**NRC INSPECTION MANUAL** NMSS/FCSS

INSPECTION PROCEDURE 88134

PIPING SYSTEMS RELIED ON FOR SAFETY

PROGRAM APPLICABILITY: 2630

88134‑01 INSPECTION OBJECTIVES

01.01 To determine whether the technical requirements detailed or
referenced in the appropriate sections of the facility Construction
Authorization Request (CAR), associated with Quality Level (QL)-1 and 2
piping have been adequately addressed in the construction specification,
drawings and work procedures; and whether the established system of
management controls is adequate.

01.02 To determine whether adequate plans, instructions and procedures
have been established to implement the Quality Assurance program for
QL-1 and QL-2 piping (except welding and nondestructive examination
(NDE)) in accordance with the CAR and the MOX Project Quality Assurance
Plan (QAP).

01.03 To determine whether specifications or procedural controls
associated with QL-1 and QL-2 piping are adequate and determine whether
any potentially generic problems or other weaknesses exist within the
appropriate technical organization.

01.04 To determine whether activities relative to QL-1 and QL-2 piping
(except welding and NDE) are being accomplished in accordance with NRC
requirements, CAR commitments, and licensee/contractor procedures.

01.05 To determine whether inadequacies in completed work, partially
completed work, or work activities in progress may indicate management
control problems or generic weaknesses.

88134‑02 INSPECTION REQUIREMENTS

Note: These requirements should be implemented so that each major
contractor installing piping in QL-1 and QL-2 systems is inspected. The
number of samples and attributes

reviewed may be adjusted upon management approval dependent on the
number of contractors and specific work being performed. Depending on
the facility contracting arrangements, it may be appropriate to perform
certain parts of IP 88135 (Piping Supports and Restraints) in
conjunction with this procedure.

02.01 Determine whether CAR and QAP commitments relating to the
following specific activities associated with QL-1 and QL-2 piping are
adequately addressed in procedures included or referenced in the QA
manual(s).

a.  Purchase documents identifying material specifications and any
    special requirements, including material test reports/certification
    of the following (as applicable):

    1.  chemical composition

    2.  physical characteristics

    3.  nondestructive examination results

    4.  heat treatment history (if applicable)

    5.  welding of prefabricated sections

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b.  Receipt inspections, including provisions for ensuring:

    1.  piping materials are in conformance with purchase
        specifications, including special requirements

    2.  marking, identification, and storage level classifications

    3.  as‑received cleanliness and protection

    4.  receipt inspection reports are generated as required

    5.  disposition of nonconforming items

c.  Inspections covering storage and issuance of the piping and related
    appurtenances including provisions for:

    1.  segregation of sizes and types of material

    2.  storage identification

    3.  storage conditions/protection

    4.  confirmation of issue of specified material

d.  Handling of the piping and related appurtenances to ensure
    protection from physical damage or contamination while handling.

e.  Installation of the piping and related appurtenances to verify that
    the following meet applicable requirements:

    1.  location

    2.  grinding, cutting, bending, etc.

    3.  piping system tolerances

    4.  cold spring

    5.  installation records to be generated during installation

    6.  type, size, location and adjustment of hangers, bellows,
        restraints, snubbers

    7.  clearances to prevent interference

    8.  hydrostatic testing (where required)

    9.  hold points

    10. removal of arc strikes

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    f.  Design changes, including field changes, to ensure proper review
        and coordination among participating design organizations.

    g.  Inspection and work performance for cleaning piping, including
        provisions for:

        1.  cleaning materials ‑ conformance to specifications,
            concentration, temperature, and use

        2.  cleanliness criteria and measurement methods

        3.  removal and installation of metering devices, orifice
            plates, valve internals, etc., that are removed from system
            to facilitate flushing

        4.  installation and removal of fine strainers, blind flanges,
            temporary piping and dams

        5.  record‑keeping requirements

02.02 Review the licensee/contractor\'s plans and schedules to audit
compliance with and effectiveness of the QA/QC requirements associated
with QL-1 and QL-2 piping, including (but not limited to) design,
procurement, receipt/storage, installa­tion, and testing.

02.03 Determine whether licensee/contractor management has an
established program for ensuring that all personnel involved in the
above mentioned activities are suitably proficient, skilled, or
otherwise qualified by experience or training to perform their assigned
duties.

02.04 In three different QL-1 piping systems and one QL-2 piping system
observe five piping activities relative to safety‑related piping, such
as handling; cleanliness control; installation of pipe spools, fittings,
and bellows; cutting; grinding; bending; supporting; cleaning and
flushing; hydrostatic testing; and quality‑related inspections.

