**NRC INSPECTION MANUAL** CPNB

INSPECTION PROCEDURE 73054

PART 52, PRESERVICE AND INSERVICE INSPECTION - REVIEW OF PROGRAM

PROGRAM APPLICABILITY: 2504

73054-01 INSPECTION OBJECTIVE

01.01 To ascertain whether the licensee\'s program pertaining to the
Preservice Inspection (PSI) and Inservice Inspection (ISI) is in
conformance with regulatory requirements of 10 CFR50.55a and the
licensee\'s commitments and is ready to support the operation of the
facility.

01.02 To ascertain that the PSI and ISI Programs include: the proper
scope of components, inspection requirements, and have been approved.

01.03 To ascertain that the Quality Assurance Program will support
execution of the PSI/ISI programs.

01.04 To ascertain that the Repair/Replacement Program is established to
allow repairs and replacements to be made in accordance with 10 CFR
50.55a and ASME Code requirements

01.05 To ascertain that records maintenance and retention will support
execution of the PSI/ISI program.

01.06 To ascertain that proper training requirements for personnel are
established.

01.07 To ascertain that reporting requirements and methods have been
established.

01.08 To ascertain that the PSI/ISI program includes methods for
requesting relief from requirements, should the need arise.

73054-02 INSPECTION REQUIREMENTS AND GUIDANCE

[General Guidance]{.underline}: This review of the licensee\'s program
includes the PSI program of each unit and the planned ISI program of
each unit for the first 10-year interval. The inspection percentages
should be increased, as outlined in the following sections, if
inspection results reveal issues in certain areas of program
development.

The preservice inspection program consists of preservice examinations
which are performed upon completion of the construction code
requirements and completed prior to initial plant startup. These
examinations serve as the baseline for which future ISI examination
results can be compared. Preservice examination requirements are defined
in the ASME Code, Section III and Section XI.

This procedure covers all ASME Code, Section XI, ISI activities with the
exception of those items in the PSI program that are covered in the
Preoperational Test Program, which is detailed by other Inspection
Procedures indexed in Appendix F of Inspection Manual Chapter 2504. Some
licensees may have implemented a risk informed ISI program. Currently,
implementation of a risk informed ISI program requires NRC approval in
accordance with 10 CFR 50.69. If the licensee has implemented a risk
informed ISI program, obtain the submittal and the Office of New
Reactors (NRO) safety evaluation before reviewing the program.
Alternatively, support may be obtained from NRO in conducting the risk
informed ISI inspection. The risk informed approach is not applicable to
the PSI requirements.

For the purpose of this inspection procedure, the term, \"PSI/ISI
program,\" includes the PSI/ISI plan, the repair/replacement program,
and the administrative, technical, and quality assurance program and
procedures required to implement the plan.

Pursuant to 10 CFR 52.83, "... all provisions of 10 CFR part 50 and its
appendices applicable to holders of construction permits for nuclear
power reactors also apply to holders of combined licenses issued under
this subpart."

10 CFR 50.55a(g)(3)(i),states "Components (including supports) which are
classified as ASME Code Class 1 must be designed and be provided with
access to enable the performance of inservice examination of these
components and must meet the preservice examination requirements set
forth in the editions and addenda of Section XI of the ASME Boiler and
Pressure Vessel Code incorporated by reference in paragraph (b) of this
section (or the optional ASME Code cases listed in NRC Regulatory Guide
1.147, through Revision 14, that are incorporated by reference in
paragraph (b) of this section) applied to the construction of the
particular component."

10 CFR 50.55a(g)(3)(ii) states, "Components which are classified as ASME
Code Class 2 and Class 3 and supports for components which are
classified as ASME Code Class 1, Class 2, and Class 3 must be designed
and be provided with access to enable the performance of inservice
examination of these components and must meet the preservice examination
requirements set forth in the editions and addenda of Section XI of the
ASME Boiler and Pressure Vessel Code incorporated by reference in
paragraph (b) of this section {10 CFR 50.55a (ed.)} (or the optional
ASME Code cases listed in NRC Regulatory Guide 1.147, through Revision
14, that are incorporated by reference in paragraph (b) of this section)
applied to the construction of the particular component."

