**NRC INSPECTION MANUAL** DQASIP

MANUAL CHAPTER 2513

LIGHT WATER REACTOR INSPECTION PROGRAM ‑

PREOPERATIONAL TESTING AND OPERATIONAL PREPAREDNESS PHASE

2513‑01 PURPOSE

The purpose of the preoperational testing and operational preparedness
phase inspection activities is to verify through direct observation,
personnel interviews, and review of facility records that:

01.01 Systems and components important to the safety of the plant are
fully tested to demonstrate that they satisfy their design requirements.

01.02 Management controls and procedures, including quality assurance
programs, necessary for operation of the facility have been documented
and implemented.

2513‑02 APPLICABILITY

This phase of the inspection program becomes effective approximately 24
months before issuance of the operating license. It includes those
activities directed toward operational readiness of the plant and will
coincide with the final portions of the construction inspection program
(IE MC 2512). Initial phases of the startup testing inspection program
(IE MC 2514) will also overlap the latter phases of this program. The
general requirements identified are applicable to both BWR and PWR
facilities; however, the detailed inspection procedures in some cases
differ dependent upon the type of facility. The requirements identified
in this inspection program should normally be completed before issuance
of an operating license.

2513‑03 DEFINITIONS

03.01 [Milestone]{.underline}. A reference point used to sequence the
inspection program.

  --------------------------------------------------------------------------------
  [Milestone]{.underline}   [Reference Point]{.underline}
  ------------------------- ------------------------------------------------------
  305                       Start of Preoperational Testing

  320                       Hot Functional Test Start

  330                       CILRT and Integrity Test Complete

  340                       Operating License Issued
  --------------------------------------------------------------------------------

03.02 [Preoperational Testing Program]{.underline}. For the purposes of
this program, the Preoperational Testing Program includes the testing
categories normally identified as construction verification tests, and
preoperational tests as defined below:

> a\. [Construction Verification Tests]{.underline}. Tests performed
> under the direction of construction management personnel before system
> or component turnover to the operating group for preoperational
> testing. These tests include those activities such as chemical
> cleaning, flushing, continuity testing, and initial calibration of
> instrumentation necessary to prepare a system for operation. They also
> include tests such as containment integrity and hydrostatic testing of
> piping systems necessary to demonstrate component, system or structure
> design and construction adequacy. Baseline inservice inspection is
> also included in this category.
>
> b\. [Preoperational Tests]{.underline}. Tests performed by or under
> the direction of the applicant\'s operations staff to demonstrate the
> proper functioning and conformance to design requirements of
> components, systems and structures. Containment leak rate tests may
> fall in this category or may be combined with the containment
> integrity test. Preoperational testing frequently forms the
> contractual basis for custody transfer from the constructor to the
> operator.

03.03 [Quarterly (Q)]{.underline}. The inspection effort should be
performed 4 times each year, so that the interval between inspections is
no less than 2 months and no greater than 4 months.

03.04 [Monthly (M)]{.underline}. The inspection effort should be
performed at least 12 times each year so that the interval between
inspections is no less than 20 days and no greater than 40 days.

03.05 [Weekly (WK)]{.underline}. The inspection effort should be
performed at least 48 times per year so that the interval between
inspections is no less than 4 days and no greater than 11 days.

03.06 [When Required (W)]{.underline}. The inspection effort should be
performed when the activity or event occurs at the facility or as
specified in the guidance section of specific inspection procedures.

2513‑04 RESPONSIBILITIES AND AUTHORITIES

04.01 [Director, Appropriate Regional Office Division]{.underline}.
Overall administration and implementation of the inspection program
outlined in this chapter for power reactors within regional boundaries.

04.02 [Chief, Appropriate Branch (Regional Office)]{.underline}.
Administration and implementation of the inspection program outlined in
this chapter for power reactors assigned.

04.03 [Section Chief (Regional Office)]{.underline}. Administration and
implementation of the inspection program outlined in this chapter for
power reactors assigned.

2513‑05 DISCUSSION

This chapter provides guidance for scheduling inspections and for
implementing the inspection program. The program establishes uniform
inspection methodology but leaves sufficient flexibility to the region
for optimizing its inspection resources.

