**NRC INSPECTION MANUAL** IIPB

INSPECTION PROCEDURE 51061

ELECTRIC CABLE ‑ PROCEDURE REVIEW

PROGRAM APPLICABILITY: 2509

51061‑01 INSPECTION OBJECTIVES

01.01 To determine whether technical requirements contained in the
facility safety analysis report (SAR) for safety‑related electric cable,
terminations and associated items have been adequately translated into
applicable construction specifications, drawings, work procedures, and
instructions, and whether these documents are of sufficient detail and
clarity for adequate work performance and control.

01.02 To determine whether applicable quality assurance plans,
instructions and procedures for the control and installation of
safety‑related electric cable, terminations, and associated items have
been established in licensee and contractor QA manuals and whether these
conform to the QA program described in the facility SAR.

01.03 To determine whether any generic problems or other weaknesses
exist within the operation of organizations responsible for quality
assurance programs and work specifications and instructions for control
and installation of electric cable, terminations, and associated items.

+-----------+------------------+------------------+-------------------+
| [I        |                  |                  |                   |
| nspection |                  |                  |                   |
| Sch       |                  |                  |                   |
| edule]{.u |                  |                  |                   |
| nderline} |                  |                  |                   |
+-----------+------------------+------------------+-------------------+
| [Inspe    | [May Be          | [Must Be         | [Must Be          |
| ction]{.u | Star             | Star             | Compl             |
| nderline} | ted]{.underline} | ted]{.underline} | eted]{.underline} |
+-----------+------------------+------------------+-------------------+
| Initial   | Six months       | Before work is   | Substantially     |
|           | before           |                  | complete before   |
|           |                  | started          | work              |
|           | work is started  |                  |                   |
|           |                  |                  | is 20% complete   |
+-----------+------------------+------------------+-------------------+
| Followup  | After work is    | After work is    | Before work is    |
|           |                  |                  | 70%               |
|           | 40% complete     | 50% complete     |                   |
|           |                  |                  | complete          |
+-----------+------------------+------------------+-------------------+

51061‑02 INSPECTION REQUIREMENTS

02.01 [Quality Assurance Program]{.underline}. Review licensee and
contractor commitments and procedures covering the span of documents to
be prepared for assuring the quality of safety‑related electric cable
and terminations.

> a\. Complete the requirements of IP 35100 for each onsite organization
> associated with safety‑related electric cable and terminations.
> Additionally, determine whether these procedures are consistent with
> the QA program described in the SAR.
>
> b\. Determine whether responsibility assignments for procedures
> preparation, review and approval include groups with necessary
> technical expertise.
>
> c\. Determine whether groups that review and approve quality records
> are required to have the necessary technical expertise to ensure that
> the information to be recorded meets applicable requirements.

02.02 [Specific Technical Review Areas]{.underline}. In addition to the
broad areas covered by IP 35100, determine whether procedures covering
work and inspection activities in the following areas are appropriate
for the activity and are technically adequate.

