ATTACHMENT 65001.03

INSPECTION OF ITAAC-RELATED INSTALLATION OF PIPING

PROGRAM APPLICABILITY: 2503

65001.03-01 INSPECTION OBJECTIVES

01.01 To determine whether work activities related to piping systems met
all requirements for the purchase, receipt inspection, storage,
handling, installation, inspection, and testing in accordance with
design specifications, approved drawings and procedures, Final Safety
Analysis Report (FSAR), and applicable codes and standards.

01.02 To verify that the appropriate records support the receipt,
storage, installation, examination, testing, and material traceability
of piping systems.

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

01.04 To evaluate whether the appropriate quality assurance (QA) program
requirements are implemented for the installation and testing of all
piping activities, and to ensure any identified problems are entered
into the corrective action process and resolved.

65001.03-02 INSPECTION REQUIREMENTS AND GUIDANCE

This inspection procedure (IP) shall be implemented at the construction
site where ITAAC‑related piping is finally installed and any location
where such piping is first assembled into piping modules prior to
installation. 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 piping. 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 piping ITAAC have been met, and piping systems important to safety
have been installed and tested in accordance with the provisions of
design specifications, drawings, and FSAR. Installation of piping
supports and mechanical equipment, such as, pumps and valves are not
covered by this procedure.

02.01 [Purchase and Receipt of Materials]{.underline}: Select at least
seven purchase orders for materials, such as, welding consumables,
piping, including pre-fabricated spool pieces, and fittings, then verify
the following.

> a\. The selected materials and their purchase orders met design
> requirements and verify conformance with design requirements.
>
> b\. The documentation of site receipt inspections for the selected
> materials conforms to their purchase orders.

[Guidance:]{.underline} The sample should be a representative cross
section of materials and vendors and include several different
components as well as welding consumables. The sample should be of
various types materials and sizes of piping, e.g., small bore - 2 inch
diameter and under and large bore - greater than 2 inch diameter. When
comparing the materials purchased against their purchase orders, direct
observation of the actual materials in the field is preferred even
though the review of receipt inspection reports is permissible.
Generally, receipt inspections include the following inspection items:

-   The selected materials conform with their purchase specifications,
    e.g., all piping is the correct size, material type, thickness,
    seamless or with seams, the specified length and quantity, and with
    the ends of the piping suitable for welding.

-   Documented involvement of engineering staff in the procurement and
    product acceptance process to identify and prevent potential use of
    fraudulent materials.

-   Quality documentation is the type required by the purchase order
    (e.g., Certified Material Test Report (CMTR) or Certificate of
    Compliance).

-   Any chemical and physical test results, including heat treatment, as
    applicable, for a CMTR comply with the material specification
    required by the design documents.

-   Markings and identification of the materials are clear and legible.

-   There is no evidence of damage to the materials, e.g., excessive
    corrosion, gouges, chemical damage, etc.

-   The materials are clean, e.g., piping is free of dirt and mud.

-   The necessity of surface protection, closures, and packaging for the
    materials is stated in purchase order.

-   Receipt inspection reports were generated and conform to the
    licensee=s procedures.

-   Nonconformances affecting the integrity of the materials were
    properly addressed in accordance with the licensee=s procedures.

02.02 [Storage and Handling:]{.underline} Select at least five types of
materials from the purchase orders in the sample selected in 02.01, then
perform the following:

> a\. Verify that the materials such as, welding consumables, piping,
> including pre‑fabricated spool pieces, and fittings are being properly
> stored and handled in accordance with approved procedures.
>
> b\. For the selected materials, verify that their storage procedures
> comply with the contractor=s (vendors) storage requirements.

[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 control of contaminants
like dirt, grease, and moisture. Contaminants can cause weld defects,
such as, lack of fusion, porosity, and cracking due to hydrogen
embrittlement. When determining whether the selected materials are
stored correctly, the storage conditions of some of the materials should
be directly observed in the field.

Piping and fittings are often stored outside, exposed to the elements in
lay-down areas at the construction site. As such, carbon steel
components may develop a light coating of oxidation (rust). This
condition is generally acceptable; however surfaces such as machined or
ground bevels must have the rust completely removed prior to the welding
operation. All carbon steel components, including chains, should be kept
from contact with stainless steel components to prevent surface rusting
of the stainless steel components. Only tape containing low levels of
halogens and chlorides should be used on stainless steel to help avoid
cracking.

