**NRC INSPECTION MANUAL** IIPB

INSPECTION PROCEDURE 37802

FIRST-OF-A-KIND ENGINEERING INSPECTIONS

PROGRAM APPLICABILITY: 2502

37802-01 INSPECTION OBJECTIVE

01.01 Verify that the design bases and/or high-level certified design
information are effectively translated into detailed construction
documents.

01.02 Assure that applicable regulatory requirements, including those
related to any specific design certification rule, are correctly
implemented by the design control processes reviewed during
first-of-a-kind (FOAK) engineering inspection activities.

37802-02 INSPECTION REQUIREMENTS

02.01 [Inspection Preparation]{.underline}

a.  [System Selection]{.underline}. Select one or two safety-related
    systems used for mitigating an accident or maintaining fission
    product barrier integrity, with the option of selecting additional
    supporting systems, sub-systems, or risk-significant components to
    ensure the inspection objective is satisfied by the scope of the
    inspection. \[Note: A risk-significant, nonsafety-related system or
    sub-system may also be considered for inspection, provided that all
    appropriate characteristics (see section 03.01 guidance) are
    considered in the system selection process.\]

b.  [Obtain Information]{.underline}. Obtain the necessary information
    for determining the design bases for the selected systems(s),
    sub-system(s), and components.

c.  [Program Review]{.underline}. Review the design information in the
    Final Safety Analysis Report (FSAR) and in the Design Control
    Document (DCD) applicable to a related design certification rule, if
    available.

d.  [Team Selection]{.underline}. Assemble an inspection team composed
    of individuals with expertise in the various engineering disciplines
    related to the design and functions of the selected system(s),
    sub-system(s), and components.

02.02 [Inspection Activities]{.underline}

a.  [Review Available System Information]{.underline}. Inspection
    activities to verify that the design bases and high-level certified
    design information are being correctly translated into detailed
    construction specifications, drawings, calculations, procedures, and
    other documents will be dependent upon the state and completeness of
    such derived products at the time of the inspection. Review
    applicant/engineering organization design procedures and relevant
    documentation in sufficient detail to establish the design flow
    logic and critical design areas for the selected systems. This
    review should encompass all of the following functional areas and
    disciplines, as applicable to the selected system sample:

    1.  Civil/Structural

    2.  Mechanical/Systems

    3.  Electrical

    4.  Instrumentation and Control

    5.  Materials

    6.  Component Engineering

    7.  Quality Assurance

> The Team Leader should ensure that the overall team plan makes
> provision for analyses of 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 exist across plant systems and functional
> areas.

b.  [Inspect Design Attributes]{.underline}. Review the
    applicant/engineering organization=s programmatic design controls,
    the flow network of the design processes, and critical design areas
    to develop the inspection attributes for each of the disciplines
    applicable to the selected systems.

> Perform the inspection activities associated with the attributes
> related to the following engineering topics:

1.  validity of design inputs and assumptions

2.  validity of and conformance to design specifications

3.  validity of analyses

4.  coordination of system interface requirements

5.  inadvertent effects of changes

6.  proper component classification

7.  revision control

8.  documentation control

9.  verification of the design

10. design changes

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c.  [Review Design Procedures and Design Calculations]{.underline}.
    Within each design discipline, review the project-specific
    specifications, instructions, procedures, and other documents that
    provide design criteria or guidance to design engineers. Also review
    a sample of design calculations relevant to the selected systems in
    each discipline to verify that: project-specific procedures have
    been met; design information and assumptions are current; methods of
    calculation are correct and properly controlled; and design
    verification principles are practiced. To achieve this result, a
    sample of the following engineering documents should be inspected,
    as applicable to each discipline related to the selected systems:

    1.  system descriptions describing design bases, system functions
        and operation, component data, and associated instrumentation

    2.  design and purchase specifications

    3.  system flow diagrams showing flow paths, calculated flows, and
        temperatures and pressures for designed conditions of operation

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

    5.  calculations and analyses

    6.  significant design reports, including audits and assessments and
        engineering contractor correspondence and documentation

02.03 [Identification and Resolution of Problems.]{.underline} Verify
that the applicant and the quality assurance (QA) departments of all
engineering organizations and contractors are identifying design issues
at an appropriate threshold and entering them in the applicable
corrective action programs. Select a sample of previously identified
design issues for the selected system(s) or related
safety/risk-significant systems and verify the effectiveness of
implemented corrective actions.

