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{{#Wiki_filter:A notice that Draft Regulatory Guide DG-1250 was available for public comment was published in the Federal Register on May 13, 2011, 76 FR 27924-27925. The comment period ended July 25, 2011. A single comment submission was received from the organization listed below. The comments and the NRC staffs response are set forth in the following table.
{{#Wiki_filter:ML11284A006 A notice that Draft Regulatory Guide DG-1250 was available for public comment was published in the Federal Register on May 13, 2011, 76 FR 27924-27925. The comment period ended July 25, 2011. A single comment submission was received from the organization listed below. The comments and the NRC staffs response are set forth in the following table.
Comments were received from:
Comments were received from:
Russell J. Bell, Director New Plant Licensing, Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street NW, Suite 400 Washington DC 20006-3708 Telephone: 1-202-739-8087 (ADAMS ML11209C487)
Russell J. Bell, Director New Plant Licensing, Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street NW, Suite 400 Washington DC 20006-3708 Telephone: 1-202-739-8087 (ADAMS ML11209C487)
Section of Comment or Basis                             Recommendation                                           NRC Resolution DG1250
Section of DG1250 Comment or Basis Recommendation NRC Resolution
: 1.           Clarification                   Modify this sentence as follows:                       Staff agrees that a clarification along the lines suggested This supplemental ITAAC closure notification would   would be beneficial, but the staff will use language that Page 2,                                        describe the resolution of the circumstances           more closely follows the language used in the rule.
: 1.
paragraph 4                                    surrounding the identification of new material beginning                                      information, and would need to contain sufficient     Sentence will be revised as follows:
Page 2, paragraph 4 beginning The regulation at proposed Clarification Modify this sentence as follows:
The                                          information to demonstrate that, notwithstanding the regulation at                                  new material information, the prescribed inspections, This supplemental ITAAC closure notification would proposed                                    tests, or analyses have been performed as required and describe the resolution of the circumstances surrounding the prescribed acceptance criteria are met.            the identification of new material information, and would need to contain sufficient information to demonstrate that, notwithstanding the new information, the prescribed inspections, tests, or analyses have been performed as required and the prescribed acceptance criteria are met.
This supplemental ITAAC closure notification would describe the resolution of the circumstances surrounding the identification of new material information, and would need to contain sufficient information to demonstrate that, notwithstanding the new material information, the prescribed inspections, tests, or analyses have been performed as required and the prescribed acceptance criteria are met.
: 2.           When referring directly to the   Modify first sentence as follows:                     Staff disagrees in that this language is a paraphrase to Commission finding required      Operation (which includes loading fuel) cannot        make the point that all acceptance criteria need to be met Page 2,      by Section 52.103(g), the actual commence until the Commission finds under 10 CFR      at that time. To be more clear the following change will paragraph 5  rule language should be used. 52.103(g) that the all acceptance criteria in the      be made to the sentence:
Staff agrees that a clarification along the lines suggested would be beneficial, but the staff will use language that more closely follows the language used in the rule.
beginning                                      combined license ITAAC are met.
Sentence will be revised as follows:
ML11284A006
This supplemental ITAAC closure notification would describe the resolution of the circumstances surrounding the identification of new material information, and would need to contain sufficient information to demonstrate that, notwithstanding the new information, the prescribed inspections, tests, or analyses have been performed as required and the prescribed acceptance criteria are met.
: 2.
Page 2, paragraph 5 beginning When referring directly to the Commission finding required by Section 52.103(g), the actual rule language should be used.
Modify first sentence as follows:
Operation (which includes loading fuel) cannot commence until the Commission finds under 10 CFR 52.103(g) that the all acceptance criteria in the combined license ITAAC are met.
Staff disagrees in that this language is a paraphrase to make the point that all acceptance criteria need to be met at that time. To be more clear the following change will be made to the sentence:  


Section of Comment or Basis                             Recommendation                                           NRC Resolution DG1250 Operation                                                                                             Operation (which includes loading fuel) cannot
2 Section of DG1250 Comment or Basis Recommendation NRC Resolution Operation Operation (which includes loading fuel) cannot commence until the Commission finds under 10 CFR 52.103(g) that all acceptance criteria in the COL are met.
.                                                                                                    commence until the Commission finds under 10 CFR 52.103(g) that all acceptance criteria in the COL are met.
: 3.
: 3.           Clarification                   Modify second sentence to refer to the specific         Staff agrees. It would be appropriate to cite Section regulation: Section 52.99(a)                            52.99(a) when discussing the ITAAC completion Page 5,                                                                                                schedule submittals required by this section. Sentence Paragraph 1                                                                                            will be revised to specify Section 52.99(a).
Page 5, Paragraph 1 beginning, Section 4 Clarification Modify second sentence to refer to the specific regulation: Section 52.99(a)
beginning, Section 4
Staff agrees. It would be appropriate to cite Section 52.99(a) when discussing the ITAAC completion schedule submittals required by this section. Sentence will be revised to specify Section 52.99(a).
: 4.           The ITAAC completion             Modify this paragraph to read as follows:                Staff agrees. The requested Level 3 schedules could be schedules referred to in Section In addition to the required schedule submittals If not  the same as those schedules submitted to satisfy the Page 5,      4 of NEI 08-01 are expected to   already included in the schedule information provided    requirements of Section 52.99(a). Section will be Paragraph 2  be one and the same as the       in accordance with Section 52.99(a), licensees should   revised as follows:
: 4.
beginning,  schedules required by Section    provide a Level 3 schedule of ITAAC-related In addition 52.99(a). Clarify guidance so it activities on site and off site (in vendor shops). These If not already included in the schedule information to        does not suggest the need for    detailed schedules will allow the staff to plan its     provided in accordance with Section 52.99(a), licensees two different submittals of      oversight activities.                                  should provide a Level 3 schedule of ITAAC-related construction schedule                                                                    activities on site and off site (in vendor shops). These information.                                                                              detailed schedules will further allow the staff to plan its oversight activities.
Page 5, Paragraph 2 beginning, In addition to The ITAAC completion schedules referred to in Section 4 of NEI 08-01 are expected to be one and the same as the schedules required by Section 52.99(a). Clarify guidance so it does not suggest the need for two different submittals of construction schedule information.
: 5.           The recommendation for           Replace this paragraph with the following:               Staff agrees with the commenters reasoning, but will applicants to submit and                                                                  modify the proposed paragraph to reflect that the Page 5,      maintain a complete              COLs will include an appendix that contains a            description of how ITAAC will be included in the Paragraph 3  consolidated listing of ITAAC    complete integrated list of ITAAC for each licensed      license is a current staff expectation. Referenced beginning,  is beyond the scope of this Reg. unit, drawn from the DCD, ESP, LWA and COL, as          paragraph will be replaced with the following:
Modify this paragraph to read as follows:
Applicants  Guide, and does not have a      applicable. The NRC expects that licensees will          The NRC expects to issue COLs which include an should    regulatory basis.                submit ITAAC closure notifications using the            appendix that contains a complete, integrated list of nomenclature and numbering scheme of the ITAAC          ITAAC for each licensed unit, drawn from the design Applicants provide a complete    identified in the COL. This will minimize errors and    control document, early site permit (ESP), limited work 2
In addition to the required schedule submittals If not already included in the schedule information provided in accordance with Section 52.99(a), licensees should provide a Level 3 schedule of ITAAC-related activities on site and off site (in vendor shops). These detailed schedules will allow the staff to plan its oversight activities.
Staff agrees. The requested Level 3 schedules could be the same as those schedules submitted to satisfy the requirements of Section 52.99(a). Section will be revised as follows:
If not already included in the schedule information provided in accordance with Section 52.99(a), licensees should provide a Level 3 schedule of ITAAC-related activities on site and off site (in vendor shops). These detailed schedules will further allow the staff to plan its oversight activities.
: 5.
Page 5, Paragraph 3 beginning, Applicants should The recommendation for applicants to submit and maintain a complete consolidated listing of ITAAC is beyond the scope of this Reg.
Guide, and does not have a regulatory basis.
Applicants provide a complete Replace this paragraph with the following:
COLs will include an appendix that contains a complete integrated list of ITAAC for each licensed unit, drawn from the DCD, ESP, LWA and COL, as applicable. The NRC expects that licensees will submit ITAAC closure notifications using the nomenclature and numbering scheme of the ITAAC identified in the COL. This will minimize errors and Staff agrees with the commenters reasoning, but will modify the proposed paragraph to reflect that the description of how ITAAC will be included in the license is a current staff expectation. Referenced paragraph will be replaced with the following:
The NRC expects to issue COLs which include an appendix that contains a complete, integrated list of ITAAC for each licensed unit, drawn from the design control document, early site permit (ESP), limited work  


