ML20086L071

Advanced BWR Design Certification Guidelines for Preparation of Insps,Tests,Analysis & Acceptance Criteria (Itaac)

ML20086L071
Person / Time
Site:	05000605
Issue date:	12/31/1991
From:	James A GENERAL ELECTRIC CO.
To:
References
NUDOCS 9112160050
Download: ML20086L071 (44)

Text

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O A.BVR DESIGN CERTIFICATION GUIDELINES FOR PREPARATION OF INSPECTIONS, TESTS, ANALYSES AND ACCEPTANCE CRITERIA (ITAAC)

DECEMBER 1991 A. J . J AMES , MANAGER MECHANICAL SYSTEMS DESIGN ADVANCED REACTOR PROGRAMS CE NUCLEAR ENERGY f'8 V

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O EXECUTIVE SUMKARY An important element of the 10CFR Part 52 licensing process is the requirement to define inspections, tests;, analyses and acceptance criteria (ITAAC) for the certified design. ITAAC will be used during construction to demonstrate the as. built facility como11es with the certified design.  ;

1TAAC will be a part of the certification Rule resulting from the design certification proceedings. Specific guidance on the form, scope and content for the ITAAC is not provided in 10CTR Part $2. The purpose of this memorandum is to defire GE's criteris for developing ITAAC for the ABVR certification effort. Construction verifiextion activ;iles deriving from 10CFR Part 50 processes such as Appendix B, continue to apply to plants licensed under Part 52. -Under Part $2, ITAAC address the top level plant design criteria and design features that are contained in the design

() certification Rule, with Part 50 addressing verification of the numerous detailed aspects of plant construction. Complete plant construction verification is thus achieved by a combination of Part $2 ITAAC and the Part 50 processes deriving from Appendix B.

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, g TABLE OF CONTENTS O SECTION NUMBER CONTENTS 1.0 Introduction 2.0 Summary 3.0 Description of 10CFR Part 52 4.0 Criteria Used for Preparation of CE ITAAC i 4.1 Documentation Structure 4.2 Scope of Tier 1 Material 4.3 Tier 1 Design Description.  ;

4.4 ITAAC Contents 4.5 Use of Generic / Discipline ITAAC '

4.6 Use of Validation Attributes 4.7 Design Acceptance Criteria ITAAC 4.8 Consideration of Non. Traditional Items in

\ Development of ITAAC 4.9 Plant Specific Implamentation of ITAAC and Part 50 j Appendices A, ABWR Systems to be Included in Tier 1 '

B. Summary of Mechanisms for Changing a' Design Subject to a Design Certification f

C, Examples of ITAAC i

D. NRC Methods for. Assuring Compliance with QA Requirements Applicable to a COL O

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t TABl.ES AND FIGURES  !

Table !?uttber Contents s

4 1 Description of Part $2 Process 2 References Stating that Tier 1 is  !

Reserved for Top. Level.

Information Firure Nwthtr Contents 1 Tier 1 Relationship to other Information l

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, i 1 .0 INTRODUCTION Ne 10CFR Part $2 licensing process requires a certification ,

4 plication to include the proposed criteria and verification means to be used during plant construction that wi*. ensure the as built facility conforms to the design approved by the certification process.

Specifically, 10CTR 52.47 (a)(vi) states a design certification application must include:

Proposed tests, inspectior.s analyses, and acceptance criteria which are necessary and sufficient to provide '

reasonable assurance that, if the tests, inspections and analyses are performed and the acceptance criteria met, a plant which references the design is built and will operate in a::cordance with the design certification.

The 10CFR Part 52 regulations do not provide spacific guidelines as to the forrn and content of these inspections, tests, analyses and ,

acceptance criteria (ITAAC).

O This memorandum describes the criteria used by CE to prepare its pilot ITAAC for the ABVR as well as the detailed guidelines for selecting technical entries for the ITAAC. CE anticipates that ITAAC submittals for ABVR will eventually include over 100 sections containing detailed technical information for ABWR systems and constructions processes, l

l l This memorandum is divided into several sections. Section 2 is a brief overview of the basic criteria which will guide the GE ITAAC preparation effort. Section 3 contains an overall description of the Part 52 process. The bases for this description are provided in terms of references to regulations SECY documents, Staff Requirements Memoranda (SRM), and other sources. Section 4 describes the detailed guidelines which CE will use; Subsections 4.3 and 4.4 are most significant as they address the bases for selecting technical material l to be included in AAC.

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- Appendices provide additions 1 supporting information, Appendix B l summarizes the mechanisms by which changes can be made ta a certified '

design by either NRC, the design certification sponsor (vendor), the ,

COL holder, or the public. Appendix D describes the applicability of the QA requirements of 10CTR I' art 50 to plants licensed under Part. 22:

The appendix includes a discussion of the NRC inspection and enforcement authority that exists under the Port 50 process.

The GE ITAAC criteria presented in this memorandum build on and are compatible with the nuclear induar y view of the subject as developed i by the NUMARC Standardization Oversight Working Group. The NUMARC report 9015, " Report of the Task Force on Inspections, Tests, Analyses and Acceptance criteria," December 1990, and has been a key source document for this memorandum.

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SUMMARY

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The following is a summary of the basic criteria used by CE to prepare ,

ITAAC.

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l 1. The necessary first action is to define the top level technical information that will be extracted from the Standard Safety Analysis Report (SSAR) and be included in Tier 1 of the design certification rule. Tint 1 is intended to encompass only top level design criteria and de ign features (see Table 1). The remainder ,

of the SSAR is designated as Tier 2 material and will be subject to the disciplined change control procest.as outlined in Appendix B of this memorandua. As an example, Appendix C includes a proposed Tier 1 design description entry for the ABVR standby liquid control system (SLCS) material.

2. ITAAC are also in Tier 1 and will be derived directly from Step 1 but not necessarily on a one for one basis. ITAAC will be aimed at confirming the as built facility complies with the Tier 1 certified design. As an example, Appendix C includes a proposed ITAAC for i the SLCS.

3. Verification of all design commitments in the SSAR will be accomplished in accordance with 10CFR Part 50, processes, such as Appendi'x B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.' Thus, construction verification of a plant licensed under Part 52 is achieved by a combination of ITAAC and the Part 50 processes.

t l An understanding of this point is important because it means the ~

NRC staff does not have to rely solely on the ITAAC process to Mnsure the as built plant complies with the SSAR design commitments. In addition to the authority provided by ITAAC, the NRC inspection and enforcement staff have further authority under O

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, , Part 50 by which to ensure ths SEAR design commitments are met.  !

+ These Part 50 -inspection and enforcersent powers are summarized in  !

Appendix D.

4. The Tier 1 design description is a top level description of the plant's principal design criteria and design features with the bulk  ;

of the SSAR design commitments contained in Tier 2.

5. ITAAC scope applies exclusively to the Tier 1 design description.

C. 10CFR Part 50 processes, will play a.very significant role in construction verification of a plant licensed under Part 52. ITAAC plus the Part 50 processes give the NRC staff comprehensive verification and oversight of plant construction activities.

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3.0 DESCRIPTION

OF 10CFR PART $2 Preparation of ITAAC and other design certification related material must be based on an understanding of the intent of 10CFR Part 52.

Figure 1 is a schematic representation of design.related and verification related information associated with design and construction of a nuclear power plant; it summarizes the Part 52 elements and their interrelationships. Table 1 summarizes these elements and relationships and identifies applicable references to the regulations, various SECY reports and Staff Review Memoranda. Table 2 explains why Tier 1 is intended to cover only top. level information. A central factor af the 10CFR Part 52 process is the important role that i 10CFR Part $0 design control and verification activities will continue to play. These Part 50 activities derive from various sources, including the Appendix B Quality Assurance criteria that are described in the SSAR quality assurance plan (QAP).

In stumnary, the key points from Figure 1 and Tables 1 and 2 are:

1. The certified design defined in the Tier i description contains top level design criteria and design features. Tier 1 material ,

can only be changed by means of rulemaking or an exemption.

