RIS 2008-05, Lessons Learned to Improve Inspections, Tests, Analyses, and Acceptance Criteria Submittal
| ML073190162 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/2008 |
| Revision: | 0 |
| From: | Case M J NRC/NRR/ADRO/DPR |
| To: | Tracy G M Division of Construction Inspection and Operational Programs |
| References | |
| RIS-08-005 | |
| Download: ML073190162 (6) | |
February 27, 2008
NRC REGULATORY ISSUE SUMMARY 2008-05 LESSONS LEARNED TO IMPROVE INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA SUBMITTAL
ADDRESSEES
The U.S. Nuclear Regulatory Commission (NRC) applicants for early site permits, design certifications, or combined licenses to construct and operate nuclear power plants under Title 10, Part 52, "Licenses, Certifications, and Approvals for Nuclear Power Plants," of Title 10 of the Code of Federal Regulations (10 CFR) Part 5
INTENT
The intent of this regulatory issue summary (RIS) is to communicate to addressees the good practices for submitting inspections, tests, analyses, and acceptance criteria (ITAAC) as part of their applications for early site permits, standard design certifications, or combined license Applicants should consider incorporating these lessons learned into their applications to provide for a more efficient inspection and ITAAC closure proces No specific action or written response is require
BACKGROUND
As required by 10 CFR Part 52, applicants for early site permits, standard design certifications, or combined licenses must submit, among other information, the proposed ITAAC that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses (ITA) are performed and the acceptance criteria met, the facility has been constructed and will be operated in conformity with the license, the provisions of the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulation Following issuance of a combined license, a licensee completes the ITAAC contained in the combined license during construction and submits notification letters to the NRC in accordance with 10 CFR 52.99,
"Inspection during Construction." The NRC subsequently verifies closure of all ITAAC through direct inspection or other methods, such as oversight of the licensee's ITAAC completion, closure, and approval processe
SUMMARY OF ISSUE
S Based on the review of recent ITAAC submittals to the NRC, the staff has identified four general categories in which ITAAC submittals could be improve These areas include (1) ML073190162 ITAAC format and content, (2) ITAAC nomenclature and language, (3) ITAAC focus, logic, and practicality, and (4) ITAAC standardization and revie ITAAC FORMAT AND CONTENT
- Applicants should consider using a consistent system to identify and number individual ITAAC within their application While an alphanumeric system has generally been used in past submittals, in some cases dashes or separate paragraphs with no labels were used in the body of the text to specify separate ITAAC requirement In other cases, the alphanumeric designations were not consistently aligned for the applicable ITAAC table requirement Use of a standard and consistent ITAAC identification system will minimize confusio
- Applicants should consider a standard methodology for identifying and organizing the structures, systems, and components (SSCs) associated with an ITAAC to allow for a more efficient inspection and ITAAC closure proces For instance, if an applicant chooses to organize SSCs in a tabular format (as opposed to system drawings), they could organize instrumentation-related components (e.g., sensors) separately from mechanical component Additionally, the applicant could list mechanical components, or a group of components that are likely to be closed together, in similar categories (e.g.,
pumps, valves).
- Applicants should consider avoiding the integration of several different engineering or construction areas into a single ITAA In one case, an applicant included all of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements and pipe break analyses for all the plant's piping into two ITAA In another instance, an applicant's definition for a system's "basic configuration" included five separate engineering and construction processes, but only two ITAAC were associated with the ITAAC NOMENCLATURE AND LANGUAGE
- All terms used in an ITAAC should clearly be define For example: - It is unclear whether an applicant using the terms "design reports" and "reports" in an ITAAC involving ASME Code piping and welding intends the ASME Code definition for "design report" and "data report" or its own definition for these term In one instance, the term "as-installed" was frequently used but not define Apparently this term was used as a substitute for the term "as-built," which was define
- If applicants use terms such as "interfacing systems," "control room features," "minimum set," "seismic structure," "equipment qualification," "fast-closing" valves, and "rapid" depressurization, they should clearly define the For instance, the term "equipment qualification," if not clearly defined, could be associated with the specific requirements for environmental qualification delineated in 10 CFR 50.49, "Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants."