Section of Comment or Basis                           Recommendation                                           NRC Resolution DG1250 list of ITAAC when             ensure consistent referencing of specific ITAAC by       authorization (LWA), and COL application, as incorporating a DCD by        the licensee, NRC and the public.                       applicable. The NRC expects that licensees will submit reference, and adding plant-  Applicants should submit and maintain a complete,       ITAAC closure notifications using the nomenclature and specific ITAAC in COLA Part    consolidated listing of the ITAAC in their COL           numbering scheme of the ITAAC identified in the COL.
3 Section of DG1250 Comment or Basis Recommendation NRC Resolution list of ITAAC when incorporating a DCD by reference, and adding plant-specific ITAAC in COLA Part
: 10. A complete integrated list applications. Providing a complete table that lists all This will minimize errors and ensure consistent of ITAAC will be established  ITAAC will ensure that the ITAAC issued with the         referencing of specific ITAAC by the licensee, the NRC, as Appendix A of the COL and  COL are accurate and will standardize a reference that   and the public.
: 10. A complete integrated list of ITAAC will be established as Appendix A of the COL and maintained as part of the license (including approved/incorporated amendments).
maintained as part of the      the staff and licensees can then use. The submission of license (including            a complete ITAAC list prior to COL issuance will approved/incorporated          reduce errors when referencing or identifying ITAAC amendments).                  and will provide the basis for the ITAAC list included as an appendix to the COL.
ensure consistent referencing of specific ITAAC by the licensee, NRC and the public.
: 6.           Clarification                 Modify second and third sentences to read as follows:   Staff agrees. These clarifications correctly identify the This section also provides guidance for the licensee   intended notifications and ITAAC completion packages.
Applicants should submit and maintain a complete, consolidated listing of the ITAAC in their COL applications. Providing a complete table that lists all ITAAC will ensure that the ITAAC issued with the COL are accurate and will standardize a reference that the staff and licensees can then use. The submission of a complete ITAAC list prior to COL issuance will reduce errors when referencing or identifying ITAAC and will provide the basis for the ITAAC list included as an appendix to the COL.
Page 5,                                    oversight of ITAAC closure activities and the           Sentence will be revised as follows:
authorization (LWA), and COL application, as applicable. The NRC expects that licensees will submit ITAAC closure notifications using the nomenclature and numbering scheme of the ITAAC identified in the COL.
Paragraph 4                                maintenance of records referenced by the ITAAC beginning,                                  closure notifications packages. In addition, Section 5   This section also provides guidance for the licensee Section 5                                  of NEI 08-01 provides an outline of ITAAC               oversight of ITAAC closure activities and the completion packages.                                    maintenance of records referenced by the ITAAC closure notifications. In addition, Section 5 of NEI 08-01 provides an outline of ITAAC completion packages.
This will minimize errors and ensure consistent referencing of specific ITAAC by the licensee, the NRC, and the public.
: 7.           As discussed in NEI 08-01,     Add language similar to this from NEI 08-01, Section     Staff agrees. By adding the reference to SECY              please add language from      4.1: As described in SECY 06-0114, Description of     0114, the reader will understand that the discussion on Page 5,      SECY-06-0114 concerning        the Construction Inspection Program for Plants           the single proprietary determinations has previously Paragraph 1  one-time submittal of a        Licensed under Part 52, licensees may submit a         been presented to the Commission. Paragraph will be beginning,  proprietary affidavit covering single affidavit to request that schedule information be added as follows:
: 6.
Section 4  the submittal of detailed      held as proprietary under 10 CFR 2.390. SECY 06-ITAAC completion schedules    0114 states, [B]ecause the nature of the information   As described in SECY 06-0114, Description of the and updates.                  would not change from initial submittal to update, no    Construction Inspection Program for Plants Licensed 3
Page 5, Paragraph 4 beginning, Section 5 Clarification Modify second and third sentences to read as follows:
This section also provides guidance for the licensee oversight of ITAAC closure activities and the maintenance of records referenced by the ITAAC closure notifications packages. In addition, Section 5 of NEI 08-01 provides an outline of ITAAC completion packages.
Staff agrees. These clarifications correctly identify the intended notifications and ITAAC completion packages.
Sentence will be revised as follows:
This section also provides guidance for the licensee oversight of ITAAC closure activities and the maintenance of records referenced by the ITAAC closure notifications. In addition, Section 5 of NEI 08-01 provides an outline of ITAAC completion packages.
: 7.
Page 5, Paragraph 1 beginning, Section 4 As discussed in NEI 08-01, please add language from SECY-06-0114 concerning one-time submittal of a proprietary affidavit covering the submittal of detailed ITAAC completion schedules and updates.
Add language similar to this from NEI 08-01, Section 4.1: As described in SECY 06-0114, Description of the Construction Inspection Program for Plants Licensed under Part 52, licensees may submit a single affidavit to request that schedule information be held as proprietary under 10 CFR 2.390. SECY 06-0114 states, [B]ecause the nature of the information would not change from initial submittal to update, no Staff agrees. By adding the reference to SECY 0114, the reader will understand that the discussion on the single proprietary determinations has previously been presented to the Commission. Paragraph will be added as follows:
As described in SECY 06-0114, Description of the Construction Inspection Program for Plants Licensed  


Section of Comment or Basis                             Recommendation                                             NRC Resolution DG1250 additional proprietary determinations would be needed   under Part 52, licensees may submit a single affidavit and routine schedule updates from the licensee would     to request that schedule information be held as be considered proprietary and would be withheld from     proprietary under 10 CFR 2.390. SECY 06-0114 states the public without further evaluation. This approach     as follows:
4 Section of DG1250 Comment or Basis Recommendation NRC Resolution additional proprietary determinations would be needed and routine schedule updates from the licensee would be considered proprietary and would be withheld from the public without further evaluation. This approach would allow for a single proprietary determination, limited to the schedule and its updates, that would apply to an entire construction project.
would allow for a single proprietary determination, limited to the schedule and its updates, that would     Because the nature of the information would not change apply to an entire construction project.                from initial submittal to update, no additional proprietary determinations would be needed and routine schedule updates from the licensee would be considered proprietary and would be withheld from the public without further evaluation. This approach would allow for a single proprietary determination, limited to the schedule and its updates, that would apply to an entire construction project.
under Part 52, licensees may submit a single affidavit to request that schedule information be held as proprietary under 10 CFR 2.390. SECY 06-0114 states as follows:
: 8.           Clarification is needed to assure Modify first sentence as follows:                       Staff agrees. By adding the recommended phrase, the the reader understands that the  The NEI guidance appropriately reflects that the NRC     sentence correctly explains that the NEI guidance Page 5,      NRC staff has determined that    expects the notification of ITAAC completion to         provides acceptable guidance on sufficient Paragraph 6  NEI 08-01 provides acceptable    contain more information than just a simple statement   information for notifications on ITAAC completion.
Because the nature of the information would not change from initial submittal to update, no additional proprietary determinations would be needed and routine schedule updates from the licensee would be considered proprietary and would be withheld from the public without further evaluation. This approach would allow for a single proprietary determination, limited to the schedule and its updates, that would apply to an entire construction project.
beginning,  guidance on sufficient                                                                The sentence will be revised as follows:
: 8.
The NRC    information.
Page 5, Paragraph 6 beginning, The NRC expects Clarification is needed to assure the reader understands that the NRC staff has determined that NEI 08-01 provides acceptable guidance on sufficient information.
expects                                                                                              The NEI guidance appropriately reflects that the NRC expects the notification of ITAAC completion to contain more information than just a simple statement
Modify first sentence as follows:
: 9.           Consistent, well understood       Modify the first 2 sentences as follows:                 Staff disagrees with the edits proposed for the first 2 language should be used to        Each 10 CFR 52.99(c)(1) submittal should include         sentences. Staff believes that the language on Page 5,      describe the required content of  sufficient information on the attributes that validate   sufficient information should be retained, and does not Paragraph 7  ITAAC Closure Notifications.      that the licensee has satisfied the acceptance criteria. see a problem with the attributes that validate beginning,  The regulatory guidance should    Licensee ITAAC Closure Notifications under 10 CFR       language. Staff agrees to revise the third sentence as Each 10    avoid use of language that is    52.99(c)(1) should include copy the ITAAC copied         proposed CFR          unlike that used anywhere else    directly from the certified design and COL to the 52.99(c)(1)  in the DG or NEI 08-01:          ITAAC statement.                                         Paragraph will be revised as follows:
The NEI guidance appropriately reflects that the NRC expects the notification of ITAAC completion to contain more information than just a simple statement Staff agrees. By adding the recommended phrase, the sentence correctly explains that the NEI guidance provides acceptable guidance on sufficient information for notifications on ITAAC completion.
4
The sentence will be revised as follows:
The NEI guidance appropriately reflects that the NRC expects the notification of ITAAC completion to contain more information than just a simple statement
: 9.
Page 5, Paragraph 7 beginning, Each 10 CFR 52.99(c)(1)
Consistent, well understood language should be used to describe the required content of ITAAC Closure Notifications.
The regulatory guidance should avoid use of language that is unlike that used anywhere else in the DG or NEI 08-01:
Modify the first 2 sentences as follows:
Each 10 CFR 52.99(c)(1) submittal should include sufficient information on the attributes that validate that the licensee has satisfied the acceptance criteria.
Licensee ITAAC Closure Notifications under 10 CFR 52.99(c)(1) should include copy the ITAAC copied directly from the certified design and COL to the ITAAC statement.
Staff disagrees with the edits proposed for the first 2 sentences. Staff believes that the language on sufficient information should be retained, and does not see a problem with the attributes that validate language. Staff agrees to revise the third sentence as proposed Paragraph will be revised as follows:  


