**NRC INSPECTION MANUAL** DQAVT

MANUAL CHAPTER 2530

INTEGRATED DESIGN INSPECTION PROGRAM

2530‑01 PURPOSE

The purpose of this chapter is to describe the methodology for
performing multidisciplinary integrated design inspections (IDIs) at
nuclear power plants.

2530‑02 OBJECTIVE

The objective of the IDI program is to gain additional assurance that
the design process for a selected facility effectively implemented NRC
regulations and the design commitments made in the Final Safety Analysis
Report (FSAR). The inspections encompass the total design and
architectural criteria through the development of the design details.
The inspection should:

a.  Verify that regulatory requirements and design bases as specified in
    the license application, are correctly implemented in
    specifications, drawings, calculations, and procedures.

b.  Verify that the correct design information has been provided to the
    responsible design organizations.

c.  Verify that design engineers have sufficient technical guidance and
    experience to perform assigned engineering functions.

d.  Verify that design controls, as applied to the original design, have
    also been applied to design changes, including field changes.

The inspection will include onsite verification of the design on a
sampling basis.

2530‑03 DEFINITIONS

03.01 [Finding]{.underline}. A finding is a deficiency, unresolved item,
or observation identified during the IDI.

a.  [Deficiency]{.underline}. A deficiency is an item which is an error,
    inconsistency, or procedural violation with regard to licensing
    commitments, specifications, procedures, codes, or regulations that
    is identified during the IDI. Followup action is required for
    licensee resolution of the deficiency and NRC evaluation of the
    resolution.

b.  [Unresolved Item]{.underline}. An unresolved item is a question that
    requires more information to reach a conclusion. Licensee response
    and NRC evaluation are required.

c.  [Observation]{.underline}. An observation is an item the inspection
    team considers appropriate to call to the attention of the licensee
    although it is neither a deficiency nor an unresolved item. It can
    include items recommended for licensee consideration that have no
    specific regulatory requirement. Licensee response is not required.

03.02 [Potential Enforcement Finding]{.underline}. An apparent
noncompliance with specific regulatory requirements or deviation from
specific commitments made by the applicant that to identified during the
IDI.

03.03 [Draft Inspection Report]{.underline}. All versions of the
inspection report from its initial development, throughout the period of
supervisory and management review, until final publication and
distribution in accordance with IE Manual Chapter 0611. The preliminary
draft inspection report provides the account and conclusions of an
official NRC inspection.

03.04 [Inspection]{.underline}. An inspection is the examination,
investigation, review, or evaluation of any record or activity of a
licensee or licensee contractor to determine the safety significance of
that record or activity and/or to ensure compliance with any rule,
order, regulation, or license condition pursuant to the Atomic Energy
Act.

03.05 [Inspection Report]{.underline}. An inspection report is the
final, published, written record of an inspection. It includes the
inspection results obtained during the site inspection as well as the
results of in‑office inspection activities conducted before and after
the actual travel to the site.

03.06 [Licensee]{.underline}: The holder of an NRC operating license or
construction permit.

03.07 [Construction Appraisal Team Inspection (CAT)]{.underline}.
Multi‑discipline inspection performed to assess the quality of
construction and hardware installation activities on a nuclear power
plant project. A CAT may precede or follow an IDI inspection for a
specific or replicate plant.

2530‑04 RESPONSIBILITIES AND AUTHORITIES

04.01 [Director, Office of Inspection and Enforcement]{.underline}.
Selects facilities to be inspected, on the basis of information received
from NRC offices at headquarters and in the regions, and issues the
results of inspections.

04.02 [Director, Division of Quality Assurance, Vendor and Technical
Training Center Programs, IE]{.underline}. Administers the IDI program.

04.03 [Chief, Quality Assurance Branch, IE]{.underline}. Implements the
IDI program.

04.04 [Regional Offices]{.underline}. Assist the Office of Inspection
and Enforcement, as needed, in management of followup actions resulting
from the IDIs, including enforcement action.

2530‑05 INSPECTION CONCEPT

05.01 IDIs at nuclear facilities are comprehensive examinations of the
development and implementation of the design for a selected system of
the facility being inspected. Conclusions about the overall design
process may then be drawn based on the results for the selected sample.
The inspection is a multidisciplinary review including, as a minimum,
areas such as mechanical systems and components, electric power, civil
and structural design, and instrumentation and control. The primary
focus is on assessment of the implemented design control process for the
organization(s) and subcontractor(s). The process is evaluated by
examining actual design details. If errors are found in the design
details, the design process is evaluated to see if the error resulted
from an isolated mistake or if it reflects a more fundamental weakness
in the design process. Also the pervasiveness of a design error or
weakness is evaluated including inspecting that aspect of design in
other sectors of the plant design. An evaluation is performed to
identify consistent weaknesses in the design process such as \"lack of
FSAR control\", \"lack of verification of design calculations\" or
\"lack of documentation of engineering judgment made in the design
process\".

An IDI is normally implemented by the following process:

a.  The scope and depth of the inspection for a particular facility is
    determined using the guidelines provided in b, c, and d below, as
    appropriate. The scope of the inspection is defined during the
    planning and preparation phase, and appropriate revisions are made
    as the inspection progresses.