- The use of the conjunction "and/or" is generally not appropriat
- If applicants use the phrase, "a report exists and concludes that...," they should consider specifying the scope and the type of repor For example, they should explain whether the scope of the report includes the design, the as-built construction (as reconciled with the design), or any other informatio
- Applicants should be consistent in the use of specific technical terms (e.g., the terms "pressure" test and "hydrostatic pressure" test are interchanged; similarly, "internal" pressure and "design" pressure are used in the same ITAAC). Applicants should also take care not to confuse the "preoperational conditions" with the applicable "operation modes" in situations involving testin ITAAC INSPECTION FOCUS, LOGIC, AND PRACTICALITY
- Applicants should avoid applying a single ITAAC to a large area of construction or activities that are likely to be widely separated in tim Large-scoped ITAAC create problems with verification activities and with the timing of construction and other requisite inspection
- Applicants should consider breaking ITAAC with a large number of SSCs into areas of constructio For instance, if an ITAAC envelops construction from the basemat to the top of containment and applies to several different buildings, the large area and scope create difficulties not only in tracking the applicable SSCs, but also in connecting the interdependent nature (e.g., seismic) of the applicable structure Breaking a large single ITAAC into several areas will make the ITAAC closure process more efficien
- Applicants that envision using modular construction should consider the impact of these activities in developing their ITAA For example, the inspection of as-built SSCs implies that "as-built" refers to the completion of construction at the final location at the plant sit However, if a module is fabricated at a remote location (e.g., a shipyard), the individual components within the module (e.g., a pipe support) would be in their final locations, even if the module had not yet been transported to the sit Such considerations will facilitate ITAAC inspections and timely closure
- Applicants should consider the timing and sequence of construction activities in the development of related ITAA Breaking the ITAAC into pieces that can be completed in the early and mid-stages of construction would help alleviate the backlog of ITAAC closure activities at the end of the proces
- Applicants should ensure that design commitments and ITAAC are consisten It is important for the language and details of the ITAAC to comport with the language of the design commitmen In one case, the design commitment indicates that the piping is designed and constructed in accordance with the ASME Code, but the acceptance criteria only require the existence of "design reports" (which would not normally encompass construction quality) for as-built pipin
- Applicants should ensure that the ITA and the associated acceptance criteria matc In one case, the ITA required an "inspection" of a makeup water syste While three separate acceptance criteria were associated with this one ITA inspection, only two of the criteria were "inspections"; the third criterion specified a flow rate, which is a "test" result and not an "inspection" criterio ITAAC STANDARDIZATION AND REVIEW
- Applicants should ensure consistency in ITAAC designations within their application In one case, a count of the ITA designations identified 33 ITAAC, while a count of the acceptance criteria designations identified a total of 38 ITAA Such an inconsistent ITAAC count could result in problems not only during the conduct of verification and inspection activities, but also when the ITAAC are closed and the notification letters, in accordance with 10 CFR 52.99, are submitte
BACKFIT DISCUSSION
This RIS requires no action or written response and is, therefore, not a backfit under 10 CFR 50.109, "Backfitting." Consequently, the NRC staff did not perform a backfit analysi
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal Register because the RIS is informational and does not represent a departure from current regulatory requirement
CONGRESSIONAL REVIEW ACT
The NRC has determined that this action is not a rule under the Congressional Review Ac
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain information collections and, therefore, is not subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.).
Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control numbe
CONTACT
This RIS requires no specific action or written respons Please direct any questions about this matter to the technical contact listed belo /RA/ /RA/ Michael Case, Director Glenn Tracy, Director Division of Policy and Rulemaking Division of Construction Inspection and Office of Nuclear Reactor Regulation Operational Programs Office of New Reactors
Technical Contact:
Omid Tabatabai (301) 415-6616 oty@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections
CONTACT
This RIS requires no specific action or written respons Please direct any questions about this matter to the technical contact listed belo /RA/ /RA/ Michael Case, Director Glenn Tracy, Director Division of Policy and Rulemaking Division of Construction Inspection and Office of Nuclear Reactor Regulation Operational Programs Office of New Reactors
Technical Contact:
Omid Tabatabai (301) 415-6616 oty@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collection ML073190162 OFFICE CCIB:DCIP:NRO Tech Ed. TL:CCIB:DCIP:NROBC:CCIB:DCIP:NRO D:DORL:NRR NAME OTabatabai HChange RLaura RRasmussen CHaney DATE 1/23/08 1/18/08 2/5/08 2/5/08 2/4/08 OFFICE D:DIRS:NRR D:DNRL:NRO D:DPR:NSIR DD:DCI:R-II D:OE NAME FBrown TBergman MLeach COgle CCarpenter DATE 2/5/08 2/8/08 2/4/08 2/1/08 1/29/08 OFFICE OGC (NLO) OGC (CRA) D:PMDA:NRO OIS LA:PGCB:NRRNAME JRund SHamrick BGusak GTrussel CHawes DATE 2/12/08 2/12/08 1/25/08 1/29/08 02/15/08 OFFICE PM:PGCB:NRR BC:PGCB:NRRD:DCIP:NRO D:DPR:NRR NAME AMarkley MMurphy GTracy MCase DATE 02/20/08 2/26/08 2/26/08 2/26/08