Typically, storage inspections include the following inspection items
for the materials stored.

-   Proper storage classification of materials.

-   Status of protective measures at the time of receipt and initial
    storage.

-   Soundness of dunnage or packing material.

-   Soundness and correct placement of such things as end caps for
    piping and protective coverings for weld preparation areas.

-   Soundness and correct placement of weather protection in the form of
    canvas or plastic coverings.

-   Protective storage measures to prevent salt water damage (chloride
    contamination), e.g., near oceans.

-   Protective storage measures against invasion of sand or windblown
    grit.

-   Correct and readily visible material identification, in accordance
    with the purchase order, and with no damage incurred by handling
    and/or environment.

-   Controls against the use of fire retardants near stainless steel
    piping to prevent any exposure to excessive halogens or chlorides.

-   Segregation of all sizes and types of material to the extent
    possible.

02.03 [Installation and Welding]{.underline}: Select at least ten
in-process welds, then verify that those welds and the installation of
associated piping components are accomplished in accordance with
approved drawings, qualified procedures, construction specifications,
and applicable codes and standards by qualified welders as specified in
the design documents by verifying the following as applicable.

> a\. The piping is being installed at the proper location in the plant,
> at the slope specified, and with the proper clearances from other
> piping and obstructions in accordance with approved drawings.
>
> b\. Welding procedures are in accordance with the codes and standards
> specified in the design documents (See guidance for clarification of
> when this should be performed).
>
> c\. Welder(s) are qualified for the piping material,
> electrode/process, and their positions.
>
> d\. Welding procedures, detailed drawings and instructions, if
> applicable, and weld data sheets are at the work station or readily
> available.
>
> e\. Surfaces to be welded have been prepared, cleaned, and inspected
> in accordance with applicable procedures.
>
> f\. Weld joint geometry is as specified in the drawings.
>
> g\. Examinations, e.g., by visual (VT) or dye penetrant (PT), of the
> surfaces to be welded have been performed, and the surfaces were found
> acceptable in accordance with the specified codes.
>
> h\. Components to be welded are assembled at specified gap and
> alignment within the limits allowed by the drawings or codes.
>
> i\. Piping material and welding consumables are of the specified type
> and grade and are uniquely identified (such as by heat number)
> preferably by markings on the material or at least in the traveler or
> accompanying documentation.
>
> j\. Tack welds and temporary attachments, such as, bridging bars or
> fit-up clips have been performed by qualified welders, in accordance
> with qualified welding procedure specification (WPS).
>
> k\. Gas purging, if specified, is used in accordance with the
> applicable procedure and is provided to shield the welding operation
> from adverse environmental conditions.
>
> l\. Preheat and interpass temperature, if specified, is maintained in
> accordance with applicable procedure requirements by observing
> welder=s instrumentation.
>
> m\. Welding equipment, including power cables and gas lines, are in
> good condition, and ammeters and voltmeters used for automatic welding
> have been calibrated in accordance with applicable procedure
> requirements.
>
> n\. Procedures specify appropriate holding and baking temperatures and
> out-of-oven exposure time for each class of coated electrode.
>
> o\. Welding consumable cleanliness is maintained, and electrode
> moisture pickup is limited in accordance with procedures.
>
> p\. Control and identification of welds rods after being issued to the
> welder are maintained in accordance with procedures.
>
> q\. Rod stubs are controlled and disposed of in accordance with
> procedures.
>
> r\. Interpass cleaning, grinding (especially starts and stops) and
> backgouging, if applicable, are conducted in accordance with the
> applicable procedures.
>
> s\. Temporary attachments, arc strikes and weld splatter are removed
> and inspected in accordance with specified procedures.
>
> t\. A welder=s identity is recorded by stamping the weld or by other
> means, such as, documentation.
>
> u\. Repairs performed after the weld is completed and found acceptable
> by visual inspection or other NDE method shall be accomplished in
> accordance with approved repair procedures and shall be documented.
>
> v\. 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.