> The planning process includes development of a logic or flow network
> of the design process. Each fundamental entity within the design
> organiza­tion will be identified. For each of these entities, internal
> and external design information will be determined. From this network,
> critical design areas will be identified. Based on the results of the
> above evaluation, a specific sample such as a portion of a system will
> be inspected.

b.  A comprehensive inspection is performed for a specified sample
    system(s) which typically has some or all of the following
    characteristics:

    1.  essential to plant safety

    2.  designed by the architect‑engineer (AE)

    3.  a clearly defined design basis

    4.  generally representative of safety‑related features in other
        systems

    5.  design involving internal interfaces between functional areas
        listed in 06.04c and external interfaces with the NSSS vendor,
        component vendors, and engineering service organizations

    6.  major portions already installed in facility

    7.  inspected by a preceding CAT thereby providing for an in‑depth
        vertical sample examination of a particular system from design
        through construction

c.  Some inspection will be conducted beyond the sample system(s), as
    needed, to test specific areas or functions.

d.  Results of PRA studies also should be considered when selecting the
    sample system(s) to be inspected.

e.  An evaluation of any program weaknesses identified by a preceding
    CAT inspection of the same facility which could have root causes in
    the design or the design process should be made.

f.  The inspection covers topics such as:

    1.  validity of design inputs and assumptions

    2.  validity of and conformance to design specifications

    3.  validity of analyses

    4.  system interface requirements

    5.  inadvertent synergistic effects of changes

    6.  proper component classification

    7.  revision control

    8.  documentation control

    9.  verification of the design

    10. verification of the as‑built condition

2530‑06 PROGRAM GUIDANCE

06.01 [Program Timetable and Scope]{.underline}. IE management will
determine the frequency of IDIs. The scope of the inspection at a
particular facility is to accomplish a multidisciplinary inspection of
the total design process and, within a given discipline, to focus
primarily on the potential areas of concern. Typical factors to be
considered in the inspection plan development and implementation are
delineated in the following sections.

The following is a typical schedule for an IDI:

+------------------------------------------------------------+---------+
| [IDI Activity]{.underline}                                 | Time    |
|                                                            |         |
|                                                            | All     |
|                                                            | ocation |
|                                                            |         |
|                                                            | [       |
|                                                            | (Weeks) |
|                                                            |  ]{.und |
|                                                            | erline} |
+============================================================+=========+
| Team Leader Planning                                       | 4       |
|                                                            |         |
| -   Licensee Notification                                  |         |
|                                                            |         |
| -   Schedule Preparation                                   |         |
|                                                            |         |
| -   Inspection Team Selection                              |         |
|                                                            |         |
| -   Information Acquisition                                |         |
|                                                            |         |
| -   Meetings with Regional Office, Licensee, AE and NSSS   |         |
+------------------------------------------------------------+---------+
| Team Preparation                                           | 1‑2     |
|                                                            |         |
| -   Team Indoctrination Meeting                            |         |
|                                                            |         |
| -   Review of Background Material                          |         |
|                                                            |         |
| -   Preparation of Draft Inspection Plans                  |         |
+------------------------------------------------------------+---------+
| Onsite and AE Entrance Meetings                            | 1       |
|                                                            |         |
| -   Initial Plant Walkdown                                 |         |
|                                                            |         |
| -   Inspection of Licensee Engineering Organization        |         |
|                                                            |         |
| -   Initiation of Inspection of AE                         |         |
+------------------------------------------------------------+---------+
| Inspection Plan Refinements and Additional Review of       | 1       |
|                                                            |         |
| Background Material                                        |         |
+------------------------------------------------------------+---------+
| Inspection of the AE                                       | 3‑4     |
+------------------------------------------------------------+---------+
| Other Needed Inspections (e.g., onsite, NSSS, vendors,     | 1       |
|                                                            |         |
| subcontractors, etc.)                                      |         |
+------------------------------------------------------------+---------+
| Documentation of Inspection Results and Completion of      | 4‑6     |
|                                                            |         |
| IDI Report                                                 |         |
+------------------------------------------------------------+---------+
| Licensee Review and Response to IDI Report                 | 8       |
+------------------------------------------------------------+---------+
| Review of Licensee Report and Reinspection                 | 4       |
+------------------------------------------------------------+---------+
| Identification of Potential Enforcement Findings to        | 4       |
|                                                            |         |
| Region for Followup                                        |         |
+------------------------------------------------------------+---------+

06.02 [Team Member Assignments]{.underline}. Inspector assignments to
the IDI shall be based on the expertise needed to implement the scope of
the inspection planned for a particular facility. Consideration will be
given to assignments of CAT team members to the IDI, particularly those
who have or are expected to participate in a CAT inspection on the same
or a replicate plant.

06.03 [Information Acquisition]{.underline}. Before the initiation of
the team planning phase for a facility inspection, the Team Leader or
his representative will contact and/or meet with representatives of the
licensee, as necessary, to identify and obtain the background
information needed for inspection preparation. The needed information
must be available to the team for the efficient development of a
meaningful specific inspection plan.

06.04 [Inspection Planning and Preparation]{.underline}

a.  A key element for a successful team inspection is detailed planning
    and preparation. The objectives of planning and preparation are:

    1.  to identify those elements that are applicable to the specific
        facility inspection

    2.  to formulate a detailed inspection plan appropriate for the
        particular facility (The inspection plan should be a guide for
        performing inspections and should be revised based on the
        results of ongoing inspection activities.)

    3.  to make specific functional assignments to each team member

    4.  to define inspection schedules

    5.  to familiarize the team members with the organization(s)
        performing design and engineering services for the selected
        facility

    6.  to familiarize the team members with the latest version of the
        documentation that defines the design (such as the FSAR, design
        procedures, specifications, design criteria, and drawings.)