02.01 [Program Organization]{.underline}. Verify the following items are
included in the PSI/ISI program:

a\. Identification of all licensee commitments and regulatory
requirements pertinent to PSI/ISI testing and monitoring.

> [Guidance]{.underline}: The inspector should contact the licensing
> project manager for the site to determine the status of any relief
> requests involving PSI/ISI activities. The inspector should develop a
> list of requirements and commitments, and determine if the licensee\'s
> program provides a means of tracking requirements and commitments.
>
> If a risk informed ISI program has been adopted, the inspector should
> obtain the licensee submittal that requested use of this alternative
> method and the safety evaluation report issued by the NRC. Compare
> this material to the ISI program to ensure the requirements are meet.

b\. Preservice examination requirements for containment are included in
the PSI/ISI program plan and meet the requirements of IWE-2200 and
IWL-2200.

c\. Means of preparing plans and schedules and filing them with
enforcement and regulatory authorities having jurisdiction at the
facility.

d\. Organizational staff is available; both in number and training, so
that ISI work will be performed.

e\. Site administrative procedures to define the authority and
responsibilities of the persons or organizations involved with the final
evaluation and acceptance of ISI results for the licensee.

f\. Process for demonstrating alternative nondestructive examination
methods to the ANII in accordance with the ASME Code, Section XI.

h\. The Code edition and addenda to be used for PSI is identified.

02.02 [Program Scope and Approval]{.underline}. Verify the PSI/ISI
program, including examinations and tests, is in conformance with
relevant ASME Code, Section XI editions and addenda, and Code cases
proposed for use as part of the plan, as follows:

[Guidance]{.underline}: Pursuant to 10 CFR 50.55a(g) and ASME Code,
Section XI IWA-6000, the licensee develops PSI and ISI plans and
schedules. Exceptions to or deviations from testing requirements shall
be in accordance with those permitted by the ISI program as approved by
the NRC.

It may be necessary to obtain support from NRO to support this phase of
inspections. Contact NRO as needed to obtain the necessary support.

a\. Obtain a listing of all ASME Code, Section XI Class 1 and 2
components and welds in the PSI/ISI database.

b\. Obtain drawings of Class 1 piping systems, including vessels and
bolted connections.

1\. Utilize table IWB-2500 of the ASME Code, Section XI to verify all
Class 1 components and ensure they are listed within the PSI/ISI
database.

2\. Verify that all of the components were selected for PSI/ISI
examination as required by IWB-2200 and the tables of IWB-2500, or the
applicable risk informed ISI requirements, excluding those exempted by
IWB-1220.

3\. Verify that the proper ISI examination for Class 1 components is
identified in the database.

4\. Identify any Class 1 weld/component not included in the database.

5\. Review can be terminated once 15% of the total components on the
listing have been verified, and no Class 1 components were
inappropriately omitted from the ISI database. If components were
inappropriately omitted from the database, continue the review with an
additional 15% of the database. If no additional components
inappropriately omitted from the database conclude the review.

6\. If additional components are identified that were inappropriately
omitted from the PSI/ISI database, terminate the review and notify the
licensee and reschedule another review after the licensee corrects the
deficiencies and reviews the database.

c\. Obtain drawings showing the bolted connections and welds for three
Class 2 piping systems, including vessels. The systems selected for
inspection should be relatively large systems in comparison to other
Class 2 systems.

1\. Utilize table IWC-2500 of the ASME Code, Section XI to verify all
Class 2 components and ensure they are listed within the PSI/ISI
database. If a risk informed ISI has been approved verify the Class 2
components are listed within the ISI database.

2\. Verify that the appropriate percentages of components were selected
for PSI/ISI examination as required by the tables of IWC-2500 or the
appropriate risk informed ISI requirements.

3\. Verify that the proper ISI examination for Class 2 components is
identified in the database.

4\. If components were inappropriately omitted from the database, review
the drawings for an additional three piping systems as outlined above.
If no other components were inappropriately omitted, terminate the
review.