[Guidance]{.underline}: The sample of welds should represent various
stages of welds in progress (e.g., weld joint preparation, fit-up, root
pass, final pass), types of welding processes (e.g., SMAW, GTAW), pipe
sizes, and material types (generally those materials designated in the
applicable edition of the ASME Boiler and Pressure Vessel Code, Section
IX as P1, P5, and P8) to the extent possible. Consideration should also
be given to welds that, because of their physical location or other
reason, are difficult to accomplish. The total weld sample after the
inspections for this IP are completed should include at least one weld
from each major risk component or its associated large bore piping, such
as, reactor vessel nozzles, steam generator, pressurizer, etc.

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 QA inspections and step completion. Material
traceability should be maintained since it has been a significant issue
at some construction sites in the past. Cold springing of pipe should be
avoided. Any observed cold spring of piping during installation must be
in accordance with allowance provided in the approved procedures. The
interpass temperature for welding austenitic stainless steels and high
nickel alloys should not exceed 350^o^ F. Weld material removal, such
as, by light grinding and rewelding is generally permissible during the
welding process. Any chain, cable, or brace should not apply anything
other than a vertical load on any component of a piping assembly ready
for welding.

\"Qualified welders\" means those employees who have achieved suitable
proficiency to do specific welds, to use certain welding processes, and
to employ certain welding techniques based on their training and/or
previous experience, and who understand the welding procedures,
drawings, and specifications necessary for their work. The licensee must
have qualification records that indicate the welder=s experience and
education.

If welding records were reviewed under IP 65001.B, then do not duplicate
that review here to determine if the procedures meet the applicable
codes and standards.

02.04 [Post Weld Heat Treatment]{.underline}. Select three welds
requiring post weld heat treatment (PWHT) over the course of the piping
installation phase of construction, then verify that PWHT is performed
in accordance with the design specifications and applicable code
requirements. The inspector should also verify that when Charpy impact
qualification is required for welds requiring PWHT, that both the base
metal and the weld material were properly qualified in accordance with
the applicable code.

[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.

Governing codes generally require that final NDE of the weld joint be
performed [after]{.underline} PWHT. Direct observation of PWHT is
preferred; however, since most welds do not require PWHT, a review of
records is acceptable.

02.05 [Pressure Testing]{.underline}. Observe the hydrostatic tests
(hydros) of piping installations during the construction phase, then
verify that the hydros are in accordance with the applicable codes ,as
specified, in the design specifications.

[Guidance]{.underline}. The sample size selected for this inspection
requirement should be representative of the total sample of hydros
associated with the ITAAC selected for review. The inspection of the
hydrostatic tests should be in accordance with IP 65001.C.

02.06 [Nondestructive Examination (NDE)]{.underline}. Observe three
welds with NDE in progress and verify that the final NDE has been
performed and found acceptable, in accordance with the applicable codes
by verifying the following as applicable.

> a\. The NDE procedure is in accordance with the applicable code as
> specified in the design specification.
>
> b\. The NDE is performed in strict accordance with the procedure by
> examiners that are qualified for that NDE method.
>
> c\. The radiographs of the three welds indicate the welds were
> acceptable per the applicable code.
>
> d\. The temperature of the weld surface is within that qualified for
> the procedure.
>
> e\. For liquid penetrant testing (PT), adequate dwell time was allowed
> for penetrant application.
>
> f\. For magnetic particle testing (MT):
>
> 1\. Yoke strength was demonstrated at the intervals specified in the
> procedure.
>
> 2\. The spacing and current for prods are in accordance with the
> procedure.
>
> 3\. Arc marks caused by prods are removed.
>
> g\. For ultrasonic testing (UT), the examiner=s qualifications, the UT
> equipment used complies with the procedure, and all UT process
> variables were strictly controlled.
>
> h\. For radiography testing (RT):
>
> 1\. The type of source, source strength, film type, source to film
> distance, use of intensifying screens, type and thickness of material
> being radiographed and exposure times are in accordance with the
> procedure.
>
> 2\. The image quality indicators are the correct type and thickness.
>
> 3\. The required sensitivity and radiograph density meet the
> applicable code requirement.
>
> 4\. Applicable radiological safety requirements are met during
> testing.

[Guidance]{.underline}. The sample should include the NDE methods used
for piping such as PT, MT, UT, and RT. If NDE is not being performed
during the inspection, then a record review would be acceptable of the
welds selected. For RT, refer to standards of American Society for
Testing and Materials (ASTM) E94-04 and E1032-06.

Typical issues with the performance of NDE are the following:

-   Inadequate cleaning of the surface for PT and MT. False indications
    may result if surface contaminants are present.