    7.  to indoctrinate team members to the team concept

> Before the start of the inspection, the Team Leader should conduct an
> indoctrination for the team members of the IDI concept. The
> indoctrina­tion should address plans for the inspection, background and
> guidance material, significant items pertinent to licensing, and
> design‑related items identified by the regional offices and the Office
> of Nuclear Reactor Regulation (NRR). The entire IDI team should
> participate in selecting the sample system to be inspected, consistent
> with the inspection objectives. Announcement of the sample system(s)
> to be inspected should not be made until just before the initiation of
> the IDI to preclude inappropriate biasing of the activities to be
> inspected. In that regard, a design work inspection cutoff date should
> be established for the inspection. The cutoff date should be the same
> date as the announcement of the sample system(s) to be inspected. The
> inspection work products should be discussed with the team, including
> information flow charts; report outlines, inspection plans, progress
> reports; details of deficiencies, or unresolved items and observation
> forms; personnel forms; area analysis forms; and other inspection
> report inputs.

b.  The team member(s) assigned a functional area should develop an
    inspection plan for that area. The team members will use the
    following materials in planning the details of and preparing for the
    inspection, especially those portions pertaining to the sample
    system(s) to be inspected.

    1.  Safety Analysis Report

    2.  Probabilistic Risk Assessment Report (where available)

    3.  NRR Safety Evaluation Report

    4.  Inspection history including:

        a.  previous CAT inspection obtaining information on any
            problems requiring further investigation during the IDI

        b.  special NRR audits and reviews in design and engineering

        c.  Vendor Program Branch and regional audits of AE, NSSS, and
            vendors involved in design and engineering

        d.  Systematic Assessment of Licensee Performance (SALP) reports

        e.  Institute of Nuclear Power Operations (INPO) evaluations of
            design or engineering

        f.  Independent Design Verification Program (IDVP) evaluations

        g.  inspection reports of site design activities including those
            of the resident inspector

    5.  10 CFR 21 and 50.55(e) reports

    6.  organization charts ‑ These charts provide the inspectors with
        an overview of the management interfaces, communication
        channels, and the identification of management personnel. Each
        inspector must develop an understanding of the organization and
        identify those managers and supervisors to be contacted. Of
        particular importance are the current project organization
        charts for licensee, NSSS, AE, and field engineering/design
        (including name of assignee) along with the changes in
        organization and personnel that have occurred over the course of
        the project.

    7.  organizational arrangements ‑ The degree to which the licensee
        acts as its own AE, use of consultants and subcontractors to the
        AE are primary sources into the evaluation of interface
        effectiveness. The team should obtain a list of all contractors
        and subcontractors doing engineering and design work for the
        licensee or one of its prime agents, including a scope of work
        for each contract.

    8.  licensee engineering organization(s) procedures:

        a.  AE engineering/design control procedures and QA procedures
            related to design including those related to any existing
            engineering assurance program

        b.  flow diagrams indicating the flow of design information in
            the AE organization

        c.  design and engineering procedures required for contractors
            and subcontractors

        d.  listing, definition of scope, and requirements for
            engineering and design work being done in the field

        e.  NSSS and AE documents indicating the scope of and procedure
            for design information exchange between the NSSS and AE.

        f.  licensee procedures indicating how it gets involved in the
            design process (e.g., by reviewing completed AE work)

        g.  quality assurance manual indexes for all organizations
            performing design work in the project

    9.  NRC‑Licensee correspondence ‑ questions and answers, principal
        meetings or special studies, and licensee or AE correspondence
        listing principal commitments and action items in response to
        NRC concerns.

    10. Licensee engineering organization documentation:

        a.  AE general design criteria

        b.  AE and NSSS system descriptions describing design bases,
            system functions and operation, component data and
            instrumentation requirements

        c.  listing of engineering, design, and purchase specifications

        d.  system flow diagram showing flow paths and calculated flows,
            temperatures, and pressures for various conditions of
            operation

        e.  piping and instrumentation diagrams for the sample system
            and interfacing systems, including symbols and legend
            diagrams

        f.  list of calculations and analyses

        g.  significant reports, meeting minutes, letters, etc., related
            to progress, status, or control of the engineering and
            design process

    11. Construction Status Information ‑ stage of completion will
        dictate the scope and types of inspections and evaluations
        appropriate for a particular discipline.

c.  The planning and preparation stage should result in initial
    inspection plans to ensure that the objectives of this chapter are
    met. For each functional area, one team member will be assigned the
    lead for preparing an inspection plan for that functional area. It
    is the responsibility of the Team Leader to integrate the proposed
    plan/schedule/activities of that functional area into an overall
    team plan and to coordinate the inspection activities. The Team
    Leader should ensure that the overall team plan makes provision for
    analyses identifying findings having similar root causes including
    all deficiencies, unresolved items and observations. The analyses
    should identify significant design and design process weaknesses
    which appear to be pervasive across plant systems and functional
    areas.

> Inspection plans should be formulated to address the following
> functional areas, as a minimum:

1.  mechanical systems

2.  mechanical components

3.  civil and structural

4.  electric power

5.  instrumentation and control

> Additional guidelines to be considered in the inspection plan
> development and implementation both generally and for each specific
> functional area are delineated in Appendix A to this chapter.
>
> The initial inspection plans may be revised as the inspection
> progresses, based on inspection results. The Team Leader is
> responsible for arranging/directing changes to the initial inspection
> plans.

2530‑07 INSPECTION CONDUCT AND DOCUMENTATION

07.01 [General]{.underline}. All team members should remain with the
team for the duration of the inspection with no other duties. Team
members will conduct the inspection in accordance with the program
guidance in 06. The Team Leader will conduct coordination meetings of
all team members, as needed, to discuss status of activities and
findings. As a result of such meetings, team members may be given
additional assignments or their effort may be redirected.

Documents pertinent to the IDI that are provided to team members,
although not marked proprietary, may contain proprietary information. In
similar manner, documents such as specifications that are reviewed in
the licensee\'s offices may contain proprietary information. All such
material handled during an IDI will be treated as potentially
proprietary. Team members will not make further copies or disclosure of
documents received during the inspection. All such documenta­tion will be
returned to the licensee when the inspection is completed.

