View source for ML19056A439

{{Adams
| number = ML19056A439
| issue date = 11/13/2017
| title = NEI Comments on Draft SRP 14-3-3
| author name = Tschiltz M
| author affiliation = Nuclear Energy Institute (NEI)
| addressee name = Bladey C
| addressee affiliation = NRC/NMSS/DDUWP/RDB
| docket = PROJ0689
| license number = 
| contact person = Notich M
| case reference number = NRC-2017-0187
| package number = ML19056A437
| document type = Letter, Safety Evaluation, Standard Review Plan
| page count = 7
}}

=Text=
{{#Wiki_filter:MICHAEL D. TSCHILTZ Senior Director, New Plant, SMRs and Advanced Reactors 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8083 mdt@nei.org nei.org November 13, 2017 Ms. Cindy K. Bladey Chief, Rules, Announcements, and Directives Branch (RADB)
Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Sent directly to www.federalregister.gov

==Subject:==
NEI Comments on Draft SRP 14.3.3, Piping Systems and Components ITAAC, 82 Fed. Reg. 42709; Docket ID NRC-2017-0187 Project Number: 689

==Dear Ms. Bladey:==

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 appreciates the opportunity to provide comments on the subject draft SRP 14.3.3 as requested in the referenced Federal Register notice.
We appreciate that the NRC has incorporated language developed as part of joint industry-NRC efforts to establish standardized ITAAC for use in future design certifications. Use of standardized ITAAC can be expected to enhance consistency, streamline the development and NRC review of design certification ITAAC, and facilitate efficient ITAAC implementation and closure. We encourage and expect that SRP 14.3 and the subsections SRP 14.3.1-12 will be updated to reflect the outcomes of the ongoing efforts to develop standardized ITAAC.
However, it should be noted that efforts to establish an appropriate set of standardized ITAAC are not yet complete, and draft SRP 14.3.3 adopts certain piping ITAAC language to which the industry strenuously objects. Of greatest concern is the proposed ITAAC on installed configuration of piping systems (see NEI Comment #11). This NRC staff-proposed ITAAC is ambiguous, unbounded and unverifiable. It is also 1
The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees and other organizations and entities involved in the nuclear energy industry.

Ms. Cindy K. Bladey November 13, 2017 Page 2 entirely unnecessary as it is redundant to other ITAAC and to the role of the Quality Assurance Program.
Complete industry comments on draft SRP 14.3.3 are provided in the attachment.
We strongly recommend elimination of the proposed installed configuration ITAAC and correction of the other significant departures from basic tenets of ITAAC identified in the attachment. At a minimum, the NRC should put the update of SRP 14.3.3 (as well as the rest of SRP 14.3) on hold pending resolution of key issues in the context of standardized ITAAC and ongoing design certification reviews.
If you have any questions concerning these industry comments, please contact me or Russ Bell (202.739.8087; rjb@nei.org).
Sincerely, Michael D. Tschiltz Attachment c:       Mr. Robert Caldwell, NRO/DEIA, NRC Mr. Joseph Colaccino, NRO/ DNRL/LB3, NRC Dr. Barbara Hayes, NRO/DNRL/LB3, NRC Mr. Mark D. Notich, NRO/ DNRL/LB3, NRC

