ATTACHMENT 65001.04

INSPECTION OF ITAAC-RELATED INSTALLATION OF

PIPE SUPPORTS AND RESTRAINTS

PROGRAM APPLICABILITY: 2503

65001.04-01 INSPECTION OBJECTIVES

01.01 To determine whether the licensee=s work and inspection activities
related to the installation of pipe supports and restraints are being
performed in accordance with design specifications, applicable codes,
approved drawings and procedures, FSAR, and regulatory requirements.

01.02 To verify that the appropriate records support the licensee=s
installation and inspection of pipe supports and restraints.

01.03 To determine if the inspections, tests, and analysis completed for
ITAAC-related pipe supports and restraints met the acceptance criteria
for those ITAAC.

01.04 To evaluate whether the appropriate quality assurance (QA) program
requirements are implemented for the licensee=s installation and
inspection of pipe supports and restraints, and to ensure any identified
problems are entered into the corrective action process and effectively
resolved.

65001.04-02 INSPECTION REQUIREMENTS AND GUIDANCE

This procedure encompasses all classes (ASME and non-safety) of pipe
supports and restraints. It includes all components, hardware, or
structural elements that support the weight or restrain possible
movement due to design basis loads, of piping, or piping components
(fittings, valves, valve actuators, etc.). This inspection procedure
(IP) shall be implemented early during the construction period at the
construction site for the installation of or at any other location for
the pre-assembly of pipe supports and restraints. After the initial
inspection at a given location, any subsequent inspections will be
scheduled as necessary to complete the overall sample for the review of
ITAAC‑related pipe supports and restraints. Note that some inspection
requirements listed in this IP are not required to be performed each
time it is implemented. The focus of this IP is to verify that ITAAC for
pipe supports and restraints have been met, and pipe supports and
restraints important to safety have been installed and inspected in
accordance with the provisions of the design specification and drawings,
FSAR, applicable codes and standards, and NRC regulations.

02.01 [General Installation]{.underline}. Depending on the specific type
of support or restraint, verify through direct inspection and record
reviews the applicable aspects of the following attributes:

a.  Restraint is assembled and installed at correct location in plant in
    accordance with the design specifications and drawing(s), and within
    specified tolerances. (Must be verified for each support or
    restraint sampled.)

b.  Functional restraint directions are in accordance with the design
    drawing. (Must be verified for each support or restraint sampled.)

c.  Components are not bent, deformed, loose, or otherwise out of
    specification.

d.  Clearances between the restraint and piping are within specified
    tolerances.

e.  Bolts, nuts, washers, locking devices and other fasteners are tight
    and secure and are of the correct type, size, material, and grade
    with required identification markings.

f.  Threaded fasteners have sufficient thread engagement, and where
    required, pre-load requirements have been met through the use of
    properly calibrated torque wrenches.

g.  Threaded connections used to adjust support load settings have
    suitable locking devices in place.

h.  Hot/cold settings are correct for the existing condition of the
    attached piping system or if settings are not indicated, the thermal
    and/or dynamic displacements are within the working range of the
    support.

i.  Restraints in high ambient temperature environments or near high
    temperature components have suitable service ratings to accommodate
    the expected operating temperatures.

j.  Shear lugs, as required by installation drawings, are welded to
    piping whenever pipe clamps are used to support vertical lines or to
    restrain axial movements and have proper distance from each other to
    ensure equal load distribution among the lugs.

k.  Sliding or rolling supports are provided with material and/or
    lubricants suitable for the environment and with compatible contact
    surfaces.

l.  The contact surfaces of sliding or rolling supports are free of
    paint, weld spatter, concrete, or other construction debris that
    would invalidate assumed design forces.

m.  Clearances between restraints or supports and adjacent components,
    equipment, and structures are in accordance with specified Arattle
    space@ requirements or have otherwise been explicitly evaluated.

n.  Spherical end-bearings, if present, are free to rotate and are
    staked in place, as required.

o.  Snubber installations should consider the following attributes:

    1.  Bleed holes are open and free from foreign material.

    2.  Hydraulic fluid levels are correct or lubricants are applied as
        specified and there does not appear to be excessive leakage.