All non‑NRC team members will be required to sign the \"Agreement\" and
\"Informa­tion Concerning Potential Conflict of Interest\" forms enclosed
as Appendix B.

07.02 [Entrance and Exit Interviews]{.underline}

a.  An entrance interview between applicant management and all IDI team
    members shall be held before starting the onsite inspection. The
    regional office is encouraged to be represented at this meeting. IP
    30703, \"Management Meeting ‑ Entrance and Exit Interviews,\" should
    be used as guidance when conducting the entrance interview.

b.  An exit interview shall be held between senior applicant management,
    senior IE management, and the IDI team. The regional office is
    encouraged to be represented at this meeting. The exit interview
    will be used to summarize the findings and to convey the
    significance thereof to senior applicant management. The results of
    the inspection shall be openly and freely discussed, but the results
    or findings shall [not]{.underline} be given the applicant in
    writing. This will ensure that preliminary information is not
    provided \"via draft reports\" before the final report is issued.

07.03 [Inspection Documentation]{.underline}. The team will prepare an
inspection report to be issued by the Director, IE, that documents all
findings (i.e., deficiencies, unresolved items, and observations)
identified during the inspection. The inspection report will conform to
the requirements of IE Manual Chapter 0610, Inspection Reports. No
disclosure of inspection notes (preliminary or draft inspection report
materials developed by IDI team members) will be made, except to
appropriate NRC staff (see 07.03 below).

a.  [Transmittal Letter]{.underline}. The transmittal letter should
    identify the deficiencies, unresolved items and significant design
    and design process weaknesses requiring licensee response. In
    addition, the letter should discuss all major items requiring
    licensee management attention.

b.  [Cover Page]{.underline}. The cover page should provide basic
    identifying information about the licensee inspected and a brief
    summary of the scope and findings of the inspection (see Exhibit 1
    of IE MC 0610).

c.  [Chapter 1 ‑ Introduction and Summary]{.underline}\*. The
    Introduction should state the specific inspection objectives; define
    findings, deficiencies, unresolved items, and observations; and
    briefly describe the inspection activities, composition of the
    inspection team, areas of review, and level of effort. The summary
    should state the major conclusions, including the principal
    deficiencies (if any) and strengths identified (if any) as well as a
    judgment as to the adequacy of control of the overall design. This
    summary should address any significant design and design process
    weaknesses identified in the inspection findings.

d.  [Chapters 2 through 6 ‑ Detailed Inspection Results by Functional
    Areas]{.underline}\*. Each of these chapters should cover one
    functional area.

> Each of these chapters will have the following standardized format:

1.  [Statement of the Objective]{.underline} indicating emphasis of the
    review.

2.  [Design Information]{.underline} describing the principal elements
    of the design process, organization, and information flow. It should
    include brief discussions of design inputs (e.g., FSAR commitments
    and NSSS requirements), design outputs (e.g., specifications and
    calcula­tions), information flow (e.g., inputs to safety analyses)
    and organization (e.g., utility/AE interface such as utility review
    of AE design).

3.  [Functional Areas]{.underline} should include details as applicable
    to each respective major engineering discipline (e.g., Mechanical
    Components technical areas may include piping stress analysis,
    piping supports, mechanical equipment, subcontractors, and NSSS).

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e.  [Chapter 7 ‑ Design Control Aspects Related to More Than One
    Functional Area]{.underline}. This chapter should cover findings
    common to more than one functional area and should identify concerns
    that cross functional areas boundaries.

f.  [Chapter 8 ‑ References]{.underline}. This chapter will contain a
    chronology of events, meeting attendance, personnel interviewed, and
    other miscellaneous items, as needed.

07.04 [Release of Draft Inspection Reports]{.underline}. In accordance
with the memorandum of October 7, 1983, \"Policy on the Distribution of
Draft Inspection and Investigation Reports,\" from W. Dircks (NRC/EDO)
and IE Manual Chapters 0610, \"Inspection Reports,\" and 0611, \"Review
and Distribution of Inspection Reports,\" under no circumstances should
draft inspection reports, either in their entirety or in part, be
released to licensees or their agents or to any source outside the NRC
without the express permission of the EDO.

In the event any draft inspection report is inadvertently or otherwise
released contrary to this policy, the Director, IE shall be promptly
advised in writing. The Director, IE will take or recommend action, as
appropriate, including prompt notification to the EDO.

07.05 [Distribution of IDI Inspection Reports]{.underline}. The final
version of the IDI report will be distributed in accordance with IE
Manual Chapter 0611. The final version of the IDI report will be sent to
NRR (DL) and to the appropriate Regional Administrator at the same time
it is sent to the licensee for proprietary review. Any NRR or regional
concurrence needed on portions of the report should be obtained during
the review and approval stage before distribu­tion. After proprietary
review, the report will be sent to all utility executives on
distribution list 1S and to other interested NRC organizations on
distribution list IE01. NRR (DL) will make a decision on board
notifications at the request of IE (DQAVT).

07.06 [Input to Systematic Assessment of Licensee Performance
(SALP)]{.underline}. In accordance with the NRC SALP program (NRC Manual
Chapter 0516), the Team Leader is responsible for submitting input to
regional management. This should be provided, as needed, or within 60
days of completion of IE review of licensee response to the IDI report,
to the appropriate region.

07.07 [Inspection Program Credits]{.underline}. Direct inspection hours
expended in the performance of an IDI are to be recorded under Dummy
Module Number 099025B, \"Integrated Design Inspections.\" The IDI team
leader will provide a draft 766 Statistical Data Form to the responsible
regional project section chief once the inspection is completed. The
regional office will determine if inspection program credits are
appropriate for the particular licensee.