5\. If additional components are identified that were inappropriately
omitted, terminate the review and notify the licensee and reschedule
another review after the licensee corrects and reviews the database.

d\. For one of the Class 2 systems, conduct a detailed review of the
drawings and, if construction has commenced, walk down the system to
validate the system, ensuring all welds are depicted, and evaluate a
selection of the components chosen by the licensee for inspection to
ascertain accessibility and clearances for future in-service
inspections.

e\. Obtain drawings for ten ASME Code Class 3 vessels (preferably
different types of vessels), showing the welded attachments.

1\. Conduct a detailed review and if the vessels are present on site
verify the accuracy of the welded attachment details for five of these
vessels.

2\. Identify all the attachment welds that are part of the ASME Code,
Section XI ISI scope as identified in the tables of IWD-2500 and ensure
they are listed within the ISI database.

3\. Verify that the appropriate number of attachment welds was selected
for PSI/ISI examination as required by the table of IWD-2500.

4\. Verify that the proper ISI examination for Class 3 vessels is
identified in the database.

f\. Obtain a listing of all ASME Class 1, 2, and 3 supports in the
PSI/ISI database. Obtain, at random, 30 piping isometric drawings from
ASME Class 1, 2, and 3 systems that show pipe support designation and
location.

1\. Verify that all piping supports on these drawings are contained
within the PSI/ISI database.

2\. Verify that the proper inspections are specified for piping supports
in the PSI/ISI database.

3\. During the construction phase, the inspector should field verify
(walk down) 10 of the piping isometric drawings and checking the
accuracy of the pipe support information.

g\. Verify that any Code Cases proposed for use as part of the PSI or
ISI plans are approved by the NRC, per 10 CFR 50.55a and detailed in
Regulatory Guide 1.147, or have been approved by NRC for use as an
alternative to the Code.

h\. Verify that relief from Code requirements has been approved by NRC
to use.

i\. The inspector may utilize the latest revision of the Electric Power
Research Institute Pressurized Water Reactor Steam Generator Examination
Guidelines as guidance for the inspection.

j\. Verify that the services of an Authorized Nuclear Inservice
Inspector (ANII) have been procured and the PSI and ISI plans have been
reviewed by the ANII in accordance with Article IWA-2120 of the ASME
Code.

k\. Verify that the PSI and ISI plans have been reviewed and approved by
the licensee\'s site nuclear safety review committee, or equivalent, and
the review and approval has been documented.

l\. Verify the PSI and ISI plans have been reviewed and approved by the
ANII and review and approval has been documented.

02.03 [Quality Assurance Program]{.underline}. Verify the following
items are included in the licensee\'s and PSI/ISI contractor\'s quality
assurance programs:

a\. Procedures for the maintenance of required PSI/ISI records.

b\. QA review includes assurance that plans and procedures have been
reviewed and meet regulatory requirements.

c\. Procedures are established for the corrective action of conditions
adverse to quality as detected during examination, including provisions
to preclude repetition of such adverse conditions.

d\. Audits or surveillance of PSI/ISI activities are conducted by
qualified QA personnel to verify compliance with the ISI program.

e\. Procedures are established to effectively oversee contractor
activities concerned with ISI/PSI.

[Guidance]{.underline}: PSI and ISI activities are subject to QA audit,
monitor, surveillance, and QC inspection. The licensee\'s QA Manual and
(if applicable) contractor\'s QA Manual should cover all PSI and ISI
activities.

The QA program must be documented in accordance with 10 CFR 50 or ASME
NQA-1,\[Edition as permitted in 10CFR50.55a(b)(2)(x)\] \"Quality
Assurance Program Requirements for Nuclear Facilities, Parts II and
III.\"

02.04 [Code Repair/Replacement Program Review]{.underline}. Verify the
Repair/Replacement Program meets the requirements of the ASME Code,
Section XI, in that it includes the following:

[Guidance]{.underline}: The Repair/Replacement Program will be a
document or set of documents that defines the managerial and
administrative control for repair/replacement activities. Elements of a
repair/replacement program that the licensee\'s procedure should include
are:

a\. Identification of the Edition and addenda of ASME Code, Section XI
to be used for the repair/replacement program.