NEI Comments on Draft SRP 14.3.3 - Piping Systems and Components ITAAC - 11/13/17 Affected Section                              Comment/Basis                                           Recommendation
: 1. II.1 - Generic Piping  This section describes the five ITAAC that relate to piping   Where the first through fifth piping ITAAC in Tier 1 Design, p. 6           design. Consistent with the subsections under Verification    are described, the SRP should state that the of Components and Systems, the SRP should identify the        Design Commitment should specify ; the ITA NRC-proposed standard ITAAC.                                  should specify ; and the Acceptance Criteria should specify . The language from the NRC-proposed standard ITAAC should be specified as is done elsewhere in this SRP for other piping-related ITAAC.
: 2. II.2.C - Hydrostatic   Consistent with other sections of this SRP, this section      Add to this section that the Design Commitment Test, p. 10            should identify the NRC-proposed standard ITAAC               should specify ; the ITA should specify ; and language for hydro testing.                                   the Acceptance Criteria should specify .
: 3. II.2.C - Hydrostatic   Editorial - the word also in the second sentence lacks      Delete also so the second sentence reads, The Test, p. 10            context.                                                      pressure boundary integrity is also ensured, in part, through .
: 4. II.2.D - Equipment     It is a general principle of ITAAC and historical practice    Acceptance Criterion (i) for seismic EQ should be Seismic and Dynamic    that Acceptance Criteria should not refer to industry codes   revised as follows to eliminate reference to industry Qualification, p. 10   and standards or NRC regulatory guidance. Instead,            codes and standards or NRC regulatory guidance:
references to codes, standards and regulatory guidance are provided in Tier 2 of the DCD along with related          i) A [seismic qualification report] exists and design information. Acceptance Criterion (i) for seismic EQ   concludes that the [XXX system] Seismic Category I violates this principle/practice as well as specific guidance equipment listed in [Table x.x.x-x], including its provided in Section II.1 of this SRP under Regulations,      associated supports and anchorages, performs its Codes and Standards. That guidance states that               function under the seismic load conditions specified references to Codes and Standards should be minimized         in the [seismic qualification report].
and identifies references to the ASME BPV Code as an exception.
1

Affected Section                          Comment/Basis                                            Recommendation
: 5. II.2.D - Equipment   The format of this section makes it hard to discern that    It would be more user-friendly to present the Seismic and Dynamic  there are two Acceptance Criteria for seismic EQ.           ITAAC language in the usual 3-column format. This Qualification, p. 10                                                             approach would be helpful in other sections as well.
: 6. II.2.D - Equipment   Starting from, In some instances,  the paragraph         Delete the latter part of the paragraph starting Seismic and Dynamic  becomes confusing and adds little value beyond the          from, In some instances, Retain only the Qualification, p. 11 discussion already presented. For example, there is a       following sentence as modified:
reference to basic configuration ITAAC in SRP 14.3, App. Detailed supporting information for dynamic D, that does not exist. In addition, the discussion of Tier qualification requirements, including seismic 2* information does not reflect updated NRC practice in     qualification records and references to applicable the wake of SECY-17-0075. Furthermore, as discussed in      Codes, Standards and regulatory guidance, is in Comment 4, above, it is inappropriate to suggest that       DCD Tier 2, Chapter 3.
references to ASME QME-1 and RG 1.100 should be included in ITAAC.
: 7. II.2.F.1.a - Pump    Refer to Comment 4, above, concerning avoiding              Modify the fourth sentence of this paragraph to and Valves, p. 12    reference in ITAAC to industry codes and standards or       read:
NRC regulatory guidance. The requirement that Functional    Acceptance Criteria should specify that the Qualification Reports be prepared in accordance with        [Functional Qualification Report] exists and ASME QME-1/RG 1.100 is appropriate to include in Tier 2     concludes that the [XXX system] safety-related of the DCD.                                                 valves listed in [Table x.x.x-x] are capable of performing their safety-related function under the full range of fluid flow, differential pressure, electrical conditions and temperature conditions
[with debris-laden coolant fluids] up to and including design basis accident conditions.
: 8. II.2.F.1.a - Pumps   The discussion of Tier 2* information does not reflect      Delete the last two sentences under paragraph (a).
and Valves, p. 13    updated NRC practice in the wake of SECY-17-0075.
Moreover, it is inappropriate to suggest that references to ASME QME-1 and RG 1.100 should be included in ITAAC.
Refer also to Comment 6, above.
: 9. II.2.F.2 - Pump and  Editorial                                                   Add pumps and so the second sentence reads:
2