2. The SSAR is designated as Tier.2 material. Similar to Tier 1.

Tier 2 may be changed by an applicant for a combined' operating license (COL) or by a COL holder only by means of rulemaking or an exemption. In addition to these mechanisms, the COL holder may also make changes from Tier 2 by using a 50.59 type process as permitted in 10CFR 52.63(b)(2),

j 3. The tiered approach to Part 52 implementation provides a means of l assuring that'the Part 52 process could be implemented in a practical manner fully consistent with its purpose. Over the lifetime of a nuclear facility, technology advances and equ!pment improvements and changes in the commercial structur of the G

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, , equipaent supply industry will occur. Additionally, at the design

- certification stage, it is neither possible nor practical to specify as procured /as built data. If every aspect of the SSAR design were to be included in the certified design description (Tier 1), the administrative burden on both the industry and the regulatory agencies in dealing with the numerous rule amendments and exe'rptions that would be necessary would make project implementation impractical. Furthermore, such an approach is not necessary to ensure the safety of plants licensed under Part 52 or to obtain the benefits of standardization. It was important to

. build into the system an allowance for a controlled change b process, a degree of practical, yet disciplined, flexibility by l

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the COL holder. The two tier approach was adopted by the Commission to facilitate that degree of controlled flexibility to  ;

the Part $2 process. This flexibility would facilitate dealing .

with construction variances, improvements in technology, obsolescence, changing vendor supply organizations and lescons learned from operating experience. Appendix B summarizes the '

change provisions associated with Part 52. .

O 4. ITAAC are Tier 1 and correlate with the Tier 1 design description in that ITAAC are aimed at verification that the as built facility complies with the top level Tier 1 certified design.

5. Under 10CFR Part 52, the existing Part 50 process, such as the l

quality assurance plan, will be used to verify all SSAR design commitmentr., including those addressed by ITAAC.

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6. Validation Attributes are Tier 2 entries but are aimed at supporting demonstration of plant compliance with the Tier 1 ITAAC in those specific instances where the acceptance criteria cannot be directly verified. Section 4.6 provides a more detailed l discussion of this subject.

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DESIGN CERTIFICATION i

TIER 1 DESIGN 4 > IThACs DESCRIPTION (RULE) l \ l\ i VALIDATION _ 5 1 ATTRIBUTES t TIER 2 t SSAR (RULE) i i

DESIGN PER  !

OTHER DETAILS PART 50 P

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, , TABLE 1. DESCRIPTION OF PART 52 PROCESS PROCESS REFERENCES The certification process is Endorsed by the Commission in SRM dated two tiered. Feb. 15, 1991. The certified design is the design described in Tier 1. The SSAR (Tier 2) c;ntains the supporting technical h tails.

Tier 1 is reserved for top level PART 52 statements of consideration:

design criteria, design features ...less detail in a certification than (i.e., a limited subset of the an application for certification SSAR with the amount of detail (SSAR)...."

proportional to the safety See also SECY 90 241, 90 377 and significance of the system, SECY 91 178.

component or structure).

PART 52 does not require the certified design (Tier 1) to include all information relied upon by Staff to reach a safety finding. (This would make Tier 2 meaningless and would be inconsistent with the tiered approach.)

ITAAC is Tier 1 material. Explicitly specified in Part 52 (10CFR 52.79(c)).

ITAAC are designed to verify Explicitly specified in Part 52 conformance with the Tier i design "...a plant which references the design description, not the SSAR. is built and will operate in accordance with the design certification." (10CFR 52.47(a)(vi))

Verification of Tier 2 design Part 52 only requires ITAAC to verify content is accomplished by the Tier 1 design. 10CFR 52.47 requires an Part 50 processes, such as the QAP SSAR; 10CFR 50.34 requires the SSAR to (i.e., not by ITAAC), include a QAP per Appendix B. ABWR CSAR commits to a QAP. 10CFR 52.83 makes Part 50 applicable to holders of a COL.

l Validation attributes (VA) reside Validation attributes are not required in Tier 2 but support but are not precluded by Part 52. The demonstration of Tier 1 acceptance concept is an industry proposal for criteria (i.e., do not verify the ITAAC support in cases where direct Tier 2 design), acceptance criteria measurement is not possible, Part 52 does not require either VA or-ITAAC to show plant compliance with the l

Tier 2 design. (Covered by the Part 50 processes'such as the QAP.)

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. TABLE 2. REFERENCES STATING THAT TIER 1 IS RESERVED FOR TOP LIVEL INFORMATION O SOURCE TIER 1 GUIDANCE PART 52 STATEMENTS OF There will be less detail in a certification CONSIDERATION: than an application for certification, and a rule certifying a design is likely to encompass roughly the same design features that 50.59 prohibits changing without prior NRC approval.

SECY 90 241, DESIGN Tier 1 include only top level design criteris CERTIFICATION: and performance standards similar to those presented in Chapter 1.2 of an FSAR.

SECY-90 377: Tier 1 will inclu@ information developed during the conceptual phase, such as design criteria and bases and certain information developed during the preliminary and detailed design phases, such as the following:

o System and key component descriptions o Functional and performance requirements for

, , plant systems l o Simplified electrical single-line diagrams i

o Simplified piping and instrumentation l drawings (P& ids) o General arrangement drawings o Inspections, tests, analyses, and acceptance criteria (ITAAC) l SECY 91 178, TIER 1 Tier 1 will be general in nature and will VERIFICATION REQUIREMENTS: address the design at a system functional performance level of detail. Numeric acceptance criteria values will only be

, specified when failure to meet the stated l acceptance criteria would clearly indicate l a failure to properly implement the design.

The Tier 1 verification requirements will be at a level of detail corresponding to that of the Tier i design. . The staff does not believe that it will be necessary for l every design element specified in the:

certified design to have a corresponding Tier 1 ITAAC.

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4.0 CRITERIA USED FOR PREPARATION OF CE ITAAC SUBMITTAh This section provides a detailed discussion of the critatia used in the preparation of Tier 1 design description and ITAAC mater.ial for the AWR.

4.1 Documentation StruenIf, An important front end decision in developing both the Tinr 1 design description and ITAAC entries is the documentation structure to be used. GE believes there are two options:

1. The safety analysis report (USAR)/ safety evaluation report (SER) chapter and subchapter structure that forms the basis of the licensing documentation and NRC review of the design certification-application.

2. The system by system product structura used by most project  !

participants for commercial and technical activities other than licensing.

i After a review of the relative merits of these two candidates, GE has concluded that the second option is superior. The following summarizes the bases for this conclusion. ,

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1. Many existing verification activities naturally fall into a system approach. Examples are pre operational tests and hydrontctic pressure tests. - Use of system based ITAACs is thus a better mesh with many of the axisting verification-prt.ctices.

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2. Most technical documentation produced by the engineering l organizations associated with design, construction _ testing'and operation of nuclear power plants is system based. A-system approach to ITAAC preparation is thus a better match with the O

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, , engineering practices of the preparing and implementing organizations; it is believed this will result in technically l

[} superior ITAAC definition and greatly facilitated implementation.

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3. Use of the SSAR structure for Tier 1 purposes would have drawbacks.

The extensive use of numbered paragraphs would limit flexibility of

• ITAAC preparation. Furthermore, any particular system has multiple entries in various chapters of the SSAR. For example, a typical mechanical system has entries in Chapter 3, Chaptar 7, Chapter 9, Chapter 14, and others. This fragmentation would not be a good i

match with field practices.

4. The NRC example ITAAC presented in SECY 91 178 uses a systems approach and thus indicates NRC acceptance of this concept.

5. If ..m essary, a cross reference between the SSAR sections and the systems structure could be prepared.

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. 4.2 Scone of Tier 1 Material A second important front end decision conce.'.is the scope of the ITAAC ,

submittal. The term ' scope of Tier 1 material" is a definition of the plant hardware and features that are to be identified in Tier 1. CE f a proceeding on the assumpt!.on that all of the systems addressed in the design certification application (i.e., the ABk'R SSAR) will have at least a Tier 1 design description entry and, in most cases, an associated ITAAC. The ABk'R SSAR contains information on essentially all of the plant systems except those that must be designed for site specific conditions. Consequently, the proposed CE approach to Tier 1 scope is all. inclusive rather than (as has been suggested by some) limited to a smaller set of systems with clearly defined safety requirements.

Appendix A lists the ABk'R systems expected to be encompassed by ITAAC submittals. This list includes approximately 140 ABVR systems; the treatment of any particular system in the Tier i design description and associated ITAAC will be graded to reflect the significance of the system to plant safety. As a result of this graded approach, there will be a significant system to system variation in th) amount of Tier 1 design description and ITAAC material. A system not directly related-to plant safety (e.g., the turbine circulating water system) will receive considerably less attention than a system whfch plays an active, central role in plant safety (e g. , a core cooling system). As development of ITAAC proceeds, some of the ABk'R structures and systems may be combined .tco one set of Tier 1 design descriptions and ITAAC.

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, , 4.3 Tier 1 Desir.n Description The intent of ITAAC is to verify the as built facility complies with the certified design defined in the Tier 1 design description.

Consequently, the necessary first step in ITAAC preparation is to put in place the Tier 1 design description. This description is a top level summary of each of the systems covered in the design ce tification application and includes principal design bases and principal c'esign festures.

It is recognized that the NRC is ultimately responsible for defining the design description which will appear in the certification Rule.

