Date: 05/18/05 - 1 - IP 88134

NRC INSPECTION MANUAL

INSPECTION PROCEDURE 88134 NMSS/FCS

S

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.
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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

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:
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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

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.
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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.
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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

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 QL1 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

03.01 For clarification, "Material Test Report" is a generic expression meaning a report of
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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:

Ladle analysis (sample of molten metal)

Check analysis (sample of solidified metal)

CTR (Chemical Test Report or Certified Test Report)

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
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such changes.

03.07 Prevalent errors and concerns. 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.
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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

END