Multinational Design Evaluation Programme
MDEP Common Position
CP-STC-01 – PUBLIC USE

April 2018
Version 1

MDEP
Common Position
CP-STC-01
Common Position addressing
First-Plant-Only-Tests (FPOT)

Participation
Regulators involved in the MDEP STC
discussions:

All MDEP members

Regulators which support the present report:

All MDEP members

Compatible with existing IAEA related
documents:

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Multinational Design Evaluation ProgrammeCommon Position
CP-STC-01 – PUBLIC USE

April 2018
Version 1

1. Introduction
2. Definitions of First-Of-A-Kind (FOAK) tests and First-Plant-Only-Tests (FPOT)
3. Examples of justifications for performing a test only on the first unit
commissioned
4. MDEP Common Position on FPOTs

Appendix 1: Preconditions for crediting FPOTs-2-Multinational Design Evaluation ProgrammeCommon Position
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Introduction
The Multinational Design Evaluation Programme (MDEP) design specific working
groups (DSWGs) are engaged in discussions on commissioning related issues assome of the member countries are entering commissioning phase of new build
nuclear power plants. A number of workshops have been held by AP1000 and EPR
working groups to address commissioning related issues for the eight AP1000
reactors and five EPR reactors being built in their respective member countries. Oneof the common topics identified in these workshops and other interactions is theconcept of First-Plant-Only-Test (FPOT) proposed by the reactor vendors. An FPOT,
if accepted by the applicants/licensee’s and regulators, will allow a test performed on
the very first reactor of a specific design to be credited for the subsequent units ofsimilar design.
MDEP has prepared this document to provide a high-level guidance forapplicants/licensees wishing to take credit for a test performed during thecommissioning of the first unit of a similar type.

2Definitions of First-Of-A-Kind (FOAK) tests and First-Plant-Only-Tests (FPOT)A test is a FOAK test, if

it tests a new feature of the design or a new concept applied to the design,and

the test has never been performed before (e.g. during Factory AcceptanceTests).

A FOAK test is not necessarily an FPOT. A test that is a FOAK test on the first unit tobe commissioned can be performed also on the other units to be commissioned lateron, only then it would not be a FOAK test anymore.
An FPOT is a FOAK test that is performed only on the very first unit of a specificdesign to be commissioned. The test results from the first unit would then be credited
for the subsequent units of similar design.
3Examples of justifications for performing a test only on the first unit
commissioned
The following are some of the examples of justification cited for performing a test only
on the first commissioned unit:

Test is complex to implement (e.g. requires specific instrumentation);

Test causes severe loads to the plant structures/equipment;Test is time consuming (e.g. includes testing in various configurations).

The test results are valid on all subsequent units only if the test conclusions are notaffected by design differences between the units or regulatory differences between
countries.

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MDEP Common Position on FPOTs
The licensee is responsible to assess the potential use of each FPOT results for itsunit(s) and to conclude such FPOT results can be credited in the commissioning
process before formally presenting the case to the regulator.
The obvious precondition for crediting FPOT results is that the design,implementation, and plant conditions are so similar that the possible existing
differences do not affect the applicability of the results to the unit where the test will
not be performed. In addition, the regulators of different countries have different
requirements and review processes. The requirements may concern the acceptancecriteria of the tests, the documentation, reporting of results, the processes of thelicensee etc. Some regulators may also expect that a representative of the regulator
witnesses the performance of the FPOT.
More detailed preconditions for crediting FPOT are presented in Appendix 1. If all
preconditions listed in Appendix 1 are all fulfilled, tests performed on the very first
specific reactor unit to be commissioned may be credited for the subsequent similar
units in any member country of the applicable MDEP design-specific working group. It
is important to note that a key concept throughout the work of the MDEP is thatnational regulators retain sovereign authority for all licensing and regulatory
decisions.
It is also recommended that the licensee seeks early discussions with the regulator toleave the least room possible to interpretation of the guidance and to reach the best
common understanding. Future nuclear power plant projects of similar design may
wish to credit FPOTs that have been performed before the start of the project inquestion. In that case, it is obvious that preconditions 4.3 and 4.4 cannot be fulfilled.
To compensate for that, special attention must be paid to the other preconditions,especially those concerning access to data and documenting the performance andresults of the tests. The licensee’s proposal should include appropriate mitigatingarguments.

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Practical arrangements for observing FPOTs (precondition 4.3)
Practical arrangements for observing FPOTs according to precondition 4.3 must beanticipated. The following is to be taken into account when planning the observationof future FPOTs:
Host licensee/regulator
The host regulator should engage early with the host licensee to check if a
specific “confidentiality agreement” is necessary between the host licensee
and observing regulators;If an agreement is necessary, the signed version will be in English;

OECD Staff Regulations and Rules prevent OECD/NEA officials from signing
any “confidentiality agreement”; OECD/NEA officials must abide by thestrictest confidentiality obligations in accordance with the OECD StaffRegulations and Rules, which set out their conditions of employment. Any
violation of these obligations would constitute misconduct, and the official
concerned would be liable to disciplinary measures decided by the OECD,including dismissal;-4-Multinational Design Evaluation ProgrammeCommon Position
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Documentation should be provided in advance of the visit to allow an initial
review by relevant subject matter experts and to facilitate a more effective
engagement;

Translator(s) should be available as appropriate.