However, beccuse the ITAAC derive directly from the design description, prep 1 ration of proposed ITAAC material ne.essarily involves development of proposed design description contents.

Selecting specific technical material to be assigned Tier 1 status is based on engineering judgment and can ot.ly be undertaken by knowledgeable engineers. The seleccion procers will draw on:

1 The engineer's knowledge of the system and understanding of which features are of particular importance to safety. >

Design features and operating characteristics identifisd as being I

of particular significance in such documents as the plant SSAR, the l relevant standard review plan (SRP), the staff's safety evaluation report (SER), plant Technical Specifications, and others, i

l As a rough model. CE anticipates-that Tier 1 design description entries .

for a system having some safety significance would be in the order of l

one to three pages of singic spaced text. The SLCS example shown in

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l Appendix C is representative. Using the graded approach, systems with little or no safety significance might have Tier 1 design description entries of no more than a few: lines.

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- The following is a summary of the guidelines to be used by GE to prepare entries in the Tier i design description. (Cuidelines for O preparing the associated ITAAC material are discussed in Section 4.4.)

1. Tier 1 design descriptions include principal design and principal design features.

The Tier i description will consist of a subset of the body of technical information in the SSAR. This selection process reflects implementation of the tiered approach to design certification (see Tables 1 and 2). The selection orocess is based on entineerint judrment. Knowledgeable engineers must identify the set of top level criteria and design features that will be included in the design certification Rule as Tier 1. entries. Not everything in the SSAR is of eg a l (high) importance, nor need to be included in Tier

1. An all inclusive approach would make the tiered concept meaningless. Exclusion of a particular technical issue from Tier 1 does not maan that either:

O a) The SSAR commitment will be exposed to future undisciplined changes that are beyond NRC control (see Appendix B for a discussion of change control under Part 52). or b) The technical issue will not be subject to a thorough construction verification process because it is not identified as an ITAAC entry. (See Section 3.0'for further discussion of how 100FR Part 50 vill achieve verification of design comrnitments not addressed by ITAAC.)

2. The level of Tier i detail for any-system will be graded to reflect system importance and safety significance.. As discussed elsewhere.

this will result in system to system variations in the amount of Tier 1 material.

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3. The Tier i design description contains numerical information to the extent needed to identify thm principal design criteria and design features. This approach is compatible with the concept that Tier 1 is limited to top level information.

4. To the extent practical Tier 1 will be self contained and will avoid references to Tier 2 documents. This approach is necessary because referencing Tier 2 documents in Tier 1 would elevate the Tier 2 documents to Tier 1 status. This is undesirable because it would impose on the referenced Tier 2 document all of the more rigorous Tier 1 controls identified in Appendix B and thus be incompatibt.e with the intent of the tiered approach.

5. The design description should consider various disciplines associated with a particular system design, including mechanical, electrical, C&I, and civil design considerations.

6. Design descriptions may include simplified P& ids. one line electrical diagrams and structural layouts which contain the deeign features addrested in the associated Tier 1 text.

7. All Tier 1 raterial must be nonpropris tary. .If use of. data that is currently proprietary becomes unavoidable, the preferred approach will be to declassify the material to nonproprietary status,

'8. Neither the Tier 1 design descriptions nor the ITAAC include any information on plant operating conditions, These are covered separately by Technical Specifications, This is compatible with the intent of part 52 that the ITAAC process be successfully completed prior to fuel load. Consequently, plant verification activities which must be conducted after fuel load (e.g., hot testing requiring nuclear heat)- cannot, by definition, be part of the ITAAC-scope.

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. t 4.4 ITAAC Contentt O The following guidelines will be used by CE to develop ITAAC for the systems covered by the Tier 1 design description.

1. The ITAACs will be derived from the certified design description ,

content and will generally correspond to the elements in the Tier 1 design description. However, there will not necessarily be a one for one relationship between the Tier i design description and the ITAAC; e.g., each design description entry will rot necessarily ,

have a corresponding ITAAC entry.

2. The ITAACs are aimed at confirming the as built facility complies with the Tier i design contained in the design description.

3. ITAACs will be prepared in tabular form that links an ITAAC to commitments made in the Tier 1 dest6 n description.

4 It is acceptable to apecify ranges and/or tolerances for numerical values included in the ITAAC. The objectife of specifying tolerances is to recognize: a) legitimate site variances that can l occur in complex construction projects such as a nuclear power plant, and b) values of input parameters can often vary without affecting safety

5. Consistent with the provisions of Part 52, the ITAAC process ends

• prior to fuel load. This means, among other things, that post fuel load testing can not be included in the ITAAC entries.

6. Tier 2 validation attributes can be used to support the Tier 1 ITAAC material. Validation attributes are directly measurable facility characteristics that can be used in analyses and studies to confirm plant compliance with acceptance criteria that cannot be

'directly measured. A typical example of validation attributes O

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.. . would be containment as built dimensional information used in analyses to confirm that the acceptance criteria for containment LOCA performance are satisfied. (For a more detailed discussion of  !

(} the validation attribute concept, see Section 4.6.)  !

7. The verification activities defined in ITAAC will utilize existing nuct s.sr power plant verification programs. ITAAC will not lead to a definition of new tests and inspections (unless necessary) that have not been used in past practices.

8. The programmatic aspects of the design and construction process (operator training, qualification of welders, etc.) are part of the licensee's program's and are commitments reade at the time of COL issuance; they are not part of ITAAC.

An important point is that the ITAAC selection process requires technical judgments similar to those used to select Tier 1 design description entries. Only the most important characteristics will be included in the ITAAC as part of Tier 1. Incorporation of a wide range of technically detailed material into the plant ITAAC would be

(} incompatible with the tiered approach which reserves Tier 1 for top-level information. Plant characteristics and features HQI selected for ITAAC treatment WILL BE VALIDATED by the 10CFR Part 50 processes that' include the Appendix B requirements. Stated differently,.it is acceptable to not include certain verification activities in ITAACs because they will be covered by the Part 50 processes.

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, 4.5 Use of Generic /Discioline ITAAC The intent of the proposed generic / discipline ITAAC concept is to group into a single ITAAC those construction activities which span more than one system. Examples of technical subjects that could potentially be 3 covered by this approach are seismic integrity, environmental qualification, etc. The use of this type of ITAAC is permitted by 10CTR Part 52 but is not required. Consequently, generic / discipline ITAACs will be used on an as.needed basis if such use would simplify the overall task of defining ITAACs for a project.

At the conceptual level, it would appear likely that a single generic / discipline ITAAC would be a better approach than addressing the same type of issue in multiple, individual system ITAACs. Ilowever, as a result of preliminary work on preparing sample generic ITAACs, it has become obvious that this approach has some potential drawbacks that might limit the extent to which they can realistically be used for the ,

Tier 1 ITAAC entries. The following nummarizes the potential drawbacks that have been identified.

O 1. Given the intended scope of the Tier 1 material, only a limited subset of the construction related disciplines can be addressed by the Tier 1 design descriptions and ITAACs. This subset of construction disciplines would address the processes that c.te of -

particular significance to one or more of the systems; any treatment of design details or the details of construction processes beyond thh would rapidly escalate the generic ITAAC scope into the comprehensive Part 50 construction verift:ation procedures. This is not consistent with the scope _of the Tier 1-design certification material.

l 2. The level of design detail associated sith the design certification application (SSAR)'does not support development at-thir time of numerical acceptance criteria-for construction related processes.

The SSAR contains the full complement of commitments to the

! -regulatory requirsments and industrial standards governing these O

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, . processes but provides little or no datails of compliance criteria;

- i.e., does not contain design drawings or specifications that would be necessary to develop generic / discipline ITAAC with extensive numerical entries. Furthermore, inany of the codes and standards referenced in the SSAR define methodology rather than numerical standards. This situation is not viewed as a deficiency in the certification application but rather is a direct consequence of the basic relationships between Parts 50 and 52. Nonetheless, the result is that detailed verification procedures and acceptance criteria for most plant construction processes will be developed later by the actual plant combined license applicant. This results in there being little need or opportunity for the use of generic ITAAC as part of the design certification process.

3. As mentioned above, generic / discipline ITAAC would usually have to be based upon design drawings and specifications cnd other information that is not contained in the SSAR or in the Tier 1 design description. Even if these documents were available for referencing, inclusion of generic / discipline aspects within the Tier 1 ITAAC would have the effect of elevating relatively less significant design information from these documents to Tier 1 status. Such a result would be inconsistent with the intent of Pcrt I and the two tiered concept for design certification.