37802-03 INSPECTION GUIDANCE

[General Guidance]{.underline}. In accordance with IMC-2502, Appendix B,
AFOAK Engineering Inspections,@ the inspection will be conducted in two
phases. Phase 1 of the inspection effort is initiated approximately one
year before the earliest time the COL could be issued, if granted, and
is intended primarily to assess the ongoing process for translating the
certified reactor design into detailed engineering documents. Phase 2 of
the inspection is implemented just before a decision on whether to issue
a COL is made. Phase 2 is to follow up on identified problems, to verify
corrective actions, and to evaluate items not previously ready for
review.

The objectives of planning and preparation are:

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

b.  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.)

c.  to make specific functional assignments to each team member

d.  to define inspection schedules

e.  to familiarize the team members with the organization(s) performing
    design and engineering services for the selected facility to
    familiarize the team members with the latest version of the
    documentation that defines the design (such as the DCD and FSAR,
    design procedures, design criteria, and high-level certified design
    information)

Before the initiation of the team planning phase for all FOAK
engineering inspection activities, the Team Leader or his representative
should contact and/or meet with applicant personnel, as necessary, to
identify and obtain the background information needed for inspection
preparation and the development of an adequate team inspection plan.

[Specific Guidance]{.underline}.

03.01 Inspection Preparation

a.  [System Selection]{.underline}. System selection should focus on
    those system(s), sub-system(s), and components with the following
    characteristics:

    1.  essential to plant safety or highly risk significant (DCD, Tier
        2, Chapter 15 systems)

    2.  a clearly defined design basis, as described in the certified
        design (if applicable), with the potential for site-specific
        impact upon the constructed facility

    3.  generally representative of safety-related features in other
        plant systems or of a highly risk significant nature that merits
        the unique consideration of certain nonsafety-related
        systems/sub-systems

    4.  design involving internal interfaces between the various
        functional areas and external interfaces with the design
        organization, component vendors, and other engineering service
        organizations

    5.  construction involving the integration of multiple subsystems
        and/or components, some of which may have already been
        fabricated by the vendors

> If more than one system is selected, the systems should complement
> each other, such as in mitigating the same type of accident. Other
> sub-systems and components chosen for review should have a supporting
> or supported relationship with the selected system(s).

b-d. [Obtaining Information, the Program Review, and Team
Selection]{.underline}. The primary focus of this inspection is on the
translation of high-level certified design information into lower-tier
construction/design documents. The inspection represents an assessment
of the design control processes being implemented by the applicant,
design organization(s), and applicable subcontractor(s). The design
control program is evaluated by examining the design details that would
be used in the actual construction/fabrication processes. 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 control program. A design error or
weakness will be evaluated and will include an assessment of the extent
to which the identified condition applies to other areas of the plant
design.

> The Team Leader will assign team members responsibility for preparing
> an inspection plan for a specific functional area. See Section 5.c of
> Appendix B of Manual Chapter 2502 for further inspection and planning
> guidance relating to inspection team composition.
>
> 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.  Design Control Document

2.  Safety Analysis Report

3.  Probabilistic Risk Assessment Report information

4.  NRR Safety Evaluation Report

5.  Design Principles, as referenced in the commitments to established
    standards (e.g., ANSI/NQA-1)

6.  Current Organization Charts for the applicant and all involved
    engineering/design organizations. These charts should provide the
    inspectors with an overview of the management interfaces,
    communication channels, and the identification of key
    engineering-management personnel

7.  A list of all contractors and subcontractors doing engineering and
    design work for the applicant or one of its prime agents, including
    a scope of work for each contract and an explanation of the
    interface between the applicant and the design organizations

8.  Applicant/engineering organization(s) procedures:

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

    b.  diagrams indicating the flow of design information

    c.  design and engineering procedures specified by contract for
        contractors and subcontractors

    d.  documents listing the scope and standards for engineering and
        design work expected to be done in the field

    e.  documents indicating the scope of and procedure for the exchange
        of design information among the design organizations

    f.  procedures describing how the applicant gets involved in the
        engineering process (e.g., oversight and audit of engineering
        activities)

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

9.  NRC-Applicant correspondence - questions and answers, principal
    meetings or special studies, and any licensee or certified design
    organization correspondence listing commitments and action items in
    response to NRC issues

10. Applicant engineering organization documents (as available):

    a.  principle design criteria

    b.  system descriptions, design bases, system functions and
        operation, component data and instrumentation

    c.  list of engineering, design, and purchase specifications

    d.  system flow diagram showing flow paths, 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 Schedule status, plans and details.