    3.  Seals are not deteriorated (if visually observable without
        dismantling).

    4.  Connecting joints, moving parts, piston shafts, seals, etc, are
        free from foreign material such as concrete, paint, weld
        spatter, excessive dirt, dust, or other material that may
        obstruct proper operation.

    5.  A mechanical snubber='s functionality should be checked if it
        was installed during construction and debris, i.e., sand may
        have entered its internal mechanism.

        p.  Contact area between support baseplates and structural
            elements (concrete floors, walls, etc.) meet specified
            minimums.

        q.  Shims or washers, if used to level baseplates, are within
            specified limitations and any grouting complies with
            specified installation procedures.

        r.  Energy absorbing materials, if used in high energy pipe
            break pipe whip restraints, has not been damaged or
            otherwise deformed.

        s.  Verify spring cans are within the expected or required
            range, and are not pinned.

[Guidance:]{.underline} Inspectors performing this inspection should be
familiar with the analytical techniques for piping analysis, since the
pipe stress analyses dictate the pipe supports or restraints= locations,
directions, and loads. The significance of any identified deficiency
will be limited unless it affects the pipe stress analysis.

For small diameter piping (2-inches and under) that may be field-routed
to a specified design criteria, drawings may be prepared or completed
onsite. Supports for small diameter piping may be selected, designed,
and located by field engineers as specified in the approved design
criteria. For some critical small-diameter piping, engineering
calculations may be required.

The installation of the pipe restraints and supports should be in
accordance with IP 65001.B, AWelding@ and IP 65001.03, APiping@.

02.02 [Pipe Support and Restraint Welding.]{.underline} For field
welding associated with pipe support and restraint installations (other
than integral welded attachments to piping), review and verify the
following:

a.  The attributes listed in IP 65001.B, as applicable, have been met.

b.  That the integral welded attachments to piping (lugs for riser
    clamps or axial restraints, stanchions, etc.) that affect pressure
    boundary material are in accordance with the guidance in IP
    65001.03.

[Guidance:]{.underline} These inspection requirements can be performed
by direct observation and/or record reviews. Inspectors performing this
inspection should be familiar with the applicable codes and requirements
so they can determine which attributes are applicable to welding pipe
supports and restraints. The inspector should also be familiar with
other requirements from the design control document (DCD),
welding-related design information, welding and QA procedures, and
licensee commitments. A knowledge of welding processes, techniques,
applications, limitations and evaluations is essential for the assigned
NRC inspectors.

The samples should include various welding processes, material
combinations, and types of pipe supports and restraints for a licensee
and each of its contractors performing ITAAC-related welding. This scope
applies to both visual observations and record reviews. A variety of
non-destructive examination processes should also be included.

The inspector should consider the efficiencies gained by performing this
inspection in conjunction with pipe and structural welding since the
same welding procedures, welders, etc may be used.

02.03 [Concrete Expansion Anchor Installation.]{.underline} For anchor
bolts and related components in storage and for installations with
concrete expansion anchors do the following:

a.  Examine the bolts and related components in storage and evaluate any
    issues involving special preservation requirements, storage
    conditions, damage controls, material and component identification,
    and nonconforming material segregation.

b.  Determine whether the installation activities are being adequately
    controlled by reviewing the applicable procedures, observing work,
    and checking (e.g., witness torque wrench operation or QA inspection
    verification) that the bolt has been torqued to the proper tension.

c.  Determine whether the appropriate quality controls have been
    implemented by using the following items and inspection criteria to
    determine compliance with work procedures and design and code
    requirements:

    1.  concrete drilling, including depth, perpendicularity, hole
        diameter, and rebar damage prevention;

    2.  embedment depth of the anchor bolt;

    3.  bolt length projection beyond the concrete surface and thread
        engagement for the nut on the bolt;

    4.  installation torque to set the anchor bolt;

    5.  torque-tension relationship controlled by design;

    6.  minimum distance from concrete edges and openings, minimum bolt
        spacing, and minimum distance from embedded steel;

    7.  bolt diameter and applicable markings/stamps;

    8.  design provisions for the subsequent installation of the
        supported components, including quality checks (e.g., use of
        torque seal).