07.08 [Program Changes]{.underline}. Each team member shall provide
recommendations (if any) to the team leader for IDI program changes. The
team leader shall provide the recommendations (as appropriate) to the
Chief, Quality Assurance Branch, IE.

2530‑08 REVIEW OF LICENSEE\'S RESPONSE AND RECOMMENDATION PROCEDURE

08.01 [Review of Licensee Response]{.underline}. The transmittal letter
for the IDI report requests the licensee to respond to the report
findings within 60 days. The licensee is requested to specify what
resolution or corrective actions it has taken or plans to take with
respect to the deficiencies and unresolved items (if any) in the IDI
report.

After the licensee\'s response is received, individual team members are
to conduct reviews of their findings and the associated responses. For
each item that required a response (deficiencies and unresolved items)
the evaluation should address:

a.  Whether the response describes an adequate resolution or the
    licensee or NRC needs to do something further to achieve resolution.
    If additional information or licensee action is deemed necessary,
    the team member should provide background information and a draft of
    the request to the licensee.

b.  Whether followup inspection is needed. Followup inspection should
    only be recommended for special situations where such inspection is
    needed to achieve resolution. Routine inspection for general
    monitoring is the responsibility of the appropriate regional office.

c.  Any general comments regarding the response.

The team members should provide a brief summary of their evaluations for
those items not needing additional information or reinspection.

The IDI Team Leader will evaluate responses by team members and prepare
a letter to the licensee for signature by the Director, Division of
Quality Assurance, Vendor, and Technical Training Center Program
(DQAVT). This letter should request the additional information needed to
resolve IDI findings and discuss plans for a reinspection (if
necessary).

08.02 [Reinspection Procedure]{.underline}. The licensee will be given
written notice stating the specific items to be reinspected when a
reinspection is necessary. A relatively short team inspection (typically
3 days) should be sufficient to resolve uncertainties regarding the
responses. Generally there would be at most one team member per
discipline participating in the reinspection. The applicable region
should be contacted by the Team Leader before the reinspection, to
provide an opportunity for regional participation. This may be
particularly helpful for identification of potential enforcement
findings. A reinspection should be documented by an Inspection Report.
This report will normally be signed by the Director, Division of Quality
Assurance, Vendor, and Technical Training Center Programs (DQAVT).

2530‑09 FOLLOWUP AND ENFORCEMENT

The focus of the IDI is evaluating the design process and the adequacy
of the existing plant design, rather than enforcement. However, after
IDI team evaluation of the licensee\'s response to the IDI report and
completion of a reinspection, the appropriate Regional Director will be
notified by the Director, DQAVT of the potential enforcement findings
(PEFs) found during the IDI for regional followup. The notification of
PEFs to the region will include a preliminary determination of an
appropriate enforcement classification for each PEF. The IDI Team Leader
is responsible for ensuring that regional tracking numbers are assigned
to each PEF and other items stemming from the IDI that require region
followup. The Director of the Enforcement Staff will concur with the
preliminary enforcement determinations.

During an inspection, situations may be encountered where the
significance of a matter warrants consideration of prompt action (e.g.,
licensee stop work, NRC order, investigation of wrongdoing). If so,
management in the OIE and the appropriate regional office will be
promptly informed and the first priority will be pursuing the matter
until the question of prompt action has been resolved. In addition, the
IDI team leader will identify those findings which are appropriate for
CAT, Vendor Program, regional programs, or NRR followup.

2530‑10 LIST OF APPENDICES

A - Additional Guidance for Inspection Plan Development and
Implementation Agreement

B - Proprietary Agreement and Conflict of Interest Forms

END

APPENDIX A

ADDITIONAL GUIDANCE FOR INSPECTION PLAN

DEVELOPMENT AND IMPLEMENTATION

PURPOSE

To provide additional guidance in developing and implementing an
inspection plan for an Integrated Design Inspection (IDI).

[GENERAL GUIDELINES]{.underline}

1.  [Project Design Procedures Review]{.underline}. Within each design
    discipline, review the project‑specific specifications,
    instructions, and procedures that provide design criteria or
    guidance to design engineers.

> The purpose of this review is to determine the extent of the formal
> guidance given to the engineers for performing design activities. The
> inspector should use the information from the review to highlight
> areas of limited or inadequate guidance to the engineers and for
> determining areas in which to focus the technical review.

2.  [Design Calculation Reviews]{.underline}. General guidance and
    information for the review of engineering calculations and design
    details are covered below. Specific details to be reviewed for each
    discipline follow in the guidelines for each functional area.

    a.  Verify that design information is current and correct. This may
        require tracing back to the source of the input. Internal and
        external interfaces should ensure that all disciplines and
        design organizations for a project use a consistent and
        up‑to‑date set of design inputs and assumptions, e.g., where the
        output of one analysis becomes the input of a second analysis.

    b.  Verify that the guidance provided by the project‑specific
        procedures has been met.

    c.  Verify that assumptions used in the design calculations are
        based on sound engineering principles and practices.

    d.  Verify that the output information has been transmitted to the
        appropriate design organizations.

    e.  Verify that the design information has been translated into
        project documents such as specifications, drawings, procedures,
        instructions, and contracts related to plant construction.

    f.  Verify that design changes (including field changes) result in
        all affected elements of the design being evaluated; e.g.,
        reanalysis may need to be performed commensurate with the
        original design.

    g.  Confirm that design verification (design review,
        alternate/indepen­dent calculations, or qualification testing) is
        being done. The extent of design verification is commensurate
        with the importance to safety, complexity, degree of
        standardization, state‑of‑the‑art, and similarity with proven
        designs.

    h.  Confirm that calculational methods, using both hand calculations
        and computer programs, are being properly controlled. This
        includes computer program verification and qualification
        (assuring that the computer program functions correctly in all
        modes and options and is used correctly in representing a
        physical process) and the proper use and accuracy of inputs.
        Particular attention should be given to the basis and validity
        of assumptions, identifying/assessing undocumented
        calculations/decisions, and confirming that as‑built conditions
        are reflected in design analyses.