Observing regulators


MDEP Secretariat is responsible for co-ordinating the necessary logisticalarrangements for the observing regulators to witness the FPOT;

The visit should focus on the implementation of the FPOT, quality
arrangements, etc. rather than the technical adequacy of the tests and theresulting data.

Observing licensees
The MDEP Secretariat inform the OOG of the dates and planning of the FPOTwitnessing;The host licensee is responsible for ensuring the necessary arrangements arein place (e.g. site access, confidentiality “agreements”, etc.) for the observing
licensees to witness the FPOT.

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APPENDIX 1: Preconditions for crediting FPOT

#Precondition

Licensee’s responsibilities
1.1
The licensee shall evaluate and assess the possibility to credit tests performed on another unit.
1.2
The licensee shall approve crediting the FPOT before submitting the application to regulator.
Justification and demonstration of the validity of the FPOT
2.1

The reasons for conducting a FPOT (cost, time, technique, safety) shall be defined, and a cost benefit analysis for
conducting a FPOT shall be made.

2.2

Similarity of the unit on which the test was conducted and the one which will credit the FPOT shall be assessed. It
shall be demonstrated that possible differences in design, manufacture and installation of the FPOT component orsystem, in the environmental and operating conditions and practices, or the codes and standards applied, do notaffect the validity of the FPOT results to other unit(s).

2.3

A statement shall be made (e.g. by vendor or by operating organization) on any potential adverse consequences ofclaiming that the FPOT characterises the performance or behaviour of a component or system whose design,
manufacture or installation do not adequately replicate that for the component or system subjected to the FPOT.

2.4

In designing the test, it should be considered whether the data could be used to design and validate a less complex
or alternative test that may be used during commissioning of follow-on units to characterise the performance or
behaviour of the component or system and thus help validate application of the FPOT data.

2.5

Where FPOT data is demonstrating the ability of a component or system to fulfil a critical nuclear safety function, forexample primary circuit integrity/inventory or reactivity control, an independent third party panel of experts shall be
appointed by each licensee to oversee all aspects of the FPOT. Consideration could be given to licensees jointly
appointing such a panel. The terms of reference of such a panel shall include the production of a report recording its
judgement on the validity of applying the resulting data to follow on units including in another country. This report isto record any caveats or conditions which, in the view of the panel, may constrain or exclude application of the data.
Test results from the first unit must be reliable to the extent that any subsequent test would be expected to produce
similar results.

2.6

It is necessary for the licensees to ensure the adequacy of the quality assurance programme of tests for the FPOTunit, considering the quality assurance requirements of the unit where FPOT may be credited. This includes-6-Multinational Design Evaluation ProgrammeCommon Position
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Precondition
ensuring the adequacy of the quality assurance programme for instrument calibration.
2.7

Any physical verification(s) that have been or will be performed to demonstrate the validity of FPOT shall beidentified.

2.8

All the test critical parameters, calculations and verification methods used during the initial test programme shall beidentified. For calculated values, this includes the calculated validation methodology, software verification andvalidation (when applicable), and the actual data inputs and outputs from the initial test results to support calculatedvalues.

2.9

The controls that vendors will have in place during the initial test programme to ensure that work performed toanother language procedures or instructions are correctly translated from the original language of the procedures orinstructions shall be documented.

Data sharing
3.1

The licensee shall have access to all necessary data for crediting the FPOT (including information relating todesign, manufacture and installation) for a period of time consistent with the licensee’s obligations under country
regulation.

3.2

Justification for crediting the FPOT, documentation concerning the testing (e.g. testing programme, result report)
and quality assurance programme of the FPOT shall be submitted to the regulator.

3.3

It shall be possible to share other relevant data and results with the regulator as necessary (material data ofequipment/structures involved in the tests, data about manufacturing and installation, quality assurance actions
taken during those phases, etc.).

Testing and testing programme
4.1

Documentation of the FPOT must be included in the commissioning programme of the subsequent unit.

4.2

The testing programme for the FPOT must address coverage of the testing, the acceptance criteria, prerequisites tothe tests, the management of deviations and the appraisal of uncertainties.

4.3

The licensee and the regulator shall be provided with possibility to witness the FPOT. Regulators can participate ina joint inspection with the regulator overseeing the FPOT unit. To do so, they have to be informed of the expectedschedule and programme and must be informed of any changes in the schedule and programme with sufficienttime.

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Precondition
4.4

Tests that demonstrate the correctness of manufacturing and installation must always be performed on theequipment/unit in question.

Other
5.1

Following completion of the FPOT, the vendor shall make a statement on the appropriateness to not repeat the test
on future units, including discussion on the significance of the test results, any unexpected behaviour(notwithstanding that the acceptance criteria may have been met) and any implications for the safety case/operationof the plant (normal and/or abnormal conditions).

5.2

Like any other commissioning test, it must be ensured that the FPOT provides adequate basic data on theoperational properties of structures, systems and equipment for use as a basis for assessing the results of periodic
testing during operation and for the assessment of changes in the operability of components.

5.3

Educational aspects must be considered. Consideration should be given to the loss of the opportunity provided byconducting the FPOT for operators to gain experience and familiarity with the component or system.

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