> [Guidance]{.underline}: Typically, this will correspond to the Edition
> and Addenda identified in the inservice inspection program. It is,
> however, permissible to use later Editions and Addenda of the ASME
> Code, Section XI for repair/replacement activities, provided all
> related requirements are met and NRC approval has been obtained.

b\. Requirements for the preparation of a repair/replacement plan
whenever a repair/replacement activity is to be performed.

c\. Notification of the Authorized Inspection Agency prior to starting a
repair/replacement activity

d\. Requirements for Authorized Inspection Agency approval of the
Owner's Report for Repair/Replacement Activity, Form NIS-2, upon
completion of all required repair/replacement plan activities.

e\. Means for reconciliation of Owners requirements, Code requirements,
material requirements, etc.

f\. Suitability review of replacements of failed components

[Guidance]{.underline}: If the inspector finds it necessary to conduct a
more detailed inspection of the technical aspects of the process
procedures used in the repair/replacement activity (i.e., welding, NDE),
the 55050 and 57050 series IPs should be used. The inspector, however,
should ensure that only the welding and NDE requirements of the Code
section used in the repair (normally ASME Code, Section XI with
referenced portions of Section III) are applied to the inspection of the
process procedures. Additionally, the inspector should ensure that the
licensee has evaluated all repair and replacement actions in accordance
with 10 CFR 50.59 to ensure that a license amendment is not required.

02.05 [Records]{.underline}. Verify that provisions for the maintenance
and retention of records, including inspection, examination, test
reports, repair and replacement, QA, and NDE records have been
established in the ISI program.

[Guidance]{.underline}: As required by ASME Code, Section XI, the
licensee prepares records of inservice inspection. The standard FSAR
specifies record retention periods, and ANSI N45.2.9 provides specific
guidance on retention periods and design features for a permanent record
storage facility. It is not necessary that all PSI and ISI records be
stored onsite. Special concern should be given to the acquisition and
proper storage of PSI records for the PSI performed by the component
manufacturer.

02.06 [Qualification of Personnel]{.underline}. Verify the program
specifies personnel qualification requirements consistent with the ASME
Code, and other applicable documents.

[Guidance]{.underline}: The inspector should review the licensee's
written practice and ensure qualified personnel are being used for
examinations. ANSI N45.2.6, \"Qualification of Inspection, Examination,
and Testing Personnel\" and RG 1.58, \"Qualification of Nuclear Power
Plant Inspection, Examination, and Testing Personnel\" provide guidance
to ensure that commitments to qualifications of organizational staff are
met. The inspector should also be aware of NRC/industry initiatives in
the area of qualification of procedures and personnel for ISI, such as
the EPRI Performance Demonstration Initiative for the qualification of
procedures and personnel for ultrasonic testing.

02.07 [Reporting Requirements]{.underline}. Verify that the licensee\'s
program includes the ASME Code and plant Technical Specification
requirements, as applicable, for submittal of written reports of PSI/ISI
results and repairs/replacements.

[Guidance]{.underline}: Intent of the review is to ensure the licensee's
program has provisions for submitting the required reports as outlined
in the ASME Code or any other applicable document such as a Technical
Requirements Manual or site director procedures manual. For reviews
during construction, just prior to commercial service, the inspector
should review the PSI summary report and initial ISI program, if
available and ensure they have been filed with the NRC for review, or
that the program has proper instruction to send the PSI summary report
and ISI program to the NRC.

02.08 [Relief Requests]{.underline}. Verify that the licensee\'s program
contains guidance regarding the identification and processing of
requests for relief from ASME Code requirements. Select up to 5 relief
requests (if any were requested), conduct a walk down inspection or an
ISI data review, as appropriate, and verify that the basis for the
relief requested is valid and accurate.

