A combined license enables the licensee to construct a plant and to operate it once construction is complete if certain standards identified in the combined license are satisfied. These standards are called Inspections, Tests, Analyses, and Acceptance Criteria, or ITAAC. The ITAAC are typically derived from one of two sources. The majority of ITAAC are from the design certification for the particular reactor technology the plant uses. The remaining ITAAC are site specific, and are submitted in the licensee's combined license (COL) or early site permit (ESP) applications. For more information, see the following topics on this page:
As required by 10 CFR 52.97(b), the ITAAC identified in the combined license are necessary and sufficient, when successfully completed by the licensee, to provide reasonable assurance that the facility has been constructed and will operate in conformity with the combined license, the provisions of the Atomic Energy Act of 1954, as amended (AEA), and the Commission's rules and regulations. The COL includes ITAAC submitted in the COL application in addition to incorporating any ITAAC from referenced early site permits and standard design certifications, with the exception of referenced ITAAC whose acceptance criteria the Commission finds have been met when issuing the COL. Both the design certification and site specific ITAAC may be found in Appendix C of a given COL.
During construction, the licensee is responsible for performing all inspections, tests, and analyses and ensuring that the specified acceptance criteria are met. Throughout the construction process, NRC inspectors will perform inspections based upon Inspection Manual Chapter 2503, "Construction Inspection Program: Inspections of Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) Related Work," and the NRC's Construction Inspection Program at the plant site to confirm that the licensee has successfully completed the ITAAC. For every completed ITAAC, the licensee must submit to the NRC an ITAAC Closure Notification (ICN) as required by 10 CFR 52.99(c)(1). The NRC staff will review each ICN to verify that the ITAAC have been successfully completed, and will periodically publish a record of these reviews in the Federal Register to inform the public of successfully completed ITAAC. These Federal Register notices will be published until the deadline for hearing requests related to ITAAC completion, but the NRC website will be updated throughout construction to reflect the NRC staff's determinations (see "ITAAC Status Report" later on this page).
In accordance with 10 CFR 52.99(c)(2), after a licensee has completed an ITAAC and submitted the ICN, the licensee is required to report new information materially altering the basis for determining that a prescribed inspection, test, or analysis was performed as required, or finding that a prescribed acceptance criterion is met. These notifications, called ITAAC Post-Closure Notifications, must document how the licensee successfully resolved the issue.
For any ITAAC that have not been successfully completed at least 225 days prior to the scheduled date for initial loading of fuel, 10 CFR 52.99(c)(3) requires the licensee to submit an Uncompleted ITAAC Notification stating that all inspections, tests, and analyses will be performed and the prescribed acceptance criteria will be met, and explain the licensee's plans for completing all ITAAC that have not yet been completed. This notification can be used by the public to determine if a hearing request on an uncompleted ITAAC is warranted.
For more information please see the "ITAAC Verification Closure Process (IVCP) Office Instruction, NRO-REG-103."
In accordance with 10 CFR 52.103(a), the licensee must notify the NRC of its scheduled date for initial loading of fuel no later than 270 days before the scheduled date. The NRC must subsequently publish a notice of intended operation in the Federal Register. This notification allows any person whose interests may be affected by plant operation the opportunity to request a hearing within 60 days of the publication of the Federal Register notice on whether the facility as constructed complies, or on completion will comply, with the acceptance criteria in the combined license. The NRC intends to publish the notice of intended operation 210 days before scheduled fuel load, although the NRC may publish this notice up to 75 days earlier than that if the uncompleted ITAAC notifications are submitted earlier than required and certain other prerequisites are satisfied.
As required by 10 CFR 2.309, a hearing request will not be granted unless it includes a showing of standing and an admissible contention. In accordance with AEA § 189a.(1)(B), the contention standards include the requirement that the petitioner show, prima facie, (1) that one or more of the acceptance criteria have not been, or will not be, met, and (2) that this nonconformance with the acceptance criteria will have specific operational consequences that are contrary to providing reasonable assurance of adequate protection of the public health and safety. If a hearing request is granted, the Commission will issue a case-specific order with procedures governing the conduct of the hearing.
A summary of the ITAAC hearing process is available. Detailed information on the ITAAC hearing process can be found in the July 1, 2016 "Final Procedures for Conducting Hearings on Conformance With the Acceptance Criteria in Combined Licenses," (81 FR 43266).
Transition from Construction to Operating Reactor
Upon successful completion of all ITAAC, 10 CFR 52.99(c)(4) requires the licensee to submit an All ITAAC Complete notification to the NRC. If the NRC staff verifies that all ITAAC acceptance criteria are met, it will find under 10 CFR 52.103(g) that all acceptance criteria are met. The licensee cannot operate the facility until this finding has been made. In the event that a hearing request on the ITAAC has been granted, interim operation during the pendency of the hearing may be authorized under 10 CFR 52.103(c) if the Commission determines that there is reasonable assurance of adequate protection of the public health and safety during the interim period.
For more information on how the NRC makes the 10CFR52.103(g) finding, see Office Instruction LIC-114 (NRR) / REG-106 (NRO) ML20055E096, "Title 10 of the Code of Federal Regulations (10 CFR) Section 52.103(g) Finding and Communication Process". This office instruction describes the specific steps necessary to make the 10 CFR 52.103(g) finding, describes communications with the Commission during the final year of construction for a Part 52 licensed facility and provides templates associated with these activities. The staff’s finding that all acceptance criteria in the combined license are met is required prior to operation.
Plant-Specific ITAAC Information
Plant specific information for each unit under construction, including additional information related to ITAAC closure and related inspection activities, can be found at the following links: Vogtle Unit 3 and Vogtle Unit 4.
Page Last Reviewed/Updated Wednesday, December 09, 2020