ATTACHMENT 65001.11

CONSTRUCTION INSPECTION PROGRAM

INSPECTION OF ITAAC RELATED CONTAINMENT INTEGRITY AND CONTAINMENT
PENETRATIONS

65001.11-01 INSPECTION OBJECTIVES

01.01 Verify that materials such as welding consumables, plate material,
including pre-fabricated plate sections, and major prefabricated
containment penetration assemblies were purchased in accordance with the
approved design. .

01.02 Verify that materials such as welding consumables, plate material,
and prefabricated containment penetrations are being properly stored and
handled in accordance with approved procedures.

01.03 Verify that the installation and welding of plate material for the
containment and containment penetration assemblies is accomplished in
accordance with approved drawings, qualified procedures, and applicable
codes and standards by qualified welders as specified in the design
documents.

01.04 Verify that post-weld heat treatment (PWHT) is performed in
accordance with the design specifications and applicable code
requirements.

01.05 Verify that final NDE has been performed and found acceptable, in
accordance with the applicable code.

01.06 For PWRs, upon completion of the containment liner and
installation of all containment penetrations and major offsite
manufactured assemblies, verify and monitor the process for erecting
reinforcing bars and the placing of concrete.

01.07 Verify that major offsite fabricated assemblies have been
fabricated and installed in accordance with the manufacturer=s
instructions and design engineering specifications.

01.08 Verify that all electrical and I&C penetrations are installed per
their design specifications.

01.09 Verify that the exterior of the containment is treated in
accordance with design engineering specifications.

01.10 Verify that the testing of the containment and the installed
containment penetrations have been successfully completed to fulfill the
requirements as specified in the design specification.

01.11 Verify that problems identified during the inspection are entered
into the licensee/constructor corrective action program in accordance
with program requirements.

65001.11-02 INSPECTION REQUIREMENTS AND GUIDANCE

This inspection procedure shall be performed prior to and during
containment construction and containment penetration installation and
during final testing of the completed containment including
certification testing.

02.01 Verify that materials such as welding consumables, plate material,
including pre-fabricated plate sections, and major prefabricated
containment penetration assemblies were purchased in accordance with the
approved design. Review a sample of Purchase Orders for these materials
and verify conformance with design requirements and purchasing
specifications. The inspector should inspect Purchase Orders for
containment plate material and Purchase Orders for containment
penetration assemblies and major prefabricated assemblies. For those
items selected, review the documentation of site receipt inspections to
ensure conformance with the Purchase Order.

[Guidance]{.underline}. For containment plate material select the sample
from a representative cross section of vendors and include plate
material and any prefabricated plate assemblies. For containment
penetrations the sample selection should include various sizes of
electrical, I&C and mechanical penetrations from different vendors.

In the case of major prefabricated assemblies (containment opening hatch
and personnel air lock) the inspector should verify the Purchase Order
for each assembly for conformance with purchase order and design
engineering specifications.

The Purchase orders should explicitly state the type of quality
documentation required (e.g., Certified Material Test Report (CMTR) or
Certificate of Compliance) in accordance with the design requirements.
If a CMTR was required, the inspector should verify that chemical and
physical test results, including heat treatment as applicable, comply
with the material specification required by the design documents.
Typical attributes included in receipt inspections are:

\$ Plate material or containment penetration assemblies are in
conformance with purchase specification

\$ Marking and identification

\$ Evidence of damage

\$ Cleanliness at time of receipt

\$ Surface protection, closures and packaging and storage requirements

\$ Disposition of non-conforming items

02.02 Verify that materials such as welding consumables, plate material,
and prefabricated containment penetrations are being properly stored and
handled in accordance with approved procedures. From the sample selected
in 02.01, verify that onsite storage is adequate and in accordance with
applicable procedures.

[Guidance]{.underline}. Welding consumables such as coated electrodes,
bare weld rod and spools, and inserts require special handling and
storage considerations because these materials are melted during the
welding process and become part of the welded joint. Welding material
storage procedures must contain requirements for environmental
cleanliness and moisture control as contaminants like dirt, grease, and
moisture can cause weld defects such as lack of fusion, porosity, and
cracking due to hydrogen embrittlement.

Plate material, prefabricated containment penetrations and penetration
materials and valves are often stored outside, exposed to the elements
in lay-down areas located around the construction site. The surface to
be welded should be reasonably smooth, and free of rust, scale, oil,
grease, and other deleterious foreign materials, including moisture.
Stainless steel components should be stored separately from carbon steel
components as contact with carbon steel can contaminate the stainless
steel and cause surface rust to appear. Likewise, contact with carbon
steel chains should be avoided when rigging to lift stainless
components. Any tape used on stainless steel material and components
should be certified as containing low halogen and chlorides as these are
known to promote cracking.