This chapter defines the minimum inspection program for a finding of
readiness for license issuance (IP 94300). In some cases, testing delays
make it impossible to verify completion of all preoperational tests. In
these cases, these items would be identified as exceptions in the
finding of readiness. In any event, the requirements of this portion of
the inspection program will require completion following system
readiness or as defined in the facility technical specifications.
Inspection requirements related to testing for twin or sister facilities
would not normally be reduced because of the typical time lag between
the two plants. In dual plant cases, a specific objective of the
inspection program is to assure that testing and procedure development
take proper cognizance of the lead facility and its status. For those
procedures and programs which would be identical to those already in use
at the operating facility (i.e., quality assurance program, operating
procedures, security and emergency plans, etc.), inspection requirements
may be reduced to those necessary to assure implementation, and to
assure that proper revisions have been made to reflect the new facility.
The region may increase the sample size or extent of the program on the
basis of assessed need or problems at a facility as well as on the
availability of inspectors to perform such work.

Appendices A and B list those inspection procedures which must be
completed before the NRC can make a finding of readiness. Appendix A
lists those procedures applicable to verifying that systems and
components important to safety of the plant are fully tested to
demonstrate that they satisfy their design requirements. Appendix B
lists those procedures applicable to verifying that management controls
and procedures, including quality assurance programs, necessary for
operation of the facility, have been documented and implemented. For
planning purposes, the listing of procedures is coded to the specific
programmatic milestones for the facility. These are indicated as either
a milestone alone, or as a time period referenced to a milestone.

Examples:

> 305 Indicates that the inspection procedure should be complete before
> the start of preoperational testing.
>
> 340‑18 Indicates that the inspection procedure should be complete 18
> months before fuel loading. All time differentials are indicated in
> months.

Those IE inspection procedures which should be completed before a
facility milestone are identified in Appendices A and B.

Certain procedures included in this phase of the inspection program
cannot by their nature be completed during a single inspection.
Activities such as review of procedures and manuals may also be
conducted over a relatively long time period. For these activities,
inspection time will be coded to the module reflecting the end product
of the inspection; however the module shall not be reported as complete
until the final inspection has been performed. As an example, review of
the draft test procedures should be coded to the module for review of
the applicable test procedures; however, the module should not be
reported as complete until the approved issue of the test procedure has
been inspected.

2513‑06 PREOPERATIONAL TEST PROGRAM

The Preoperational Test Inspection Program is composed of three
inspection procedure classifications. The first classification is the
mandatory test inspection procedure. These are the inspection procedures
which shall be completed at each unit.

The second classification is the primal test inspection procedure. The
inspector is required to select five of these tests for the following:
test procedure review, testing witnessing, and test results evaluation.
Primal tests chosen for procedure review are not required to be the same
as those selected for test witnessing or test result evaluation.
Specific inspection procedures are provided for primal tests concerning
test procedure review, test witnessing, and test results evaluation.

The third classification includes all preoperational tests required by
the FSAR except those designated as mandatory tests and those selected
from the primal test list. The primal tests not chosen are to be
included in this classifica­tion.

Regulatory Guide 1.68 identifies the tests to be included in the
preoperational testing program. The inspection requirements listed in
this Manual Chapter are centered upon these tests. Regulatory Guide 1.68
states that the applicant should make the test procedures available 60
days before the scheduled test, but not less than 60 days before the
scheduled fuel loading date. Drafts of the procedures should be made
available as soon as possible to provide sufficient time for the
inspector to perform the required review function.

2513‑07 RESIDENT INSPECTION PHILOSOPHY

A Resident Inspector is assigned to each construction site where
construction is more than 15% complete. At single‑unit construction
sites, a second Resident Inspector for operations is assigned at the
beginning of preoperational testing. The Resident Inspector for
construction activities is normally reassigned elsewhere at some point
during startup testing, after the OL has been issued. For multiunit
sites, units under construction have one dedicated Resident Inspector
assigned for that function. One or two Resident Inspectors for
operations are also assigned, depending on the number of units in
operation or preoperational testing.