[Guidance:]{.underline} Judgment should be used in selecting the
specific sample size for inspection of the concrete expansion anchor
installation process. In selecting the sample of installations of
concrete expansion anchors , priority should be given to those with
ITAAC impact, early installations to do process control checks, and
those installations diverse from other installations (e.g., for
structural, piping, electrical, or HVAC) for supports using concrete
expansion anchors.

QA procedures provide a key element for the effective implementation of
inspections, and confirmation that concrete expansion anchor
installation controls are adequate. QA inspections should require direct
verification of important specification requirements and should not be
accomplished merely by surveillance. Laboratory and field testing
activities should provide for direct verification of correct material
usage, the selection of proper reference standards, and the selection of
inspection and testing parameters based on, approved procedural
direction and guidance. The installation and related procedures should
require hold points for in-process inspection activities and address the
stop work authority and controls for process control problems.

If any rebar is damaged or cut during installation, ensure design
controls are in place to evaluate the cumulative effect on the affected
concrete structures. Ensure the anchor bolt embedment depth accounts for
any non-structural finish coats, coverings, or grout, on concrete slabs,
especially floors.

02.04 [Documentation Packages.]{.underline} For records for
installations of pipe supports and restraints verify the following:

a.  That documentation packages for completed pipe support and restraint
    installations are thorough and accurate.

b.  That the installations were in accordance with the provisions of the
    design specifications and applicable codes for the following
    attributes:

    1.  Material composition and physical characteristics of materials,
        such as, pipe clamps, spring cans, structural members, support
        components, and welding consumables can be determined by their
        unique identification (e.g., heat number).

    2.  Welding and NDE procedures and personnel are identified for each
        weld.

    3.  NDE records demonstrate that acceptance criteria were met.

    4.  Installers were qualified relative to applicable pipe support
        and restraint installation procedures, welding procedures, and
        anchor bolt installation procedures.

    5.  As-built drawings are available and any deviations from original
        design are reconciled with the design documents (e.g., design
        report).

        c.  That the records provide traceability to all aspects of the
            pipe supports and restraints= installations, such as,
            materials certification, inspections performed and results,
            inspectors, and qualification records for procedures and
            personnel.

[Guidance:]{.underline} The final documentation package for pipe support
and restraint installation should contain sufficient information and
references to demonstrate that the installations met the design
specifications and code requirements. The installation records should be
retained and stored in accordance with site requirements.

02.05 [Problem Identification and Resolution:]{.underline} Select 1 to 2
inspection-identified problems and also, if applicable, problems
identified prior to this inspection, then do the following:

a.  Verify that the inspection-identified problems were entered, as
    required, into the licensee=s PI&R processes.

b.  Review the associated QA program records for the problems identified
    during the inspection and identify any specific deficiencies with
    verification and oversight.

c.  Verify for the problems identified prior to the inspection, as
    applicable, that the licensee addressed their extent of conditions
    and took the appropriate corrective measures.

[Guidance:]{.underline} This inspection is to ensure that problems are
entered into the PI&R processes to ensure the appropriate corrective
actions are developed and prioritized. The deficiencies with
verification and oversight are to be considered during inspections of QA
Program implementation, effectiveness of PI&R, and Self-Assessment which
will be performed under the MC 2504 process.

65001.04-03 RESOURCE ESTIMATE

Inspection resources necessary to complete this inspection procedure are
estimated to be

400 hours of direct inspection effort over the course of plant
construction.

65001.04-04 REFERENCES

NRC Bulletin 79-02, Pipe Support Base Plate Designs Using Concrete
Expansion Anchor Bolts.

NRC Bulletin 79-14, Seismic Analyses for As-Built Safety-Related Piping
Systems

NRC Bulletin 87-02, Fastener Testing to Determine Conformance with
Applicable Material Specifications.

ASME, Section III, Subsection IWF, Requirements for Class 1, 2, and 3
Component Supports of Light-Water Cooled Power Plants.

AISC, Manual of Steel Construction

END

Attachment 1: Revision History

Attachment 1

Revision History for IP 65001.04

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