April 21, 2008 

MEMORANDUM TO: Richard Rasmussen, Chief 

Construction Inspection & Allegation Branch 

 Division of Construction Inspection 

 & Operational Programs 

 Office of New Reactors 

FROM: Ian Spivack /RA/ 

Construction Inspection & Allegation Branch 

 Division of Construction Inspection 

 & Operational Programs 

Office of New Reactors 

PARTICIPANTS: Public, Industry, and NRC Staff 

SUBJECT: SUMMARY OF PUBLIC MEETING HELD ON APRIL 2 AND 3, 2008, TO 

DISCUSS ITAAC CLOSURE AND ASSESSMENT AND ENFORCEMENT 

FOR NEW REACTORS 

The Construction Inspection and Allegations Branch of the Division of Construction Inspection 

and Operational Programs (DCIP) in the Office of New Reactors (NRO) and Region II 

Construction Inspection Programs conducted a Category 3 meeting on April 2nd and 3rd, 2008, in 

Rockville, Maryland. The meeting on April 2nd was lead by Region II and discussed Inspections, 

Tests, Analyses, and Acceptance Criteria (ITAAC) scheduling, and handling of proprietary 

information. The meeting on April 3rd was guided by DCIP and discussed safety culture 

considerations for new reactor construction, ITAAC closure letters, option C for resolving Design 

Acceptance Criteria (DAC), industry guidelines for the ITAAC closure process under 10 CFR 

Part 52, post fuel load timeline, and the public release of inspected ITAAC. The meeting was 

the seventh in a series of meetings discussing these topics, was attended by members of the 

NRC headquarters staff, NRC Region II, the Nuclear Energy Institute (NEI), industry, and the 

general public. 

On April 2nd, 2008, the NRC staff provided opening remarks related to continuing good working 

relationships, promoting common understanding, and leveraging existing working group 

knowledge and resources for the benefit of ITAAC scheduling. The NEI staff provided opening 

comments on the industries roadmap to success and emphasized the importance of preplanning and appreciated the exchange of ideas between the NRC and the industry. 

At the completion of the opening remarks the NRC staff discussed the agencies roadmap to 

success and provided information on the responsibilities Region II and Headquarters will have 

with regards to ITAAC scheduling and closure. The discussion also noted that the current NRC 

plans are to have a scheduler on-site that may reduce unnecessary licensee burden and the 

need for electronic schedule information to flow freely. An overview of the ITAAC inspection 

framework was also presented (ADAMS ML081060154). 

CONTACT: Ian Spivack, NRO/DCIP/CCIB 

 301-415-2564 
R. Rasmussen -2-

The industry had concerns on closing ITAAC by family rather than individually closing ITAAC 

when the ITAACs were submitted for closure. Specifically, why should the industry complete 

and send ITAAC closure notifications to the NRC if the ITAAC would not be closed until the 

NRC completed the majority of targeted ITAAC inspections in that family? If an issue arose, 

how would that impact closed ITAACs related to the same open family? The discussion shifted 

and focused on reasons for making the targeted ITAAC publically available. The industry noted 

that if the targeted ITAAC was publically available and construction resources became available 

the schedulers could focus on scheduling targeted ITAAC earlier to preclude potential late 

issues related to ITAAC. The industry also discussed the release of ITAAC family completion 

percentages by the NRC, (i.e., periodic status update by the NRC). 

The NRC staff continued with an overview of the current flowpath for processing construction 

schedule information. The industry highlighted concerns over release of construction schedules 

and noted the need to treat the schedules as proprietary information. Other suggested having 

daily/weekly meetings with the resident to ensure the residents were aware of all schedule 

changes. Discussion continued with respect to the pilot scheduling program Region II is 

conducting and when it will be completed. The NRC noted that the current target date for 

completing the pilot testing will be in the fall of 2008. Currently DOE has requirements on 

providing insurance to the industry if any delays are NRC related and expressed concern over 

the use of NRC developed software instead of using software readily available in the industry. 