Section of Comment or Basis                             Recommendation                                         NRC Resolution DG1250 submittal
5 Section of DG1250 Comment or Basis Recommendation NRC Resolution submittal
: 1. Sufficient             Modify the third sentence as follows:               Each 10 CFR 52.99(c)(1) submittal should include information on the      The ITAAC determination basis (IDB) should          sufficient information on the attributes that validate that attributes that          include a clearly written, detailed process on      the licensee has satisfied the acceptance criteria. The validate                description of how the licensee completed the        licensee should copy the ITAAC directly from the COL
: 1. Sufficient information on the attributes that validate
[ITAAC]                                            to the ITAAC statement. The ITAAC determination
: 2. clearly written, detailed process Modify the third sentence as follows:
: 2. clearly written,                                                          basis (IDB) should include a clearly written description detailed process                                                            of how the licensee completed the inspections, tests, or analyses and should explain how it met the acceptance criteria. The licensee.
The ITAAC determination basis (IDB) should include a clearly written, detailed process on description of how the licensee completed the
: 10.         Clarification.                   Revise second sentence as follows:                   Staff agrees. References to proposed requirements The 225-day notification mandated by proposed 10   should be removed from the final regulatory guide.
[ITAAC]
Page 6,      Also, do not refer to proposed  CFR 52.99(c)(3), must include sufficient information Sentence will be revised as follows:
Each 10 CFR 52.99(c)(1) submittal should include sufficient information on the attributes that validate that the licensee has satisfied the acceptance criteria. The licensee should copy the ITAAC directly from the COL to the ITAAC statement. The ITAAC determination basis (IDB) should include a clearly written description of how the licensee completed the inspections, tests, or analyses and should explain how it met the acceptance criteria. The licensee.
Paragraph 3  requirements in the final        so that interested persons will have access to beginning,  regulatory guide.                information on uncompleted ITAAC                   The 225-day notification mandated by10 CFR Section                                                                                          52.99(c)(3), must include sufficient information so that 7                                                                                                interested persons will have information on uncompleted ITAAC
: 10.
: 11.         Clarification                   Revise last sentence as follows:                     Staff agrees. The clarification improves the readability The uncomplete notification will be a predictive   of the sentence. Sentence will be revised as follows:
Page 6, Paragraph 3 beginning, Section 7
Page 6,                                      summary for how the licensee plans to complete the Paragraph 3                                  ITAAC that are if that ITAAC is not completed by     The uncomplete notification will be a predictive beginning,                                    225 days before the scheduled loading of fuel.     summary for how the licensee plans to complete the Section                                                                                          ITAAC that are not completed by 225 days before the 7                                                                                                scheduled loading of fuel.
Clarification.
: 12.         Regulatory guidance             The preceding paragraph that begins, The licensee  Staff disagrees to deleting the paragraph, but agrees with concerning the 225-day           must demonstrate  provides apt and sufficient      the proposed edits. This position on the content of the Page 6,      uncompleted ITAAC letter         regulatory guidance for implementing Section        uncomplete ITAAC notification is consistent with Paragraph 5  should focus on the information 52.99(c)(3). Thus we recommend deleting this        discussions in the public ITAAC workshop series and beginning,  required by Section 52.99(c)(3). paragraph (which continues onto page 7) in its       agrees with the content of NEI 08-01 Revision 4 Section Each        That regulation does not require entirety.                                            7 and Appendix E.
Also, do not refer to proposed requirements in the final regulatory guide.
proposed 10  the uncomplete letter to 5
Revise second sentence as follows:
The 225-day notification mandated by proposed 10 CFR 52.99(c)(3), must include sufficient information so that interested persons will have access to information on uncompleted ITAAC Staff agrees. References to proposed requirements should be removed from the final regulatory guide.
Sentence will be revised as follows:
The 225-day notification mandated by10 CFR 52.99(c)(3), must include sufficient information so that interested persons will have information on uncompleted ITAAC
: 11.
Page 6, Paragraph 3 beginning, Section 7
Clarification Revise last sentence as follows:
The uncomplete notification will be a predictive summary for how the licensee plans to complete the ITAAC that are if that ITAAC is not completed by 225 days before the scheduled loading of fuel.
Staff agrees. The clarification improves the readability of the sentence. Sentence will be revised as follows:
The uncomplete notification will be a predictive summary for how the licensee plans to complete the ITAAC that are not completed by 225 days before the scheduled loading of fuel.
: 12.
Page 6, Paragraph 5 beginning, Each proposed 10 Regulatory guidance concerning the 225-day uncompleted ITAAC letter should focus on the information required by Section 52.99(c)(3).
That regulation does not require the uncomplete letter to The preceding paragraph that begins, The licensee must demonstrate provides apt and sufficient regulatory guidance for implementing Section 52.99(c)(3). Thus we recommend deleting this paragraph (which continues onto page 7) in its entirety.
Staff disagrees to deleting the paragraph, but agrees with the proposed edits. This position on the content of the uncomplete ITAAC notification is consistent with discussions in the public ITAAC workshop series and agrees with the content of NEI 08-01 Revision 4 Section 7 and Appendix E.  


Section of Comment or Basis                             Recommendation                                           NRC Resolution DG1250 CFR         describe both completed and        If the NRC elects to retain this paragraph,          Paragraph will be revised as follows:
6 Section of DG1250 Comment or Basis Recommendation NRC Resolution CFR 52.99(c)(3) submittal describe both completed and uncompleted elements of an ITAAC, nor does it require a schedule for completing ITAAC. Since developing guidance to this effect in 2008, the industry has determined that parsing completed versus uncompleted ITAAC elements, and providing a schedule for completing ITAAC (beyond that required by Section 52.99(a)), would be problematic and would not add value in terms of information to the public, in part due to the rapidly changing status of ITAAC closures during the last several months before fuel load.
52.99(c)(3) uncompleted elements of an submittal  ITAAC, nor does it require a       proposed should be deleted from first sentence (see Each 10 CFR 52.99(c)(3) notification should include schedule for completing            comment 15)                                          sufficient information for both the completed and ITAAC. Since developing                                                                  uncompleted elements of the ITAAC. The licensee guidance to this effect in 2008,  Refer to clearly written description instead of      should copy the ITAAC directly from the COL to the the industry has determined that  detailed process (see comment 9)                    ITAAC statement. Items that the licensee has parsing completed versus                                                                completed toward ITAAC closure should be uncompleted ITAAC elements,                                                              accompanied by a clearly written description that and providing a schedule for                                                            describes how it completed those portions of the completing ITAAC (beyond                                                                inspections, tests, or analyses. Items that remain that required by Section                                                                uncomplete for ITAAC closure should be accompanied 52.99(a)), would be                                                                      by a clearly written description that describes how the problematic and would not add                                                            licensee expects to complete those portions of the value in terms of information to                                                        inspections, tests, or analyses and that subsequently the public, in part due to the                                                          concludes that the acceptance criteria will be met. The rapidly changing status of                                                              licensee should include enough detail on each ITAAC closures during the last                                                          inspection, test, or analysis for both completed and several months before fuel load.                                                        uncompleted portions to clearly indicate how it We plan to propose a revision                                                            completed, or will complete, those portions. The to NEI 08-01 guidance on the                                                            submittal should also include a schedule for completing 225-day uncompleted ITAAC                                                                the ITAAC and a list of references applicable to the letter later this year for                                                              ITAAC and available for NRC review. Appendix E to discussion with the NRC staff.                                                          NEI 08-01 presents examples of uncomplete Pending consideration of                                                                notifications.
We plan to propose a revision to NEI 08-01 guidance on the 225-day uncompleted ITAAC letter later this year for discussion with the NRC staff.
revised guidance, NRC regulatory guidance need not and should not go beyond the existing regulations in this area.
Pending consideration of revised guidance, NRC regulatory guidance need not and should not go beyond the existing regulations in this area.
: 13.         It is not necessary to give       Delete this sentence:                                 Staff agrees. The references to program and system special emphasis to ITAAC          Licensees are responsible for ensuring that these    continuity during operation is beyond the scope of this Page 7,      Maintenance requirements for      programs maintain the validity of prior ITAAC        regulatory guide. Referenced sentence will be deleted Paragraph 5  security and emergency            conclusions on security and emergency preparedness    as proposed. The paragraph, as revised after deleting 6
If the NRC elects to retain this paragraph, proposed should be deleted from first sentence (see comment 15)
Refer to clearly written description instead of detailed process (see comment 9)
Paragraph will be revised as follows:
Each 10 CFR 52.99(c)(3) notification should include sufficient information for both the completed and uncompleted elements of the ITAAC. The licensee should copy the ITAAC directly from the COL to the ITAAC statement. Items that the licensee has completed toward ITAAC closure should be accompanied by a clearly written description that describes how it completed those portions of the inspections, tests, or analyses. Items that remain uncomplete for ITAAC closure should be accompanied by a clearly written description that describes how the licensee expects to complete those portions of the inspections, tests, or analyses and that subsequently concludes that the acceptance criteria will be met. The licensee should include enough detail on each inspection, test, or analysis for both completed and uncompleted portions to clearly indicate how it completed, or will complete, those portions. The submittal should also include a schedule for completing the ITAAC and a list of references applicable to the ITAAC and available for NRC review. Appendix E to NEI 08-01 presents examples of uncomplete notifications.
: 13.
Page 7, Paragraph 5 It is not necessary to give special emphasis to ITAAC Maintenance requirements for security and emergency Delete this sentence:
Licensees are responsible for ensuring that these programs maintain the validity of prior ITAAC conclusions on security and emergency preparedness Staff agrees. The references to program and system continuity during operation is beyond the scope of this regulatory guide. Referenced sentence will be deleted as proposed. The paragraph, as revised after deleting  


Section of Comment or Basis                             Recommendation                                     NRC Resolution DG1250 beginning,   preparedness programs and         to support an affirmative 10 CFR 52.103(g) finding the sentence, continues to correctly identify the areas of The        systems. Licensees understand and provide continuity after those programs and        emergency preparedness and security to be included as regulation  their responsibility to maintain systems are turned over to the operations staff. part of ITAAC maintenance.
7 Section of DG1250 Comment or Basis Recommendation NRC Resolution beginning, The regulation preparedness programs and systems. Licensees understand their responsibility to maintain the validity of all prior ITAAC conclusions.
the validity of all prior ITAAC conclusions.
Providing continuity after those programs and systems are turned over to the operations staff is beyond the scope of this regulatory guide.
Providing continuity after those programs and systems are turned over to the operations staff is beyond the scope of this regulatory guide.
: 14.         Do not refer to required 10       Delete proposed from second sentence.           Staff agrees. The entire regulatory guide has been CFR 52.99(c)(3) submittals as                                                        edited to remove proposed when referencing the rule.
to support an affirmative 10 CFR 52.103(g) finding and provide continuity after those programs and systems are turned over to the operations staff.
Page 8,     proposed Paragraph 4 beginning, Section 8.1.2
the sentence, continues to correctly identify the areas of emergency preparedness and security to be included as part of ITAAC maintenance.
: 15.          DG-1250 presents five             None                                              No action.
: 14.
criteria/thresholds for Page 7,      determining when an ITAAC Paragraph 5  post-closure notification is beginning,  necessary, including material Section    error or omission. The 8.1.2      industry does not object to treating material error or omission as a fifth notification threshold, and will plan to revise NEI 08-01 accordingly.
Page 8, Paragraph 4 beginning, Section 8.1.2 Do not refer to required 10 CFR 52.99(c)(3) submittals as proposed Delete proposed from second sentence.
: 16.         The industry has no objection     None                                              No action.
Staff agrees. The entire regulatory guide has been edited to remove proposed when referencing the rule.
to the suggested clarification to 7
: 15.
Page 7, Paragraph 5 beginning, Section 8.1.2 DG-1250 presents five criteria/thresholds for determining when an ITAAC post-closure notification is necessary, including material error or omission. The industry does not object to treating material error or omission as a fifth notification threshold, and will plan to revise NEI 08-01 accordingly.
None No action.
: 16.
The industry has no objection to the suggested clarification to None No action.


