The resource estimate for conducting inspections of pre-construction activities depends on the amount of such activities occurring before a COL is issued that may support the NRC’s closure verification of ITAAC. However, the resource estimate for conducting pre-construction inspections should not exceed approximately 100 hours of direct inspection. icensees may have contractors acting as their agent but using separate QA programs. For this circumstance, additional resources may be necessary to review additional QA program. The following areas should be evaluated for each contractor to determine if QA program should be reviewed and the necessary level of review: The contractor’s scope of work; applicability of each criteria of 10 CFR Part 50, Appendix B; and The need for full or partial samples for each applicable criterion. REFERENCES NOTE: Additional references specific to Appendix 1 through Appendix 18 are included in the Reference section of that appendix. 10 CFR Part 21, “Reporting of Defects and Noncompliance.” 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities,” Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.” 10 CFR 50.55, “Conditions of permits, site permits, combined licenses, and manufacturing licenses.” 10 CFR Part 52, “Licenses, Certifications, and Approvals for Nuclear Plants.” ASME NQA-1, “Quality Assurance Requirements for Nuclear Facility Applications,” American Society for Mechanical Engineers. Inspection Manual Chapter 0613, “Documenting 10 CFR Part 52 Construction and Test Inspections.” Inspection Manual Chapter 2502, “Construction Inspection Program: Pre-Combined License (Pre-COL) Phase.” Inspection Manual Chapter 2503, “Construction Inspection Program: Inspection of Inspection, Tests, Analyses, and Acceptance Criteria (ITAAC).” Inspection Manual Chapter 2504, “Construction Inspection Program: Inspection of Construction and Operational Programs.” Inspection Procedure 65001, “Inspection of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Related Work” (NOTE: There are over 25 IPs with two numbering schemes (e.g., 65001.01 and 65001.A) that support IP 65001.)
Exhibit 1. Inspection Frequency Matrix for IP 35007 Appendices. IP Appendix # 10 CFR Part 50 Appendix B Criterion Title and IP 35007 Appendix Title Year 1: Initial Team Inspection within 6 mo. of initiation of construction activities and other QA Program Implementation Inspections QA Program Implementation QA Program Review (initial team inspection) QA Program Implementation (during initial team inspection and throughout Year 1) 1 Organization x x x 2 Quality Assurance Program x x x 3 Design Control x x x 4 Procurement Document Control x x x 5 Instructions, Procedures, and Drawings x x x 6 Document Control x x x 7 Control of Purchased Material, Equipment, and Services x x x 8 Identification and Control of Materials, Parts, and Components x x x 9 Control of Special Processes x implementation inspection through other IPs 10 Inspection x x x 11 Test Control x implementation inspection through other IPs 12 Control of Measuring and Test Equipment x x x 13 Handling, Storage and Shipping x x x 14 Inspection, Test, and Operating Status x x (if activities exist in this area) x 15 Nonconforming Materials, Parts, or Components x x x 16 Corrective Action x x x 17 Quality Assurance Records x x x 18 Audits x x x NOTE: This matrix shows the recommended periodicity for implementing each of the 18 appendices. ach appendix is considered complete when the minimum number of samples is completed within the time period . The actual inspection may be completed at any time within the given time period.
Appendix 3. Inspection of Criterion III – Design Control 35007-A3.01 INSPECTION OBJECTIVES A3.01.01 Verify that the licensee’s QA implementing documents for design control are consistent with the NRC-approved QAPD and commitments in the FSAR, including the appropriate version of NQA-1, as applicable. A3.01.02 Verify that the licensee is effectively implementing its design control program. 35007-A3.02 RELATED INSPECTION PROCEDURES AND REFERENCES 10 CFR 50.59, “Changes, tests, and experiments” COL-ISG-025, “Interim Staff Guidance on Changes during Construction under 10 CFR Part 52” IP 37805, “Engineering Design Verification Inspections” (conducted under IMC 2507) IP 65001.14, “Inspection of ITAAC-Related Installation of Complex Systems with Multiple Components” IP 65001.16, “Inspection of ITAAC-Related Engineering” IP “Inspection of the ITAAC-Related Design and Fabrication Requirements” 35007-A3.03 SAMPLE SIZE A3.03.01 This IP appendix is focused on the design activities that are associated with preserving and implementing the completed design during the construction phase after the final system designs have been completed. This can be accomplished by periodically reviewing a sample of two design changes, four field changes, and six material substitutions. In addition, inspectors should assess the implementation of the licensee’s documents for controlling the turnover of the design information from the design authority to the licensee or from multiple construction contractors to the licensee. The review of the turnover of design information should be accomplished for three systems on a one-time basis.
Affected Parameter Inspection Activity Materials/Replacement Components: • material compatibility • functional properties • environmental qualification • seismic qualification classification Verify materials/replacement components are compatible with physical interfaces. Verify that galvanic corrosion considerations have been appropriately addressed. Verify material/replacement component properties serve functional requirements under accident/event conditions. This includes potential post LOCA debris sources and blockage mitigation. Verify materials/replacement components are environmentally qualified for application. Verify replacement components are seismically qualified for the application and that seismic two over one design requirements have been appropriately considered. Verify Code and safety classification of replacement SSCs is consistent with design bases. Verify replacement schedule consistent with inservice/equipment qualification life. Timing: • sequence • response time • duration Verify that any sequence changes are bounded by accident analyses and loading on support systems are acceptable. Verify SSC response time is sufficient to serve accident/event functional requirements assumed by design analyses. Verify modified SSC response time does not cause an unintended interaction with other SSCs. Verify equipment will be able to function for the duration required under accident/event conditions. Heat Removal Verify that heat removal requirements can be addressed by support systems accident/event conditions.
Commitment Tracking Number Accession Number Date Change Notice Description of Change Description of Training Required and Completion Date Comment and Feedback Resolution Accession Number (Pre-Decisional, Non-Public Information) N/A ML16285A443 12/0816 CN 16-032 Revised to include refinements developed from implementation of this IP. Specifically provides guidance on initial program and implementation inspection samples; for subsequent years, provides guidance on the selection of QA criteria and sample recommendations; and clarifies estimated resources may vary based on end of cycle recommendations. Includes guidance regarding vendors purchasing commercial-grade calibration and testing services from domestic and international calibration and testing laboratories accredited by a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) in lieu of performing a commercial-grade survey. Furthermore, deletes requirements for team to conduct one-week in-office and one-week onsite inspection and that NRC vendor inspection branches should participate in QA inspection. N/A ML16286A675