03.02 [Design Inspection]{.underline}. The purpose of a design
inspection is to verify that the system(s) will function as required.
For a FOAK engineering inspection, the certified design and
higher-tiered engineering concepts have already been reviewed and
approved by the NRC. The design details that will be used to actually
construct the plant warrant further NRC engineering review. In the
process of reviewing these lower-tier design details and documents, the
inspectors should verify the appropriateness of the design assumptions,
design input, boundary conditions, and models. Independent calculations
by the inspectors may be needed to verify the acceptability of the
applicant/design organizations= methods of analysis. The interface
between safety-related and non-safety systems, as well as between
supporting and supported systems, should also be reviewed.

In some instances, the design may not be complete and design
documentation will not be available. In this case, ensure that there is
a DAC which will verify the appropriate design item at a later date. If
there is no DAC to inspect or verify this item, ensure that the
engineering contractor, equipment vendor or the licensee has a
commitment to inspect and verify this item, and report the results of
that inspection to the NRC inspection team responsible for that item.
The lack of this type of information would prevent a license from being
issued. Close communication and coordination with NRR will be needed if
this situation is identified.

a.  [Reviewing Available System Information]{.underline}. The
    Attachments included in this Inspection Procedure contain guidelines
    that are illustrative of the extent of the inspection to be
    conducted in each functional area. These guidelines are not intended
    to be used only as a checklist by team members, but also to provide
    a guidance framework that may be reviewed in the development of
    individual inspection plans. Inspection plans for each discipline
    will be developed for all FOAK engineering inspections at each plant
    inspected.

b.  [Inspecting Design Attributes]{.underline}. The attributes for a
    proper design emanate from the inputs into the system design, the
    component fabrication details, supporting and supported sub-system
    functions, and the interrelationship among these areas. Appendix A
    to this Inspection Procedure lists the design inputs to be
    considered in inspecting the selected systems, sub-systems, and
    components. In addition, Section 5.e of Appendix B of Manual Chapter
    2502 lists other NRC Inspection Procedures which may also provide
    useful guidance, insight, and references for the successful conduct
    of the design/engineering inspection activities relevant to the FOAK
    engineering inspection process.

c.  [Reviewing Design Procedures and Calculations]{.underline}. The
    following guidance reflects the intent of the inspection objective
    of verfiying that the design bases are correctly translated into
    construction documents. Samples of these construction documents
    (which have been developed by the engineering organization=s
    transfer of design details from the higher-tiered, certified design
    information) should be inspected, as necessary, within each
    functional area/discipline to confirm with reasonable assurance that
    the transfer of design principles, data, criteria, and other
    critical information is being properly controlled and effectively
    implemented.

    1.  Design Procedures Review. Within each design discipline, review
        the project‑specific specifications, instructions, and
        procedures that provide design criteria or guidance to design
        engineers. Determine the extent of the formal guidance given to
        the engineers for performing design activities. Focus the
        technical review on areas of limited or inadequate guidance to
        the engineers.

    2.  Design Calculation Reviews. Review engineering calculations and
        design details, as follows:

        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. Do not repeat reviews that
            were conducted as part of the design certification.

        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 result in all affected elements
            of the design being evaluated; e.g., re-analysis 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.

> During the course of FOAK engineering inspection activities ,
> documents pertinent to the inspection that are provided to team
> members may contain proprietary information. Treat design information
> as potentially proprietary. Do not make further copies or disclosure
> the documents received during the inspection without coordinating such
> needs through the NRC Team Leader. Normally, all such documentation
> will be returned to the licensee when the inspection is completed.

03.03 See Inspection Procedure 71152, AIdentification and Resolution of
Problems,@ for additional guidance.

37802-04 RESOURCE ESTIMATE

This inspection procedure is estimated to use approximately 1600
inspection hours for Phase 1 activities and 400 hours for Phase 2
activities. See Sections 4.b & 5.b of Appendix B of Manual Chapter 2502
for a further discussion of the projected level of effort, program scope
and timetable, and the team composition expected to be used in the
conduct of this multi-disciplinary FOAK engineering inspection.

37802-05 COMPLETION STATUS

This inspection procedure is completed when the Phase 1 and Phase 2 FOAK
engineering inspection activities, as discussed in Manual Chapter 2502,
Appendix B, have been conducted. An inspection sample of one or two
safety system reviews (including supporting system, sub-system, and
component reviews) deemed necessary to meet the inspection objectives,
is sufficient to constitute completion of this procedure.