Section of Comment or Basis                               Recommendation                                           NRC Resolution DG1250 Page 8,     the ITAAC Maintenance PWV Paragraph 2, example, and we will revise beginning,  NEI 08-01 accordingly.
8 Section of DG1250 Comment or Basis Recommendation NRC Resolution Page 8, Paragraph 2, beginning, Example:
Example:
the ITAAC Maintenance PWV example, and we will revise NEI 08-01 accordingly.
: 17.         We understand that the NRC       Revise sentence 3 as follows:                           Staff agrees. The determination process for an ITAAC staff intends no difference with If that is the case, the licensee should make an ITAAC maintenance prompt notification is the same both before Page 8,      the industry guidance on the    maintenance prompt notification within 24 hours of     and after the All ITAAC Complete notification is Paragraph 5, timing of post closure ITAAC    determining that the determination of the new           submitted, and the only difference is that the expected beginning,  notifications after the all      information exceeds a notification threshold, and       time to submit will be 24 hours instead of the 7 days Section    ITAAC complete letter is        should follow the format presented in Appendix G of     expected for new information arising before an All 8.1.3      submitted. Thus we request      NEI 08-01. Section 8.1.3 of NEI 08-01 recommends       ITAAC Complete notification submittal. Sentence will that the NRC use identical      that the licensee should evaluate new information or   be revised as follows:
: 17.
language to that provided in    conditions expeditiously to determine if a notification NEI 08-01, Section 8.1.3.        threshold is exceeded during this period before the 10 If that is the case, the licensee should make an ITAAC CFR 52.103(g) finding.                                  maintenance prompt notification within 24 hours of determining that the new information exceeds a notification threshold, and should follow the format presented in Appendix G of NEI 08-01. Section 8.1.3 of NEI 08-01 recommends that the licensee should evaluate new information or conditions expeditiously to determine if a notification threshold is exceeded during this period before the 10 CFR 52.103(g) finding.
Page 8, Paragraph 5, beginning, Section 8.1.3 We understand that the NRC staff intends no difference with the industry guidance on the timing of post closure ITAAC notifications after the all ITAAC complete letter is submitted. Thus we request that the NRC use identical language to that provided in NEI 08-01, Section 8.1.3.
: 18.         Replace the word initial with Revise sentence 2 as follows:                            Staff agrees. It is correct to refer to the notification as a Section 52.99(c)(1)           After the licensee submits the initial Section        Section 52.99(c)(1) closure notification instead of Page 9,                                       52.99(c)(1) closure notification on a common issue to  initial. Sentence will be revised as follows:
Revise sentence 3 as follows:
Paragraph 3,                                  the NRC, subsequent licensees could submit beginning,                                    notifications referencing identical information;        After the licensee submits the Section 52.99(c)(1)
If that is the case, the licensee should make an ITAAC maintenance prompt notification within 24 hours of determining that the determination of the new information exceeds a notification threshold, and should follow the format presented in Appendix G of NEI 08-01. Section 8.1.3 of NEI 08-01 recommends that the licensee should evaluate new information or conditions expeditiously to determine if a notification threshold is exceeded during this period before the 10 CFR 52.103(g) finding.
ITAAC                                        however,                                              closure notification on a common issue to the NRC, closure                                                                                            subsequent licensees could submit notifications referencing identical information; however,
Staff agrees. The determination process for an ITAAC maintenance prompt notification is the same both before and after the All ITAAC Complete notification is submitted, and the only difference is that the expected time to submit will be 24 hours instead of the 7 days expected for new information arising before an All ITAAC Complete notification submittal. Sentence will be revised as follows:
: 19.         Clarify guidance on reference   Revise last sentence in paragraph as follows:           Staff agrees. The additional information clarifies field by one licensee to common        After the licensee submits the initial closure        activities, and also properly requests plant-specific 8
If that is the case, the licensee should make an ITAAC maintenance prompt notification within 24 hours of determining that the new information exceeds a notification threshold, and should follow the format presented in Appendix G of NEI 08-01. Section 8.1.3 of NEI 08-01 recommends that the licensee should evaluate new information or conditions expeditiously to determine if a notification threshold is exceeded during this period before the 10 CFR 52.103(g) finding.
: 18.
Page 9, Paragraph 3, beginning, ITAAC closure Replace the word initial with Section 52.99(c)(1)
Revise sentence 2 as follows:
After the licensee submits the initial Section 52.99(c)(1) closure notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however, Staff agrees. It is correct to refer to the notification as a Section 52.99(c)(1) closure notification instead of initial. Sentence will be revised as follows:
After the licensee submits the Section 52.99(c)(1) closure notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however,
: 19.
Clarify guidance on reference by one licensee to common Revise last sentence in paragraph as follows:
After the licensee submits the initial closure Staff agrees. The additional information clarifies field activities, and also properly requests plant-specific  


Section of Comment or Basis                               Recommendation                                               NRC Resolution DG1250 Page 9,     ITAAC closure information         notification on a common issue to the NRC,                 information for acceptance criteria that are plant-Paragraph 3, submitted by another, including    subsequent licensees could submit notifications            specific, i.e., acceptance criteria requiring field beginning,  what is meant by field            referencing identical information; however, licensees      activities. Sentence will be revised as follows:
9 Section of DG1250 Comment or Basis Recommendation NRC Resolution Page 9, Paragraph 3, beginning, ITAAC closure ITAAC closure information submitted by another, including what is meant by field activities.
ITAAC      activities.                      must provide plant specific information concerning closure                                      acceptance criteria that require field activities, such as After the licensee submits the Section 52.99(c)(1) inspection of as-built SSCs or testing to verify the      closure notification on a common issue to the NRC, ability of installed SSCs to perform required              subsequent licensees could submit notifications functions.                                                referencing identical information; however, licensees must provide plant-specific information concerning acceptance criteria that require field activities, such as inspection of as-built SSCs or testing to verify the ability of installed SSCs to perform required functions.
notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however, licensees must provide plant specific information concerning acceptance criteria that require field activities, such as inspection of as-built SSCs or testing to verify the ability of installed SSCs to perform required functions.
: 20.         Clarify paragraph to focus on     The third sentence containing the reference to             Staff agrees. Removal of the sentence that references assuring that performing          standard industry practice is largely redundant to the   standard industry practice does not detract from the P.9,        inspections, test, or analyses at  second. It may and should be deleted so the paragraph     intent of the RG. The previous sentence in the RG Paragraph 6  other than the final installed    reads as follows:                                         includes a broader reference to technical justification beginning    location is technically                                                                      and standard industry practice is included under the Section 8.5  justifiable. To avoid confusion,  Section 8.5 of NEI 08-01 includes guidance for             NEI 08-01 topic of technical justifiability. Paragraph of        the regulatory guide need not      inspections, tests, or analyses performed at locations     will be revised as follows:
information for acceptance criteria that are plant-specific, i.e., acceptance criteria requiring field activities. Sentence will be revised as follows:
mention standard industry        other than final installed locations for licensees using practice, which, as discussed    the definition of as -built provided in NEI 08-01.               Section 8.5 of NEI 08-01 includes guidance for in NEI 08-01, is one aspect in    For ITAAC that specify that the inspection, test, or       inspections, tests, or analyses performed at locations assuring technical justifiability. analysis is to be performed as-built, licensees may       other than the final installed locations for licensees using take credit for inspections, tests, or analyses           the definition of as-built provided in NEI 08-01. For performed at locations other than the final installed     ITAAC that specify that the inspection, test, or analysis location provided that it is technically justifiable to do is to be performed as built, licensees may take credit for so. In certain cases, and consistent with Section 8.5 of   inspections, tests, or analyses performed at locations NEI 08-01, use of other than final in-place, as-built     other than the final installed location provided that it is inspections, tests, or analyses to satisfy as-built       technically justifiable to do so. NEI 08-01 provides ITAAC may be exercised when performing them               guidance on when it is technically justifiable for the earlier is consistent with standard industry practice. licensee to take credit for inspections, tests, and analyses NEI 08-01 provides guidance on when it is technically     performed at locations other than the final installed 9
After the licensee submits the Section 52.99(c)(1) closure notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however, licensees must provide plant-specific information concerning acceptance criteria that require field activities, such as inspection of as-built SSCs or testing to verify the ability of installed SSCs to perform required functions.
: 20.
P.9, Paragraph 6 beginning Section 8.5 of Clarify paragraph to focus on assuring that performing inspections, test, or analyses at other than the final installed location is technically justifiable. To avoid confusion, the regulatory guide need not mention standard industry practice, which, as discussed in NEI 08-01, is one aspect in assuring technical justifiability.
The third sentence containing the reference to standard industry practice is largely redundant to the second. It may and should be deleted so the paragraph reads as follows:
Section 8.5 of NEI 08-01 includes guidance for inspections, tests, or analyses performed at locations other than final installed locations for licensees using the definition of as -built provided in NEI 08-01.
For ITAAC that specify that the inspection, test, or analysis is to be performed as-built, licensees may take credit for inspections, tests, or analyses performed at locations other than the final installed location provided that it is technically justifiable to do so. In certain cases, and consistent with Section 8.5 of NEI 08-01, use of other than final in-place, as-built inspections, tests, or analyses to satisfy as-built ITAAC may be exercised when performing them earlier is consistent with standard industry practice.
NEI 08-01 provides guidance on when it is technically Staff agrees. Removal of the sentence that references standard industry practice does not detract from the intent of the RG. The previous sentence in the RG includes a broader reference to technical justification and standard industry practice is included under the NEI 08-01 topic of technical justifiability. Paragraph will be revised as follows:
Section 8.5 of NEI 08-01 includes guidance for inspections, tests, or analyses performed at locations other than the final installed locations for licensees using the definition of as-built provided in NEI 08-01. For ITAAC that specify that the inspection, test, or analysis is to be performed as built, licensees may take credit for inspections, tests, or analyses performed at locations other than the final installed location provided that it is technically justifiable to do so. NEI 08-01 provides guidance on when it is technically justifiable for the licensee to take credit for inspections, tests, and analyses performed at locations other than the final installed  