4 By their very nature, generic / discipline design requirements and specifications tend to be of lesser importance than system based requirements, and it is often possible to accept as is some of the nonconformances with generic / discipline requirements contained in k aa.t drawings and specifications.- For example, nonconformances tv M ing support dimensions, rebar spacing, and weld length often are not significant to the safety function of the strue.ture or system in question, and such nonconformances usually may be accepted without rework or repair. However, if such ge.neric/

discipline requirements were to be embodied in ITAAC, the licensee t -

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, , would be forced either to rework or to repair the nonconformance or obtain an exemption from and/or amendment to the ITAAC. Such a result is unnecessary from a safety standpoint and would impose additional costs and administrative burdens.

As a result of these obsurvations, the current GE approach is to prepare a very limited set of generic / discipline ITAAC and to cover critically important construction related issues in the individual system ITAAC for which the issue is important. CE is still considering whether selected generic / discipline ITAAC for issues such as EQ, ,

seismic design, etc. , might be appropriate and feasible (see discussion below). All other generic / discipline issues are deferred to the time when the part 50 verification procedures are defined for a particular license application. ,

As an example of the expected scope and content of generic ITAAC, Appendix C contains a proposed ITAAC covering environmental qualification (EQ) of safety equipment. This EQ ITAAC example embodies programmatic approach to confirmation that plant equipment has been properly qualified. It would not be appropriate for the ITAAC to include a quantification of environmental conditions, test procedures, and acceptance criteria. There are well in excess of 1000 equipment items in the plant requiring qualification. This equipment is located throughout the facility and is subject to a wide range of pressure, temperature,; radiation and dynamic loading conditions. Furthermore, details of the material used in

, constructing the equipment and the criteria for successful qualification are equipment / vendor specific and thus unknown at the time of.

certification. Inclusion of such a massive compilation of technical information in the ITAAC (even if it were all available) would be clearly inconsistent with the Tier 1 concept. Consequently, GE proposes to limit the scope of this generic ITAAC as shown-in Appendix C and to rely on this ITAAC'in combination with the much broader plant-specific, l equipment specific Part 50 verification procedures for assurance that equipment will meet the detailed EQ requirements. To the extent that ,

other generic ITAAC may be desirable, CE would propose to utilize an approach that is similar to the EQ ITAAC contained in Appendix C.

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, , Selecting technical subjects to be covered by generic ITAACs is based

- on engineering judgment. Construction related activities will be at '

least considered as candidates for generic ITAAC treatment if they meet the following criteria:

1. The ITAAC would have multi system applir,ation.

2. The activity in question is n21 a wel2. established, widely understood and relatively routine countruction activity (for example, rebar placement and welding).

3. Criteria governing the activity a';e t;rpically contained in safety analysis reports.

4. Nonconformance with the criterfa are likely to result in a condition that could affect aGversely the safety of operations.

The underlying rationale for Item 2 is that th;s type of routine activity is best handled by the Part 50 processes. Ceneric ITAAC would be reserved for less routine technieni matters that do not have implementing processes clearly specified in either regulatory requirements or the applicable industrial codes and standards.

Activities in this category are more susceptible to differing interpretations and may thus merit generic ITAAC treatment. Since most nuclear power plant construction activities are " routine," it is anticipated that application of these criteria will result in a small

set of generic ITAAC.

l Using these criteria, the following are examples of issues which would and would not be considered for generic ITAAC.

Considered-Environmental qualification (including seismic)

Software development and verification '

Instrument setpoint methodology EgLConsidered Welding i Concrete properties l

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s

, , 4.6 Use of Validation Attributta -

7alidation attributes (VA) are Tier 2 entries but are directly related

( to the Tier 1 ITAAC -. as illustrated in Figure 1. As a result of this Tier 2 designation, validation attributes are not part of the certified design itself.

The validatiott attribute is a concept developed by industry to cover those instances where an ITAAC cannot be verified through direct measurement. Validation attributes reside in Tier 2 and are an approved means of supporting the demonstrction of conformance with the first tier acceptance criteria. Validation attributes are readily acasurable, or otherwise verifiable. As such, validation attributes provide a technically sound and practical link between construction and design in those situations where, because of the nature of certain i acceptance criteria, direct verification by field test or inspection is not practical. Examples of validation attributes are:

a) The inputs to the analyses that confirm the as built containment structure complies with the certified design in terms of its

(} response to a postulated loss of.coclant accident, b) Inputs to the analyses which determine that the heat removal capacity of a heat exchanger is in-compliance with the required capacity as stated in the certified design, ,

The COL holder may make changes to validation attributes only if the l changes are consistent with a change-control process similar to that-utilized in the 10CFR 50.59 process. i At this time it is not anticipated that validation attributes will be a major feature of the design certification documentation. Their use will be limited to those cases where analyses will be necessary to demonstrate compliance with acceptance criteria that-cannot be directly measured.

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, 4.7 Desir_n Acceptance Criteria ITAAC ,

() Design certification <eplications (i.e., the SSAR) do not contain detailed information on equipment items when these details are dependent upon site specific, as procured and as. built information.

This is consistent with Sub part B of 10CFR Part $2, which provides that an application for desi6 n certification need not include such design information. Furthermore, the Staff Requirements Memorandum (SRM) dated February 15, 1991, on SECY 91 377, " Requirements for Design Certification Under 10CFR Part $2,* states that information required in a certification application is not expected to include " site-specific, as procured, and as. built information." In lieu of providing these details, the certification application must include a comprehensive definition of the requirements which the final plant specific hardware +

must meet. The scope and nature of these SSAR equipment requirements vary, depending upon the equipment item being addressed. Furthermore, the SSAR does not normally describe the details of the design nrocess.

by which the design input requirements for an equipment item will be translated into actual hardware designs.

O The NRC staff has recently indicated that in a limited number of instances, they do not believe this approach provides sufficient information upon which they can base a safety finding, This staff position stems from several factors not the least of which are earlier regulatory experiences involving multiple design organizations working from supposedly identical design requirements. The (undesirable) result was widely varying interpretations of the requirements and development of very different hardware configurations, some of which did not comply with the staf f's understanding of the requirements.

Stated differently, the staff is concerned that certification of only the design requirements can and/or will lead to videly varying project to project equipment designs, some of which may not be acceptable. Industry and the-staff have agreed that this issue can be addressed by the so called design acceptance criteria (DAC) ITAAC concept. This approach involves the-following steps: ,

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- 1. Confirming that for the equipment in question the SSAR contains the necessary functional requirements as well as the full spectrum of O- applicable regulatory requirements and industrial standards.

Selected parts of this information may be assigned Tier 1 status.

2. Including in the SSAR a description of the proposed processes (design, manufacturing, tu ting) which will be used to translate the SSAR requirements into fully operational field equipment. This I

description vill retsain in Tier 2.

3. Including in the $ AR as part of Step 2, identification of points in the process which will be used by the staff to assess compliant:e with requirements as the design is oeveloped and implemented.

These assessment steps will utilize predefined and agreed to acceptance criteria.

4. Tier 1 DAC ITAAC will then be added to the list of " conventional"

! construction verification ITAAC. These DAC ITAAC will be used to define and enforce acceptance of the design implementation process.

d Each design review and assessment point will have a DAC ITAAC which includes a summary of:

.a) What should have been accomplished at this point in the-process, b) What inspections, tests or analyses will be undertaken to assess that this comtnitment has been met, and c) The acceptance criteria to be used as a measure of success.

I It is CE's understanding that application of the design acceptance l

criteria ITAAC concept vill be very limited and will only be invoked for the following:

I

1) Aspects of nuclear power plant equipment technology likely to undergo significant (and beneficial) evolution during the lifetime of the certification. Under these circumstances, D

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, , requiring more details in the SSAR could lock in outdated technology and preclude future use of benefict.a. technological ,

advances. In practice, this is primarily of importance to plant control and instrumentation systems and control room design.

2) In cases where the staff has concerns about the final design but where development of more details would involve as built, as procured equipment and is thus not within the scope of 10CFR Part 52 design certification. The primary use of DAC ITAAC will be for areas of plant design which involve complex design processes with the potential for differing interpretations of how to implement the SSAR requirements. Design of safety related piping uses complex dynamic analysis methods and is a representative candidate for DAC treatment under th!s provaion.

At the conceptual level, incorporating DAC ITAAC into the overall design certification ITAAC document would not appear to pose any significant difficulties. The scope of the DAC ITAAC should be made compatible with the top level nature of Tier 1 material.

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, 4.8 Eggiideration of Non Traditional Items in Develemment cf ITAAC i

In ita Staff Requirements Memorandur; (SRM) of Sepenber 24, 1991, on SECY+91 176, the Commission requested the NRC staff to provide the-Commission with informat)on on "how non-traditional items such as PRA insights, severe accident issues, and instrumentation and controls 1

that incorporate new technology 4 will be considered in the development of ITAAC, using fully developed and specific examples."