[Guidance]{.underline}: Requests for relief based on component
inaccessibility should be verified by performing a field inspection
(walk down) of the item for which relief was requested. For requests
based on other limitations to inspection, a review of existing NDE data
should be performed. Also, during PSI program reviews, the inspector
should verify that the relief requests do not involve matters that are
rejectable under the original system construction code (i.e., ASME Code
Section III).

73054-03 RESOURCE ESTIMATE

Total resource estimate is between 400 and 516 hours, depending on what
is identified during the inspection. The inspection hours are broken out
by sections as identified below.

03.01 [Review of the Program Organization.]{.underline} In accordance
with section 02.01, which involves a review of programmatic procedures,
should take 40 hours.

03.02 [Review of the Program Approval.]{.underline} In accordance with
section 02.02, which includes review of drawings, databases, and walk
downs, should take on the order of 300-400 hours, depending on issues
that arise.

03.03 [Review of the Quality Assurance Program.]{.underline} In
accordance with section 02.03 should take on the order of 10 hours.

03.04 [Review of the Repair/Replacement Program.]{.underline} In
accordance with section 02.04 should take on the order of 10 hours.

03.05 [Review of Records.]{.underline} In accordance with section 02.05
is included within the estimate for the review of section 02.01.

03.06 [Review of Qualification of Personnel.]{.underline} In accordance
with section 02.06 should take on the order of 16 hours.

03.07 [Review of Reporting Requirements.]{.underline} In accordance with
section 02.07 in included within the estimate for the review of section
02.01.

03.08 [Review of Relief Requests.]{.underline} In accordance with
section 02.08, which includes walk downs of specific inspection points
for which relief has been requested should take on the order of 24-40
hours.

73054-04 REFERENCES

ASME Code, Section XI, \"Rules for Inservice Inspection of Nuclear Power
Plant Components.\"

ANSI N45.2.6, \"Qualification of Inspection, Examination, and Test
Personnel.\"

ANSI/ASNT CP-189 "ASNT Standard for Qualification and Certification of
Nondestructive Personnel"

ANSI N45.2.9., \"Requirements for Collection, Storage, and Maintenance
of QA Records.\"

Regulatory Guide 1.58, \"Qualification of Nuclear Power Plant
Inspection, Examination, and Testing Personnel.\"

ANSI NQA-1, \"Quality Assurance Program Requirements for Nuclear
Facilities, Parts II and III.\"

Regulatory Guide 1.147, \"Inservice Inspection Code Case Acceptability -
ASME Section XI Division 1.\"

10 CFR 50.55a, "Codes and Standards"

10 CFR 52.83, "Applicability of Part 50 Provisions"

10 CFR 52.99, "Inspection During Construction"

73051-05 PROCEDURE COMPLETION

Transition of the ISI to the ROP will constitute completion of this
procedure.

END

Attachment 1: Revison History for IP 73054

Attachment 1

Revision History for IP 73054

+--------+--------+-----------------+------------+-------+-------------+
| Comm   | Issue  | Description of  | Training   | Tra   | Commitment  |
| itment | Date   | Change          | Needed     | ining | Resolution  |
| Tr     |        |                 |            | Compl | Accession   |
| acking |        |                 |            | etion | Number      |
| Number |        |                 |            | Date  |             |
+--------+--------+-----------------+------------+-------+-------------+
| N/A    | 07     | Initial issue   | None       | N/A   | ML070920379 |
|        | /01/08 | to support      |            |       |             |
|        |        | inspections of  |            |       |             |
|        | CN     | operational     |            |       |             |
|        | 08-019 | programs        |            |       |             |
|        |        | described in    |            |       |             |
|        |        | IMC 2504,       |            |       |             |
|        |        | NON-ITAAC       |            |       |             |
|        |        | INSPECTIONS.    |            |       |             |
|        |        |                 |            |       |             |
|        |        | Completed 4     |            |       |             |
|        |        | year search of  |            |       |             |
|        |        | historical CNs  |            |       |             |
|        |        | and found no    |            |       |             |
|        |        | commitments.    |            |       |             |
+--------+--------+-----------------+------------+-------+-------------+