> a\. [Receiving Inspection Procedures]{.underline}. Receiving
> inspection and related procedures provide means to ensure that:
>
> 1\. Received components are as specified, properly identified and
> controlled ‑ or otherwise noted.
>
> 2\. Inputs from other groups or other organizations to be used during
> receiving inspection activities are properly utilized; such as the
> results of source inspections, environmental qualification tests and
> other required quality tests.
>
> 3\. Procurement requirements such as qualification tests (seismic,
> environmen­tal, etc.), functional tests and other quality tests
> (material, physical and chemical) have been successfully completed or
> status of how and when such requirements will be satisfied is
> documented and adequately controlled.
>
> b\. [Storage Procedures]{.underline}. Storage procedures provide means
> to ensure that:
>
> 1\. The proper storage environments (as specified by the construction
> specifica­tions and the manufacturers) are established for the various
> types of electric cable and cable system components and meet
> applicable storage classifica­tion levels regardless of the location of
> the stored item.
>
> 2\. Storage inspection procedures require initial verification of
> storage conditions and periodic verifications for the duration of the
> storage period. They must also ensure that special and in‑place
> storage requirements are met.
>
> c\. [Work Procedures]{.underline}. Work procedures are established to
> ensure that:
>
> 1\. NRC requirements and SAR commitments are properly translated into
> the work procedures (construction specifications, drawings and work
> instructions) for adequate control and installation of electric cable
> and associated items. Areas to review shall include, but are not
> limited to, the following:
>
> \(a\) Raceway completion (edge softeners, bushings, supports,
> identification, sharp edges, etc.) and condition (free of debris)
> before use.
>
> \(b\) Cable type and size.
>
> \(c\) Cable temperature (if stored in cold weather).
>
> \(d\) Cable splices (where allowed).
>
> \(e\) Pulling attachments, lubricating compounds, and tension
> (including calibration of tension devices).
>
> \(f\) Bending radius (during and after installation).
>
> \(g\) Cable identification.
>
> \(h\) Cable routing.
>
> \(i\) Separation and independence.
>
> \(j\) Segregation (power, control, instrument).
>
> \(k\) Cable supports (grips).
>
> \(l\) Handling of cable and termination materials to ensure protection
> from damage and contamination (includes the protection of cable ends
> from moisture).
>
> \(m\) Protection of cables from adjacent construction activities.
>
> \(n\) Hold points.
>
> \(o\) Termination activities such as:
>
> \(1\) Application of materials (lugs, tapes, stress cones, connectors,
> terminal blocks, etc.).
>
> \(2\) Use of calibrated torque wrenches and crimping tools.
>
> \(p\) Raceway loading.
>
> \(q\) Fire barriers and seals as required.
>
> 2\. Interface controls are adequate when multiple contractors are
> involved.
>
> d\. [Inspection Procedures]{.underline}. Inspection procedures have
> been established and include the following:
>
> 1\. Positive identification of the cable system and/or activity to be
> inspected and the specific inspection method(s) to be used.
>
> 2\. All the technical aspects of inspection requirements to
> sufficiently determine whether installation, testing, maintenance and
> protection conform to applicable design and construction
> specifications.
>
> 3\. Identification of the specific acceptance criteria and
> verification that acceptance criteria are met, including special
> requirements.
>
> 4\. All required data that is to be recorded on inspection reports and
> to whom the completed reports are to be transmitted.
>
> 5\. Qualification of inspection personnel.
>
> 6\. Review and evaluation of inspection reports.
>
> e\. [Construction Testing Procedures]{.underline}. Procedures for
> cable system and component testing provide means to ensure that:
>
> 1\. Required construction testing is controlled and performed as
> specified using qualified personnel.
>
> 2\. Cable systems and components to be tested are properly identified
> along with tests to be conducted.
>
> 3\. Proper type of test equipment (range, accuracy, calibration, etc.)
> is specified.
>
> 4\. Special conditions of testing, prerequisites, sequence,
> precautions, etc., and acceptance criteria are specified and meet
> requirements.
>
> 5\. Type of data to be recorded and method of reporting results are
> specified.
>
> 6\. Test results are evaluated by qualified personnel.
>
> 7\. Discrepancies are resolved.
>
> f\. [Personnel Qualification]{.underline}. A program has been
> established for ensuring that all craft, examination and inspection
> personnel associated with electric cable systems are trained and
> qualified to perform their assigned duties. The program includes:
>
> 1\. The proper use of installation equipment (tension devices, pulling
> compounds, etc.).
>
> 2\. The proper handling, supporting and protection of cables and cable
> segments stored in place.
>
> 3\. Approved methods for cable end protection.
>
> 4\. Identification of requirements for the installation of
> safety‑related cables.
>
> 5\. Approved methods for cable termination and splices.
>
> g\. [Change Control Procedures]{.underline}. Procedures have been
> established to control design and field changes for cable systems and
> ensure:
>
> 1\. Coordination among participating design and construction
> organiza­tions.
>
> 2\. Retrieval of voided drawings and specifications at work sites is
> controlled.
>
> 3\. Periodic inspection of drawings, specifications, and procedures
> used in the field.