The purpose of this Section is to describe GE's understanding of how such items will h considered in the development of ITAAC.

r As discussed in'SECY-91-178, p. 3, ITAAC are Tier 1 verification requirements that "will be at a level of detail corresponding to the Tier 1 design information of the certified design rule." As.a result, the ITAAC "will specify the Ocportant design elements that are to be verified through inspections, tests, or analyses" and "will'be> general in nature and vill address the design at a system functional performance level of detail."

ITAAC correspond to, r.' am te compliance with, the' Tier i design, ITAAC will not discus im chat is- considered in deve: loping the design (unless it is part of the Tier-1 design or-is necessary to show-compliance with the Tier 1 design). As a' result, items such as PRA insights and severe accident-issues which actLas input -for design . i

! development will not be directly addressed. in ITAAC. However, because-these non-traditional' items _ affect the " system functional-. performance" -

and the Tier 1 design,'the.ITAAC will indirectly address these items.

Similarly, the Tier 1 design and associated ITAAC will address'the system functional performance:of instrumentation and controls, which will enable a. licensee to utilize new technology.as long as:the new -

technology complies with the Tier 1; design and-ITAAC, These concepts are.illustreted below.

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s 4 a s a) PRA Insights In general, the results of a PRA vill show that either 1) particular events contribute substantially to the risk posed by the >

i plant design and that additional design features are warranted to mitigate the risks; or 2) the existing features of the design are such that ;ne overall risk is acceptable and that additional design featut?* are not warranted. In the first case, it is expected that the mitigative features added to the design as a result of the PRA will be part of the Tier 1 design at a system functional performance level. As a result, there will be ITAAC corresponding to these features that will demonstrate the capability of the features to perform their mitigative functions. In the second '

case, it is expected that the existing features of the plant that are important factors in achieving an acceptable level of risk will be part of ' Tier 1 design. As a result, there will be ITAAC corresponding to these features that will demonstrate the capability of the features to perform their safety functions.

O d F xample, the PRA for the Advanced Boiling Water Reactor (ABWR),

an acceptable core damage frequency _(i.e., on the order of 10 One of the most important factors. contributing to this low le.,quency is t.e fact that the Emergency Core Cooling System-(ECCS) for the ABVR consists of three separate divisions. It is expected that the Tier i design for the AbWR will-describe the principal design features of these three divisions and their functional performance requirements, and that the ITAAC wil1~ verify these.

features and their capability to satisfy the performance requirements. Simi.larly, it.is expected that other features of the c l ABWR that are important factors contributing to the acceptable core l damage frequency will be treated-in a like manner.

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s As another example, the FRA for the ABWR shows that the conditional containment failure prol, ability (CCFP) satisfles the goal of 0.1, due in part to the three 6 vision Residual Heat Removal (RHR)

System. It is expected that the Tiur 1 design for the ABWR will describe the principt? design feat'res of these three divisions and their functional performance requirements, and that the ITAAC will verify these features and their capability to satisfy the performance requiremencs. Similarly, it is expected that other featuren of the ABWR that are important factors contributing to the acceptable CCFP will be treated in a like manner.

b) Severe Accidant Issues As discursed in SECY-90-016, and as approved by the Commission in its Staff Requirements Memorandum dated June 26, 1990, the Staff will be requiring advanced light water reactors (ALURs) to include certain features to mitigate severe accidents. These features include control of hydrogen generation, ability to cool core debris, control of high pressure core melt ejection, and containment performance-during a severe accident. It is expected that these features will be part of the Tier 1 design, As a re n,ul t , there will be ITAAC corresponding to:these features that

, will demonstrate their functional capability in the event of a severe accident.

For example, the design of the ABWR includes provisions for an inerted containment and hydrogen recombiners for hydrogen control, temperature sensitive fusible plugs that will allow suppression pool water to enter the drywell cavity to cool core debris, a safety grade depressurization system to red 2ce the risks of high-pressure core melt ejection, and a wetwell containment vent to

-protect against containment overpressure. It is expected that the:

. Tier 1 design for the ABWR will describe the principal design features of these measures and their functional performance O

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, , requirements, and that the ITAAC will verify these features and their capability to satisfy the performance requirements.

O Similarly, it is expected that other features of the ABWR that are important for mitigating severe accidents, such as instrumentation for monitoring accident conditions, will be treated in a like manner.

c) Instrumentation and Controls (IC) that Incorporate New Technology As discussed in the staff's meeting with the Commission on October 17,1991, I6C technology is rapidly advancing. Items that are state-of-the-art today may be obsolete several years from now. It is not necessary or desirable at this time to specify the identity of the instruments and controls to be used in the ALWRs. Instead, it is preferable to allow the ALWRs to take advantage of advances in technology. In order to permit such flexibility while enabling the staff to make its final safety determination, it is expected that the Tier 1 design for the ABWRs will describe I&C functional performance requirements and that compliance with these

(""i requirements will be verified through design acceptance criteria (DAC). The concept of DAC ITAAC is discussed in Section 4.7.

Under the DAC concept, it is expected that the Tier 1 design will

1) identify the types of I&C that will be necessary (e.g. , identify the types of information that must be available to operators and the types of automatic and manual controls that must exist), and 2) identify the functional performanca requirements for these I6C, It is expected that the corresponding ITAAC will consist of objective measures to confirm that the 160 in-the Tier 1 design have been installed and are capable cf satisfyiug their functional performance requirements.

The process of verifying compliance with the ITAAC acceptance criteria for I&C may consist of several steps, with provisions ~ for NRC Staff-acceptance of each step. For example, there may be separate steps for b

v 11-18:AJJ8-33

, . verification that the Tier 1 design requirements have been properly reflected in the design documents, that the hardware has been installed in accordance with the Tier 1 design requirements, and that the installed hardware is capable of satisfying the Tier 1 functional performance requirements. Thus, there will be several steps associated with the DAC, each of which will be governed by objective acceptance criteria associated with the Tier 1 design requirements.

Conclusion Non traditional items, such as PRA insights, severe accident issues, and I&C that incorporate'new technology, are considered in the development of the important design elements for ABWR. These elements, and their functional performance requirements, will be included.in the Tier 1 design for the ABWR. ITAAC will be developed to verify satisfactory implementation of these requirements. Therefore, the ITAAC will indirectly address each of the non traditional items mentioned by the Commission.

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, . 4.9 Plant Specific Imolementation of ITAAC and Part 50 For facilitias licensed under Part $2, construction verification will be

(} achieved by complementary implementation of ITAAC and the Part 50 processes. It is envisioned that the COL applicant and NRC will agree upon a plan for sequenced implementation, review and acceptance of ITAAC and Part 50 ve-ification activities. The aim of the plan will be to achieve NRC sign off of both the ITAAC and Part 50 verification activities on a sequential basis starting early in the construction cycle.

Elaboration of the details (schedule, timing, etc.) of COL implementation of ITAAC and Part 50 verification activities is not within the scope of this memorandum. However, the following overall general comments regarding implementation may contribute to an understanding of how the '

ITAAC and the Part 50 verification activities would each be icplemented.

Part 50 Verifiention Activities The COL applicant would plan with the NRC to conduct inspections anl to issue a formal letter of acceptance of the Part 50 verification activities for each phase of. construction. This plan would consist of

() the following key steps: 1) a schedule of activities; 2) contemporaneous NRC inspections of the activities; 3) NRC identification of any concerns, licensee corrective actions, and follow up NRC inspections; and 4) NRC letter of acceptance.

ITAAC Activities The COL applicant-would plan with the NRC to conduct inspections and to issue a Federal Register notice of successful completion of ITAAC activities for each phase of construction. This plan would consist of the following key steps: 1) a schedule of activities;f2) contemporaneous NRC inspections of the activities; 3) NRC identification of any concerns, licenses corrective' actions, and follow-up NRC inspections; and 4)lNRC Federal Register' notice of successful completion of the ITAAC.

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- The periodic NRC letter of acceptance of the Part 50 verification activities would not supplant or necessarily result in iusuance of the periodic Federal Register notices of successful completion of ITAAC activities. Convercely, the failure to issue a letter of acceptance of a Part 50 activity would not necessarily preclude the h7C from finding that the ITAAC had been successfully completed. A deficiency related to a Part 50 verification activity would be material to satisfaction of an ITAAC only to the extent that the deficiency precludes a determination of I reasonable assurance that the acceptance criteria in the 1TAAC have been satisfied. However, regardless of their relationship to ITAAC, any deficiencies in Part 50 verification activities would be subject to the full range of NRC enforcement actions under Part 50 and Appendix C to Part 2, including if warranted an order stopping construction work. (See Appendix D for further discussion.)