37802-06 REFERENCES

Inspection Procedure 71152, AIdentification and Resolution of Problems@

NRC Inspection Manual Chapter 2502, Appendix B, AFirst-of-a-Kind
Engineering Inspections@

NRC Inspection Manual Chapter 2512, ALight-Water Reactor Inspection
Program - Construction Phase@

NRC Inspection Manual Chapter 2515, ALight-Water Reactor Inspection
Program - Operations Phase@

NRC Inspection Manual Chapter 2530, AIntegrated Design Inspection
Program@

ASME NQA-1 - 1994 Edition, AQuality Assurance Requirements for Nuclear
Facility Applications@

END

Attachments: Functional Area Inspection Guidelines

> Attachment A, Civil and Structural
>
> Attachment B, Mechanical Systems
>
> Attachment C, Electrical Power
>
> Attachment D, Instrumentation and Control
>
> Attachment E, Materials, Welding, and Nondestructive Examination
>
> Attachment F, Mechanical Components
>
> Attachment G, Quality Assurance

Appendix A, Design Input Considerations

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Attachment A: Functional Area Inspection Guidelines

for

Civil and Structural

The overall design basis of the mechanical fluid system(s) or other
process systems selected for the inspection sample 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.

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

    1.  pumps and valves

    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 the FSAR 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 identified in the FSAR or Design Control Document 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 make
    products, 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 the following organizations or events:

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1.  design office

2.  engineering contractors

3.  the applicant

4.  identified interference/coordination problems

5.  identified errors in engineering

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j.  Review and evaluate the acceptance process used in the
    civil‑structural area for final acceptance of the structures or
    elements thereof. Inspection Procedure 37051 should be reviewed for
    guidance and criteria relevant to this effort.

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

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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.

Attachment B: Functional Area Inspection Guidelines

for

Mechanical Systems

To accomplish a review of the mechanical fluid system, it may be
necessary to review how the applicant 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 various design organizations. Review calculations that
    confirm that certified design 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 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,
    sub-compartment pressurization, and plans for the 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.

Attachment C: Functional Area Inspection Guidelines

for

Electric Power

The degree to which emergency power, and electric power in general, are
relied upon as safety-related or risk-significant features of the
design, or asset protection support systems, should be considered in the
development of a electric power inspection plan for the facility. The
reliance on emergency and safety-related electric power sources will
depend upon the unique facility design and the specific types of power
sources (AC or DC) that are used for the safety grade actuation or risk
mitigation features of that design. Such unique design applications in
the use of electric power should be reviewed and considered in the
formulation of an inspection plan for the safety-related and risk
significant components that comprise the electric power system for the
facility. Therefore, depending upon the plant design, the following
inspection guidance should be flexibly adapted to the focus on power
sources (AC or DC) and component selection (e.g., diesel generators or
batteries) that provide the most safety significant impact and risk
return for the inspection resources expended.

a.  Identify all components of the process and mechanical fluid
    system(s) selected that require electric power to perform their
    safety function(s) or otherwise use electric power to reduce risks
    or preserve plant assets. Determine whether the electric power
    system supplying power to each of these components will be capable
    of providing the required electric energy (AC or DC) as needed by
    each component.

> For AC circuits, 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. For
> example, a review of diesel‑generator load sequencing of the selected
> mechanical fluid system components (if they require emergency electric
> power to perform their safety function) should be performed.

b.  Identify all components of the process or mechanical fluid system(s)
    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
    process or mechanical fluid system(s) 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, AC and DC valve operators, batteries, battery chargers,
    inverters, 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 applicant commitments and certified design
    information.

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

f.  Examine the qualification documentation of at least two motors,
    valve operators, relays, batteries, battery chargers, inverters,
    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 (AC or DC) 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 (AC
    or DC) 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.

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Attachment D: Functional Area Inspection Guidelines

for

Instrumentation and Control.

The I&C design acceptance criteria (DAC) will likely need to be verified
in order to accomplish an adequate review of I&C under a FOAK
engineering inspection.

> NOTE: If the I&C programmatic concepts and Tier 1 material cannot be
> validated as part of the FOAK engineering / pre‑COL inspection
> activities using this procedure, supplemental I&C inspections may be
> needed during the construction phase. Any post‑COL inspections, while
> related, are not considered part of the FOAK engineering reviews under
> IMC‑2502, but will be addressed, as applicable, in other manual
> chapters.