Typical considerations for inspecting adequacy of storage areas are as
follows:

\$ Improper storage classification.

\$ Determination of the status of protective mechanisms at the time of
site receipt and initial storage.

\$ Adequacy of dunnage for plate material, containment penetration
assembly components, and major prefabricated assemblies during storage.

\$ Continued adequacy of end caps for containment penetration assemblies
protective coverings for weld preparation areas.

\$ Weather protection in the form of canvas or plastic coverings. (In
most deficiencies, the original protective covering was adequate, but
inattention to damage and normal \"wear and tear\" led to substandard or
unacceptable protective provisions.)

\$ Sites near salt water should receive special attention to assure that
protective storage measures are considerate of salt water damage
(Chloride Contamination).

\$ Storage areas located on sandy soil or near sandy beaches require
special attention to avoid the entry of wind-driven sand particles into
plate material and containment penetration assemblies and assembly
components.

\$ Inadequate or illegible material identification (damage by handling
and/or environment).

\$ Storage of stainless steel pipe on dunnage treated with fire
retardants may expose the piping to excessive halogens or chlorides.

\$ Fire-retardant coatings applied to structural steel may have high
halogen or chloride contents. Adjacent stainless steel materials and
components should be protected from these compounds.

02.03 Verify that the installation and welding of plate material for the
containment and containment penetration assemblies is accomplished in
accordance with approved drawings, qualified procedures, and applicable
codes and standards by qualified welders as specified in the design
documents. Select several in-process welds for detailed review. Further
guidance on welding can be found in IP 65001.B.

[Guidance]{.underline}. The combination of welds selected should
represent various stages of the welding process (e.g., weld joint
preparation, fit-up, root pass, final pass), various weld processes
(e.g., SMAW, GTAW, GMAW), and various material types and pipe size
(generally those materials designated in the applicable edition of the
ASME Boiler and Pressure Vessel Code, Section IX). Emphasis should also
be given to welds that, because of their physical location are difficult
to accomplish.

The inspector should review the applicable welding procedures in detail
to verify that the procedures are properly qualified in accordance with
the codes and standards specified in the design documents. For those
welds selected, verify that the welder(s) is properly qualified for the
piping material, electrode / process, and position and that the welder=s
identity is recorded via stamping the weld or by other means such as
documentation.

The welding process is generally controlled by a traveler which will
specify the steps in completing the weldment, materials to be used, and
will also document QC inspections and step completion. Verify that
welding procedures, detailed drawings and instructions if applicable,
and weld data sheets are at the work station or readily available.
Material traceability has been a significant issue at some construction
sites in the past. The inspector should verify that the containment
plate material and the containment penetration assemblies and/or
materials and welding consumables are of the specified type and grade
and are adequately and uniquely identified (such as by heat number) in
the traveler or accompanying documentation.

The inspector should verify the following:

\$ The containment liner plate sections are being installed at the
proper location in the plant in accordance with approved drawings. If a
plate joint fit-up is specified, verify the installation is within in
the tolerance provided in the specification. Inspection should include
verification that plate-to-plate gap and overall structure requirements
are in compliance with drawing and code requirements.

\$ Weld joint geometry is as specified in the drawings and surfaces to
be welded have been prepared, cleaned, and inspected in accordance with
applicable procedures.

\$ NDE such as visual inspection, magnetic particle (MT) or dye
penetrant (PT) examination of the surfaces to be welded has been
performed and found acceptable in accordance with the specified code.

\$ Components to be welded are assembled and held in place within
specified gap and alignment tolerances and that alignment is within
limits allowed by the drawings or code. Cold springing of plate sections
should be avoided. Any observed cold spring of containment plate
sections during installation must be in accordance with allowance
provided in the approved procedures, or by engineering evaluation and
analysis.

\$ Tack welds and temporary attachments such as bridging bars or fit-up
clips have been performed by qualified welders, in accordance with
qualified WPS.

\$ Gas purging, if specified, is used in accordance with the applicable
procedure and that protection is provided to shield the welding
operation from adverse environmental conditions.

\$ Preheat and interpass temperature, if specified, is maintained in
accordance with applicable procedure requirements. The interpass
temperature for welding austenitic stainless steels and high nickel
alloys should not exceed 350^o^ F.

\$ Welding equipment, including power cables and gas lines, are in good
condition and that ammeters and voltmeters used for automatic welding
have been calibrated in accordance with applicable procedure
requirements.

\$ Procedures specify appropriate holding and baking temperatures and
out-of-oven exposure time for each class of coated electrode. Procedures
for maintaining welding consumable cleanliness and limiting electrode
moisture pickup are strictly adhered to.

\$ Procedures for weld rod control maintain identification after the
welding materials are issued to the welder and are strictly adhered to.
Rod stubs are controlled and disposed of in accordance with the
procedures.