Section of Comment or Basis                               Recommendation                                           NRC Resolution DG1250 justifiable for the licensee to take credit for         location for as-built ITAAC.
10 Section of DG1250 Comment or Basis Recommendation NRC Resolution justifiable for the licensee to take credit for inspections, tests, and analyses performed at locations other than the final installed location for as-built ITAAC.
inspections, tests, and analyses performed at locations other than the final installed location for as-built ITAAC.
location for as-built ITAAC.
: 21.           The summary description of       Revise paragraph as follows:                            Staff disagrees with the proposed edits, but agrees to NEI 08-01, Appendix C, should     Appendix C to NEI 08-01 generally describes           revise the section. The proposed edits do not correctly Page 10,      be revised to better reflect the  common industry processes and practices used in         describe NEI 08-01 Appendix C as it appears in Paragraph 3  intent of Appendix C.            performing ITAAC-related activities. The purpose is     Revision 4.
: 21.
beginning                                      to describe, in a general way, procedures, training and Appendix C NEI plans to clarify this intent    other processes that are used in performing ITAAC to   Paragraph will be revised as follows:
Page 10, Paragraph 3 beginning Appendix C The summary description of NEI 08-01, Appendix C, should be revised to better reflect the intent of Appendix C.
of Appendix C in the next        aid members of the public in understanding ITAAC revision of NEI 08-01.           Closure Notifications. ITAAC categories and            Appendix C to NEI 08-01 generally describes common discusses categories such as calculations and analyses, industry processes and practices used in performing test procedures, special processes, inspection          ITAAC-related activities of common acceptance criteria programs, code design reports from the American        categories. These categories include calculations and Society of Mechanical Engineers, existing reports that  analyses, test procedures, special processes, inspection conclude that acceptance criteria are met,              programs, code design reports from the American procurement, material control, and training and        Society of Mechanical Engineers, reports that exist and qualification. These discussions are intended to assist conclude that acceptance criteria are met, procurement, the licensee in preparing closure notifications or      material control, training and qualification, and modular uncomplete notifications for each type of ITAAC        construction and testing.
NEI plans to clarify this intent of Appendix C in the next revision of NEI 08-01.
category.
Revise paragraph as follows:
: 22.           Licensees apply a graded QA       Revise last sentence in paragraph as follows:           Staff disagrees. The proposed changes would limit the approach for SSCs identified as  In particular, the licensee should adapt a graded QA   scope of the original paragraph, and would incorrectly Page 10,      significant contributors to plant approach for the construction and installation of the   focus the discussion to SSC, and not performance of the Paragraph 4 safety per NUREG-0800, not          ITAAC completion of nonsafety-related ITAAC and         ITAAC as originally intended.
Appendix C to NEI 08-01 generally describes common industry processes and practices used in performing ITAAC-related activities. The purpose is to describe, in a general way, procedures, training and other processes that are used in performing ITAAC to aid members of the public in understanding ITAAC Closure Notifications. ITAAC categories and discusses categories such as calculations and analyses, test procedures, special processes, inspection programs, code design reports from the American Society of Mechanical Engineers, existing reports that conclude that acceptance criteria are met, procurement, material control, and training and qualification. These discussions are intended to assist the licensee in preparing closure notifications or uncomplete notifications for each type of ITAAC category.
beginning In based on whether SSCs are        ITAAC associated with the regulatory treatment of addition to  ITAAC-related or not.            nonsafety-related systems nonsafety-related SSCs that are significant contributors to plant safety to assure satisfactory performance and documentation of any 10
Staff disagrees with the proposed edits, but agrees to revise the section. The proposed edits do not correctly describe NEI 08-01 Appendix C as it appears in Revision 4.
Paragraph will be revised as follows:
Appendix C to NEI 08-01 generally describes common industry processes and practices used in performing ITAAC-related activities of common acceptance criteria categories. These categories include calculations and analyses, test procedures, special processes, inspection programs, code design reports from the American Society of Mechanical Engineers, reports that exist and conclude that acceptance criteria are met, procurement, material control, training and qualification, and modular construction and testing.
: 22.
Page 10, Paragraph 4 beginning In addition to Licensees apply a graded QA approach for SSCs identified as significant contributors to plant safety per NUREG-0800, not based on whether SSCs are ITAAC-related or not.
Revise last sentence in paragraph as follows:
In particular, the licensee should adapt a graded QA approach for the construction and installation of the ITAAC completion of nonsafety-related ITAAC and ITAAC associated with the regulatory treatment of nonsafety-related systems nonsafety-related SSCs that are significant contributors to plant safety to assure satisfactory performance and documentation of any Staff disagrees. The proposed changes would limit the scope of the original paragraph, and would incorrectly focus the discussion to SSC, and not performance of the ITAAC as originally intended.


Section of Comment or Basis                               Recommendation                                             NRC Resolution DG1250 associated ITAAC.
11 Section of DG1250 Comment or Basis Recommendation NRC Resolution associated ITAAC.
: 23.         Licensees may perform             Modify the 4th and 5th sentence as follows:                Staff disagrees. The technical justification used to take inspections, tests, or analyses at                                                            credit for ITA performed at an other-than-final-installed Page 10,   other than the final installed    This also applies to the technical justification for       location for an as-built ITAAC, including those Paragraph 5 location provided doing so is      completing inspections, tests, or analyses if they are     covered by the generic technical justifications contained beginning  technically justified. NEI 08-    performed at locations other than the final installed     in NEI 08-01, should appear in the IDB, as this is Appendix D 01 provides generic technical      location when those ITA are not covered by the             material to sufficiently describe how the ITAAC was justifications for common          generic technical justifications contained in NEI 08-     completed.
: 23.
situations where licensees are    01. In cases in where it is acceptable for the licensee expected to do so. Each            to perform these inspections, tests, or analyses at ITAAC closure notification will    locations other than the final installed location, but the reference NEI 08-01 as a source    ITA are not covered by the generic technical of guidance and acceptable        justifications contained in NEI 08-01, the licensee technical justifications. The      must should document summarize the associated guidance in DG-1250 should be      technical justification in the ITAAC Completion clarified to indicate that ITAAC  Package and summarize it in the IDB of the closure closure notifications need to      notification to establish that it has successfully summarize the technical            completed the ITAAC in conformance with the justification for inspections,    definition of as-built. This can include appropriately tests, or analyses performed at    specific references to the generic technical other than the final installed    justifications in Section 8.5 of NEI 08-01.
Page 10, Paragraph 5 beginning Appendix D Licensees may perform inspections, tests, or analyses at other than the final installed location provided doing so is technically justified. NEI 08-01 provides generic technical justifications for common situations where licensees are expected to do so. Each ITAAC closure notification will reference NEI 08-01 as a source of guidance and acceptable technical justifications. The guidance in DG-1250 should be clarified to indicate that ITAAC closure notifications need to summarize the technical justification for inspections, tests, or analyses performed at other than the final installed location only if the ITA are not covered by the generic technical justifications in NEI 08-01.
location only if the ITA are not covered by the generic technical justifications in NEI 08-01.
ITAAC closure notifications D-16 and D-17 in NEI 08-01 are examples that describe generically justified inspections (dimensional checks) performed at a fabrication facility, and reference to NEI Modify the 4th and 5th sentence as follows:
ITAAC closure notifications D-16 and D-17 in NEI 08-01 are examples that describe generically justified inspections (dimensional checks) performed at a fabrication facility, and reference to NEI 11
This also applies to the technical justification for completing inspections, tests, or analyses if they are performed at locations other than the final installed location when those ITA are not covered by the generic technical justifications contained in NEI 08-
: 01. In cases in where it is acceptable for the licensee to perform these inspections, tests, or analyses at locations other than the final installed location, but the ITA are not covered by the generic technical justifications contained in NEI 08-01, the licensee must should document summarize the associated technical justification in the ITAAC Completion Package and summarize it in the IDB of the closure notification to establish that it has successfully completed the ITAAC in conformance with the definition of as-built. This can include appropriately specific references to the generic technical justifications in Section 8.5 of NEI 08-01.
Staff disagrees. The technical justification used to take credit for ITA performed at an other-than-final-installed location for an as-built ITAAC, including those covered by the generic technical justifications contained in NEI 08-01, should appear in the IDB, as this is material to sufficiently describe how the ITAAC was completed.