Affected Section                               Comment/Basis                                            Recommendation Valve Preop Testing,                                                                  for verification of the performance of these
: p. 14                                                                                 pumps and valves.
: 10. II.2.F.2.b.i, iii, iv - There is no basis in NRC regulations or NRC guidance to       Delete the end the Acceptance Criteria in Valve Preop Testing,    require preoperational diagnostic test data to correlate      paragraphs (i), (iii), and (iv) from with sufficient
: p. 15-16                valve test results to valve design basis capability. This has diagnostic data so the last words of each are not been a requirement in either Tier 1 or Tier 2 of any      and flow conditions.
previous DCD. As indicated by the vague requirement for sufficient diagnostic data, there is no approved            Also revise the paragraph at the bottom of p. 16 to methodology for correlating preop results to design basis     eliminate discussion of analyses for correlating capability. Moreover, an Acceptance Criterion that requires   preop test results to design basis capability.
sufficient data violates the key tenet that ITAAC be clear and objective with respect to demonstrating Acceptance Criteria are met.
: 11. II.2.G - Installed      The Installed Configuration ITAAC envisioned by this SRP      Delete paragraph G on Installed Configuration Configuration, p. 17    is ambiguous, unbounded, unverifiable, and completely         entirely.
unnecessary. It is redundant to other ITAAC that provide reasonable assurance that SSCs are properly installed and will operate as designed. It is also redundant to the Quality Assurance Program which is approved and overseen by the NRC and assures that quality-related activities associated with plant design, procurement, fabrication, construction, testing (including use of appropriate and calibrated tools) and operation are implemented properly and in accordance with licensee procedures, applicable codes and standards and NRC regulations. QAP implementation as well as turnover and commissioning testing confirm the proper configuration and performance of systems.
ITAAC and the QAP have distinct, yet complementary roles. While the QAP assures the proper implementation of quality-related activities, ITAAC focus on verifying that as-3

Affected Section                        Comment/Basis                                        Recommendation built SSCs satisfy the top level design and performance standards specified in the COL. The envisioned Installed Configuration ITAAC would not maintain the vital distinction between the roles of ITAAC and the QAP and significantly expand the scope of Tier 1 and ITAAC to include matters that have historically, effectively and appropriately been addressed in Tier 2.
Inclusion of this ITAAC would negate the extensive efforts expended to ensure the clarity and focus of every other ITAAC, as well as the important distinction between verifying the top-level design and performance characteristics of Tier 1 versus the balance of design information in Tier 2. The unbounded nature of this ITAAC renders it essentially unverifiable under the ITAAC closure process. This is precisely the reason for the distinction between ITAAC and the QAP and the why the ITAAC process relies upon - and does not repeat - QAP activities that assure the proper implementation of quality-related activities.
For these reasons, no functional arrangement, installed configuration, or similar ITAAC is included in the standardized ITAAC developed for use by KHNP, NuScale or future design certification applicants, and none should be called for anywhere in SRP 14.3.
: 12. II.2.H - RTNSS,   Existing guidance and practice makes clear that Tier 1 and  Delete paragraph H on RTNSS entirely.
: p. 17             ITAAC must cover the entirety of the SSCs within the scope of the certified design (an essentially complete design), and that the level of detail provided in Tier 1 is based on a graded approach, including both safety-related and safety-significant SSCs.
Thus RTNSS SSCs are already considered and evaluated 4

Affected Section                           Comment/Basis                                      Recommendation for inclusion in Tier 1/ITAAC as appropriate, and it is unnecessary and potentially confusing to add SRP guidance calling for ITAAC on equipment within the scope of the RTNSS program.
: 13. II.2.I - DRAP, p.17 During discussions on development of standardized          Delete paragraph I on DRAP entirely.
ITAAC, NRC concluded that DRAP ITAAC was not necessary in future design certifications and would not be included as a standard ITAAC. Agreement that DRAP should be addressed as a Tier 2 matter only was based in part on experience indicating that implementing DRAP ITAAC for AP1000 has provided little or no value. This SRP should be revised to reflect this conclusion.
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