02.05 For those five activities selected for observation (in 02.04,
above) determine whether the following requirements, as applicable, are
met:

a.  conformance with construction/installation specifications

b.  personnel are adequately qualified by certification, experience or
    training

c.  conformance with inspection (QC) and work performance procedures

d.  conformance with record‑keeping requirements

e.  identification and control of material

f.  control of nonconforming items

02.06 For one location (or run) in each of two QL-1 piping systems and
one QL-2 system determine whether piping runs are (or are being)
installed as required by applicable specifications, field drawings, and
procedures.

02.07 For one QL-1 and one QL-2 piping system determine whether there
have been significant design changes subsequent to the issuance of
approved installation drawings. Review the implementation of the
licensee\'s/contractor\'s design control measures, including the
necessity for a revised stress analysis, as appropriate, to determine
whether design control procedures were properly followed.

02.08 Review the pertinent quality related records of three parts (e.g.,
pipe spools, fittings, bellows) in a QL-1 piping system and two parts in
QL-2 piping systems. Select no more than two components of any one size.
Determine whether each record meets requirements related to:

a.  Confirming that required material characteristics, performance
    tests, environmental qualification tests, nondestructive tests, and
    other specification requirements were met.

b.  Confirming that the selected components were installed as specified.

c.  Confirming that the required inspections were performed.

02.09 Review any licensee/contractor procedures specifically for
reporting and dispositioning nonconforming materials, parts and
components associated with QL-1 and QL-2 piping and determine whether
the procedures properly implement the QAP commitments. Review
approximately 10 nonconformance/deviation reports to sample system
effectiveness and determine if the procedures are being adequately
implemented.

02.10 Determine whether appropriate qualification requirements are in
place for licensee/contractor craft and inspection personnel being
employed on QL-1 and QL-2 piping installation work. Determine whether
personnel performing the work meet the qualification requirements by
reviewing a sampling (4 to 6) records, covering several different
disciplines of personnel qualification if possible.

02.11 Review relevant portions of licensee/contractor audit reports
concerning the installation of QL-1 and QL-2 piping. Review two to four
reports to determine whetherthe required audits have been performed in
accordance with the requirements in the QAP and implementing procedures.

88134‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}

Requirements of this procedure apply to each organization installing
QL-1 and QL-2 piping. Applicable parts of the CAR and Quality Assurance
Plan (QAP) should be reviewed to determine licensee commitments relative
to construction, inspection, and records requirements before performing
this inspection. The inspector(s) should utilize the appropriate CAR
section during the review of the licensee/contractor\'s implementing
construction specifications, drawings, work procedures, and QA
implement­ing procedures. Most of this review can be completed during
inspection preparation within the regional office after the documents
have been obtained from the site.

The purpose of the inspection requirements in Section 02 of this
procedure is to determine whether the licensee/contractor(s) activities,
other than welding and NDE, have met QA program requirements for piping
receipt, fabrication, erection, inspection, and testing of QL-1 and QL-2
piping systems. Also, this inspection requirement should provide
specific information about the licensee commitments, plans, and
schedules for performing required comprehensive audits in the areas of
interest listed above. Information should be obtained about audit
procedures, checklists, auditor qualification, schedules, and the
identification of those having direct audit responsibilities. Specific
attention should be directed toward reviewing licensee actions for
ensuring that only qualified personnel are permitted to perform the
construction and inspection work covered by this procedure.

The license/contractor procedures involved may vary from contractor to
contractor, and may take many forms, such as formal procedures,
instructions, checklists, drawings, etc. Review the inspection
procedures/lists and compare with the requirements in the applicable
codes and construction specifications. Evaluation should indicate
whether adequate quality‑related inspections are established and are
based on appropriate criteria, and further, whether the results of the
licensee/contractor\'s inspection will be transmitted to responsible
quality assurance and management personnel. The regional inspector must
determine if the licensee controls are adequate and are properly
implemented in a timely manner.

[Specific Guidance]{.underline}

03.01 For clarification, \"Material Test Report\" is a generic
expression meaning a report of test results to confirm that material,
chemical and physical properties are consistent with the applicable
specification. Vendor terms used, which can be identified with the
expression \"Material Test Report,\" include:

a.  Ladle analysis (sample of molten metal)

b.  Check analysis (sample of solidified metal)

c.  CTR (Chemical Test Report or Certified Test Report)

d.  MTR (Material Test Report ‑ usually includes chemical and physical
    tests)

03.02 The generic terms CTR and MTR should not be confused with the term
\"Certification.\" A \"Certification\" is a document issued in lieu of
actual quality documentation records stating that the quality
requirements contained in specifications and purchase orders have been
met.

03.03 \"Quality Release Form\" and \"Certificate of Equipment\" are
examples of generic designations for forms used by manufacturers to
serve as certifica­tions of quality (in lieu of original quality
documentation) for components and equipment.