02.03 [Followup Procedure Review]{.underline}. When cable and
terminations are about 50% installed, review work and QA/QC procedures
pertaining to installation and inspection. Review a selected sample of
procedures addressed in Sections 02.01 and 02.02, above. Note
significant changes made (revisions, deletions, additions, etc.) and
determine whether the changes are appropriate and whether NRC
requirements and licensee commitments remain in these procedures.

02.04 [Additional Inspection]{.underline}. Additional inspections may be
conducted in the areas covered above if Regional management concludes
that recent findings when evaluated by the SDP will likely result in an
assigned color of \>white or above=. In these cases, particular
consideration should be given to an expanded sample of items to be
inspected under Sections 02.01, 02.02c and 02.02d, above.

51061‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}

> a\. This IP applies, but is not limited, to all safety‑related
> electric power, control and instrument cables, terminations, splices,
> fire barriers and seals. The term \"cable\" includes all conductors
> such as wires, cables and busbars. The term \"termination\" includes
> all electric conductor terminations such as lugs, splices, connectors,
> and terminal strips which directly contribute to the electrical
> continuity of the circuit. Terminations also include potheads,
> bushing, stress cones, taping, compounds, and other devices or
> techniques which directly contribute to the continuity of the
> electrical insulation system.
>
> b\. Applicable portions of the SAR, Safety Evaluation Report (SER) and
> NRR/licensee questions and answers should be reviewed during
> inspection preparation. Determine specific licensee procedural and
> work instruction commitments relative to construction and inspection
> (QC) requirements for electric cables and terminations. The inspector
> should then utilize the above information during review of the
> licensee\'s construction specifica­tions, drawings, work, and
> inspection procedures to determine whether SAR requirements are
> adequately translated into the appropriate documents.
>
> c\. Procedures control activities such as storage, installation,
> inspection, calibration and testing. To be adequate, they must contain
> sufficient detail to assure that the specific work steps which affect
> the functioning of the installed equipment will be performed properly.
> These work steps are to be identified and adequately controlled. While
> reviewing procedures, be aware of and look for inadequacies that could
> lead to construction deficiencies and/or indicate an inadequate
> management control system.
>
> d\. It may be appropriate to complete portions of this IP in
> conjunction with similar requirements of IPs 51051 and 52051. Where
> the same contractor, procedures and personnel are utilized for
> activities covered by the above IPs, it is not necessary to repeat
> similar inspection requirements for each of these IPs. (If so, the NRC
> inspection records should reflect that electrical, instrumentation,
> and electric cable areas have been addressed.)
>
> e\. The inspector should bear in mind that the procedures selected for
> detailed NRC review cover only a representative sample of the
> procedures involved. Thus, substantive errors or departure from
> requirements identified in NRC\'s sample raises the issue of whether
> the NRC inspector and/or the licensee should conduct additional
> examinations to determine the extent of the identified problem.
>
> f\. Findings from this inspection activity should address each
> functional area as being satisfactory, being unresolved and requiring
> resolution, or being in violation and requiring correction. When
> significant inadequacies are identified indicating weakness within the
> responsible organization, the inspector should inform cognizant
> regional supervision. The issue should be addressed also at the
> appropriate level of licensee management.