[FUNCTIONAL AREA INSPECTION PLAN GUIDELINES]{.underline}

The following guidelines are illustrative of the extent of inspection to
be conducted in each functional area. These guidelines are not intended
as a checklist to be used by team members. Individual inspection plans
will be developed for each plant inspected.

1.  [Mechanical Systems Inspection Plan Guidelines]{.underline}. The
    overall design basis of the mechanical fluid system should be known
    by the inspection team. Particular attention should be given to the
    functional and performance requirements imposed on the system for
    the purpose of assuring reactor safety. To accomplish a review of
    the mechanical fluid system, it may be necessary to review how the
    licensee intends to meet the General Design Criteria as well as the
    system description for the selected fluid system.

    a.  If the selected fluid system is directly connected to or related
        in function and behavior to the reactor coolant system, it will
        be necessary to review the requirements imposed by the reactor
        coolant system. The associated parameters could include such
        items as temperature, pressure, flow rates, chemical
        characteristics as well as information related to redundancy,
        accident analyses, physical location and protection from or
        control of the surrounding environ­ment. This is a good
        opportunity to evaluate the interface between the NSSS (reactor
        system designer) and the AE (fluid system designer). Review
        calculations that confirm that NSSS requirements can be met.

    b.  Identify a function which is related to the selected mechanical
        fluid system. Determine whether the design ensures that this
        function will be met during all plant conditions. Various system
        parameters, such as temperature, pressure, flow rates, chemical
        composition, and action times, should be reviewed to verify
        proper design basis and to evaluate system interfaces. The
        system flow diagram and supporting calculations should be
        reviewed to evaluate whether the design ensures that system
        functions will be met under all anticipat­ed conditions.

    c.  Review calculations which are important to the performance of
        the system to be inspected, e.g., net positive suction head
        calculations for fluid systems and flow calculations for systems
        such as auxiliary feedwater where required flow rates are
        safety‑related items.

    d.  Review the design methods and assumptions used in evaluating the
        effects of pipe rupture on targets. Interfaces are involved in
        reviewing the designs of protective structures, pipe whip
        restraints, break exclusion runs, environmental effects of pipe
        rupture on essential electrical equipment and instrumentation,
        subcompartment pressurization, and inservice inspection of
        piping within protective structures or guard pipes.

    e.  Verify that the portions of the system penetrating the
        containment barrier are designed with isolation features that
        are acceptable for maintaining containment integrity for all
        operating and accident conditions. Check interfaces with the
        instrumentation and control functional area relative to
        isolation valve actuation and control.

    f.  Evaluate the classification of the structures related to the
        selected fluid system for conformance to the requirements for
        safety‑related systems. Evaluate the spectrum of conditions that
        have been considered in the design of the structures. Evaluate
        the loading conditions that arise from events such as pipe
        rupture, LOCA, earthquakes, operational transients, reactor
        trip, loss of component cooling, etc.

    g.  Verify the compatibility of the materials and components of the
        selected fluid system with the service conditions, including
        normal and accident conditions as well as the design life.
        Ensure that the fluid system\'s components have proper safety
        and code classifica­tions.

2.  [Mechanical Components Inspection Plan Guidelines]{.underline}

    a.  Select a sample of calculations to be reviewed; it should
        include the following items:

        1.  piping analysis problems

        2.  major components attached to the piping problem such as a
            pump or tank

        3.  valves in the pipe run

        4.  pipe supports: rigid, snubber, and spring

    b.  Review all input information used in the piping analysis. This
        will require coordination with other team members to determine
        that the correct inputs are used. Also, to the extent possible,
        verify that the correct as‑built information has been obtained
        from the field (see Inspection Procedure 37051).

    c.  Review the model used in the piping analysis. This includes
        review of the analyses performed (thermal, deadweight, seismic,
        etc.), review of the computer programs and the analytical model
        for conformance with licensee commitments and procedures.
        Particular attention should be given to the model used for
        seismic analysis for the appropriateness of the boundary
        conditions assumed at anchors and supports.

    d.  Review stress and support load summary sheets for correct load
        combinations as specified in the licensing commitments. Also
        verify that these documents have been transmitted to the
        appropriate group for support evaluations.

    e.  Review component design reports to verify that the basic
        premises are correct and that data are in conformance with
        licensee commitments. Review test qualification documents, if
        applicable, including correctness of the test parameters for
        conformance with the licensee commitments. This review should
        verify that the loads from the piping analysis are included in
        the component evaluation.

    f.  Review valve design reports for conformance with licensee
        commit­ments. Particular attention should be given to the
        operability evaluation for seismic events. Also, valve actuator
        qualification documentation should be reviewed for conformance
        with licensee commitments.

    g.  Review the loads used in the evaluation of pipe supports and
        verify that these are the correct loads from the piping
        analysis. Review the support analysis for conformance with
        licensee commitments and procedures. The load combinations
        should be checked for the correct specification of primary and
        secondary loadings.

> Verify that integral attachments have been evaluated for their effects
> on the piping and that buckling of compression members has been
> considered. For spring hangers and snubbers, verify that thermal
> movements were considered. Review the attachment to the structure and
> verify that the loads have been considered by the structural group.