The NRC explained it intends to use existing software platforms widely available. The 

discussion continued with a focus on modular construction, modular construction ITAAC 

inspections and schedules for qualification testing. The NRC emphasized the importance on 

providing a better understanding of modular construction and qualification test schedules. 

The NRC staff also provided a presentation on the proof-of-concept (pilot testing) for acquiring 

and translating Primavera construction schedule information that will be used for inspection 

scheduling and ITAAC closure (ADAMS ML081060168). This would require some manipulation 

of the information from Primavera to incorporate it into the current IT resources used by the 

agency. The industry provided feedback on the use of Primavera filters while the NRC 

emphasized this required the use of activity codes that are specific to ITAAC such that all or 

selected ITAAC could be pulled and tabulated as an excel file if needed. Primavera does allow 

the creation of user-defined layout and filter views that require read only permission to the 

licensee database and would only be stored on the user’s computer. 

The NRC provided a presentation on the Construction Inspection Program Information 

Management System, (CIPIMS) and how CIPIMS will be used for ITAAC, non-ITAAC and 

vendor inspections (ADAMS ML081060186). The industry representatives asked if CIPIMS 

would be publically available. Currently the NRC’s plans to make CIPIMS data publically 

available, but has not finalized the specific CIPIMS data or output format that will be publically 

available. The NRC also provided information on the ITAAC numbering, for the AP-1000 & 

ABWR, which was previously publically available (ADAMS ML0702500122). 

NEI provided an open discussion with the Design Center Working Group (DCWG) on the 

software that they are using and their current status for developing the construction schedules. 

 

NEI continued the discussion with a suggestion of using the 10 CFR 2.390 process for handling 

proprietary information. The NRC continued with a presentation on the control of proprietary 

information within the NRC. This highlighted current procedures with the presentation ending 

with an overview of the 10 CFR 2.390 process and how the agency handles requests for 

withholding proprietary information from public disclosure. The industry was informed of a 
R. Rasmussen -3-

SECY paper that details this process and its application to electronic construction schedules 

(ADAMS ML060740479). One difference between the normal processes is that only one 

affidavit needs to be submitted for all construction schedules and their associated updates. This 

process is currently being used for other construction projects under NRC oversight. It was 

suggested that a draft affidavit be created which all licensees could use. NEI has taken the lead 

on this action. 

The NRC revisited the discussion on the integration of the industry software and the NRC’s 

software. The specific items discussed were the level of detail needed to implement the pilot 

project and a consistent ITAAC numbering scheme between DCD and construction schedules. 

NEI has taken the lead on identifying a DCWG that is willing to provide a construction schedule 

for pilot project. 

At the conclusion of the meeting NEI noted that they would work with the industry to identify a 

DCWG that would interface with the NRC on pilot testing, module construction ITAAC inspection 

and ITAAC inspection schedule. The NRC would continue to develop the construction schedule 

pilot test and work with the industry to develop the needed framework that will allow electronic 

transfer of the appropriate data. The NRC and NEI will develop a consistent ITAAC numbering 

system for each DCWG. In addition, closing ITAAC by family verses individually and making 

targeted ITAAC publically available are program issues and will be discussed in the routine 

ITAAC closure, assessment and enforcement for new reactors public meetings. This 

scheduling working group will focus on detailed ITAAC inspection schedule information and 

issues surround the ITAAC and modular construction inspection schedules with DCWGs and 

periodically provide an overview and lesson learned to all the working groups through the 

ITAAC closure and assessment and enforcement for new reactors public meeting. 

On April 3rd 2008, the NRC presented Safety Culture Considerations for New Reactor 

Construction (ADAMS ML080880454). NUREG 1055, “Improving Quality and the Assurance of 

Quality in the Design and Construction of Nuclear Power Plants” was written in order for the 

NRC to document lessons learned from previous construction activities. This NUREG 

documents lessons learned from a prevailing attitude that construction activities at nuclear 

power plants had no immediate threat to public health and safety. However, this belief did not 

consider potential future impacts due to low quality construction at nuclear power plants. The 

Commissioners strongly support and requested an expansion of agency policy regarding safety 

culture for new reactor construction. 