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s-APPENDIX A ABWR SYSTEMS TO BE INCLUDED IN TIER 1 DESIGN DESCRIPTION AND ITAAC In determining the list of systems to be addressed in Tier 1, the guideline has been to include at least a design description antry for each system identified in the certification SSAR. Each system will not necessarily have a separate ITAAC entry, and some ITAAC modules may encompass more than one system. -

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.. TIER I . DESIGN DESCRIPTION FOR ABWR

1. INTRODUCTION

2. DESIGN DESCRIPTION 2.1 NUCLEAR STEAM SUPPLY 2.1.1 Reactor Pressure Vessel System >

2.1.2- Nuclear Boiler System 2.1,3 Reactor Recirculation System 2.2 CONTROL AND INSTRUMENT 2.2.1 - Rod Control and Info >mation System-2.2.2 Control Rod Drive System 2.2.3 Feedwater Control System 2.2.4 Standby Liquid Control System.

2.2.5 Neutron Monitoring System .

2.2.6 Remote Shutdown System --

2.2.7 Reactor Protection System 2.2.8 Recirculation Flow Control System 2.2.9 Automatic Power Regulator System 2.2.10 Steam Bypass and Pressure Control System 2.2.11 Process Computer 2.2.12 : Refueling Platform Control Computer-

' 2.2.13 CRD Removal Machine Control Cn oputer; 2.3 RADIATION MONITORING 2.3.1 Radiation Monitoring System :

2.3.2 - Area Radia* ' tonitoring System 2.3.3 Dust Radit..ic.. .stonitoring System

?.3.4: Containment Atmospheric Monitoring System ;

=2.4 CORE COOLING -

2.4.1 Residual Heat Removal System 2.4.2 .High Pressuit Core Flooder System .

M 4.3 Leak Detection and Isolation System d 2.4.4 L . Reactor Core Isolation System l' 9/13/91t

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, . TIER 1- DESIGN DESCRIPTION FOR ABWR

- (Continued)

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2.5 REACTOR SERVICING EQUIPStENT 2.5.I Fuel Senice Equipment 2.5.2 Miscellaneous Servicing Equipment 2.5.3 Reactor Pressure Vessel Servicing Equ'pment 2.5.4 RPV Intarnal Senicing Equipment 2.5.5 Refueling Equipment 2.5.6 Fuel Storage Facility ,

2.5.7 Under Vessel Senicing Equipment 2.5.8 CRD Maintenance Facility 2.5.9 Intemal Dump Maintenance Facility 2.5.10 Fuel Cask Cleaning Facility 2.5. I 1 Plant Start-up Test Equipment 2.5.12 Inservice Inspection Equipment 2.6 CEACTOR AUXILIARY 2.6.1 Reactor Water Cleanup System O 2.6.2 Fuel Pool Cooling and Cleanup System-.

2.6.3 Suppression Pool Cleanup System 2.7 CONTROL- PANELS 2.7.1 Main Control Room Panel 2.7.2 Radioactive Waste Control Panel--

2.7.3 Local Control Panels

~2.7.4- Instrument Racks .

2.7.5- Multiplexing System 2.7.6 Local Control Box 2.8L NUCLEAR FUEL' 2.8.1 Nuclear Fuel 2.8.2 Fuel Channel--

2.9: RADIOACTIVE WASTE 2.9.1 - . Radwaste System O.

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, , TIER I - DESIGN DESCRIPTION FOR ABWR

- (Conunued) t r

' 2,10 POWER CYCLE 2.10.1 Turbine Alain Steam Sys:em 2.10.2 Condensate, Feedwater and Condensate Air Extracuon System 2.10.3 Heater Drain and Vent System 2 10.4 Condensate Purification System 2.10.5 Condensate Filter Facility 2.10.6 Condensate Demineralizer 2.10.7 N1ain Turbine 2.10.8 Turbine Control System 2.10.9 Turbine Gland Steam System 2.10.10 Turbine Lubricating Oil System 2.10.11 .\1oisture Separator Heater 2.10.12 Extraction System 2.10.13 Turbine Bypass System 2.10.14 Reactor Feedwater Pump Driver A 2.10.15 Turbine Auxiliary Steam System i 4 V 2.10.16 Generator 2.10.17 Hydrogen Gas Cooling System 2.10.18 Generator Cooling System 2.10.19 Generator Sealing Oil System v.mr4 2.10.20 Exciter

2.10.21 Niain Condenser 2.10.22 Off-Gas System 2.10.23 Circulating Water System 2.11 STATION AUXILIAB*

• 2.11.1 Niakeup Wa'er System (Purified)

I 2.11.2 Niakeup Water System (Condensate)(

2.11.3 Reactor Building cooling Water System l

2.11.4 ' Turbine Building Cooling Water System l 2.11.5 HVAC Notmal Cooling Water System 1

2.11.6 HVAC Emergency Cooling Water System

2. I 1.7 Oxygen Injection System

'- 2.11.8 Ultimate Heat Sink 3 9/13/91

. TIER 1- DESIGN DESCRIPTION FOR ABWR

- (Continued)

O 2.11.9 Reactor Service Water System 2.11.10 Turbine Senice Water System 2.11.11 Station Service Air System 2.11.12 Instrument Air System 2.11.13 High Pressure Nitrogen Gas Supply System 2.11.14 Heating Steam & Condensate Water Return System 2.11.15 House Boiler 2.11.16 Hot Water Heating System 2.11.17 Hydrogen Water Chemistry System 2.11.18 Zine Injection System 2.11.19 Breathing Air System 2.11.20 Breathing Air System 2.11.21 Sampling System 2.11.22 Freeze Protection System 2.11.23 Iron lon injection System 2.12 STATION ELECTRICAL

% 2.12.1 Electncal Power Distribution System 2.12.2 ' nit Auxiliary Transformer 2.12.3 Isolated Phase Bus 2.12.4 Non-Segregated Phase Bus 2.12.5 Metal Clad Switchgear 2.12.6 Power Center 2.12.7 Motor Control Center 2.12.8 Raceway System 2.12.9 Grounding Wire 2.12.10 ElectncalWiring Penetr; tion 2.12.11 Combustion generator.

2.12.12 Dimet Current Power Supply 2.12.13 Emergency Diesel Generator System 2.12.14 Reactor Protection System Alternate Current Power Supply 2.12.15 Vital A.C. Power Supply 2.12.16 Instrument and Control Power Supply I'

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.. ~> TIER I- DESIGN = DESCRIPTION FOR ABWR (Continuedt 2.12.18 Lighting and Service Power Supply 2.13 POWER TR ANS311SSION 2.13.1 Resene Auxiliary Transformer 1

i 2.14 CONTAIN.\ LENT AND ENVIRONNIENTAL CONTROL 2.14.1 Primary Containment System 2.14.2 Containment Internal Structures 2.14.3 Reactor Pressure Vessel Pedestal 2._14.4 Standby Gas Treatment System 2.14.5 PCV Pttssure and Leak Testing Facility 2.14.6 Atmospheric Control System :

2.14.7 Drywell Cooling System 2.14.8 ' Flammability Control System 1 2.14.9 Suppression PoolTemperature Alonitoring System _

2.15 STRUCTURES AND SERVICING 2.15.1 Foundation V' tk 2.15.2 Turbine Pedesal-2.15.3 Crane and Hoist 2.15.4 Elevator l 2.15.5 Heating, Ventilating and Air Conditioning .

2.15.6 Fire Protection System 2.15.7. Floor Leakage Detection System!

2.15,8 Vacuum Sweep System =

2.15.9_- Decontamination System.

2.15.10 - Reactor Building

- 2.15.11 ; Turbine Building

- 2.15.12 ~ Control Building _.

2.15.13 Radwaste Building.

- 2.15.14 Service Building; 12.16 - YARD-STRUCTURES AND EQUIPNIENT - -

2.16.1 Stack 2.16.2 ' Oil Storage atid Transfer Systems : .

~ 5_ ~4/13/9i_

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.. . TIER I- DESIGN DESCRIPTION FOR ABWR

' (Continued) 2.16.3 Site Secunty

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. APPENDIX B r

SUMMARY

OF MECIMNISMS FOR CilANCING

. A DESIGN SUBJECT TO A DESIGN CERTIFICATION ,

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21tshrnisma_IsL Ihrnzinga 21gn_sub_ittLista_Re si gn_Cen111snio_n

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(1) After Design Certification (2) During COL (3) After Issuance ,

and Before COL Application Application Stage of COL NRC Tier 1 Rulemaking - only if necessary Same as Column 1. _ NRC can also make Saec as Column 2. (10 CTR for compliance with NRC f acility-specific changes during COL 52.63(a)(3))

regulations or to provide application review process, but only if 1) adequate protection. (10 CR chariges are necessary for coorpliance with 32.63(a)(1)) NRC regulations or to provide adequate protection; 2) special circumstances exlet under 10 CTR 50.12(a); and 3) special circumstances outweigh reduction in standardization. (10 CIR 52.63 (a)(3))

Tier 2 Same as above. (2/15/91 SRM, Same as above. (2/15/91 SRM, p. 4) Same as above. (2/15/91 SRM p =)

p. 4)

D.C.' Holder; Tier 1 D.C. Holder can su'imit Request COL Applicant has the same rulemaking COL Holder has the same mechanisms as l COL Applicant ; for Rulemaking. Exemption mechanisms as the Public in Column 1. the COL Applicant in Column 2.

