**NRC INSPECTION MANUAL** ILPB

MANUAL CHAPTER 2514

LIGHT WATER REACTOR INSPECTION PROGRAM

STARTUP TESTING PHASE

2514‑01 PURPOSE

The purpose of startup testing phase inspection activities is to verify
that the licensee is meeting the requirements and conditions of the
facility license for precritical tests, initial fuel loading, initial
criticality, low‑power testing, and power ascension tests. This
verification is to be achieved through reviewing procedures and records,
direct observation, witnessing tests, reviewing test data, and
evaluating test results.

2514‑02 APPLICABILITY

This phase of the inspection program becomes effective approximately 6
months before issuance of the operating license and continues
approximately 1 month after the facility completes the full‑power
testing program and all results have been reviewed and accepted. This
inspection effort will overlap inspection activities directed towards
the plant operating activities (MC 2515) and preoperational test and
operational preparedness activities (MC 2513).

2514‑03 DEFINITIONS

The following definitions are used in this program description:

03.01 [Startup Testing]{.underline}. That testing conducted following
issuance of the operating license. It starts with initial fuel loading
and precritical tests, and continues until the plant reaches commercial
operating status at or near its licensed power rating. This testing is
normally performed by the operating staff, usually under the technical
guidance of the NSSS and AE startup test organization.

03.02 [Power Ascension Test]{.underline}. A portion of the startup
testing program performed following low‑power testing which involves
testing and data recording at increasing reactor power levels,
temperatures, pressures, and flows.

3.  [Startup Testing Group]{.underline}. A division of the startup test
    procedures into two groups, A and B, to facilitate the inspection
    effort and to increase its uniformity (see Table II).

2514‑04 RESPONSIBILITIES AND AUTHORITIES

04.01 [Director, Appropriate Regional Office Division]{.underline}.
Overall administration and implementation of the inspection program
outlined in this chapter for power reactors within regional boundaries.

04.02 [Chief, Appropriate Branch (Regional Office)]{.underline}.
Administration and implementation of the inspection program outlined in
this chapter for power reactors assigned.

04.03 [Section Chiefs (Regional Office)]{.underline}. Administration and
implementation of the inspection program outlined in this chapter for
power reactors assigned.

2514‑05 DISCUSSION

The bases for the licensee\'s startup testing program are contained in
Regulatory Guide 1.68, Initial Test Programs for Water‑Cooled Nuclear
Power Plants. Chapter 14 of the Final Safety Analysis Report (FSAR) and
the Safety Evaluation Report (SER) contain the specifics of the
licensee\'s approved program for startup testing. The series of tests to
be performed can be arranged as follows:

a.  Initial Fuel Loading and Precritical Tests

b.  Initial Criticality

c.  Low Power Tests

d.  Power Ascension Tests

The startup testing phase inspection program examines tests from each of
these areas.

Appendix A lists all the inspection procedures applicable to the startup
test program. Specific facility plans should be prepared for the
facility being inspected to accommodate the planned test program, the
unique organizational and administrative features, and current
regulatory requirements. Startup testing inspection requirements for
dual or twin facilities would not normally be reduced because of the
typical time lag between the two plants. In dual plant startup testing
cases, the inspector must ensure that testing procedures take proper
cognizance of the lead facility and its status.

2514‑06 STARTUP TESTING INSPECTION PROGRAM

The bulk of the Startup Testing Phase Inspection Program is accomplished
by three types of inspections: (1) test procedure review; (2) test
witnessing; and (3) test data evaluation. The degree of inspection
coverage for each inspection type is a function of the system(s) being
tested. Table I describes four system test categories (Category I, II,
III, & IV) and inspection requirements associated with each category.
Table II lists the Category I tests for both BWRs and PWRs. The tests
are split into two groups, Group A and B.

For Category I tests, all three types of inspections (test procedure
review, witnessing, and data evaluation) must be accomplished for either
Group A or for Group B, Category I tests (Table II). For power ascension
plateau testing, certain test data will also be required to be evaluated
at selected startup test plateaus. The region has the option of
selecting Group A or Group B, Category I tests. With approval of the
Regional Administrator, the region has the discretion to substitute some
Group A tests with Group B tests and vice versa. The remaining Category
I tests must be verified to have been performed under approved
procedures and a determination should be made that the evaluation by the
licensee indicates satisfactory test results.