The NRC established an internal working group to evaluate the use of safety culture component 

for new nuclear reactor construction. As one input to the working group, the NRC contracted a 

report to investigate the safety culture component of the ROP. This report agreed with the 

findings of NUREG 1055, which stated that previous safety culture issues were mostly related to 

organizational climate and construction quality issues. The NRC internal working group is 

currently evaluating the contract report, defining substantive cross cutting issues, and 

determining the appropriate level of follow up inspections. Future work includes an 

implementation plan, further development work, and a Commission paper. 

The industry commented that there were lessons learned from nuclear reactor startup testing, 

and that there seemed to be a dichotomy between construction problems and no immediate 

impact. The NRC re-iterated the point from NUREG 1055 that this attitude was a major problem 

during previous construction of nuclear reactors, which caused major problems during nuclear 

reactor testing phase. 
R. Rasmussen -4-

The industry requested a copy of the contractor report that looked at the feasibility of utilizing 

the ROP safety culture components. The NRC stated that they will evaluate this request. 

The industry stated that safety culture cross cutting issues are already addressed in current 

activities, and they are not sure of the added value for an additional layer of regulatory 

oversight. The NRC stated that safety culture cross cutting issues are not an additional layer of 

oversight, but are used to see if there is a underlying performance theme within the various 

programs. Examples of safety culture cross cutting issues are safety conscious work 

environment. 

The industry questioned the need of cross cutting issues and stated that they are already 

included in the ROP and addressed in enforcement activities. Industry stated that their current 

programs clearly cover safety culture components. The NRC stated that safety culture is the 

ability to connect the dots between various problems before a significant breakdown occurs. 

Cross cutting issues is a larger indication of an organization problem and looks at the 

organization horizontally instead of vertically. Safety culture will be assessed as part of the 

normal baseline inspection; it will not necessarily be a separate inspection. Enforcement 

decisions based on safety culture assessment are still under consideration. The appropriate 

response will be based on a stepped approach that has been presented at previous public 

meetings. 

The industry commented that the ROP is based on years of data and operating experience and 

that there is no data right now for nuclear reactor construction that can be used as a basis for 

safety culture cross cutting issues. For example, the ROP just finished going through an 18 

month trial period about additional changes to safety culture and will be finalized next 

December. Industry further stated that safety culture cross cutting issue development is 

premature and that there are not enough details provide. The NRC stated that they are 

currently developing these ideas internally. The NRC stated that there is no action matrix, but 

instead will be a Construction Response Table (CRT), which was presented at previous 

meetings. 

The industry suggested that the NRC involve the industry in the NRO led safety culture and 

substantive cross cutting issue task group for new reactor construction. The industry is not part 

of the Office of Enforcement led safety culture working group for other issues, but the NRC has 

given the industry periodic meeting updates. The NRC will continue to have frequent public 

meetings where ideas can be shared and developed. The NRC stated that safety culture is 

important and will be involved in the construction program for new nuclear reactors. The NRC 

stated that these public meetings are open discussions where feedback on proposed ideas are 

actively solicited and reflected in the development of our programs and policies. 

Four ITAAC example closure letters and uncomplete notifications were reviewed, which were 

resubmittals from previous workshops. Although the quality is generally high with the examples, 

a few reoccurring problems were identified such as inspection requirements for as-built 

conditions and better delineation between completed and uncompleted work. 

Closure letter ABWR ITAAC 2.3.3 Item 3 (ADAMS ML081060427) states that the system or 

component must be in its final arrangement to satisfy the acceptance criteria. There was a 

discussion regarding electrical isolation for this ITAAC and how it would be closed if non 

Class1E electrical equipment encroached on Class 1E equipment. The NRC also noticed that 

attention to detail was declining with these resubmittals, particularly in closure letter ABWR 