-   For MT, inadequate magnetic field due to a defective yoke.

-   The sensitivity of UT to equipment condition and examiner=s
    performance and interpretation of results.

02.07 [Review of Records]{.underline}. Select three installed piping
sections, then verify that their documentation packages are thorough,
accurate, and support installation in accordance with the provisions of
the design specification and applicable codes.

[Guidance]{.underline}. The final documentation package for piping
installation including welds shall contain the necessary information and
references to support the installation met all design, regulatory, and
code requirements. The following are examples of where the inspector can
focus this review of records.

-   Identification of materials, such as, piping, fittings, and welding
    consumables by, for example, heat number to assess material
    composition, physical characteristics, and traceability for their
    receipt, storage, installation, and testing.

-   Welding and NDE procedures and welders and examiners are identified
    for each weld.

-   NDE results indicate that all acceptance criteria were met.

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

-   Code data reports are complete and signed off by the assigned
    Authorized Nuclear Inspector.

-   The work or traveler packages conform with the relevant work
    procedures and other requirements.

02.08 [Problem Identification and Resolution]{.underline}. Select 1- 2
problems identified during the inspection and then confirm that the
problems are entered into the licensee/constructor corrective action
program in accordance with program requirements. 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.

[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 MC 2504 process.

65001.03-03 RESOURCE ESTIMATE

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

1600 hours of direct inspection effort over the course of plant
construction.

65001.03-04 REFERENCES

> American Society of Mechanical Engineers, Boiler and Pressure Vessel
> Code, Section III (applicable edition)
>
> American Society of Mechanical Engineers, Boiler and Pressure Vessel
> Code, Section II (applicable edition)
>
> American Society of Mechanical Engineers, Boiler and Pressure Vessel
> Code, Section V (applicable edition)
>
> American Society of Mechanical Engineers, Boiler and Pressure Vessel
> Code, Section IX (applicable edition)
>
> American Society of Mechanical Engineers, Boiler and Pressure Vessel
> Code, Section XI (applicable edition)
>
> Regulatory Guide 1.38, \"Quality Assurance Requirements for Packaging,
> Shipping, Receiving, Storage, and Handling of Items for Water‑Cooled
> Nuclear Power Plants\"
>
> Regulatory Guide 1.58, \"Qualification of Nuclear Power Plant
> Inspection, Examination, and Testing Personnel\"
>
> ASTM E94-04, AStandard Guide for Radiographic Examination@
>
> ASTM E1032-06, AStandard Test Method for Radiographic Examination of
> Weldments@
>
> ANSI N45.2.2, \"Packaging, Shipping, Receiving, Storage, and Handling
> of Items for Nuclear Power Plants\"
>
> ANSI N45.2.6, \"Qualifications for Inspection, Examination and Testing
> Personnel\"

END

Attachment 1: Revision History for IP 65001.03

Attachment 1

Revision History for IP 65001.03

+--------+-------+-------------------------+------+-------+------------+
| Comm   | Issue | Description of Change   | Trai | Tra   | Comment    |
| itment | Date  |                         | ning | ining | Resolution |
| Tr     |       |                         | Ne   | Compl | Accession  |
| acking |       |                         | eded | etion | Number     |
| Number |       |                         |      | Date  |            |
+--------+-------+-------------------------+------+-------+------------+
| N/A    | 08/   | Researched commitments  | N/A  | N/A   | N/A        |
|        | 19/08 | for 4 years and found   |      |       |            |
|        |       | none.                   |      |       |            |
|        | CN    |                         |      |       |            |
|        | 0     | Initial issuance to     |      |       |            |
|        | 8-024 | support ITAAC related   |      |       |            |
|        |       | inspections under       |      |       |            |
|        |       | 10CFR52.                |      |       |            |
+--------+-------+-------------------------+------+-------+------------+
|        |       |                         |      |       |            |
+--------+-------+-------------------------+------+-------+------------+
|        |       |                         |      |       |            |
+--------+-------+-------------------------+------+-------+------------+
|        |       |                         |      |       |            |
+--------+-------+-------------------------+------+-------+------------+
|        |       |                         |      |       |            |
+--------+-------+-------------------------+------+-------+------------+
|        |       |                         |      |       |            |
+--------+-------+-------------------------+------+-------+------------+