Living with ITAAC. ASME Nuclear Technical Seminars: Blueprint for New Build June 5-8, 2011 Columbia, SC

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1 Living with ITAAC ASME Nuclear Technical Seminars: Blueprint for New Build June 5-8, 2011 Columbia, SC Presented by: Augi Cardillo, Ed Pleins, Thom Ray Westinghouse Electric Company

2 Definition and Purpose of ITAAC ITAAC Definition ITAAC - Inspection, Test or Analysis, and Acceptance Criteria Purpose of ITAAC The purpose of the ITAAC is to verify that an as-built facility conforms to the licensed plant design described by the AP1000 Design Control Document

3 Role of ITAAC in the Part 52 Process The role of ITAAC is to establish a set of actions and criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, the facility has been constructed and will be operated in conformity with the combined license, the provisions of the Act, and the Commission's rules and regulations. The licensee must complete all ITAAC, the NRC staff verifies successful ITAAC completion, and the Commission must find that all ITAAC are met before the licensee may operate the facility.

4 AP1000 ITAAC Breakdown ITAACs categorized into six bins to allow for easy of separating them into categories: 1. Analyses (examples are EQ testing, DAC, procurement activites, etc.) - (~120 Acceptance criteria) 2. Pre-Operational Testing - (~300 Acceptance criteria) 3. Inspections (examples are final system walkdowns, EQ reconciliations, ASME Code Stamping, etc.) - (~230 Acceptance criteria) ~ 72 ASME specific ITAACs Usually 6 per system (3 components & 3 piping) As-built Design Report, NDE of Pressure Boundary Welds, Hydrostatic (pressure) test 4. Construction Tests (examples are system hydro tests and ILRT) (~30 Acceptance criteria) 5. Security Related (security structures and design) - (~20 Acceptance criteria) 6. Non-System Based -e.g. Structures (~115 Acceptance criteria)

5 ASME Section III Process

6 RCS System Example of Design Report ITAAC. Design Commitment 2.a) The components identified in Table as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements. 2.b) The piping identified in Table as ASME Code Section III is designed and constructed in accordance with ASME Code Section III requirements. Inspections, Tests, Analyses Inspection will be conducted of the as-built components as documented in the ASME design reports. Inspection will be conducted of the as-built piping as documented in the ASME design reports. Acceptance Criteria The ASME Code Section III design reports exist for the as-built components identified in Table as ASME Code Section III. The ASME code Section III design reports exist for the as-built piping identified in Table as ASME Code Section III. How the ITAAC will be Met The as-built Design Reports for all the specified components will be verified with the N-5 Data Report. The as-built Design Reports for all the specified piping packages will be verified with the N-5 Data Report.

7 RCS System Example of NDE ITAAC. Design Commitment 3.a) Pressure boundary welds in components identified in Table as ASME Code Section III meet ASME Code Section III requirements. 3.b) Pressure boundary welds in piping identified in Table as ASME Code Section III meet ASME Code Section III requirements. Inspections, Tests, Analyses Inspection of the as-built pressure boundary welds will be performed in accordance with the ASME Code Section III. Inspection of the as-built pressure boundary welds will be performed in accordance with the ASME Code Section III. Acceptance Criteria A report exists and concludes that the ASME Code Section III requirements are met for non-destructive examination of pressure boundary welds. A report exists and concludes that the ASME Code Section III requirements are met for non-destructive examination of pressure boundary welds. How the ITAAC will be Met The NDE Reports for all the specified components will be verified with the N-5 Data Report,. The NDE Reports for all the piping packages will be verified with the N-5 Data Report.

8 RCS System Example of Hydrostatic test. Design Commitment 4.a) The components identified in Table as ASME Code Section III retain their pressure boundary integrity at their design pressure. 4.b) The piping identified in Table as ASME Code Section III retains its pressure boundary integrity at its design pressure. Inspections, Tests, Analyses A hydrostatic test will be performed on the components required by the ASME Code Section III to be hydrostatically tested. A hydrostatic test will be performed on the piping required by the ASME Code Section III to be hydrostatically tested. Acceptance Criteria A report exists and concludes that the results of the hydrostatic test of the components identified in Table as ASME Code Section III conform with the requirements of the ASME Code Section III. A report exists and concludes that the results of the hydrostatic test of the piping identified in Table as ASME Code Section III conform with the requirements of the ASME Code Section III. How the ITAAC will be Met The Hydrostatic (Pressure) Reports for all the specified components will be verified with the N-5 Data Report. The Hydrostatic (Pressure) Reports for all the piping packages will be verified with the N-5 Data Report.

9 Background & Industry Goals N-5 Code Data Report Demonstrates Construction Complete and Closes ASME ITAAC.

10 ITAAC Maintenance for the Period Between Construction Complete & the 10CFR 103(g) Finding. ASME Process Supports ASME ITAAC Closure. N-5 Code Data Report(s) Demonstrates Construction Complete and Closes ASME ITAAC. ASME ITAAC (s) are to be Satisfied When an N stamped Component is Installed & N stamped as Part of Piping System. To Reach This Point: As-built Design Report, NDE Welds, Pressure Test, etc.

11 Review Options for Repairs of N Stamped Components. Component Damaged and Requires Repair. ASME Code (Today) Provides Three Alternatives: 1. Ship Component Back to N Certificate Holder and Repair Under Section III. Not practical for Large Components. Practical for Valves. 2. N Certificate Holder has Two Options: Extend Certificate (N stamp) to Site & Repairs Under Section III. Subcontract to Site (NPT) Certificate Holder With Approved Repair Plan. 3. Repair under Owner s Section XI Program.

12 Approach for Repairs of Component & Piping Systems. Engineering Procurement Construction (EPC) Repairs to be Completed Under Existing Code Rules (Options 1 & 2). Reviewed with Authorized Inspection Agency (AIA) on How Repairs are to be Addressed & Documented. AIA Position-Options 1, 2 & 3 are in Compliance with the ASME Code (Today). EPC NA / NPT (Installer) and Major Code Component N Certificate Holder on Site to Execute Repair Plans.

13 Conclusions N-5 Code Data Report Documents Construction Complete in Accordance with Code Requirements & Closes ASME ITAAC. Continue discussion on ASME Section III to Section XI transition after System N-5 Data Report.

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