ITAAC 2.1.1d Item 3 (ADAMS ML081060449). The NRC stated that they are not sure if 25% 
R. Rasmussen -5-

completion is accurate for the additional detail added to the closure letter, but that 75% 

completion would be more accurate. The NRC also stated that the items completed section and 

items to be completed section were disconnected. Also, it can not be determined from a 225 

day letter that significant experience of personal already exists at the site, and that the 

examples would need to be corrected to remove that predetermination. Closure letter ABWR 

ITAAC 2.14.4a Item 4a (ADAMS ML081060472) has same comment from the previous 

example. Closure letter ABWR ITAAC 3.3 Item 1 (ADAMS ML081060431) also had very 

minimal edits. The NRC requested the industry to bring an ABWR basic configuration ITAAC 

closure letter to the next meeting. NEI is preparing to include in their guide on how to maintain 

ITAAC validation after it is closed. 

A continuation of a previous discussion on Option C for Resolving DAC after the issuance of a 

combined license was presented (ADAMS ML081060444). Following the resolution of a DAC 

item,. NRC staff expects licensees to perform an inspection to verify DAC is met. The licensee 

would evaluate any resulting departures from the design control document or changes to the 

plant-specific final Safety Analysis Report (FSAR). The licensee would use the applicable 

change process to determine if a license amendment was needed. The licensee would update 

their FSAR to reflect the more detailed design information from DAC resolution, as required by 

10 CFR 50.71 (e). Industry stated that there is a lot of detailed design information developed, 

and only a portion of this information would be appropriate to place in the FSAR. The NRC 

agreed with this statement. 

NEI presented “Industry Guideline for the ITAAC Closure Process under 10 CFR Part 52” 

(ADAMS ML080950402). NEI 08-01 will provide guidance to applicants on ITAAC closure 

process and will ensure a standard industry approach. The next steps will be to receive formal 

comments from the NRC and to work with the NRC on resolving comments and issue the final 

document. NEI would like an endorsement of this document in the form of a Regulatory 

Guidance. NRC stated that they are open to a smaller Category 2 meeting so there could be a 

smaller dialog with questions. 

A draft timeline of the post-fuel load period was presented (ADAMS ML080880467). The 

timeline starts with the fuel arriving onsite and goes to commercial operation. The power hold 

points are for a typical PWR, but are detailed and further described in Regulatory Guide 1.68. 

Regulatory Guide 1.68, revised in 2007, discusses details for the testing through this period. 

NRC solicited comment if inspected ITAAC should be public or withheld. The industry stated 

that the ranking should not be too difficult to figure out, and which ITAAC are important. 

Industry commented that it is important for scheduling of targeted ITAACS that targeted ITAACS 

are public and the site teams can plan for the ITAAC inspection. Inspection Manual Chapter 

2504 focuses on construction and operational programs and is more based on the traditional 

inspection. The NRC commented if the targeted ITAAC were to be made public, it would still 

not give the industry the specific items that the NRC planned to inspect. For families that do not 

have targeted ITAAC, the NRC will pick the most risk significant activities, or the NRC might 

choose a low risk activity if an uninspected subcontractor is performing that activity. These 

issues might not be known until the NRC reaches that time. The NRC may expand the scope of 

inspections if weaknesses are found. Industry commented that the NRC has the information on 

the most important processes that that there is nothing wrong with telling the public that certain 

ITAAC are more important than others. The industry commented that the targeted ITAAC 

should be disclosed in order to aid scheduling. The negative view is that the public might believe 

the licensee is not doing an adequate job on non-targeted ITAAC. Targeted ITAAC are chosen 

by the plant design. NEI stated the industry will be prepared every day for inspection and that 
R. Rasmussen -6-

this discussion allows them to manage their process and coordinate activities and allow for 

efficient operations. NRC stated that releasing the list might increase the burden on staff in 

order to keep the information up to date on the public website. Industry stated that an opened 

list of targeted ITAAC might increase public confidence in having more information regarding 

inspections. In summary, the industry and NEI comments favored release. 