If the I&C design is not complete when this FOAK engineering inspection
is conducted, the governing design verification program (i.e.,
established by the licensee, engineering contractor, or vendor, as
applicable) will be reviewed instead of detailed design material. In
this situation, the inspector should check whether specific ITAAC or DAC
are available to validate the acceptability of the design at a later
time. If it cannot be established that ITAAC/DAC are directly applicable
to the selected I&C inspection sample, the licensee commitments and/or
programmatic controls, as a minimum, should be checked to ensure an
adequate approach to the verification of complete and accurate I&C
design functions and system installation details.

Refer any apparent ITAAC/DAC deficiencies to the NRR/EEIB for additional
review and consideration. If the requisite design documentation is found
to be incomplete during a FOAK engineering inspection, the applicable
I&C program specifications and procedural controls should be evaluated
to assure compliance with all regulatory requirements and commitments in
the areas of design verification, design change and interface controls,
and quality record generation and retention.

Because of the known limitations of the pre‑COL I&C design, inspector
judgement must be used when selecting the I&C inspection sample and when
determining the scope and level of detail that can be verified using the
specific inspection attributes, as discussed below.

a.  Select two different process parameter measurements, such as flow,
    level, pressure, temperature, etc., providing inputs/outputs to a
    digital system which is the intelligence for the mechanical fluid
    system selected (reference: Attachment 02) and select two associated
    controlsystems.

> At least one of the parameters should be selected from those that
> perform a critical function such as reactor trip or actuation of one
> or more engineered safety features. If the mechanical fluid system
> selected for inspection is not emergency core cooling system (ECCS)
> related, additional consideration should be given to ECCSsignal
> inputs.

b.  Review all system requirement input information used for the design
    related to the selected parameters and control systems; it will be
    necessary to interface with the electrical power system design and
    the mechanical system design. Verify that the I&C design inputs 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 ITAAC, DAC, or licensee commitments, as
    applicable. If the installation drawings are not available, review
    the engineering contractor=s or vendor=s hardware specification,
    system architecture, block diagram, and/or other programmatic
    information provided to determine whether the functional and
    installation requirements are accurate, complete, well documented
    and conform to ITAAC, DAC, or licensee commitments.

d.  Select several design change requests (or, as applicable, any
    revisions to the I&C system specifications or drawing details) and
    verify that the engineering contractor=s and/or vendor\'s
    configuration control program and design verification program are
    being effectively and accurately implemented. A review of the
    configuration control program and design verification program should
    include the following:

    1.  the verification method;

    2.  the procedure for implementation;

    3.  the authority for the design change;

    4.  the associated equipment documentation, such as equipment
        specification purchase orders, IEEE Standards, Regulatory
        Guides, construction drawings, and drawing revisions that
        complete the design change cycle;

    5.  the results of the functional tests available for fabricated
        components; and

    6.  the documentation to assure that all design changes have been
        evaluated for general implications.

> If the design is not complete, and no design change requests are
> available, review the engineering contractor=s or vendor\'s design
> verification program to ensure conformance with committed industry and
> regulatory standards. Focus on the adequacy of the controls for
> handling design changes or revisions to other engineering documents.
> To the extent that licensing guidance would be helpful to the
> inspector in reviewing I&C system characteristics and attributes,
> Chapter 7 of the Standard Review Plan can be used as a reference.

e.  Review qualification documentation for safety‑related instruments to
    determine compliance with regulations, regulatory guides and
    national standards applicable to qualification. If qualification
    documents are not yet available, review the engineering contractor=s
    or vendor=s requirements for such documentation, as applicable, to
    assess the existence and adequacy of qualification controls.

f.  For each of the process and mechanical fluid system(s) selected for
    inspection (as well as for any applicable supporting electrical
    systems), identify alarms or annunciators provided as part of the
    instrumentation and review the basis for providing these alarms or
    annunciators, their set‑points, and their locations.

g.  Review the I&C portion of the system descriptions for the mechanical
    fluid system(s) selected for inspection. Check for any unusual
    operating requirements and verify that the I&C design details that
    are available for review adequately address all operational
    conditions and any abnormal 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, verification that passive
    systems have actuated and performed as designed, or any special
    automatic/manual control features.