COL 11 older under 10 CFR 52.63, or Walver Additionally, COL Applicant can submit under 10 CFR 2.758. (2/15/91 Request for Exemption under 10 CFR SRM, p. 4) [ Note: Although 30.12(a) (special circumstances must the SPJi refets to exemptions outweigh reduction in standardization).

and waivers, there does not This Request could be a subject for appear to be any contexts in hearing. (10 CR 52.63 (b)(1) and which such mechanisms could be 52.93(a)).

utilized)

• Tier 2 Same as above. Same as above. (SECT-90-377. p. 19) Same es above. Additionally, COL Holder can utilize an Evaluation Process similar to 10 CR 50.59. (10 CFR 52.63(b)(2) and 2/15/91 SRM p. 4) i Public Tier 1 Petition for Rulemaking - any Same as Column 1. Additionally, the Petition for Rulemaking satisfying 10 rulemaking amendment must meet Pu;>11e can submit a Request for Waiver CFR 52.63(a)(1) or 2.206 Petition the standards of 10 CFR under 10 CFR 2.758. (10 CFR 52.63(a)(4) satisfying 10 CTR 52.63(a)(3). Also.

52.63(a)(1). and 2/15/91 SRM, p. 3). during hearings on fuel load, a Request for Waiver under 10 Cft 2.758.

Tier 2 Same as above. Same as above. Same as above.

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APPENDIX C O

EXAMPLES OF ITAAC

1. Standby Liquid Control

2. Generic ITAAC for Environmental Qualification i

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O SAMPLE TIER 1 DESIGN DESCRIPTION AND ITAAC ABWR STANDBY LIQUID CONTROL SYSTDiS (SLCS)

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ABWR cosign Document l 2.2.4 Standby Liquid Control System Design The standbv liquid control system (SLCS) is designed to inject neutron absorbmg poison using a boron soludon into the reactor and thus provide back-up reactor shutdown capability mdependent of the normal reacuvity conuol asstem based on interuon of control blades mto the core. The miem is capable of operauon over a wide range of reactor pressure condidons up to and meludmg the elevated pressures associated with an anticipated plant transient coupled with a failure to scram (ANS).

The standby liquid control system (SLCS) is designed to provide the capability of brtnging the reactor. at any ume m a cycle, from full power and mmimum control rod inventory (which is defined to be at the peak of the xenon transient) to a subcnucal condition with the reactor in the most reacave xenon free state without control rod movement.

The SLCS consists of a boron soludon storage tank. two posiuve displacement pumps, two motor operated injecuon valves which are provided in parallet for redundancy and associated piping and valves used to transfer borated water from the storage tank to the reactor pressure vessel iRPV). The borated soluuon is discharged through the 'B' high pressure core flooder (HPCF) subsystem sparger. Figure 2.2.4 shows major svitem components. Kev equipment performance requirements are:

a. Pump flow 50 gpm per pump

b. Maximum reactor pressure 1250 psig (for injecdon)

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! c. Pumpable volume in 6100 L*.S. gal storage tank (minimum) l l The required volume of solution contained in the storage tank is dependent upon the solution concentration and this concentranon can vary during reactor operations. A required boron soludon volume /concentradon relationship is used to define acceptable SLCS storage tank conditions durmg plant operation.

The SLCS is manually initiated from the main contro! room. The SLCS provides borated water to the reactor core to compensate fer the vanous reactmtv errects dunng the required conditions. These efTecu include xenon decay, elimination of steam voids changing water density due to the reduction in water temperature, Doppler etTect in uramum, changes in neutron leakage and changes in control rod worth as boron afTects neutron migration length. To meet this objective, it is necessary to inject a quandtv of boron which produces a minimum concentration of 850 ppm of natural boron in the reactor core at 70*F. To allow for potential leakage and imperfect mmng in the reactor system, an addidonal 25% (220 ppm) is l added to the above requirement. The required concentranon is achieved

! account.ag for dilution in the RPV with normal water level and mcluding the volume in the residual heat removal shutdown cooling piping. This quanuty of boron solution is the amount which is above the pump sucdon shutofT level in the tank thus allowmg for the portion of the tank volume which cannot be injected. ,

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ABWR Dasign Document

( / The pumps are capable of producmg discharge pressure to mject the soluuon mio the reactor when tne reactor is at high pressure condiuons l corresponding to the system rehef valve actuauon, Signals indicaung storage tank hquid level, tank outlet valve posiuon, pump dischange pressure l and mjecuon valve posidon are available m the control room.

The SLCS uses a dissolved soluuon of sodiam pentaborate as the neutron absorbing poison. This pluuon is held in a storage tank which has a heater to mamtam soluuon temperature above the saturauon temperature.

The SLCS soludon tank, a test water tank, the two posiuve displacement pumps, and associated valving is located in the secondary contamment on the floor elevauon below the operaung floor. This is a Seismic Category I structure, and the SLCS equipment is protected from phenomena such as earthquakes, tornados, hurncanes and floods as well as from mternal poirulated accident phenomena. In this area, the SLCS is not subject to conditions such as missiles, pipe whip, and discharging fluids.

The pumps, heater, valves and controls are powered from the standbv power supply or normal offsite power. The pumps and valves are powered and controlled from separate buses and circuits so that a smgle acuve failure will not prevent rntem operatson. The power supplied to one motor operated injecuon valve, storage tank discharge valve, and injecuon pump is powered from Division I, 480 VAC. The power supply to the other motor. operated injecuon valve, storage tank outlet valve, and injection pump is powered from Division II, 480 VAC. The power supply to the ank heaters and heater controls is connectable to a standby power source. The standby power source is Class IE from an on-site source and is independent of the off site power.

O Q All componenu of the system which are required for injection of the neutron absorber into the reactor are classified Seismic Category L All major mechanical components are designed to meet ASME Code requirements as shown below.

ASME Design Conditions Component Pressure Temocrature Code Class l Storage Tank 2 Static Head 150*F 1

1 Pump / Motor 2 1560 psig 150*F Injection Valves 1 1560 psig 150*F Piping' Inboard of 1 1250 psig 575'F Injectson Valves Design provisions to permit system testing include a test tank and associated piping and valves. The tank can be supplied with demineralized water which can be pumped in a closed loop through either pump or injected into the reactor.

Inspections, Table 2.2.4 provides a definition of the inspections, tests, and/or analyses Tests, Analyses together with associated acceptance enteria which will be undertaken for the and Acceptance SLCS. .

Criteria ,

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r STANDBY LIQUID CONTROL SYSTEM ,

inspections, Tests, Analyses and Acceptance Criteria I Certified Design Comenitrnent inspections. Tests. Analyses Acceptance Criteria I. The minimum average poison 1 Construelion records revi-ws and plant 1. It suust 1.c sh..wn si.e St CS e an a. hieve 4 concentration in the reactor after visual examinations wdl be undertaken gd,.no aoin entrau..n of H50 ppus os 3 operation of the St.CS shall be equdl to or . to assess the as buih parameters listed gecate assuming a 25% .bluti no .lue to

. greater than 850 ppm. below for compatibility with St.rS design r.on.unif.n m mimmg in she sea. s.. aiul calculations. If e.ecessary, an as-built au s.unting for diluuon .n ihr RilR SILS analysis will be conducted to shumil..wn . oolmg apersse, 'l his ,

demonstrate the aucptan(c triscria is t oen e.itrasi..n nousa I.c 4. I rs. .I usults met. specm design basis s on.lats.nss  !

l Critical Farameters: Validation Attribuses:

a. Storage tank pumpable volume Sienage tank pinnpahtc s..lume sange 6i00 - 1800 gal.  ;

b. RPV water inventury at 70*F RPV weser inventony s 100 m 10"11.

e. RIIR shutdown usoling spican water inventory at 70*F RilR shuni..wn .. .hng sps. m nivenieny j- g .287 a 10 f8 II.