Section of Comment or Basis                             Recommendation                                             NRC Resolution DG1250 08-01 is provided.
12 Section of DG1250 Comment or Basis Recommendation NRC Resolution 08-01 is provided.
: 24.           Appendix H presents examples     Revise paragraph as follows:                           Staff agrees. Appendix H to NEI 08-01 contains to illustrate when a post-closure Appendix H to NEI 08-01 provides examples of          examples for when post-closure notifications would be Page 11,      ITAAC notification would or      ITAAC maintenance. The examples are various            required and also when post-closure notifications would Paragraph 5  would not be required.            scenarios and events that show whether an ITAAC        not be required. Paragraph will be revised as follows:
: 24.
beginning                                      post-closure notification would or would notlikely be Appendix H                                    required.                                              Appendix H to NEI 08-01 provides examples of ITAAC maintenance. The examples are various scenarios and events that show whether an ITAAC post-closure notification would or would not be required.
Page 11, Paragraph 5 beginning Appendix H Appendix H presents examples to illustrate when a post-closure ITAAC notification would or would not be required.
: 25.           As discussed in public           Revise Item 3 as follows:                              Staff agrees. The revision below clarifies the use of meetings, the industry plans to   Use of Examples in NEI 08-01                          templates versus examples in NEI 08-01. The Page 12, Item clarify the intent and use of                                                             examples will need to be further completed with details 3            templates versus examples        NEI 08-01 includes examples for notifications           that are specific to the actual situation encountered presented in NEI 08-01. In the    required by 10 CFR 52.99. Although these examples       during completion of the ITAAC. The reader should not meantime, the NRC regulatory      are intended to templates for illustrate ing and       assume that the examples can be used without guidance should avoid            reinforce ing the guidance in NEI 08-01, the licensee   modifying them for ITAAC completion activities that improperly mixing these terms. should not consider the NRCs endorsement of this       are specific to a particular licensee.
Revise paragraph as follows:
industry guideline document a determination that each example applies to all licensees as it is presented and Item #3 will be revised as follows:
Appendix H to NEI 08-01 provides examples of ITAAC maintenance. The examples are various scenarios and events that show whether an ITAAC post-closure notification would or would notlikely be required.
written in the guide. A licensee should ensure that an example applies to its particular circumstances before 3.         Use of Examples in NEI 08-01 implementing the example guidance or template, as presenteddescribed.                                    NEI 08-01 includes examples for notifications required by 10 CFR 52.99. Although these examples are intended to illustrate and reinforce the guidance in NEI 08-01, the licensee should not consider the NRCs endorsement of this industry guideline document a determination that each example applies to all licensees as it is presented and written in the guide. A licensee should ensure that an example applies to its particular circumstances before implementing it. The sufficient 12
Staff agrees. Appendix H to NEI 08-01 contains examples for when post-closure notifications would be required and also when post-closure notifications would not be required. Paragraph will be revised as follows:
Appendix H to NEI 08-01 provides examples of ITAAC maintenance. The examples are various scenarios and events that show whether an ITAAC post-closure notification would or would not be required.
: 25.
Page 12, Item 3
As discussed in public meetings, the industry plans to clarify the intent and use of templates versus examples presented in NEI 08-01. In the meantime, the NRC regulatory guidance should avoid improperly mixing these terms.
Revise Item 3 as follows:
Use of Examples in NEI 08-01 NEI 08-01 includes examples for notifications required by 10 CFR 52.99. Although these examples are intended to templates for illustrate ing and reinforce ing the guidance in NEI 08-01, the licensee should not consider the NRCs endorsement of this industry guideline document a determination that each example applies to all licensees as it is presented and written in the guide. A licensee should ensure that an example applies to its particular circumstances before implementing the example guidance or template, as presenteddescribed.
Staff agrees. The revision below clarifies the use of templates versus examples in NEI 08-01. The examples will need to be further completed with details that are specific to the actual situation encountered during completion of the ITAAC. The reader should not assume that the examples can be used without modifying them for ITAAC completion activities that are specific to a particular licensee.
Item #3 will be revised as follows:
: 3.
Use of Examples in NEI 08-01 NEI 08-01 includes examples for notifications required by 10 CFR 52.99. Although these examples are intended to illustrate and reinforce the guidance in NEI 08-01, the licensee should not consider the NRCs endorsement of this industry guideline document a determination that each example applies to all licensees as it is presented and written in the guide. A licensee should ensure that an example applies to its particular circumstances before implementing it. The sufficient  


Section of Comment or Basis Recommendation                     NRC Resolution DG1250 information, required by 10 CFR 52.99(c)(1), for any individual ITAAC closure notification can only be generically guided by the examples presented in NEI 08-01 Revision 4. Ultimately, sufficient information must be determined with respect to the specific facts surrounding each ITAAC performance and closure.
13 Section of DG1250 Comment or Basis Recommendation NRC Resolution information, required by 10 CFR 52.99(c)(1), for any individual ITAAC closure notification can only be generically guided by the examples presented in NEI 08-01 Revision 4. Ultimately, sufficient information must be determined with respect to the specific facts surrounding each ITAAC performance and closure.}}
13}}

Latest revision as of 01:40, 13 January 2025

Staff Responses to Public Comments on DG-1250
ML11284A006
Person / Time
Issue date: 08/28/2012
From:
Office of Nuclear Regulatory Research
To:
Jervey, Richard
Shared Package
ML112580016 List:
References
DG-1250 RG 1.215, Rev 1
Download: ML11284A006 (13)
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Text

ML11284A006 A notice that Draft Regulatory Guide DG-1250 was available for public comment was published in the Federal Register on May 13, 2011, 76 FR 27924-27925. The comment period ended July 25, 2011. A single comment submission was received from the organization listed below. The comments and the NRC staffs response are set forth in the following table.

Comments were received from:

Russell J. Bell, Director New Plant Licensing, Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street NW, Suite 400 Washington DC 20006-3708 Telephone: 1-202-739-8087 (ADAMS ML11209C487)

Section of DG1250 Comment or Basis Recommendation NRC Resolution

1.

Page 2, paragraph 4 beginning The regulation at proposed Clarification Modify this sentence as follows:

This supplemental ITAAC closure notification would describe the resolution of the circumstances surrounding the identification of new material information, and would need to contain sufficient information to demonstrate that, notwithstanding the new material information, the prescribed inspections, tests, or analyses have been performed as required and the prescribed acceptance criteria are met.

Staff agrees that a clarification along the lines suggested would be beneficial, but the staff will use language that more closely follows the language used in the rule.

Sentence will be revised as follows:

This supplemental ITAAC closure notification would describe the resolution of the circumstances surrounding the identification of new material information, and would need to contain sufficient information to demonstrate that, notwithstanding the new information, the prescribed inspections, tests, or analyses have been performed as required and the prescribed acceptance criteria are met.

2.

Page 2, paragraph 5 beginning When referring directly to the Commission finding required by Section 52.103(g), the actual rule language should be used.

Modify first sentence as follows:

Operation (which includes loading fuel) cannot commence until the Commission finds under 10 CFR 52.103(g) that the all acceptance criteria in the combined license ITAAC are met.

Staff disagrees in that this language is a paraphrase to make the point that all acceptance criteria need to be met at that time. To be more clear the following change will be made to the sentence:

2 Section of DG1250 Comment or Basis Recommendation NRC Resolution Operation Operation (which includes loading fuel) cannot commence until the Commission finds under 10 CFR 52.103(g) that all acceptance criteria in the COL are met.

3.

Page 5, Paragraph 1 beginning, Section 4 Clarification Modify second sentence to refer to the specific regulation: Section 52.99(a)

Staff agrees. It would be appropriate to cite Section 52.99(a) when discussing the ITAAC completion schedule submittals required by this section. Sentence will be revised to specify Section 52.99(a).

4.

Page 5, Paragraph 2 beginning, In addition to The ITAAC completion schedules referred to in Section 4 of NEI 08-01 are expected to be one and the same as the schedules required by Section 52.99(a). Clarify guidance so it does not suggest the need for two different submittals of construction schedule information.

Modify this paragraph to read as follows:

In addition to the required schedule submittals If not already included in the schedule information provided in accordance with Section 52.99(a), licensees should provide a Level 3 schedule of ITAAC-related activities on site and off site (in vendor shops). These detailed schedules will allow the staff to plan its oversight activities.

Staff agrees. The requested Level 3 schedules could be the same as those schedules submitted to satisfy the requirements of Section 52.99(a). Section will be revised as follows:

If not already included in the schedule information provided in accordance with Section 52.99(a), licensees should provide a Level 3 schedule of ITAAC-related activities on site and off site (in vendor shops). These detailed schedules will further allow the staff to plan its oversight activities.

5.

Page 5, Paragraph 3 beginning, Applicants should The recommendation for applicants to submit and maintain a complete consolidated listing of ITAAC is beyond the scope of this Reg.

Guide, and does not have a regulatory basis.

Applicants provide a complete Replace this paragraph with the following:

COLs will include an appendix that contains a complete integrated list of ITAAC for each licensed unit, drawn from the DCD, ESP, LWA and COL, as applicable. The NRC expects that licensees will submit ITAAC closure notifications using the nomenclature and numbering scheme of the ITAAC identified in the COL. This will minimize errors and Staff agrees with the commenters reasoning, but will modify the proposed paragraph to reflect that the description of how ITAAC will be included in the license is a current staff expectation. Referenced paragraph will be replaced with the following:

The NRC expects to issue COLs which include an appendix that contains a complete, integrated list of ITAAC for each licensed unit, drawn from the design control document, early site permit (ESP), limited work

3 Section of DG1250 Comment or Basis Recommendation NRC Resolution list of ITAAC when incorporating a DCD by reference, and adding plant-specific ITAAC in COLA Part

10. A complete integrated list of ITAAC will be established as Appendix A of the COL and maintained as part of the license (including approved/incorporated amendments).

ensure consistent referencing of specific ITAAC by the licensee, NRC and the public.

Applicants should submit and maintain a complete, consolidated listing of the ITAAC in their COL applications. Providing a complete table that lists all ITAAC will ensure that the ITAAC issued with the COL are accurate and will standardize a reference that the staff and licensees can then use. The submission of a complete ITAAC list prior to COL issuance will reduce errors when referencing or identifying ITAAC and will provide the basis for the ITAAC list included as an appendix to the COL.

authorization (LWA), and COL application, as applicable. The NRC expects that licensees will submit ITAAC closure notifications using the nomenclature and numbering scheme of the ITAAC identified in the COL.

This will minimize errors and ensure consistent referencing of specific ITAAC by the licensee, the NRC, and the public.

6.

Page 5, Paragraph 4 beginning, Section 5 Clarification Modify second and third sentences to read as follows:

This section also provides guidance for the licensee oversight of ITAAC closure activities and the maintenance of records referenced by the ITAAC closure notifications packages. In addition, Section 5 of NEI 08-01 provides an outline of ITAAC completion packages.

Staff agrees. These clarifications correctly identify the intended notifications and ITAAC completion packages.

Sentence will be revised as follows:

This section also provides guidance for the licensee oversight of ITAAC closure activities and the maintenance of records referenced by the ITAAC closure notifications. In addition, Section 5 of NEI 08-01 provides an outline of ITAAC completion packages.