\$ Interpass cleaning, grinding (especially starts and stops) and
backgouging, if applicable are conducted in accordance with the
applicable procedure.

\$ Temporary attachments, arc strikes and weld splatter are removed and
inspected in accordance with specified procedures.

\$ Minor weld material removal such as by light grinding and rewelding
is generally permissible during the welding process. Repairs performed
after the weld is completed and as a result of final visual or other NDE
method finding the weld unacceptable shall be accomplished in accordance
with approved repair procedures and shall be documented. Any repairs or
modifications to ASME Code-stamped components shall be properly
documented in the applicable Code data report as required by ASME
Sections III and XI.

\$ The welding process preheat and interpass temperatures do not damage
degradable materials (e.g., cable or instrumentation lines) inside
containment penetrations.

02.04 Verify that post-weld heat treatment (PWHT) is performed in
accordance with the design specifications and applicable code
requirements. Select several welds requiring post-weld heat treatment
over the course of the containment plate installation and the
containment penetration installation phase of construction. Direct
observation is preferred however, since most welds do not require post
weld heat treatment, a review of records is acceptable.

[Guidance]{.underline}. The need for PWHT is generally determined by the
material type and thickness. For example, carbon steel, low alloy piping
such as ASME SA106 typically requires PWHT when the thickness is 1-1/2\"
or greater when ASME is the applicable code however, PWHT is required
when the thickness is greater than 3/4\" when B31.1 is the applicable
code.

The PWHT procedure shall be in accordance with the applicable code and
specify essential parameters such as number and placement of
thermocouples, heat up and cool down rate, and soak time and
temperature. The PWHT documentation should support that these variables
were controlled throughout the process. Typically, chart recorders are
used to demonstrate that the heat treat operation was successfully
completed.

Often, Charpy impact qualification is required for weldments requiring
PWHT. It is essential that the inspector verify that both the base metal
and weld material were properly qualified in accordance with the
applicable code for PWHT. Governing codes generally require that final
NDE of the weld joint be performed [after]{.underline} PWHT.

02.05 Verify that final NDE has been performed and found acceptable, in
accordance with the applicable code. Observe NDE in progress on several
welds when this procedure is performed. Examiners must be qualified for
the method and procedure that they are performing. If NDE is not being
performed during the inspection, perform a record review. In addition,
review the radiographs of three welds.

[Guidance]{.underline}. The inspector should verify the following:

-   The sample should contain a range of NDE methods such as liquid
    penetrant (PT), magnetic particle (MT), ultrasonic (UT), and
    radiography (RT).

-   The NDE procedure is in accordance with the applicable code as
    specified in the design specification.

-   The NDE is performed in strict accordance with the procedure.
    Typical issues with NDE performance are:

-   Inadequate cleaning of the surface for PT and MT. False indications
    may result if surface contaminants are present. Verify adequate
    dwell time for penetrant application and that the temperature of the
    weld surface is within that qualified for the procedure.

-   Inadequate magnetic field due to a defective yoke. Yoke strength
    should be demonstrated at intervals specified in the procedure. If
    prods are utilized, verify that the spacing and current are in
    accordance with the procedure. Any arc marks caused by prods must be
    removed.

-   UT is the method most sensitive to examiner performance and
    interpretation. The inspector should verify that those doing UT are
    properly qualified by training, experience and test
    demonstration**;** and the UT equipment complies with the procedure
    and that all variables are strictly controlled.

-   For RT, verify that isotope source strength, film type, source to
    film distance, and exposure times are in accordance with the
    procedure. Verify that image quality indicators are the correct type
    and thickness and that the required sensitivity and radiograph
    density meet the applicable code requirement.

02.06 For PWRs, upon completion of the containment liner and
installation of all containment penetrations and major offsite
manufactured assemblies, verify and monitor the process for erecting
reinforcing bars and the placing of concrete. Ensure that control of
construction debris and liquids is in effect. Ensure that the owner has
control of foreign materials (wood, rags, liquids, etc.) which could
cause corrosion of the steel liner. Prior to placing concrete ensure
that the containment liner is coated on the exterior surface in
accordance with the design specifications. The inspector should verify
that any exterior coatings or treatments are applied if required in
accordance with the owner=s guidance and engineering design
specifications.

02.07 Ensure that major offsite fabricated assemblies, such as personnel
airlock assemblies and equipment hatch assemblies, have been fabricated
and installed in accordance with the manufacturer=s instructions and
design engineering specifications. After installation and prior to
testing of these assemblies, ensure that the assembly has been protected
from damage and is maintained in operable condition.

