ATTACHMENT 65001.06

INSPECTION OF ITAAC-RELATED INSTALLATION OF

MECHANICAL COMPONENTS

PROGRAM APPLICABILITY: 2503

65001.06-01 INSPECTION OBJECTIVES

01.01 To determine whether mechanical component installation and related
licensee quality control activities are being performed in accordance
with design specifications, Code requirements, approved procedures, and
regulatory requirements.

01.02 To determine whether ITAAC-related mechanical component tests and
verification activities are being conducted in accordance with design
specifications, approved procedures, and design criteria.

01.03 To determine whether mechanical component installation welding is
being conducted in accordance with design specifications, Code
requirements, and approved procedures.

01.04 To determine whether mechanical component installation records,
welding records, and test/verification records reflect work
accomplishment in accordance with design specifications, Code
requirements, and approved procedures.

01.05 To evaluate the adequacy of the implementation of the specific
quality assurance program requirements related to mechanical component
installation activities and verify that problems are entered into the
corrective action process.

65001.06-02 INSPECTION REQUIREMENTS AND GUIDANCE

For purposes of this procedure, Mechanical Components include all
classes (ASME and non-safety) of various types of equipment (e.g.,
pumps, heat exchangers, strainers, unique steel support structures for
components, fabricated metal tanks, the Pressurizer for PWRs, and the
Steam Generators for PWRs). It does not include valves, HVAC equipment,
pipe supports, or the reactor vessel.

02.01 [General Installation.]{.underline} Select a sufficient number of
mechanical component ITAACs covering general installation requirements
for review. Through direct inspection, confirm the following attributes,
as applicable, have been met:

a\. Installation requirements including: proper location and placement,
volume, area dimensions, quantity, material type/shape/size, special
features such as coatings and insulation, orientation, alignment,
seismic and other mounting requirements (i.e., torquing or tightening of
nuts, bolts and expansion anchors), flow direction, tolerances, and
expansion clearance. Requirements can be located in engineering
drawings, engineering specifications and the work packages.

b\. Adhere to the precautions which can if followed prevent damage
during placement and mounting.

c\. Availability and use of specially trained personnel and special
tools or equipment which conforms to the manufacturer\'s instructions.

d\. Correct drawings and work procedures are available to installers.
Installation requirements, construction drawings, specifications, and
work procedures are the latest revisions.

e\. Hold points are observed and quality inspections are properly
conducted, as required.

f\. Lifting and rigging are in accordance with procedures and
requirements.

g\. Installation cold setting locations meet requirements.

h\. Preparation of installation and inspection records meet quality
program requirements.

i\. Field changes that apply to the work being observed have been
correctly processed.

[Guidance:]{.underline} For components, the inspector should pay
particular attention to the traceability of material and equipment to
prevent the use of incorrect or defective materials, parts and
components. The inspector should ensure that required identification of
the item is maintained by heat number, part number, serial number or
other similar means, either on the item or on records traceable to the
item, and that required markings are on the item.

In the case of fasteners, compliance with the material specification
(e.g., ASTM or ASME material and grade) should be verified by required
markings on the bolts and nuts and the certified material test reports
or certificates of conformance as required by the procurement drawings
and specifications and/or by the codes and specifications.

In the case of vendor‑supplied equipment assemblies containing
fasteners, samples should be inspected to verify compliance with
approved vendor drawings and specifications and other information such
as materials used for equipment qualification tests and/or analyses.

Field observations can include independent measurement/observation or
observation of licensee/contractor inspections. While all applicable
attributes do not need to be reviewed for each sample, the majority
should be reviewed and samples/attributes reviewed should include all
facets of installation activities.

Records should document the status of the installed component. They
should confirm required inspections have been performed by appropriately
qualified personnel. And, they should confirm all critical installation
and ITAAC requirements have been met. The records should be properly
stored in accordance with quality assurance requirements.

Typical problems which can occur in this area include, but are not
limited to:

\- Inadequate or unclear guidance for installers and inspectors.

\- Use of improper or uncalibrated tools for installation and
measurement.

\- Weak management coordination which can result in skipped hold points
or other errors in installation.

\- Record storage and/or retrieval problems.

Generic QA implementation processes, such as receiving inspections and
component and records storage, are inspected separately, however, the
inspector should remain mindful of any problems that reflect on
performance in these areas and report these to the NRC regional
inspectors for that task area.

02.02 [Component Welding.]{.underline} If welding is required for
component installation (other than pipe welding), select a sufficient
sample of welds to review so that the inspection objectives will be
demonstrated. Confirm the applicable attributes listed in IP 65001.B,
"Welding", have been met.

[Guidance:]{.underline} The inspector should determine what specific
acceptance criteria are specified in the ITAAC including those
associated with the attributes and select those that are best confirmed
through observation. Others should be confirmed through record/data
review.

