ITAAC is a critical subset of the information required for Tier 1. Since ITAAC represents the most significant licensing uncertainty (i.e., ITAAC closure is open to a public hearing prior to fuel load), ITAAC development is critical to the overall plant construction and final plant startup (or plant turnover) process. EXCEL has the best experience for the ITAAC lifecycle from development through closure. EXCEL has been a licensing lead or reviewer for Tier 1/ ITAAC for most Design Certifications (DC) reactor vendors. EXCEL has developed or worked on all Combined License Applications (COLA) ITAAC. EXCEL has been involved in first-of-kind ITAAC negotiations for various issues representing reactor vendors and utilities in developing RAI responses for the NRC and in meetings with ACRS. EXCEL played a critical role on the NEI COL and CIP Task Force. As part of this work, EXCEL worked with NEI and the industry to develop NEI 08-01, “Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52.” EXCEL worked with Southern Nuclear Company (SNC) and the NRC for first ever ITAAC closures for VEGP Units 3 & 4.
EXCEL’s extensive ITAAC experience with all aspects of the lifecycle place it in a unique position to work with new reactor vendors to develop, review, and advise throughout the DC process. Developing clear ITAAC with straightforward closure mechanisms is critical. EXCEL brings recent, relevant lessons learned from the VEGP Units 3 & 4 closure work with the NRC Construction Inspection branch to provide the best consulting advice to potential DC applicants.