> If the fluid system and I&C support descriptions are not yet
> available, review the mechanical fluid system requirements and any
> related I&C functional details or operational objectives for similar
> criteria and design conformance to licensing commitments.

h.  Verify that the I&C system (as detailed in the available design
    documents or in the programmatic requirements and commitments)
    detects and maintains essential parameters during all anticipated
    plant conditions. Determine if the detection and control capability
    during a loss of offsite power, or other anticipated operational
    occurrences and accident conditions, meets design requirements.

i.  Assure that all logic functions, (e.g., interlocks, automatic
    actuation and permissives) are properly specified in accordance with
    the design program and detailed, to the extent that the design is
    complete, with an accuracy that assures proper implementation.

j.  Assure that bypassed and inoperable status is indicated as necessary
    or, as a minimum, that programmatic controls exist to adequately
    address the I&C design criteria for alerting operations personnel of
    such equipment or system unavailability.

k.  Review the procedures and basis for developing set points and for
    ensuring that as‑built deviations are considered or will be
    considered when the as‑built information is available.

l.  Determine if the engineering contractor=s or vendor=s design for the
    selected I&C inspection sample of digital systems meets the basic
    requirements established in the applicable IEEE /other industry
    standards and in other commitments.

> Determine if the following programmatic considerations have been
> adequately addressed in the digital system design :

1.  a software qualification program,

2.  a verification and validation (V&V) program,

3.  a design approach that invokes the diversity or defense‑in‑depth
    requirements stipulated in ITAAC, DAC, or licensee commitments.

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Attachment E: Functional Area Inspection Guidelines

for

Materials, Welding, and Nondestructive Examination

To accomplish a review of the materials, fabrication, and nondestructive
examination (NDE) activities, it may be necessary to review the
applicant=s commitments in the Final Safety Analysis Report (FSAR) and
the Design Control Document (DCD) as it relates to the fluid systems,
structural components and structures selected for inspection.

a.  Review and evaluate the process by which materials, welding, and NDE
    requirements are translated into design documents, engineering
    drawings, and procedures to ensure that licensing commitments, ASME
    Code and/or other applicable codes and standard requirements are
    met.

b.  Review examples of components and structures to ascertain that the
    process ensures that materials, welding and NDE requirements are
    incorporated in the design of the component and/or structure.

c.  Verify that the applicant has established an acceptable procurement
    program which includes provisions for procurement of materials,
    welding, and/or NDE services.

d.  Review examples of purchase orders involving procurement of
    materials, welding, and/or NDE services. The verification should
    include the following:

    1.  Verify that appropriate procedural controls have been
        established to ensure that procurement documents adequately
        describe the work the materials supplier will perform.

    2.  Verify that applicable regulatory, design, technical,
        administrative, and reporting requirements are included in the
        purchase specifications.

    3.  Verify that governing codes and standards are referenced in the
        purchase specifications.

    4.  Verify that applicable NDE, qualification, test and acceptance
        requirements stated in the governing codes and standards are
        referenced in the purchase specifications.

        e.  For components and structures selected for review in
            accordance with item (b) above, verify that selected
            materials are compatible with the intended service of the
            component and/or structure. In addition, verify that the
            specified welding processes and NDE are suitable to produce
            the quality required by the governing codes and standards.

        f.  For components and structures selected for review in
            accordance with item (b) above, ascertain that
            lessons-learned from operating experience has been included
            during the design phases of the component and/or structure.

        g.  For components and structures selected for review in
            accordance with item (b) above, ascertain that procedures
            exist to control design changes involving substitution of
            materials, welding processes and NDE. Verify that changes
            are approved in accordance with an approved procedure or
            process.

Attachment F: Functional Area Inspection Guidelines

for

Mechanical Components

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.

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 applicant
    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 applicant
    commitments. Particular attention should be given to the operability
    evaluation for seismic events. Also, valve actuator qualification
    documentation should be reviewed for conformance with certified
    design information.

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 applicant commitments and
    construction 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.

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Attachment G: Functional Area Inspection Guidelines

for

Quality Assurance

a.  Verify that the design activities were conducted in accordance with
    an approved QA program.

b.  Select for review several risk-significant components described in
    the applicable construction procedure, a mix of safety related and
    non-safety related. Focus on components selected for the inspection
    and verify the following:

    1.  The reliability requirement for each component is equal to or
        greater than the reliability specified by the design-reliability
        assurance program.

