualification, design attributes, and, most importantly, functionality) cannot be seen. Therefore, the scope of any ITAAC using the term "exists" might be inappropriately expected to include attributes (like functionality in accordance with the design) that cannot be validated by only an inspection that something exists. This is another case in which an objective ITAAC may be improperly expanded to include the scope of attributes that cannot be verified by the inspection. Below is an example of an ITAAC that illustrates improper use of the term exist.
Design Commitment Inspection, Tests, Analyses Acceptance Criteria Controls exist in the Main Control Room.
Tests will be performed for the existence of control signals from the Main Control Room.
Controls exist in the Main Control Room.
The ITAAC should have enough detail to describe what is being verified.
Although the necessary information may be included in the DCD, it is neither provided in the ITAAC nor provided by reference to any other detailed information or tables that would adequately support licensee inspection or NRC
verification.
Applicants should ensure that revisions to ITAAC are thoroughly reviewed. Applicants should check revisions to ITAAC for applicability to all related system ITAAC and also for the impact of referenced SSC table revisions. ITAAC reviews should include verification checks, especially in situations involving ITAAC revisions or ITA activities that generically apply to similar systems or components. An assessment of ITAAC change controls, after the implementation of each DCD revision, could provide the needed confirmation that similar ITAAC are written using consistent language and establish the same revised requirements for all applicable ITAAC.
-
For example, the ITAAC for one system refer to tests of motor-operated valve (MOV) functions and squib valve functions. The ITAAC references a table identifying the related valves and their respective functions. However, an ITAAC
for a similar safety-related system that also employs MOVs and squib valves with active functions refers only to MOV tests and inappropriately neglects the squib valve tests.
-
In the previous example, the applicant later revised the referenced table to change the active function of the MOV to none. However, the ITAAC written to test the operation of the MOV was never deleted. This entire ITAAC was no longer applicable because there was no active function for the MOVs associated with this ITAAC.
RIS 2008-05, Rev. 1
BACKFIT DISCUSSION
This revised RIS provides addressees information to aid in the submittal of ITAAC as part of their applications for ESPs, standard DCs, or COLs and does not represent a new or different NRC staff position on the implementation of 10 CFR Part 52. It does not create or impose any new or different applicable NRC staff positions inconsistent with 10 CFR Part 52. It requires no action or written response beyond what is required in 10 CFR Part 52.
This RIS requires no action or written response and is, therefore, not a backfit under
10 CFR 50.109, Backfitting. The NRC staff does not intend or approve any imposition of requirements or backfitting through the guidance of this RIS. The staff does not expect any sponsor of an existing DC or any holder of an existing ESP to take any action with respect to such DC or ESP as a result of this RIS. Consequently, the NRC staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
This RIS is informational and does not represent a departure from current regulatory requirements. A notice of opportunity for public comment was not required and was not published in the Federal Register, however a public meeting was held on July 29, 2010, to discuss a draft of the RIS. In addition, this RIS was posted on the NRC Public Web site for comment for 30 days. The NRC staff received valuable comments during the public meeting and the posting for comment, and revised the RIS. These comments and the staff response can be found in ML102390002.
CONGRESSIONAL REVIEW ACT
This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. 801-808) and, therefore, is not subject to the Act.
PAPERWORK REDUCTION ACT STATEMENT
This RIS contains existing information collection requirements that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were approved by the Office of Management and Budget, approval number 3150-00151.
Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.
RIS 2008-05, Rev. 1
CONTACT
This RIS requires no specific action or written response. Please direct any questions about this matter to the technical contact listed below.
/RA/
/RA/ by JTappert for
Timothy McGinty, Director
Glenn Tracy, Director Division of Policy and Rulemaking
Division of Construction Inspection and Office of Nuclear Reactor Regulation
Operational Programs
Office of New Reactors
Technical Contact:
(301) 415-2043
calvin.cheung@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
RIS 2008-05, Rev. 1
CONTACT
This RIS requires no specific action or written response. Please direct any questions about this matter to the technical contact listed below.
/RA/
/RA/ by JTappert for
Timothy McGinty, Director
Glenn Tracy, Director Division of Policy and Rulemaking
Division of Construction Inspection and Office of Nuclear Reactor Regulation
Operational Programs
Office of New Reactors
Technical Contact:
(301) 415-2043
Calvin.Cheung@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
ADAMS Accession Number: ML102500244
TAC ME3682 OFFICE
CTSB:DCIP:NRO
Tech Ed.
TL:CTSB:DCIP:NRO
BC:CTSB:DCIP:NRO
OGC (CRA)
NAME
CCheung KAzasiah RLaura MKowal SCroston DATE
5/27/2010
6/18/2010
5/27/2010
5/28/2010
6/17/2010
OFFICE
D:PMDA:NRO
OIS
D:DIRS:NRR
D:DNRL:NRO
NAME
NHilton BGusack TDonnell FBrown DMatthews DATE
6/14/2040
5/28/2010
6/7/2010
6/15/2010
6/8/2010
OFFICE
DD:DCI:R-II
D:DORL:NRR
LA:PGCB:NRR
PM:PGCB:NRR
NAME
COgle JGiitter (RNelson for)
MZobler (RWeisman for)
CHawes CMH
TMensah DATE
6/15/2010
6/22/2010
7/19/2010
07/20/2010
09/22/10
OFFICE
BC:PGCB:NRR
D:DCIP:NRO
D:DPR:NRR
NAME
SRosenberg (TAlexion for)
GTracy (JTappert for)
TMcGinty
DATE
9/23/2010
9/1/2010
9/23/2010