02.08 Ensure that all electrical and I&C penetrations are installed per
their specifications, reference Inspection Procedures 65001.8, 65001.9
and 65001.10. Ensure that installed electrical and I&C penetrations have
no visible damage and are ready to function in accordance with
manufacturer=s instructions and design engineering specifications.

02.09 Ensure that the exterior of the containment is treated in
accordance with design engineering specifications. Ensure that any
required coatings and preservatives on all containment surfaces are
applied in accordance with design specifications and manufacturer=s
instructions.

02.10 Upon completion of containment construction, including all
penetrations and major offsite fabricated assemblies, verify that the
testing of the containment and the installed containment penetrations
have been successfully completed to fulfill the requirements of 10 CFR
50, Appendix J Type A, Type B and Type C testing requirements and as
specified in the design specification. The inspector should observe the
performance of the Type A , B, and C tests, if used, during the
construction and testing phases. These reviews should examine the final
test results and the technical resolution of any observed or documented
anomalies.

[Guidance]{.underline}. The inspector should verify the following:

-   That the local leakage testing procedure contains provisions which
    comply with the governing code (e.g., temperature requirements, test
    pressure, hold time, and inspection methods).

-   Pressure gages, recorders, and other test equipment are within the
    pressure range specified by the code and that calibration is
    current.

02.11 [Problem Identification and Resolution]{.underline}. The inspector
should confirm that problems identified during the inspection are
entered into the licensee/constructor corrective action program in
accordance with program requirements. The inspector should also confirm
that licensee construction and testing procedures contain appropriate
criteria defining what constitutes a non-conforming condition and what
requires documentation in the corrective action process.

The inspector may review licensee actions to address similar or related
problems that were previously identified, in order to check the extent
of condition and confirm the effectiveness of the licensee=s corrective
measures. Ensure that the licensee=s program procedures address the
extent of condition for similar problems in other areas to avoid
repetition of problem conditions.

[Guidance]{.underline}. This inspection is to assure that problems are
entered into the applicable process to assure corrective actions
appropriate to the circumstances are developed and prioritized.
Inspections of Quality Assurance Program implementation, effectiveness
of Problem Identification and Resolution, and Self-Assessment will be
performed under the IMC 2504 processes.

65001.11-03 RESOURCE ESTIMATE

Due to the length and complexity of the construction of the containment
and the importance of the component, the average resource expenditure
for this procedure is estimated to be 300 inspection hours per Unit.

65001.11-04 REFERENCES

Inspection Procedure 65001.B.01 Programmatic ITAAC Attributes for
Welding

10 CFR 50, Appendix A, General Design Criteria 50, Primary Containment

10 CFR 50, Appendix J, Primary Containment Leakage Testing for
Water-Cooled Power Reactors

10 CFR 50.55a Codes and Standards

NUREG/CR-5096, \"Evaluation of Seals for Mechanical Penetrations of
Containment Buildings.\" August 1988

NUREG/CR-3855, \"Characterization of Nuclear Reactor Containments,\"
June 1984

NUREG/CR-6154, \"Experimental Results from Containment Piping Bellows
Subjected to Severe Accidents,\" Sept. 1994.

NUREG-1273, \"Technical Findings and Regulatory analysis for GI
II.E.4.3, \"Containment Integrity Check,\" April 1988.

END

Attachment 1: Revision History for IP 65001.11

Attachment 1

Revision History For 65001.11

+--------+--------+----------------------+------+-------+-------------+
| Comm   | Issue  | Description of       | Trai | Tra   | Comment     |
| itment | Date   | Change               | ning | ining | Resolution  |
| Tr     |        |                      | Ne   | Compl | Accession   |
| acking |        |                      | eded | etion | Number      |
| Number |        |                      |      | Date  |             |
+--------+--------+----------------------+------+-------+-------------+
|        | 08     | 1\. Initial issuance | None | N/A   | N/A         |
|        | /19/08 | to support ITAAC     |      |       |             |
|        |        | related inspection   |      |       |             |
|        | CN     | under 10CFR52.       |      |       |             |
|        | 08-024 |                      |      |       |             |
|        |        | 2\. Number range     |      |       |             |
|        |        | CHAPTERResearched    |      |       |             |
|        |        | commitments for 4    |      |       |             |
|        |        | years and found      |      |       |             |
|        |        | none.                |      |       |             |
+--------+--------+----------------------+------+-------+-------------+
|        |        |                      |      |       |             |
+--------+--------+----------------------+------+-------+-------------+
|        |        |                      |      |       |             |
+--------+--------+----------------------+------+-------+-------------+
|        |        |                      |      |       |             |
+--------+--------+----------------------+------+-------+-------------+
|        |        |                      |      |       |             |
+--------+--------+----------------------+------+-------+-------------+
|        |        |                      |      |       |             |
+--------+--------+----------------------+------+-------+-------------+