03.01 [Specific Guidance]{.underline}

> a\. [Inspection Requirements 02.01 and 02.02]{.underline}. The
> expertise of the inspector is important for the proper completion of
> the inspection. The individual selected to perform 02.01 should have a
> general knowledge of and background in quality assurance, and the
> individual selected for 02.02 should be thoroughly knowledge­able of
> the technical requirements associated with electric cables and
> terminations. One individual may perform both requirements if he/she
> exhibits appropriate knowledge in both areas.
>
> b\. [Inspection Requirement 02.02]{.underline}. For the purpose of
> this IP, the term \"work procedures\" includes construction
> specifications, drawings, and work instructions. (Procedures
> describing methods of fabrication, construction or installation are
> sometimes called construction procedures.)
>
> c\. [Inspection Requirement 02.02a]{.underline}
>
> 1\. Receiving inspection procedures should reflect the requirements of
> RG 1.38/ANSI N45.2.2 or equivalent requirements. They should contain
> provisions for assuring that:
>
> \(a\) Cable and termination materials are in conformance with purchase
> specifications including special requirements.
>
> \(b\) Adequate marking and identification are provided.
>
> \(c\) As‑received cleanliness and protection are adequate.
>
> \(d\) Receiving inspection reports are complete.
>
> \(e\) Control and disposition of non‑conforming items are adequate.
>
> 2\. The SAR should identify and describe all cable and associated
> items which must operate in a hostile environment (e.g., high
> radiation, temperature, humidity) during or subsequent to an accident
> (e.g., loss of coolant, steamline break). Where environmental
> qualification testing or other qualification provisions are specified,
> means shall be established to assure that the results of this testing
> are documented, reviewed, and determined to be acceptable. This is a
> particularly significant area for NRC review.
>
> 3\. Procedures shall include provisions to assure that the applicable
> environmen­tal, functional, and other quality tests have been passed by
> the cable, pulling compounds, and termination materials. The design
> criteria for these tests should be specified or referenced in the
> procurement documentation.
>
> 4\. The following tests may be required to be performed either
> sequen­tially or synergistically: radiation, fire resistance, high
> potential, insulation resistance, continuity, temperature, humidity,
> submergence, steam or water impingement, chemical spray, aging, and/or
> chemical compatibility with pulling compounds or soil (if direct
> burial).
>
> 5\. Fire barriers and cable penetration seals require qualification.
> The tests and criteria can be found in 10 CFR 50, Appendix R, Section
> M; IEEE 634, Cable Penetration Fire Stop Qualification Test; and
> ASTM/ANSI E119, Fire Tests of Building Construction and Materials.
>
> d\. [Inspection Requirement 02.02b]{.underline}
>
> 1\. Special storage requirements are typically specified by the
> manufacturer or an industry standard, such as ANSI N45.2.2. The
> requirements should include such things as taping or sealing cable
> ends; controlling material and cable or cable reel identification;
> maintaining proper ambient temperature; separation from nonconforming
> items; and placement on dunnage.
>
> 2\. Cable and termination materials may be released for installation
> on the merits of certifications if the organization involved has
> established satisfactory program control and audit requirements in
> this area (ANSI N45.2.13). However, certifications do not release the
> licensee from having other records for operation and for the life of
> the plant.
>
> e\. [Inspection Requirement 02.02c]{.underline}. Appropriate and
> adequate construction specifications and other work instructions for a
> particular activity should be approved and available before that
> activity is started.
>
> f\. [Inspection Requirement 02.02c1(a)]{.underline}. The procedure
> should require QC acceptance of raceway installations before routing
> cable.
>
> g\. [Inspection Requirement 02.02c1(b)]{.underline}. Some method or
> procedure should be established to assure that the cable is properly
> qualified for the environment in which it is to be located.
>
> h\. [Inspection Requirement 02.02c1(d)]{.underline}. Splices in
> certain locations, such as raceways, may not be allowed. Refer to RG
> 1.75 and licensee commitments.
>
> i\. [Inspection Requirement 02.02c1(i)]{.underline}. Refer to the
> following for information pertaining to separation and independence:
> 10 CFR 50, Appendix A, General Design Criteria 5, 17, 21, and 22; RG
> 1.75; and IEEE Standard 384.
>
> j\. [Inspection Requirement 02.02c1(p)]{.underline}. Procedures should
> require verification that loading requirements (both thermal and mass)
> are not exceeded in final cable routings in trays, busways, conduits,