    2.  Operations, maintenance, and monitoring activities were assessed
        during the process of estimating the reliability of these
        components.

c.  Verify that design control measures provide for verifying or
    checking the adequacy of design, such as by the performance of
    design reviews, by the use of alternate or simplified calculational
    methods, or by the performance of a suitable testing program for the
    selected system or systems as follows:

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1.  The verifying or checking process is performed by individuals or
    groups other than those who performed the original design, but who
    may be from the same organization.

2.  The results of design verification are clearly documented with the
    identification of the verifier clearly indicated.

3.  Design verification is performed by any competent individual(s) or
    group(s) other than those who performed the original design but who
    may be from the same organization. This verification may be
    performed by the originator=s supervisor, provided the supervisor
    did not specify a singular design approach or rule out certain
    design considerations and did not establish the design inputs used
    in the design or, provided the supervisor is the only individual in
    the organization competent to perform the verification. Cursory
    supervisory reviews are not acceptable.

4.  Design verification is performed for changes, including evaluation
    of the effects of those changes on the overall design and on any
    design analyses upon which the design is based that are affected by
    the change to previously verified design.

5.  Where design adequacy is to be verified by qualification tests, the
    tests are identified. The test configuration is clearly defined and
    documented. Testing demonstrates the adequacy of performance under
    conditions that simulate the most adverse design conditions.
    Operating modes and environmental conditions in which the item must
    perform satisfactorily are considered in determining the most
    adverse conditions. Where the test is intended to verify only
    specific design features, the other features of the design are
    verified by other means. Test results are documented and evaluated
    by the responsible design organization to assure that test
    requirements have been met. If qualification testing indicates that
    modifications to the item are necessary to obtain acceptable
    performance, the modification is documented and the item modified
    and retested or otherwise verified to assure satisfactory
    performance. When tests are being performed on models or mockups,
    scaling laws are be established and verified. The results of model
    test work are subject to error analysis, where applicable, prior to
    use in final design work.

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d.  Verify the following for any significant condition adverse to safety
    that is associated with the system or systems selected:

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1.  The corrective action was adequate.

2.  The corrective action was reviewed and approved by appropriate
    levels of management.

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e.  Verify that the applicant=s audits of the design control process are
    adequate as follows:

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1.  Planned and periodic audits are carried out to verify compliance
    with the significant elements of the design control process and to
    determine the effectiveness of the program.

2.  Audit results are documented and reviewed by management having
    responsibility in the area audited.

3.  Followup action, including re-audit of deficient areas, is taken
    where indicated.

4.  The individual or organizational (responsible for verifying QA
    program implementation activities) are periodically audited by
    designated offsite personnel.

5.  The auditing organization develops and documents an audit plan for
    each audit. This plan identifies the audit scope, requirements,
    audit personnel, activities to be audited, organizations to be
    notified, applicable documents, schedule, and written procedures or
    checklists.

6.  The auditing organization selects and assigns auditors who are
    independent of any direct responsibility for performance of the
    activities which they audit.

7.  Personnel having direct responsibility for performing the activities
    being audited are not involved in the selection of the audit team.

8.  Audit personnel have sufficient authority and organizational freedom
    to make the audit process meaningful and effective.

9.  Conditions requiring prompt corrective action are reported
    immediately to management of the audited organization.

10. Follow-up action is taken to verify that corrective action is
    accomplished as scheduled.

11. The QA program for any engineering contract associated with the
    design control process has been reviewed, approved and audited by
    the applicant.

APPENDIX A

Design Input Considerations

(Excerpt from ASME NQA-1 - 1994 Edition, Appendix 3A-1)

a.  Basic functions of each structure, system, and component.

b.  Performance requirements such as capacity, rating, and system
    output.

c.  Codes and standards, regulatory requirements and commitments or
    responses to Federal, State, and Local Regulations. For example,
    these may include, but not be limited to:

    1.  Safety Analysis Report

    2.  NRC=s Safety Evaluation Report and supplements thereto

    3.  Environmental Report

    4.  NRC=s environmental statement and supplements thereto

    5.  Technical Specifications

    6.  Regulatory Guides

    7.  Code of Federal Regulations

    8.  NRC bulletins, circulars, notices, and generic letters

    9.  Commitments in correspondence with NRC

d.  Design conditions such as pressure, temperature, fluid chemistry,
    and voltage.

e.  Loads such as seismic, wind, thermal and dynamic; the cumulative
    effect of design changes on the analytical design basis, e.g., the
    addition of a load to an existing wall or the addition of an
    instrument to a cabinet.