7.

Page 5, Paragraph 1 beginning, Section 4 As discussed in NEI 08-01, please add language from SECY-06-0114 concerning one-time submittal of a proprietary affidavit covering the submittal of detailed ITAAC completion schedules and updates.

Add language similar to this from NEI 08-01, Section 4.1: As described in SECY 06-0114, Description of the Construction Inspection Program for Plants Licensed under Part 52, licensees may submit a single affidavit to request that schedule information be held as proprietary under 10 CFR 2.390. SECY 06-0114 states, [B]ecause the nature of the information would not change from initial submittal to update, no Staff agrees. By adding the reference to SECY 0114, the reader will understand that the discussion on the single proprietary determinations has previously been presented to the Commission. Paragraph will be added as follows:

As described in SECY 06-0114, Description of the Construction Inspection Program for Plants Licensed

4 Section of DG1250 Comment or Basis Recommendation NRC Resolution additional proprietary determinations would be needed and routine schedule updates from the licensee would be considered proprietary and would be withheld from the public without further evaluation. This approach would allow for a single proprietary determination, limited to the schedule and its updates, that would apply to an entire construction project.

under Part 52, licensees may submit a single affidavit to request that schedule information be held as proprietary under 10 CFR 2.390. SECY 06-0114 states as follows:

Because the nature of the information would not change from initial submittal to update, no additional proprietary determinations would be needed and routine schedule updates from the licensee would be considered proprietary and would be withheld from the public without further evaluation. This approach would allow for a single proprietary determination, limited to the schedule and its updates, that would apply to an entire construction project.

8.

Page 5, Paragraph 6 beginning, The NRC expects Clarification is needed to assure the reader understands that the NRC staff has determined that NEI 08-01 provides acceptable guidance on sufficient information.

Modify first sentence as follows:

The NEI guidance appropriately reflects that the NRC expects the notification of ITAAC completion to contain more information than just a simple statement Staff agrees. By adding the recommended phrase, the sentence correctly explains that the NEI guidance provides acceptable guidance on sufficient information for notifications on ITAAC completion.

The sentence will be revised as follows:

The NEI guidance appropriately reflects that the NRC expects the notification of ITAAC completion to contain more information than just a simple statement

9.

Page 5, Paragraph 7 beginning, Each 10 CFR 52.99(c)(1)

Consistent, well understood language should be used to describe the required content of ITAAC Closure Notifications.

The regulatory guidance should avoid use of language that is unlike that used anywhere else in the DG or NEI 08-01:

Modify the first 2 sentences as follows:

Each 10 CFR 52.99(c)(1) submittal should include sufficient information on the attributes that validate that the licensee has satisfied the acceptance criteria.

Licensee ITAAC Closure Notifications under 10 CFR 52.99(c)(1) should include copy the ITAAC copied directly from the certified design and COL to the ITAAC statement.

Staff disagrees with the edits proposed for the first 2 sentences. Staff believes that the language on sufficient information should be retained, and does not see a problem with the attributes that validate language. Staff agrees to revise the third sentence as proposed Paragraph will be revised as follows:

5 Section of DG1250 Comment or Basis Recommendation NRC Resolution submittal

1. Sufficient information on the attributes that validate
2. clearly written, detailed process Modify the third sentence as follows:

The ITAAC determination basis (IDB) should include a clearly written, detailed process on description of how the licensee completed the

[ITAAC]

Each 10 CFR 52.99(c)(1) submittal should include sufficient information on the attributes that validate that the licensee has satisfied the acceptance criteria. The licensee should copy the ITAAC directly from the COL to the ITAAC statement. The ITAAC determination basis (IDB) should include a clearly written description of how the licensee completed the inspections, tests, or analyses and should explain how it met the acceptance criteria. The licensee.

10.

Page 6, Paragraph 3 beginning, Section 7

Clarification.

Also, do not refer to proposed requirements in the final regulatory guide.

Revise second sentence as follows:

The 225-day notification mandated by proposed 10 CFR 52.99(c)(3), must include sufficient information so that interested persons will have access to information on uncompleted ITAAC Staff agrees. References to proposed requirements should be removed from the final regulatory guide.

Sentence will be revised as follows:

The 225-day notification mandated by10 CFR 52.99(c)(3), must include sufficient information so that interested persons will have information on uncompleted ITAAC

11.

Page 6, Paragraph 3 beginning, Section 7

Clarification Revise last sentence as follows:

The uncomplete notification will be a predictive summary for how the licensee plans to complete the ITAAC that are if that ITAAC is not completed by 225 days before the scheduled loading of fuel.

Staff agrees. The clarification improves the readability of the sentence. Sentence will be revised as follows:

The uncomplete notification will be a predictive summary for how the licensee plans to complete the ITAAC that are not completed by 225 days before the scheduled loading of fuel.

12.

Page 6, Paragraph 5 beginning, Each proposed 10 Regulatory guidance concerning the 225-day uncompleted ITAAC letter should focus on the information required by Section 52.99(c)(3).

That regulation does not require the uncomplete letter to The preceding paragraph that begins, The licensee must demonstrate provides apt and sufficient regulatory guidance for implementing Section 52.99(c)(3). Thus we recommend deleting this paragraph (which continues onto page 7) in its entirety.

Staff disagrees to deleting the paragraph, but agrees with the proposed edits. This position on the content of the uncomplete ITAAC notification is consistent with discussions in the public ITAAC workshop series and agrees with the content of NEI 08-01 Revision 4 Section 7 and Appendix E.

6 Section of DG1250 Comment or Basis Recommendation NRC Resolution CFR 52.99(c)(3) submittal describe both completed and uncompleted elements of an ITAAC, nor does it require a schedule for completing ITAAC. Since developing guidance to this effect in 2008, the industry has determined that parsing completed versus uncompleted ITAAC elements, and providing a schedule for completing ITAAC (beyond that required by Section 52.99(a)), would be problematic and would not add value in terms of information to the public, in part due to the rapidly changing status of ITAAC closures during the last several months before fuel load.

We plan to propose a revision to NEI 08-01 guidance on the 225-day uncompleted ITAAC letter later this year for discussion with the NRC staff.

Pending consideration of revised guidance, NRC regulatory guidance need not and should not go beyond the existing regulations in this area.

If the NRC elects to retain this paragraph, proposed should be deleted from first sentence (see comment 15)

Refer to clearly written description instead of detailed process (see comment 9)

Paragraph will be revised as follows:

Each 10 CFR 52.99(c)(3) notification should include sufficient information for both the completed and uncompleted elements of the ITAAC. The licensee should copy the ITAAC directly from the COL to the ITAAC statement. Items that the licensee has completed toward ITAAC closure should be accompanied by a clearly written description that describes how it completed those portions of the inspections, tests, or analyses. Items that remain uncomplete for ITAAC closure should be accompanied by a clearly written description that describes how the licensee expects to complete those portions of the inspections, tests, or analyses and that subsequently concludes that the acceptance criteria will be met. The licensee should include enough detail on each inspection, test, or analysis for both completed and uncompleted portions to clearly indicate how it completed, or will complete, those portions. The submittal should also include a schedule for completing the ITAAC and a list of references applicable to the ITAAC and available for NRC review. Appendix E to NEI 08-01 presents examples of uncomplete notifications.

13.

Page 7, Paragraph 5 It is not necessary to give special emphasis to ITAAC Maintenance requirements for security and emergency Delete this sentence:

Licensees are responsible for ensuring that these programs maintain the validity of prior ITAAC conclusions on security and emergency preparedness Staff agrees. The references to program and system continuity during operation is beyond the scope of this regulatory guide. Referenced sentence will be deleted as proposed. The paragraph, as revised after deleting

7 Section of DG1250 Comment or Basis Recommendation NRC Resolution beginning, The regulation preparedness programs and systems. Licensees understand their responsibility to maintain the validity of all prior ITAAC conclusions.

Providing continuity after those programs and systems are turned over to the operations staff is beyond the scope of this regulatory guide.

to support an affirmative 10 CFR 52.103(g) finding and provide continuity after those programs and systems are turned over to the operations staff.

the sentence, continues to correctly identify the areas of emergency preparedness and security to be included as part of ITAAC maintenance.

14.

Page 8, Paragraph 4 beginning, Section 8.1.2 Do not refer to required 10 CFR 52.99(c)(3) submittals as proposed Delete proposed from second sentence.

Staff agrees. The entire regulatory guide has been edited to remove proposed when referencing the rule.

15.

Page 7, Paragraph 5 beginning, Section 8.1.2 DG-1250 presents five criteria/thresholds for determining when an ITAAC post-closure notification is necessary, including material error or omission. The industry does not object to treating material error or omission as a fifth notification threshold, and will plan to revise NEI 08-01 accordingly.

None No action.

16.

The industry has no objection to the suggested clarification to None No action.

8 Section of DG1250 Comment or Basis Recommendation NRC Resolution Page 8, Paragraph 2, beginning, Example:

the ITAAC Maintenance PWV example, and we will revise NEI 08-01 accordingly.

17.

Page 8, Paragraph 5, beginning, Section 8.1.3 We understand that the NRC staff intends no difference with the industry guidance on the timing of post closure ITAAC notifications after the all ITAAC complete letter is submitted. Thus we request that the NRC use identical language to that provided in NEI 08-01, Section 8.1.3.

Revise sentence 3 as follows:

If that is the case, the licensee should make an ITAAC maintenance prompt notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of determining that the determination of the new information exceeds a notification threshold, and should follow the format presented in Appendix G of NEI 08-01. Section 8.1.3 of NEI 08-01 recommends that the licensee should evaluate new information or conditions expeditiously to determine if a notification threshold is exceeded during this period before the 10 CFR 52.103(g) finding.