For Category II tests, the results of test data should be evaluated for
50% of the tests (IP 72301). For the remaining Category II tests,
ascertain that approved procedures exist and make a determination that
the evaluation by the licensee indicates satisfactory test results.

For Category III tests, ascertain that approved procedures exist and
that evaluations made by the licensee indicate satisfactory test
results. No inspection activities are required for Category IV tests.

Certain procedures included in this phase of the inspection program
cannot by their nature be completed during a single inspection.
Activities such as review of procedures and manuals may also be
conducted over a relatively long time period. For these activities,
inspection time will be coded to the procedure reflecting the end
product of the inspection; however, the procedures shall not be reported
as completed until the final product inspection has been performed. As
an example, review of draft test procedures should be coded to the
inspection procedure for review of the applicable test procedure;
however, it should not be reported as complete until the approved issue
of the test procedure has been inspected.

Regulatory Guide 1.68, Revision 2, Appendix B, states that not less than
60 days before initial fuel loading the licensee should have available
for NRC regional inspectors\' review, copies of the procedures for fuel
loading, initial startup testing, and supporting activities. This is to
permit sufficient time for review before issuance of the operating
license. Failure to meet this 60‑day requirement could, in some
instances, result in a delay in issuance of the Operating License. In
order to ensure that the licensee\'s final procedure meets regulatory
requirements, the inspector may review a draft copy in parallel with the
licensee\'s final review before approval. The possession of such
procedures by the inspectors should not impede the review, revision, and
refinement of the procedures by the licensee.

Inspectors must keep informed of the expected dates of testing in order
to witness the licensee tests. Inspectors are cautioned to be certain
that licensees do not interpret requests for notification of expected
tests as \"hold points\" for the tests. Licensees are [not]{.underline}
expected to delay conduct of a test until the inspector arrives.

Following issuance of a facility license and completion of initial fuel
loading, the power ascension testing program is normally conducted on a
preplanned schedule with minimal delays. However, the schedules for
conducting power ascension testing programs may be delayed, for various
reasons, and the facilities may operate at less than full power levels
for extended periods of time. To ensure the safety of operations,
licensees must conduct a certain minimum level of testing to demonstrate
that safety‑related plant systems and equipment meet design objectives
of the licensed power levels and are capable of controlling the
anticipated transients discussed in the FSAR.

The minimum testing that must be conducted in the event of delays in the
power ascension testing schedule at reactor facilities will normally be
documented as a license condition. If unanticipated delays occur, this
information should be brought to the attention of NRR to determine if
licensing action is warranted. In no event shall testing be conducted at
power levels greater than that authorized by the facility license.

2514‑07 RESIDENT INSPECTION PHILOSOPHY

A Resident Inspector is assigned to each construction site at which
construction is more than 15 percent complete. At single‑unit
construction sites, a second Resident Inspector for operations is
assigned at the beginning of preoperational testing. The Resident
Inspector for construction activities is normally reassigned elsewhere
at some point during startup testing, after the OL has been issued. For
multi‑unit sites, units under construction have one dedicated Resident
Inspector assigned for that function. One or two Resident Inspectors for
operations are also assigned, depending on the number of units in
operation or in preoperational testing.

Once the operating license is issued, the Resident Inspector is
responsible for conduct of inspections required by MC 2515. In addition,
the Resident Inspector will likely be called upon to do inspections
described herein. It should be recognized that many of the inspections
required by the start‑up testing inspection program also satisfy routine
inspection requirements in MC 2515. As an example, witnessing of a test
would likely include most of the elements of the operating reactor
inspection program requirement for control room and plant tours (IP
71707). For reporting purposes, if an inspection is being done that
covers MC 2514 and MC 2515 activities, the time should be reported with
the appropriate MC 2514 inspection procedure.

The Resident Inspector provides the major onsite NRC presence for direct
observation and verification of a licensee\'s activities. The Resident
Inspectors are also the primary onsite evaluators for the NRC inspection
effort stemming from events or incidents. It is expected that the
greater part of initial event‑related inspection effort will be
performed by the Resident Inspector (who may be supplemented by other
inspectors depending on the type of event). Regional managers will
decide when normal inspection activities will be resumed by those
involved with inspecting the event.

The operating reactor inspection program provides for 20 percent
independent inspection for Resident Inspectors. Because of the increased
level of activities during start‑up testing and increased inspection
requirements placed on the Resident Inspector during this time, it may
be difficult to attain this goal during the startup testing phase.