3.  [Civil and Structural Inspection Plan Guidelines]{.underline}

    a.  Identify the location of the fluids system selected. Include
        associated equipment, such as:

        1.  pumps

        2.  tanks

        3.  power supplies

        4.  control systems

        5.  piping supports

> There is no attempt in this inspection procedure to evaluate the
> global behavior of the individual buildings or the foundations.
> However, the load path of the structure or structural elements should
> be reviewed to ensure that the applied loads are properly carried
> through the structure or structural elements to the supporting points.

b.  Verify that structural safety categories are consistent and correct.
    Consider the location and possible effect of non‑safety‑related
    items on the fluids system.

> Review the safety categories defined in FSAR Section 3 and the
> classification of structures. Compare the safety categories of the
> mechanical fluid system selected against these criteria for
> compatibility.

c.  Review the model and boundary conditions used in the structural
    analysis of the design configuration utilizing the output and
    information from other functional areas such as mechanical,
    electrical power, instrumentation and control, and systems design to
    verify the correctness. Also review the output provided from the
    civil structural area to the other disciplines. Assess the safety
    impact of these reviews.

d.  Verify that all pertinent loads and load combinations are considered
    in the analysis of structural elements, in addition to the piping
    system. Examine the sensitivity of the structural analysis and
    design to changes in piping system loads, supports, and
    configura­tions as well as the influence on resulting structural
    deformations.

> Emphasis should be placed on the identification of the discipline
> boundaries and necessary interfaces in the design process. Ascertain
> that the correct loads and load combinations have been used and that
> techniques for combining loads or load elements are correct.

e.  Review samples of the design calculations based on the internal
    forces resulting from the analyses. Ascertain that the design
    techniques committed to in the SAR have been or are being met. Also
    review specific areas of the design calculations.

f.  Review examples of the design documents produced as a result of the
    design calculations, such as detailed specifications, drawings, and
    procedures.

g.  Review examples where the basic design documents are used to produce
    product, components, or elements that will be integrated into the
    final structure. This review would include such items as fabrication
    and shop drawings, produced by a subcontractor, or installation
    procedures, defined by a supplier.

h.  Review and evaluate the process by which design documents are
    checked and verified and the process by which the final documents
    are issued for use and construction.

i.  Review and evaluate several types of design changes, such as those
    initiated by:

    1.  design office

    2.  field engineering

    3.  the licensee

    4.  errors or interference in construction

    5.  errors in engineering

j.  Review and evaluate the acceptance process used in the
    civil‑structural area for final acceptance of the structures or
    elements thereof. As‑built information, information per Inspection
    Procedure 37051, should be used in this portion of the effort.

k.  Review the seismic analysis of one seismic Category I structure that
    is associated with the sample system being inspected.

    1.  Review seismic inputs, such as the developing of ground response
        spectra, artificial time‑history generation.

    2.  Review procedure of seismic modeling, including stiffness,
        masses, damping values. Verify that the seismic model is
        representative of and consistent with the actual structural
        configuration.

    3.  Review the techniques dealing with modal combinations, peak
        broadening, closely spaced modes, etc.

    4.  Review the adequacy of computer programs used for seismic
        analysis.

    5.  Review the procedure for soil‑structure interaction (SSI), if
        applicable, to ensure that the adequacy of the procedure and the
        methodology prescribed is consistent with FSAR commitments.

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4.  [Electric Power Inspection Plan Guidelines]{.underline}

    a.  Identify all components of the mechanical fluid system selected
        that require electric power to perform their safety function(s).
        Determine whether the electric power system supplying power to
        each of these components will be capable of providing the
        required electric energy as needed by each component. Examine
        required voltage, current, and frequency (maximums, minimums,
        and nominal including transient values) and compare with power
        source voltage, current and frequency for several sample sets of
        conditions representative of maximum and minimum loads and
        expected perturba­tions on the power source. Determine if
        required power quality can be provided for the needed time of
        interest. A review of diesel‑generator load sequencing of the
        selected mechanical fluid system components (requiring power to
        perform their safety function) should be performed.

    b.  Identify all components of the mechanical fluid system that
        require disconnection from their electric power source in order
        to perform their safety function. Review the control circuit for
        at least two such components to determine if it meets its design
        requirements. Focus on time allowed for disconnection from power
        source in the electric power system design and the corresponding
        time assumed in safety analysis.

    c.  Examine the control relaying for at least two components of the
        mechanical fluid system that require power to perform their
        safety function and two that require power disconnection to
        perform their safety function. Evaluate the documentation and
        actual installation of these circuits and assess the ability of
        the circuits to perform as required.

    d.  For several samples of each kind of electric component (i.e.,
        motors, valve operators, relays, connections, cables), determine
        if the design meets acceptance criteria for performing the
        required safety function in the presence of the most severe
        environment specified in the component\'s design bases. Verify
        that acceptance criteria are consistent with licensee
        commitments.

    e.  Examine the physical arrangement of redundant electric power
        source components, including separation, barriers, and
        environmental controls, to ensure that single failures affecting
        such components will not cause the mechanical fluid system to
        fail to be able to perform its safety function(s).

    f.  Examine the qualification documentation of at least two motors,
        valve operators, relays, connections/connectors, and cables to
        determine if:

        1.  the test conditions specified were consistent with predicted
            accident conditions at the equipment location

        2.  required equipment performance was properly specified for
            the worst accident for which the equipment was required to
            operate

        3.  test results showed the equipment able to meet specified
            performance under the design‑basis conditions specified

    g.  Compare procurement specifications for equipment examined in
        item (f) above to determine if they are consistent with
        qualification specification for performance and environment.