Staff agrees. The determination process for an ITAAC maintenance prompt notification is the same both before and after the All ITAAC Complete notification is submitted, and the only difference is that the expected time to submit will be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of the 7 days expected for new information arising before an All ITAAC Complete notification submittal. Sentence will be revised as follows:

If that is the case, the licensee should make an ITAAC maintenance prompt notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of determining that the new information exceeds a notification threshold, and should follow the format presented in Appendix G of NEI 08-01. Section 8.1.3 of NEI 08-01 recommends that the licensee should evaluate new information or conditions expeditiously to determine if a notification threshold is exceeded during this period before the 10 CFR 52.103(g) finding.

18.

Page 9, Paragraph 3, beginning, ITAAC closure Replace the word initial with Section 52.99(c)(1)

Revise sentence 2 as follows:

After the licensee submits the initial Section 52.99(c)(1) closure notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however, Staff agrees. It is correct to refer to the notification as a Section 52.99(c)(1) closure notification instead of initial. Sentence will be revised as follows:

After the licensee submits the Section 52.99(c)(1) closure notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however,

19.

Clarify guidance on reference by one licensee to common Revise last sentence in paragraph as follows:

After the licensee submits the initial closure Staff agrees. The additional information clarifies field activities, and also properly requests plant-specific

9 Section of DG1250 Comment or Basis Recommendation NRC Resolution Page 9, Paragraph 3, beginning, ITAAC closure ITAAC closure information submitted by another, including what is meant by field activities.

notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however, licensees must provide plant specific information concerning acceptance criteria that require field activities, such as inspection of as-built SSCs or testing to verify the ability of installed SSCs to perform required functions.

information for acceptance criteria that are plant-specific, i.e., acceptance criteria requiring field activities. Sentence will be revised as follows:

After the licensee submits the Section 52.99(c)(1) closure notification on a common issue to the NRC, subsequent licensees could submit notifications referencing identical information; however, licensees must provide plant-specific information concerning acceptance criteria that require field activities, such as inspection of as-built SSCs or testing to verify the ability of installed SSCs to perform required functions.

20.

P.9, Paragraph 6 beginning Section 8.5 of Clarify paragraph to focus on assuring that performing inspections, test, or analyses at other than the final installed location is technically justifiable. To avoid confusion, the regulatory guide need not mention standard industry practice, which, as discussed in NEI 08-01, is one aspect in assuring technical justifiability.

The third sentence containing the reference to standard industry practice is largely redundant to the second. It may and should be deleted so the paragraph reads as follows:

Section 8.5 of NEI 08-01 includes guidance for inspections, tests, or analyses performed at locations other than final installed locations for licensees using the definition of as -built provided in NEI 08-01.

For ITAAC that specify that the inspection, test, or analysis is to be performed as-built, licensees may take credit for inspections, tests, or analyses performed at locations other than the final installed location provided that it is technically justifiable to do so. In certain cases, and consistent with Section 8.5 of NEI 08-01, use of other than final in-place, as-built inspections, tests, or analyses to satisfy as-built ITAAC may be exercised when performing them earlier is consistent with standard industry practice.

NEI 08-01 provides guidance on when it is technically Staff agrees. Removal of the sentence that references standard industry practice does not detract from the intent of the RG. The previous sentence in the RG includes a broader reference to technical justification and standard industry practice is included under the NEI 08-01 topic of technical justifiability. Paragraph will be revised as follows:

Section 8.5 of NEI 08-01 includes guidance for inspections, tests, or analyses performed at locations other than the final installed locations for licensees using the definition of as-built provided in NEI 08-01. For ITAAC that specify that the inspection, test, or analysis is to be performed as built, licensees may take credit for inspections, tests, or analyses performed at locations other than the final installed location provided that it is technically justifiable to do so. NEI 08-01 provides guidance on when it is technically justifiable for the licensee to take credit for inspections, tests, and analyses performed at locations other than the final installed

10 Section of DG1250 Comment or Basis Recommendation NRC Resolution justifiable for the licensee to take credit for inspections, tests, and analyses performed at locations other than the final installed location for as-built ITAAC.

location for as-built ITAAC.

21.

Page 10, Paragraph 3 beginning Appendix C The summary description of NEI 08-01, Appendix C, should be revised to better reflect the intent of Appendix C.

NEI plans to clarify this intent of Appendix C in the next revision of NEI 08-01.

Revise paragraph as follows:

Appendix C to NEI 08-01 generally describes common industry processes and practices used in performing ITAAC-related activities. The purpose is to describe, in a general way, procedures, training and other processes that are used in performing ITAAC to aid members of the public in understanding ITAAC Closure Notifications. ITAAC categories and discusses categories such as calculations and analyses, test procedures, special processes, inspection programs, code design reports from the American Society of Mechanical Engineers, existing reports that conclude that acceptance criteria are met, procurement, material control, and training and qualification. These discussions are intended to assist the licensee in preparing closure notifications or uncomplete notifications for each type of ITAAC category.

Staff disagrees with the proposed edits, but agrees to revise the section. The proposed edits do not correctly describe NEI 08-01 Appendix C as it appears in Revision 4.

Paragraph will be revised as follows:

Appendix C to NEI 08-01 generally describes common industry processes and practices used in performing ITAAC-related activities of common acceptance criteria categories. These categories include calculations and analyses, test procedures, special processes, inspection programs, code design reports from the American Society of Mechanical Engineers, reports that exist and conclude that acceptance criteria are met, procurement, material control, training and qualification, and modular construction and testing.

22.

Page 10, Paragraph 4 beginning In addition to Licensees apply a graded QA approach for SSCs identified as significant contributors to plant safety per NUREG-0800, not based on whether SSCs are ITAAC-related or not.

Revise last sentence in paragraph as follows:

In particular, the licensee should adapt a graded QA approach for the construction and installation of the ITAAC completion of nonsafety-related ITAAC and ITAAC associated with the regulatory treatment of nonsafety-related systems nonsafety-related SSCs that are significant contributors to plant safety to assure satisfactory performance and documentation of any Staff disagrees. The proposed changes would limit the scope of the original paragraph, and would incorrectly focus the discussion to SSC, and not performance of the ITAAC as originally intended.

11 Section of DG1250 Comment or Basis Recommendation NRC Resolution associated ITAAC.

23.

Page 10, Paragraph 5 beginning Appendix D Licensees may perform inspections, tests, or analyses at other than the final installed location provided doing so is technically justified. NEI 08-01 provides generic technical justifications for common situations where licensees are expected to do so. Each ITAAC closure notification will reference NEI 08-01 as a source of guidance and acceptable technical justifications. The guidance in DG-1250 should be clarified to indicate that ITAAC closure notifications need to summarize the technical justification for inspections, tests, or analyses performed at other than the final installed location only if the ITA are not covered by the generic technical justifications in NEI 08-01.

ITAAC closure notifications D-16 and D-17 in NEI 08-01 are examples that describe generically justified inspections (dimensional checks) performed at a fabrication facility, and reference to NEI Modify the 4th and 5th sentence as follows:

This also applies to the technical justification for completing inspections, tests, or analyses if they are performed at locations other than the final installed location when those ITA are not covered by the generic technical justifications contained in NEI 08-

01. In cases in where it is acceptable for the licensee to perform these inspections, tests, or analyses at locations other than the final installed location, but the ITA are not covered by the generic technical justifications contained in NEI 08-01, the licensee must should document summarize the associated technical justification in the ITAAC Completion Package and summarize it in the IDB of the closure notification to establish that it has successfully completed the ITAAC in conformance with the definition of as-built. This can include appropriately specific references to the generic technical justifications in Section 8.5 of NEI 08-01.

Staff disagrees. The technical justification used to take credit for ITA performed at an other-than-final-installed location for an as-built ITAAC, including those covered by the generic technical justifications contained in NEI 08-01, should appear in the IDB, as this is material to sufficiently describe how the ITAAC was completed.

12 Section of DG1250 Comment or Basis Recommendation NRC Resolution 08-01 is provided.

24.

Page 11, Paragraph 5 beginning Appendix H Appendix H presents examples to illustrate when a post-closure ITAAC notification would or would not be required.

Revise paragraph as follows:

Appendix H to NEI 08-01 provides examples of ITAAC maintenance. The examples are various scenarios and events that show whether an ITAAC post-closure notification would or would notlikely be required.

Staff agrees. Appendix H to NEI 08-01 contains examples for when post-closure notifications would be required and also when post-closure notifications would not be required. Paragraph will be revised as follows:

Appendix H to NEI 08-01 provides examples of ITAAC maintenance. The examples are various scenarios and events that show whether an ITAAC post-closure notification would or would not be required.

25.

Page 12, Item 3

As discussed in public meetings, the industry plans to clarify the intent and use of templates versus examples presented in NEI 08-01. In the meantime, the NRC regulatory guidance should avoid improperly mixing these terms.

Revise Item 3 as follows:

Use of Examples in NEI 08-01 NEI 08-01 includes examples for notifications required by 10 CFR 52.99. Although these examples are intended to templates for illustrate ing and reinforce ing the guidance in NEI 08-01, the licensee should not consider the NRCs endorsement of this industry guideline document a determination that each example applies to all licensees as it is presented and written in the guide. A licensee should ensure that an example applies to its particular circumstances before implementing the example guidance or template, as presenteddescribed.

Staff agrees. The revision below clarifies the use of templates versus examples in NEI 08-01. The examples will need to be further completed with details that are specific to the actual situation encountered during completion of the ITAAC. The reader should not assume that the examples can be used without modifying them for ITAAC completion activities that are specific to a particular licensee.

Item #3 will be revised as follows:

3.

Use of Examples in NEI 08-01 NEI 08-01 includes examples for notifications required by 10 CFR 52.99. Although these examples are intended to illustrate and reinforce the guidance in NEI 08-01, the licensee should not consider the NRCs endorsement of this industry guideline document a determination that each example applies to all licensees as it is presented and written in the guide. A licensee should ensure that an example applies to its particular circumstances before implementing it. The sufficient

13 Section of DG1250 Comment or Basis Recommendation NRC Resolution information, required by 10 CFR 52.99(c)(1), for any individual ITAAC closure notification can only be generically guided by the examples presented in NEI 08-01 Revision 4. Ultimately, sufficient information must be determined with respect to the specific facts surrounding each ITAAC performance and closure.

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