The Resident Inspector provides the major onsite NRC presence for direct
observation and verification of an applicant\'s activities. The Resident
Inspectors are also the primary onsite evaluators for the NRC inspection
effort stemming from events or incidents. It is expected that the
greater part of initial event‑related inspection effort will be
performed by the Resident Inspectors (who may be supplemented by other
inspectors depending on the type of event). Regional managers will
decide when normal inspection activities will be resumed by those
involved with inspecting the event.

The inspection program provides for 20% independent inspection for
Resident Inspectors. It is expected that as a direct result of the
Resident Inspectors\' increased onsite time coupled with their broad
facility knowledge, they will identify certain areas where an
independent inspection may be warranted.

This inspection program prescribes inspection activities to be performed
on backshifts or weekends each week. Backshift and weekend inspections
will be performed by both the Senior Resident Inspector and Resident
Inspector. The goal for backshift and weekend inspection activities is
20% of an inspector\'s normal work week, averaged over a year. It is
expected that this effort will include normal inspector coverage of
items in the program (e.g., test witnessing) as well as those
specifically designated for the backshifts. There is no requirement that
the inspector leave the site and return on the backshift for backshift
inspection effort.

2513‑08 REGIONAL INSPECTION PHILOSOPHY

Region‑based inspectors will conduct inspection procedures as directed
by their supervisors. Region‑based inspectors often will be involved in
inspection activities of a more specialized nature than those inspection
activities performed by the Resident Inspectors. Certain aspects of
their inspection activity (i.e., portions of procedure review and
administrative program inspection) should be conducted in the Regional
Office.

The region‑based inspector may also conduct independent inspection
activities. There is no stated goal for region‑based inspections on
backshift or for independent inspection. However, backshift inspection
will be performed whenever required to complete the inspection.

The Senior Resident Inspector must be kept apprised of region‑based
inspector activities at his facility. The appropriate section chief
shall ensure coordination of regional inspection activities and keep the
Senior Resident Inspector informed.

Region‑based inspectors should contact the Senior Resident Inspector
before the inspection to obtain information concerning the availability
of specific licensee personnel and the status of plant conditions which
may affect the planned inspection. In addition, region‑based inspectors
shall make contact with the Senior Resident Inspector as soon as is
convenient after their arrival at the site to ensure a coordinated NRC
presence at the facility. They should advise the Senior Resident
Inspector of changes to their planned inspection effort and schedule for
the licensee exit interview. The region‑based inspectors will inform the
senior resident inspectors of any unique activities in progress and will
brief the Senior Resident Inspector about the results of their
inspection before the exit interview with licensee management. The
Senior Resident Inspector and/or the Resident Inspector should attend
all exit meetings where significant enforcement action or other
significant unresolved issues are expected to be discussed.

2513‑09 GENERAL GUIDANCE

Although each inspection procedure contains many line items, these items
are provided as guidance and the individual inspector is expected to
apply professional judgment regarding the need for completing each
specific item. For example, he may have assurance that the basic
requirement has been satisfied via some other source (i.e., CDR
followup, independent inspection effort, temporary instruction
followup). In such cases he should not perform these specific items. In
summary, the line items in Section 02 of inspection procedures list the
attributes which should be considered when evaluating the area covered
by the inspection procedure.

As stated in 10 CFR and elsewhere in this Manual (IE MC 2500), NRC
inspectors perform a basic mission in determining that an applicant
meets current regulatory requirements and commitments. Identifying
specific instances where an applicant fails to meet such requirements
and commitments, although important, has frequently in the past resulted
in correction of symptoms rather than correction of underlying causes of
licensee problems. Because of limited number of inspectors, the NRC
inspection program covers only a very small sample of licensee
activities in an area. Thus, it is important that an applicant evaluate
whether a noted noncompliance or deficiency represents an isolated case
or may signify a broader, more serious problem in that area. To provide
the perspective to perform this evaluation, the inspector should:

> a\. Keep currently informed of deficiencies, audit findings, and plant
> problems identified by the applicant\'s own organization.
>
> b\. Ascertain whether additional personal inspection effort is merited
> in the area under consideration.

END