f.  Environmental conditions anticipated during storage, construction,
    and operation, and accident conditions, such as pressure,
    temperature, humidity, corrosiveness, site elevation, wind
    direction, exposure to weather, flooding, nuclear radiation,
    electromagnetic radiation and duration of exposure; qualification
    test requirements; shelf or service life limitations.

g.  Interface requirements including definition of the functional and
    physical interfaces involving structures, systems, and components:

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1.  the effect on existing plant equipment capability, such as DC
    battery loads, AC bus capacity, available stored water inventory,
    service instrument air capacity, water systems capability (intake,
    service and component cooling water), and HVAC capability;

2.  the effect of cumulative tolerances in the design;

3.  the effect on design and safety analyses to ensure the analytical
    bases remain valid;

4.  the compatibility with unimplemented design changes to specify any
    required sequence for implementation;

5.  compatibility with Technical Specification requirements.

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h.  Material requirements including such items as compatibility,
    electrical insulation properties, protective coatings, and corrosion
    resistance.

i.  Mechanical requirements such as vibration, stress, shock, and
    reaction forces.

j.  Structural requirements covering such items as equipment foundations
    and pipe supports.

k.  Hydraulic requirements such as pump net positive suction heads
    (NPSH), allowable pressure drops and allowable fluid velocities.

l.  Chemistry requirements including provisions for system flushing,
    batch sampling and in-line sampling. Power plant water chemistry
    treatment for primary systems, steam generator, and plant
    limitations on water chemistry.

m.  Electrical requirements such as power, load profile voltage,
    electrical insulation, motor requirements, physical and electrical
    separation of circuits and equipment; the effect of cable routing or
    rerouting on the cable tray system (loading, seismic capability, and
    capacity limitations).

n.  Layout and arrangement requirements.

o.  Operational requirements under various conditions such as startup,
    normal operation, shutdown, maintenance, abnormal, or emergency
    operation, special or infrequent operation including installation of
    design changes, and the effect of system interaction.

p.  Instrumentation and control requirements including indicating
    instruments, controls, and alarms required for operation, testing,
    and maintenance. Other requirements such as type of instrument,
    installed spares, range of measurement and location of indication
    are included.

q.  Security requirements to include access and administrative control
    requirements and system design requirements including redundancy,
    power supplies, support system requirements, emergency operational
    modes, and personnel accountability.

r.  Redundancy, diversity and separation requirement of structures,
    systems and components.

s.  Failure effects requirements of structures, systems and components
    including a definition of those events and accidents which they must
    be designed to withstand.

t.  Test requirements including pre-operational and subsequent periodic
    tests and conditions under which they will be performed.

u.  Accessibility, maintenance, repair, and pre-service and inservice
    inspection requirements for the facility including the conditions
    under which these will be performed.

v.  Personnel requirements and limitations including the qualification
    and number of personnel available for operation, maintenance,
    testing and inspection, and radiation exposures to the public and
    facility personnel.

w.  Transportability requirements such as size and shipping weight,
    limitation, and regulations for interstate commerce.

x.  Fire protection or resistance requirements:

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1.  safe shutdown analyses, the introduction of safe shutdown equipment
    into fire areas;

2.  routing of piping and electrical cables and the necessity for cable
    fireproofing and/or fire stops;

3.  fire detection and fire suppression capability;

4.  fire barrier capability including fire door installation;

5.  fire dampers;

6.  access to fire fighting and emergency equipment;

7.  use of non-combustible materials;

8.  introducing combustible materials into safe shutdown areas by design
    or during installation or operation;

9.  Smoke and toxic gas generation.

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y.  Handling, storage, cleaning and shipping requirements.

z.  Other requirements to prevent undue risk to the health and safety of
    the public.

a.  Materials, processes, parts, and equipment suitable for application.

b.  Safety requirements for preventing personnel injury including such
    items as radiation safety, minimizing radiation exposure to
    personnel, criticality safety, restricting the use of dangerous
    materials, escape provisions from enclosures and grounding of
    electrical systems.

c.  Quality and quality assurance requirements.

d.  Reliability requirements of structures, systems, and components
    including their interactions, which may impair functions important
    to safety.

e.  Interface requirements between equipment and operation and
    maintenance personnel.

f.  Requirements for criticality control and accountability of nuclear
    materials.

g.  Load path requirements for installation, removal, and repair of
    equipment and replacement of major components.