03.04 The inspector should bear in mind that NRC\'s sample covers only a
very small portion of the records involved. Thus, substantive errors or
departure from requirements raise the issue of whether the licensee is
adequately controlling the process.

03.05 The qualifications of those engaged in quality sensitive or
special processes related to pipe installation, inspection and testing
work should be sampled for an assessment of compliance with licensee
commitments. Also, depending on the type and extent of design
engineering work being performed at the site, it may be appropriate to
review the qualifications of certain key individuals assigned to this
design area.

03.06 A piping run, for purposes of this procedure, is meant to be a
particular section of piping, for example: a piping section between
components or major supports or relief valve discharge piping. The
intent of requirement 02.06 is to determine whether piping is being
installed according to properly approved drawings; either the original
design drawings or properly approved revisions; and, if revisions are in
process, that these changes are properly handled in accordance with
established procedures.

Appropriate standards can be used as a guide in this area. For example,
NQA-1 and the QAP require that where changes to previously verified
designs have been made, design verification shall be required for the
changes, including effects of those changes on the overall design. Also,
changes made to piping during construction which may result in
significant deviations from the (CAR) design should also be subject to a
design verification. Such changes could result in an accumulation of
design change documents and/or marked‑up drawings. These documents
reflect as‑built conditions and should be adequately controlled so they
will be readily available for future use especially during future
evaluations of other design changes. Additionally, the as‑built process
should result in proper and timely updating of the original/master
drawings and specifications to incorporate such changes.

03.07 [Prevalent errors and concerns]{.underline}. This section is
included to provide background for inspectors on what past problems of a
generic nature have been identified and is for information only.

a.  The status of protective measures at the time of site receipt and
    initial storage of piping and piping system components.

b.  Adequacy of dunnage for piping and piping system components during
    storage. Dunnage treated with fire retardants may expose pipe to
    excessive levels of halogens and chlorides.

c.  Continued adequacy of such things as end caps for piping and
    protective coverings for weld prep areas.

d.  Weather protection in the form of canvas or plastic covering. (In
    most deficient cases, the original protective covering was adequate,
    but inattention to damage and normal \"wear and tear\" led to
    substandard or unacceptable protective covers.

e.  Storage areas located on sandy soil require special attention to
    avoid the entry of wind‑driven sand particles into piping
    components.

f.  Improper location of storage. In some instances, storage locations
    are selected without consideration for construction traffic
    patterns, or possible falling objects and/or missiles.

g.  Inadequate or illegible piping identification. (Damaged by handling
    and/or environment.)

h.  Stability of work force or QA/QC personnel and the attitudes in work
    crews and relations between construction personnel and QA/QC
    personnel.

i.  Power grinders used for weld preparation of pipe that result in
    violation of minimum wall thickness.

j.  Piping runs containing mud, sand, and other foreign material.

k.  Incorrect size orifices installed in pump recirculation lines.

l.  Surfaces for welding not properly free of paint, oil, rust, or other
    material that is detrimental to welding.

m.  Drawings or other records fail to show evidence of actual piping
    components installed in pipeline or are not a current revision.

n.  Piping changes without proper design change authorization.

o.  Repairs of linear indications on pipe spool pieces not properly
    performed as to testing for wall thickness and blending uniformly
    into the surrounding surfaces.

p.  Controls over the installation/removal of cleaning and flushing
    devices are inadequate.

q.  Refer to IE Bulletin 79‑14 for additional concerns relating to
    as‑builts.

88134‑04 RESOURCE ESTIMATE

This inspection procedure is expected to take, on the average, 24 to 32
hours for each review of licensee/contractor activities. The procedure
should be run once early in the installation of piping relied on for
safety, with primary focus on procedures and personnel qualifications. A
second inspection should be conducted about mid-way in the installation
of piping relied on for safety with the primary focus on observation of
work and review of installation records.

88134‑05 REFERENCES

Duke, Cogema, Stone and Webster, Mixed Oxide Fuel Fabrication Facility,
MOX Project Quality Assurance Plan (MPQAP), Docket Number 070-03098,
under US Department of Energy Contract DE-AC02-99-CH10888, latest
revision accepted by NRC.

Duke, Cogema, Stone and Webster, Mixed Oxide Fuel Fabrication Facility
Construction Authorization Request, latest revision accepted by NRC.

10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants
and Fuel Reprocessing Plants

10CFR70, Domestic Licensing of Special Nuclear Material

10CFR21, Reporting Defects and Noncompliance

Parts I and II of ASME NQA-1-1994, Quality Assurance Program
Requirements for Nuclear Facility Applications, as revised by the
ASME-1a-1995 Addenda

Regulatory Guide 1.28, Quality Assurance Program Requirements (Design
and Construction), Revision 3

ASME B31.3-2002, Process Piping

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