,,f,,*"'**;,,','"',"".",,'"

. 2. A simplified system configuration is 2. Inspections of installation tc<ords shown ::: Figure 2.2A. sogether with plasis walkdowns will I.c ,

< uniduc ted to on. firm that the installed  !

equipment is in compliam e with the

- design c onfiguration driined in Figuse 2.2.4.

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Table 2.2.4 STANDBY LIQUID CONTROL (Continued) inspections, Tests, Analyses and Acceptance Criteria i

Certified Design Comrnitrnent inspections, Tests. Analyses Acceptance Criteria

3. Eat h SI.CS pump shall be capable of 3. System preoperasion tests will he 3. It suust 1.c shown ihan ti.c Si t 5. o delivering 50 gpen of soludon against conduc ted to demosnarate e cptal le injca t 50 gym (ca.h pump) again..a the elevated pressure conditions which pump and system perfinrname. These scan sor pemme of im psig-can exist in the reat-tor during events tests will involve establishing test invoking SLCS inidadon. conditions that simulate conditios:s wliich will exist during an St.CS design

- basis event.

4. The system is designcd to permit in- 4. Field tests will be conducted alter sysicm 4. Using normally instatied ionisols. ,

service functional testing of St.CS. installation to confirm, in-service power supplies aint other auxiliar cs.

system tesdng can be performed. the syssem has the s ap.sbilsey su pe ssonm:

4. Pump tries in a e losed I. .p on she r test tank and

b. Reae nor pressuse vessel mgen sions tests usmg demmeraluest water inom die test tasik.

.5. The pumps heaucr. valves and controls 5. Sysican tests will be conduited alter 5. 't he installed equipmen e an be gu wried .

can bepowered from the standby AC isistallation to confirm that slic from the stamiley AG gw.wc supply.

power supply as described in Section ' cles trical gu wcr supply couligurations 2.2.4.* -

ase in e urnplianne with elesign e ommit ments.

• This entry suay bc ::ansfensed to the stamiby AC gnewes ITAAC in Sr.sino 2.1213.

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VENT PRIMAFiY CONTAINMENT y STORAGE TANK L i HEATER I I H3 8 I

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M-- - - - - - - HPCF 'B' I I SUCTION VALVES (WITH POSITION i

, , INDICATION)

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. M. _ -_ .__.-M-. '

ASME F-g- -

a V p--- L- CODE q 'n CLASS ! , ,

• I I PUMPS  :

INJECTION I I _ g VALVES I 8 P 8 8 8 I- - - - 8 ,'

(WITH POSITION l - -- J INDICATION) , t______ ____________

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l l______I_____lASME ' '

l CODE CLASS 2 l l

'------ TEST 8 TANK l Figure 2.2.4 STANDBY LIQUID CONTROL SYSTEM (STANDBY MODE)

I s HNiP15 GENERIC II g ABk'R EQUIPMENT ENVIRONMENTAL OUALIFICATION l

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CONSTRUCTION-RELATED ITAAC - ENVIRONMENTAL QUALIFICATION EXAMPLE DESICN COMMITMENT INSPECTIONS. TESTS, ANALYSES ACCEPTANCE CRITERIA Safety-related mechanical and Documentation relating to EQ issues It will be confirmed that:

electrical equipment will be will be audited for selected qualified for the environmental safety-related equipment items. This a. The conditions used to qualify conditions that will exist up to and documentation will be in the form of equipment equal or exceed the including the time the equipment has device specific qualification plant environmental conditions finished performing its safety- packages. This selection will be for each item.

related, function. Conditions that aimed at sampling approximately 101 b. Testing, analyses, or a exist during normal, abnormal and of the equipment items in the combination of both as allowed design basis accident events will be facility for which environmental in the applicable regulatory considered in terms of their qualification is required. Sample requirements were used to cumulative effect on equipment selection will be biased towards qualify each equipment item.

performance. These conditions will complex equipment which utilizes c. Qualification results confirm be considered for the time period up materials potentially susceptible to that the equipment is qualified to the end of component degradation and is located in areas for its applicable service refurbishment interval or end of subject to harsh environmentel condition.

equipment. life. These conditions conditions. In the event d. Results of the equipment include number and/or' duration of noncompliances with the Acceptance qualification activities have equipment functional and test' Criteria are discovered, the saapling been documented and retained.

cycles / events; process fluid process will be expanded to include ,

conditions (where applicable); an audit of the attribute [s] in energization statu..of the question for an equal or greater-equipment; the dynauic loads sample of items.

associated with seisuic and other vibration inducing events,.and the The audit will include review of pressure, temperature, humidity, specified environmental conditions, chemical and radiation environments, qualification methods (e.g., analyses aging, and submergence.(if any) that or testing), and documentation of  ;

can affect or degrade equipment- qualification results.

perfo rmance .

11-18-L:AJJ8

e, . APPENDIX D e

NRC METHODS F0P. ASSURING COMPLIANCE WITH QA REQUIREMENTS APPLICABLE TO A COL I. The OA Recuirements in 10CFR 50 Anoendix B are Anolicable to a COL 10CFR 52.81 states that COL applications will be reviewed according to the standards in 10CFR Part 50 "as they apply to applications for construction permits and operating licenses for nuclear power plant."

Similarly, 10CFR 52.83 states that "all provisions of 10CFR Part 50 and its appendices applicable to holders of construction permits for nuclear power reactors also apply to holders of" COLs.

II. The Requirements Related to ITAAC Are in Addition to, and Not a Substitute for. the OA Reauirements in Anoendix B The requirements in 10CFR 52.99 and 52.103(c) related to satisfaction of the ITAAC are in addition to the QA requirements in Appendix B.

Thus, with respect to a holder of a COL, the NRC has more mechanisms

() for ensuring that the plan' is built correctly than it does with respect to the holder of a construction permit.

III. NRC Will Not Issue a COL Unless It Finds the COL's QA Program to Be Acceptable Under Anoendix B 10CFR 52.79 statas that, in addition to proposed ITAAC, an applicant for a COL must rabmit "the technically relevant information' required of applicants for an operating license by 10CFR 50.34," which includes a description "of how the applicable requirements of Appendix B will be satisfied." Prior to issuance of-the COL, the NRC will review and accept this QA program description as part of the Safety Evaluation Report, j

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, o,. i IV. NRC Will Perform Periodic Inspections of the COL's QA Program and Its Imolementation to Assure Comollance with Accendix B

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The NRC Inspection Manual describes th', types of inspections which the NRC conducts under 10CFR Part 50. These inspections are equally applicable to a COL. Specifically, NRC Inspection Manual Chapter 2510 provides the inspections during each phase of construction:

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o Pre Construction Phase In4pections (Manual Chapter 2511) to assure that the applicant and its principal contractors have established and are implementing an acceptable QA program prior to issuante of the COL.

o Construction Phase Inspections (Manual Chapter 2512) to assure the adequacy of licensee performance during construction. The NRC's construction inspection program is tied to various Construction Milestones, which ensures that the NRC conducts contemporaneous inspections of each aspect of construction, including inspections of program, design, foundations, structures-, supports, piping, mochanical components, electrical components, 160 components, welding, and fire protection, o Preenerational Testine and Ooerational Preneredness Insoections i

(Manual Chapter 2513) to assure that :ystems and components are i \s- fully tested to demonstrate that they satisfy their design j requirements, and that management controls and procedures for i operation have been documented and implemented. This inspection program is tied to various Testing Milestones, which ensures that the NRC conducts contemporaneous inspections of each aspect of testing.

V. NRC Has Enforcement Powers Under 10CFR 50 *a Compel a COL Holder to Comolv with Accendix B NRC Enforcement Policy in 10CFR 2 Appendix C.is equally applicable to COL holders as it is to holders of construction permits. Under Appendix C, NRC has a full range of enforcement mechanisms to compel a COL holder to comply with the QA requirements in Appendix B. These l-mechanisms include:

I l o Notices of Violations to identify noncompliances with applicable i

requirements, including QA requirements, and to obtain corrective actions.

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gr ^ o' o Enforcement Conferences to discuss violations, their significance, and corrective actions, i

o Confirmatory Action Letters to confirm a licensee's agreement to take certain actions to remove significant concerns.

o Orders, including:

- Orders to modify a COL when some enange in equipment, procedures, or management controls is necescary.

- Orders to suspend construction _ when the licensee's QA program implementation is not adequate to provide confidence that construction activities are being properly carried out.

Orders revoking a COL when a licensee is unable or unwilling to comply with requirements or refuses-to correct a violation.

VI. Conclusions In addition to ITAAC, the NRC has the same mechanisms for ensuring that the COL holder complies with QA requirements in Appendix B as it has for ensuring compliance by a holder of a construction permit. These mechanisms include review and acceptance of the QA progran description in the SSAR, instretion of compliance, and enfcrcement actions to O' ensure compliance, l

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