The samples should include sufficient variety to assure the different
welding processes and material combinations are observed for each
subcontractor, group or division performing ITAAC related welding. This
scope applies to both observations and record reviews. A variety of
nondestructive examination processes should also be included in the
inspection sample.

Records should provide traceability to all aspects of the welding
activity including weld procedures used, welders, material
certifications, inspections performed and their results, inspectors, and
qualification record for procedures and personnel. These records,
including radiographs, should be retained and stored in accordance with
QA requirements.

02.03 [Post Installation Activities.]{.underline} Select a sufficient
number of mechanical components to enable implementation of the
inspection objectives. The selected components should be from several
different systems and, if possible, fabricated/installed by different
subcontractors. The selection should emphasize, but must not be limited
to, the components previously selected for Section 02.01. Confirm the
following actions are completed for these components.

a\. Licensee surveillance activities are being performed according to
instructions.

b\. Protection is provided as required, including protection against
such conditions as adverse temperature, humidity, flooding, and foreign
materials, such as dirt, dust, soda cans, and general debris.

c\. Lubrication, rotation, and electrical resistance checks are being
performed, if required.

d\. Records are being maintained, recording the status of installed
components.

e\. Recording methods such as; stamps, tags, markings, etc. are being
used to prevent omission of inspections by the licensee: to record the
completion of tests; to record acceptances; and preclude inadvertent
operation.

[Guidance]{.underline}: Post installation activities should be observed
throughout the construction period frequently enough to allow formation
of a conclusion that mechanical components, equipment, and supports are
properly serviced or maintained, if required, until final turnover.

02.04 [Testing and Verification]{.underline}. Select ITAAC-related
mechanical component testing activities to assure testing is conducted
in accordance with approved procedures and that test acceptance criteria
have been met.

[Guidance]{.underline}: The inspector should investigate the specific
acceptance criteria that were established and select for observation
those that are best confirmed through observation. Others should be
confirmed through record/data review. The inspector should try to focus
on those testing activities related to the more safety-significant
systems.

02.05 [Problem Identification and Resolution:]{.underline} The inspector
should confirm that problems identified during the inspection were
entered into the licensee/constructor corrective action program in
accordance with program requirements. In order to check the extent of
condition and confirm the effectiveness of the licensee=s corrective
measures, the inspector should review licensee actions to address
similar or related problems that were previously identified.

[Guidance:]{.underline} This inspection is to verify that problems are
entered into the corrective action process and that corrective actions
appropriate to the circumstances, are developed and undertaken. The
inspector should review the relative priority of the actions, to verify
that those most important to safety are acted on most swiftly.
Inspections of Quality Assurance Program implementation, effectiveness
of Problem Identification and Resolution, and Self-Assessment will be
performed under the MC 2504 inspection program.

65001.06-03 RESOURCE ESTIMATE

Inspection resources necessary to complete this inspection procedure are
estimated to be 1600 hours of direct inspection effort over the course
of plant construction.

65001.06-04 REFERENCES

Generic Letter 81‑07, \"Control of Heavy Loads\" (Microfiche locations
7964/024,7900/310, and 90191/292)

NUREG‑0612 \"Control of Heavy Loads at Nuclear Power Plants\"
(Microfiche location 6411/280)

Regulatory Guide 1.14, Reactor Coolant Pump Flywheel Integrity

Regulatory Guide 1.36, Nonmetallic Thermal Insulation for Austenitic
Stainless Steel

Regulatory Guide 1.44, Control of the Use of Sensitized Stainless Steel

Regulatory Guide 1.54, Service Level I, II and III Protective Coatings
Applied to Nuclear Power Plants

Regulatory Guide 1.84, Design and Fabrication Code Case Acceptability,
ASME Section III, Division 1

Regulatory Guide 1.143, Design Guidance for Radioactive Waste Management
Systems, Structures, and Components Installed in Light-Water-Cooled
Nuclear Power Plants

END

Attachment 1: Revision History

Attachment 1

Revision History for 65001.06

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| Comm   | Issue  | Description of Change  | Trai | Tr     | Comment    |
| itment | Date   |                        | ning | aining | Resolution |
| Tr     |        |                        | Ne   | Comp   | Accession  |
| acking |        |                        | eded | letion | Number     |
| Number |        |                        |      | Date   |            |
+--------+--------+------------------------+------+--------+------------+
|        | 04     | Researched commitments | N/A  | N/A    | N/A        |
|        | /18/08 | for 4 years and found  |      |        |            |
|        |        | none.                  |      |        |            |
|        | CN     |                        |      |        |            |
|        | 08-012 | Initial issuance       |      |        |            |
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