The next meeting will be held Tuesday May 13th, 2008 in a location to be determine. The 

Instrumentation and Controls (I&C) group would like to participate in the next meeting to discuss 

I&C DAC. The next meeting will be July 10th, 2008 and August 28th, 2008 at a location to be 

determined. 
R. Rasmussen -6-

this discussion allows them to manage their process and coordinate activities and allow for 

efficient operations. NRC stated that releasing the list might increase the burden on staff in 

order to keep the information up to date on the public website. Industry stated that an opened 

list of targeted ITAAC might increase public confidence in having more information regarding 

inspections. In summary, the industry and NEI comments favored release. 

The next meeting will be held Tuesday May 13th, 2008 in a location to be determine. The 

Instrumentation and Controls (I&C) group would like to participate in the next meeting to discuss 

I&C DAC. The next meeting will be July 10th, 2008 and August 28th, 2008 at a location to be 

determined. 

Enclosure: Attendees List 

DISTRIBUTION

PUBLIC RidsNroDcipCcibCCIBr/f 

RidsOgcMailCenter RidsRgn1MailCenterRidsAcrsAcnwMailCenter 

RidsRgn2MailCenter RidsRgn4MailCenterRidsRgn3MailCenter 

RidsNroDcipCcib RidsNroDcipRidsOpaMail 

R. Pascarelli RidsNroDcipCqvp 

R. Laura I. Spivack 

G. Khouri 

ADAMS ACCESSION: Package: ML081060483, Public Meeting Notification - April 2 and 3, 2008: ADAMS 

ML080780164, Summary of April 2 and 3 public meeting: ADAMS ML081060112, ITAAC Inspection_Closure 

Scheduling: ADAMS ML081060154, ITAAC Counting Methods: ADAMS ML081060168, CIPIMS for 4-2: ADAMS 

ML081060186, ABWR basic configuration defn: ADAMS ML081060220, NRO-Safety Culture 0403: ADAMS 

ML080880454, ITAAC Closure Letter 2.3.3 Item 3a & bFinal: ADAMS ML081060427, ABWR 2 1 1 3_225 day RPV 

System Hydro_3_14_08: ADAMS ML081060449, ABWR 2 14 4 4a_225 day SGTS Pressure Test_3_14_08: ADAMS 

ML081060472, ABWR ITAAC 3.3 Item 1_sample closure letter_final: ADAMS ML081060431, DAC Option C: ADAMS 

ML081060444, Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52: ADAMS ML ML080950402, 