This inspection program prescribes inspection activities likely to be
performed on backshifts or weekends each week. Backshift and weekend
inspections will be performed by both the Senior Resident Inspector and
Resident Inspector. The goal during the operating reactor inspection
program for backshift and weekend inspection activities is 10 percent of
an inspector\'s normal work week, averaged over a year. It is expected
that this effort will include normal inspector coverage of items in the
program (e.g., test witnessing) as well as those specifically designated
for the backshifts. During startup testing it is anticipated that normal
inspector coverage of items required by the startup testing inspection
program will fulfill this goal.

2514‑08 REGIONAL INSPECTION PHILOSOPHY

Region‑based inspectors will conduct inspection procedures as directed
by their supervisors. Region‑based inspectors often will be involved in
inspection activities of a more specialized nature than those inspection
activities performed by the Resident Inspectors. Certain aspects of
their inspection activity (i.e., portions of procedure review) may be
conducted in the regional office.

The region‑based inspector may also conduct independent inspection
activities. There is no stated goal for region‑based inspections on
backshift or for independent inspection. However, backshift inspection
will be performed whenever required to complete the inspection.

The Senior Resident Inspector must be kept apprised of region‑based
inspector activities at the facility. The appropriate Section Chief
shall ensure coordination of regional inspection activities and keep the
Senior Resident Inspector informed.

Region‑based inspectors should contact the Senior Resident Inspector
before a planned inspection to obtain information concerning the
availability of specific licensee personnel and the status of plant
conditions which may affect the planned inspection. In addition,
region‑based inspectors shall make contact with the Senior Resident
Inspector as soon as is convenient after their arrival at the site to
ensure a coordinated NRC presence at the facility. They should advise
the Senior Resident Inspector of changes to their planned inspection
effort and schedule for the licensee exit interview. The Senior Resident
Inspector will inform the region‑based inspectors of any unique
activities in progress and the region‑based inspectors will brief the
Senior Resident Inspectors about the results of their inspection before
the exit interview with licensee management. The Senior Resident
Inspector should attend all exit meetings at which significant
enforcement action or other significant unresolved issues are expected
to be discussed.

2514‑09 OPERATIONAL READINESS ASSESSMENT TEAM INSPECTIONS

The conduct of Operational Readiness Assessments Team Inspections (IP
93806) is required before issuance of the low‑power license and before
issuance of the full‑power license or during power escalation. The
inspection schedule and scope of these inspections is to be tailored to
the individual plant circumstances.

The purpose of this inspection effort is to focus on the effectiveness
of management oversight, corrective action programs, root cause
analysis, and the readiness to support operations. Results from these
inspections will provide a major input and basis for an NRC
determination of startup readiness.

2514‑10 GENERAL GUIDANCE

Although each inspection procedure contains many line items, the
individual inspector is expected to apply professional judgement
regarding the need for completing each specific line item in order to
make a decision that the objectives of the inspection procedure have
been met. The inspector may have knowledge that a basic line item
requirement has been satisfied via some other source (i.e., independent
inspection effort or temporary instruction followup). In such cases the
inspector should not perform the requirements of that specific line
item. In summary, the line items in Section 02 of inspection procedures
list the attributes which should be considered when evaluating the area
covered by the inspection procedure.

NRC inspectors perform a basic mission in determining that a licensee
operates the plant in a safe manner and meets current regulatory
requirements and commitments. Because the number of inspectors is
limited and the inspection program covers only a very small sample of
licensee activities, it is important that the inspector verify that the
licensee is addressing the root cause of identified problems rather than
just the correction of symptoms. Thus the inspector should verify that
the licensee has a program that evaluates whether or not a noncompliance
or a deficiency represents an isolated case or whether it may signify a
broader more serious problem in that area. To provide the perspective to
perform this evaluation of the licensee\'s performance, the inspector
should:

a.  Keep currently informed of deficiencies, audit findings, and plant
    problems identified by the licensee\'s own organization.

b.  Ascertain whether additional personal inspection effort is merited
    in the area under consideration.

Where the evidence indicates that an uncorrected problem may exist,
Regional action should be employed to require the licensee to
demonstrate to the NRC that it has not lost control of that area.
Regional supervision should be consulted whenever enforcement action
appears appropriate to the individual inspector.

END