    h.  Examine methods and procedures for providing electric power to
        operable electric equipment when the normal offsite source and
        the normal onsite emergency source are unavailable. Determine if
        these methods or procedures could compromise redundant power
        source independence or prevent supply of electric power to one
        or more redundant loads.

    i.  Confirm the power distribution system to safety‑related electric
        loads has been adequately designed with regard to breaker, motor
        starter, and cable sizing, as well as breaker coordination.
        Review several sample calculations in this area.

    j.  For at least 2 electric loads, determine the basis for
        interruption of electric power in the case of an electric power
        demand in excess of the normal rating for the loads. Determine
        what basis was used to decide whether the system was designed to
        ensure the performance of the safety function or to protect the
        equipment in cases of overloads. Review design of electric
        motor‑operated valves provided with torque switches used to
        cause motor shutdown when excess torque is detected. Determine
        the validity of basis for torque switch settings. Review
        procedures for testing such switches.

    k.  Examine specifications for several items of electric equipment
        and compare to the expected environment in their designated
        location to determine if special environmental controls should
        have been provided or if a different location should have been
        selected.

    l.  Determine how the need for special environmental controls (e.g.,
        battery room ventilation) on electric equipment was determined.
        Review design documentation (descriptions, drawings, etc.) to
        determine how the environment is to be maintained and how
        operating personnel are made aware of the needs for these
        special environmental controls.

5.  [Instrumentation and Control Inspection Plan Guidelines]{.underline}

    a.  Select two different process measurements, such as flow, level,
        pressure, temperature, etc., associated with the mechanical
        fluid system selected and select two associated control (or
        non‑safety measurement) systems. The selected measurements (at
        least one) should be selected from those that perform a safety
        function, such as reactor trip or actuation of one or more
        engineered safety features.

    b.  Review all input information used for the design; it will be
        necessary to interface with the electrical power system design
        and the mechanical system design. Verify that the design input
        parameters meet the design requirements for the fluid system
        design. This should include the ranges of system process
        parameters required for normal and accident conditions.

    c.  Review the appropriate functional, wiring, and installation
        drawings to assure conformance to licensee commitments.

    d.  Select several field design change requests and verify that the
        vendor\'s design verification program is being effectively and
        accurately implemented. The inspector should review: the
        verifica­tion method; the procedure for implementation; the
        authority for the design change; the associated equipment
        documentation, such as equipment specification purchase orders,
        IEEE Standards, Regulatory Guides, \"Approved for Construction\"
        drawings, and the as‑built installation drawings that complete
        the design change cycle; the results of the functional tests
        after the components/systems have been installed; the
        documentation to assure that the field change had been evaluated
        for general implications.

    e.  Review qualification documentation associated with
        safety‑related instruments to determine compliance with
        regulations, regulatory guides and national standards applicable
        to qualification.

    f.  Identify alarms or annunciators provided from the
        instrumentation for the mechanical fluid system and review the
        basis for providing these alarms or annunciators, their
        set‑points, and their locations.

    g.  Review the system description for any unusual operating
        requirements. Examples of these requirements could be: special
        operation required of the systems during and after an accident,
        capability of the systems to shut down the reactor from a remote
        location, or any special automatic/manual control features.

    h.  Verify that the instrumentation and control system detects and
        maintains essential parameters during all anticipated plant
        conditions. Check if the capability to provide the required
        detection and control during loss of offsite power, or other
        anticipated operational occurrences and accident conditions
        meets design requirements.

    i.  Assure that all logic functions, i.e., interlocks, automatic
        actuation and permissives, are properly implemented.

    j.  Assure that bypassed and inoperable status is indicated as
        necessary.

    k.  Review procedures and basis for developing set points and for
        ensuring that as‑built deviations are considered.

END

APPENDIX B

PROPRIETARY AGREEMENT AND CONFLICT OF INTEREST FORMS

[AGREEMENT]{.underline}

For proprietary and potentially proprietary information that is
disclosed to me in connection with my work on the NRC\'s Integrated
Design Inspection of the (plant name), I agree:

1.  Not to make further disclosures

2.  Not to make further copies

3.  To return my copies to the NRC Team Leader upon completion of the
    inspection project unless copies were previously returned to the
    applicant or applicable design organizations.

4.  Not to make further disclosures or copies of inspection notes that
    contain potentially proprietary information.

> SIGNA­TURE DATE

[INFORMATION CONCERNING POTENTIAL CONFLICT OF INTEREST]{.underline}

Integrated Design Inspection Team

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

> Proposed Team Member Organization

My participation in the Integrated Design Inspection
of [                       ]{.underline} does ( ) does not ( ) involve
situations or relationships of the type set forth in 41 CFR
20‑1.5403(b)(1). In particular, I have ( ) do not have ( ) direct
previous involvement with activities at the plant that I will be
reviewing and have ( ) do not have ( ) conflicting roles which might
bias my judgment in relation to my work for the NRC. In addition:

1\. ( ) I have not been previously employed by the Applicant to do
similar design work.

> ( ) I have been previously employed by the Applicant. (State the
> nature of the employment.)

2\. ( ) I do not own or control significant amounts of Applicant stock.

> ( ) I own or control significant amounts of Applicant stock. (State
> the nature of the ownership.)

3\. ( ) Members of my present household are not employed by the
Applicant.

> ( ) Members of my present household are employed by the Applicant.
> (State the nature of the employment.)

4\. ( ) My relatives are not employed by the Applicant in a management
capacity.

> ( ) My relatives are employed by the Applicant in a management
> capacity. (State the nature of the employment.)

In the above statement, the \"Applicant\" is construed to mean the
applicant ([                        ]{.underline} ), the
architect‑engineer ([                        ]{.underline} ), or the
NSSS vendor ([                        ]{.underline}) for
[                            ]{.underline} .

> Signature Date