Draft Post-Fuel Load Timeline Rev1: ADAMS ML080880467 

OFFICE NRO/DCIP/CCIB NRO/DCIP/CCIB 

NAME ISpivack RRasmussen 

DATE 4/21/08 4/21/08 
ENCLOSURE 

Construction Inspection Program Assessment and Enforcement, 

and ITTAC Closure Letter Workshop 

April 2nd and April 3rd, 2008 

Location: Hilton Hotel, Rockville, MD 

Meeting Attendees

Name Organization

Larry Arnold STP U3 and 4 

Molly Keefe NRC 

John Mohr MNES 

Mark Giles Entergy 

Jonathan Ortega-Luciano NRC 

Larry Walsh Shaw 

Leslie Kass NEI 

Patrick Boyle NRC 

David Deslnrers NRC 

Alan Blamy NRC 

Bob Lukes NRC 

Stanley Day UniStar 

Ron Gardner NRC 

Tony Cerne NRC 

Jefferson Rhodes MNES 

Pat Sheppard Exelon 

Les Duncan AREVA 

Jerome Blake NRC 

Julie Kug NEI 

Jim Cassidy Duke Energy 

John Mammeran Fluor 

Jim Uchiyama MNES 

Takanori Murakami MNES 

Patricia Campbell GE Hitachi 

Caroline Schlaseman MPR for Toshiba 
Russ Bell NEI 

Jason Jennings NRC 

Dave Trimble NRO 

Barry Bryant Dominion 

Mike Woods Bechtel 

Lrunero Lorlin EPRI 

Guy Davant Entergy 

Wren Flower NRC 

Tim Durkin Energetics Inc 

Michael Webb NRC 

Nian Agles STP 

Dave Bogstma Bechtel 

Julie Giles SCE&G 

Dan Manarelli AREVA 

Bob Taylor Kievit 

Goerge Khouri NRC 

Roger Lanksbury NRC 

Isabelle Schonefield NRC 

Alan Torres SCEG 

John Oddo Shaw 

Ian Spivack NRC 

James Gaslevan NRC 

Donald Lindgren Westinghouse 

Jamie Malln PSEG 

Matthew Williams Dominion 

Robert Pascarelli NRC 

Larry Arnold STP U3 and 4 

Molly Keefe NRC 

John Mohr MNES 

Mark Giles Entergy 
Jonathan Ortega-Luciano NRC 

Larry Walsh Shaw 

Leslie Kass NEI 

Patrick Boyle NRC 

David Deslnrers NRC 

Alan Blamy NRC 

Bob Lukes NRC 

Stanley Day UniStar 

Ron Gardner NRC 

Tony Cerne NRC 

Jefferson Rhodes MNES 

Pat Sheppard Exelon 

Les Duncan AREVA 

Jerome Blake NRC 

Julie Kug NEI 

Jim Cassidy Duke Energy 

John Mammeran Fluor 

Jim Uchiyama MNES 

Takanori Murakami MNES 

Patricia Campbell GE Hitachi 

Caroline Schlaseman MPR for Toshiba 

Russ Bell NEI 

Jason Jennings NRC 

Dave Trimble NRO 

Barry Bryant Dominion 

Mike Woods Bechtel 

Lrunero Lorlin EPRI 

Guy Davant Entergy 

Wren Flower NRC 

Tim Durkin Energetics Inc 
Michael Webb NRC 

Nian Agles STP 

Dave Bogstma Bechtel 

Julie Giles SCE&G 

Dan Manarelli AREVA 

Bob Taylor Kievit 

Goerge Khouri NRC 

Roger Lanksbury NRC 

Isabelle Schonefield NRC 

Alan Torres SCEG 

John Oddo Shaw 

Ian Spivack NRC 

James Gaslevan NRC 

Donald Lindgren Westinghouse 

Jamie Malln PSEG 

Matthew Williams Dominion 

Nanette Gilles NRC 

Robert Pascarelli NRC 

John Ashcraft NRC 

Kimberley Corp NRC 
CC: 

larnold@stpegs.com

Molly.keefe@nrc.gov

mgiles@entergy.com

Jonathan.ortega-luciano@nrc.gov

Larry.walsh@shawgrp.com

lck@nei.org

Patrick.boyle@nrc.gov

David.desaulnicrs@nrc.gov

Ajb3@nrc.gov

Robert.lukes@nrc.gov

Stanley.day@constellation.com

Rng2@nrc.gov

Acc1@nrc.gov

Jefferson_rhodes@mnes.us.com

Jrpatrick.sheppard@exelon.com

Leslie.duncan@areva.com

jyk@nei.org

jressily@dukeenergy.com

John.hammeran@fluor.com

Junich_uchiyama@mnes.us.com

Takanori_murakami@mnes.us.com

patriciaL.campbell@ge.com

cschlaseman@mpr.com

rjb@nei.org

jason.jennings@nrc.gov

Dct2@nrc.gov
Barry.brant@dom.com

dmwoods@bechtel.com

leloflin@epri.com

gdavant@enetergy.com

Wren.fowler@nrc.gov

tdurkin@energetics.com

Micahel.webb@nrc.gov

jungles@stpegs.com

dlpostm@bechtel.com

jmgiles@scana.com

Daniel.magnarelli@areva.com

Bob.tayro@kievit.com

George.khouri@nrc.gov

Roger.lanksbury@nrc.gov

iss@nrc.gov

atorres@scana.com

John.oddu@shawgrp.com

Ian.spivack@nrc.gov

James.gaslevan@nrc.gov

James.mallon@pseg.com

Matthew.b.williams@dom.com

Robert.pascarelli@nrc.gov

Nanette.gilles@nrc.gov

jma3@nrc.gov

Kimberley.Corp@nrc.gov