> etc. This verification should include review of actual cable routing,
> cable routing records, and design calculations.
>
> k\. [Inspection Requirement 02.02c1(q)]{.underline}. Only specified
> materials should be used for fire barriers, fire stops, and fire
> retardants; and installation should be in accordance with approved
> procedures. Cables may have to be derated when fire retardant
> materials are used.
>
> l\. [Inspection Requirement 02.02d]{.underline}
>
> 1\. The licensee or contractor procedures involved will differ from
> site to site, and may take various forms, such as formal procedures,
> instructions, checklists, drawings, etc. Review the inspection
> procedures and compare with the requirements in the applicable codes
> and construction specifications. Evaluation should indicate whether
> adequate quality‑related inspection procedures are established and are
> based on appropriate criteria, and further, whether the results of the
> licensee\'s inspection will be transmitted to responsible quality
> assurance and management personnel.
>
> 2\. Provisions should include monitoring or surveillance of installed
> cables by inspection (QC) personnel to assure that adequate protection
> is provided against possible damage from adjacent construction
> activities, including construction traffic. (Where protective means
> used during construction may affect proper operation, provisions
> should be provided for timely removal.)
>
> m\. [Inspection Requirement 02.02d4]{.underline}. Records of initial
> and followup inspections must include the specific results of the
> inspection. This should include the specific characteristics being
> inspected (or the actual measured values), the inspector\'s
> determination of acceptability, and identification of any
> nonconformances found.
>
> n\. [Inspection Requirement 02.02e]{.underline}
>
> 1\. This item does not include preoperational testing. Construction
> testing generally verifies that certain components pass specific tests
> as required but is not a test of system capability, especially systems
> that include nonelectrical equipment.
>
> 2\. The intent of this requirement is to determine whether adequate QA
> procedures have been established to assure that the required testing
> is satisfactorily completed and corrective action, if required, is
> properly performed.
>
> o\. [Inspection Requirement 02.02f]{.underline}
>
> 1\. It is particularly important that licensee management have an
> established program for ensuring that all personnel involved in cable
> system installation activities are suitably proficient, skilled, or
> otherwise qualified by experience or training to perform their
> assigned duties.
>
> 2\. An effective indoctrination and training program should be in
> place to assure that suitable proficiency is achieved and maintained
> for craft personnel. This is especially true for electricians
> conducting special tests.
>
> 3\. Inspection personnel shall be qualified in accordance with RG 1.58
> (ANSI N45.2.6) or similar requirements.
>
> p\. [Inspection Requirement 02.02g]{.underline}. Cable routing changes
> are made quite frequently after the start of cable pulling. It is
> important to determine whether an adequate system of controls for
> these changes is established, especially for field‑initiated changes.
> The established procedures to control these changes should result in
> correct and prompt changes to route slips, pull cards, or whatever
> means the electricians and inspectors use to determine cable routing.
> Procedures should be established also to periodically verify that the
> system is working properly.

03.02 [Prevalent Problems and Concerns]{.underline}. The inspector
should be alert to problems of a generic nature, such as:

> a\. Adequate procedures or other means have not been established to
> assure and document that all safety‑related systems have met
> applicable acceptance criteria, or to specifically document
> nonconformances.
>
> b\. Inspection procedures do not include adequate inspection
> requirements and acceptance criteria.
>
> c\. Inadequate means to control location and status of electric cable
> and components ‑ especially during removal for repair or replacement.
>
> d\. Inadequate procedures to control the evaluation, approval and use
> of field changes. (Means should be established also by the licensee or
> contractor to assure that only the latest approved field changes and
> other revisions or changes are being used for installation and
> inspection activities.)

51061‑04 REFERENCES

10 CFR 50, Appendix A ‑ General Design Criteria for Nuclear Power
Plants, Criteria 1, 2, 3, 4, 5, 17, 18, 19, 20, 22, 24, 34, 35, 38, 39,
40 and 46

10 CFR 50, Appendix B ‑ Quality Assurance Criteria for Nuclear Power
Plants

Facility SAR, Chapters 1, 3, 5, 6, 7, 8, 9 and 17, including pertinent
codes and standards referenced in the SAR

END