Issue Date: 04/01/10 1 88140 

 NRC INSPECTION MANUAL NMSS/RII 

INSPECTION PROCEDURE 88140 

INSTRUMENTATION AND CONTROL SYSTEMS 

PROGRAM APPLICABILITY: 2630, 2694, 2696 

88140-01 INSPECTION OBJECTIVES 

Note the term licensee refers to licensees, holders of certificates of compliance, 

applicants for a license, contractors, subcontractors, vendors, and other employers 

subject to NRC authority. 

01.01 To determine whether technical requirements detailed or referenced in the 

facility’s licensing documents (i.e., Construction Authorization Request (CAR), License 

Application, Safety Analysis Report (SAR) or Quality Assurance Plan (QAP)) associated 

with Items Relied on for Safety (IROFS) instrumentation and controls (I&C) in Quality 

Level (QL)-1 systems, and associated items have been adequately addressed in the 

licensee and/or contractor construction specifications, drawings, work procedures, and 

instructions, and whether these documents are of sufficient detail and clarity for 

adequate work performance and control. 

01.02 To determine whether applicable quality assurance (QA) plans, instructions, and 

procedures for IROFS I&C, and associated items have been established in licensee and 

contractor QA/Quality Control (QC) manuals and whether these conform to the QA 

program described in the approved QAP. 

01.03 To determine, through direct observation and independent evaluation of work, 

whether the licensee’s work and inspection performance relative to IROFS I&C in QL-12 

systems, as applicable, are being controlled and accomplished in accordance with 

approved specifications, drawings, and procedures. 

01.04 To determine whether the licensee is adequately implementing the QA program 

associated with I&C including preparing, reviewing, and maintaining a system of quality 

records; whether the records reflect work accomplishment consistent with NRC 

requirements, licensing document commitments, and the QAP; and whether the records 

indicate any potentially generic problems, management control inadequacies, or other 

weaknesses that could have safety significance. 
Issue Date: 04/01/10 2 88140 

88140-02 INSPECTION REQUIREMENTS 

02.01 QA Procedure Review. For the Licensee and each contractor with QA 

responsibilities, review commitments and procedures covering the scope of documents 

to be prepared for assuring the quality of I&C systems that are designated as IROFS. 

a. Determine whether the installation procedures for I&C IROFS are consistent 

with the QA program and licensing document commitments. 

b. Determine whether responsibility assignments for procedures preparation, 

review and approval, include groups with necessary technical expertise. 

c. Determine whether Licensee individuals or contractors that review and approve 

quality records are required to have the necessary technical expertise to ensure 

that the information to be recorded meets applicable requirements. 

d. Determine whether construction drawings incorporate the most recent design 

requirements. 

02.02 Specific Technical Review Areas. Determine whether procedures covering work 

and inspection activities in the following areas are appropriate for the activity and are 

technically adequate: 

 a. Receipt Inspection Procedures (IPs). Receipt inspection and related procedures 

provide means to ensure that: 

1. Material is in good condition, not damaged in shipment and that shipping 

and handling requirements have been met. 

2. Inputs from other groups or other organizations to be used during 

receiving inspection activities are properly utilized; such as the results of 

source inspections, environmental qualification tests, and other required 

quality tests. 

 3. Procurement requirements such as qualification tests, certificate of 

conformance, functional tests and other quality tests (material, physical 

and chemical) have been successfully completed or status of how and 

when such requirements will be satisfied is documented and adequately 

controlled. 

 b. Storage Procedures. Storage procedures provide means to ensure that: 

1. The proper storage environments (as specified by the construction 

specifications and the manufacturers instructions) are established for the 

various types of I&C system components and meet applicable storage 

classification levels regardless of the location of the stored item. 
Issue Date: 04/01/10 3 88140 

 2. Storage IPs requires initial verification of storage conditions and periodic 

verifications for the duration of the storage period. They must also ensure 

that special and in-place storage requirements are met and shelf life limits 

are not exceeded. 

 c. Work Procedures. Work procedures are established to ensure that: 

1. Licensing document commitments are properly translated into the work 

procedures (construction specifications, drawings and work instructions) 

for adequate control and installation of IROFS I&C system components 

and associated items. 

2. Interface controls are adequate when multiple contractors are involved. 

3. Procedures cover special handling, installation, termination, and 

maintenance requirements, including those pertaining to protection, 

preservation of internal cleanliness, and maintenance of component 

qualification requirements. For example, all covers, seals, plugs, internal 

preservatives, and protective coatings are left intact until installation 

and/or use, as appropriate. 

 d. Inspection Procedures. QC IPs is established to ensure that: 

1. All safety-related aspects of construction specifications, drawings, and 

work instructions are included in the scope of planned inspections. 

2. The technical aspects of inspection requirements and acceptance criteria 

are sufficient to determine whether the components and their installation 

(including terminations and interface seals), calibration, test, maintenance, 

and protection conform to applicable design and construction 

specifications. 

3. Records of initial and follow-up inspections include the specific results of 

the inspection. This should include the specific characteristics being 

inspected (or the actual measured values), the inspector's determination 

of acceptability, and identification of any nonconformance(s) found. 

 e. Construction Testing and Calibration Procedures. Procedures are established 

to ensure that special conditions of testing and calibration of process 

instruments (prerequisites, sequence, special handling, removal, precautions, 

etc.) are included and described in proper detail as required to conduct and 

monitor the work performed. For example, if density compensation is required 

for a liquid level instrument, the proper technique for density correction should 

be included in the calibration procedure. 

 f. Change Control Procedures. Procedures have been established to control 

design and field changes to ensure that: 
Issue Date: 04/01/10 4 88140 

 1. Retrieval of voided drawings and specifications at work sites is controlled. 

 2. Field changes are subject to adequate design control processes and are 

incorporated into the as-built records. 

02.03 Follow-up Procedure Review. When I&C systems are in process of being 

installed, review work and QA/QC procedures pertaining to installation and inspection. 

Review a selected sample of the procedures addressed in Sections 02.01 and 02.02, 

above, and note significant changes made (revisions, deletions, additions, etc.). 

Determine whether the changes are appropriate and whether regulatory requirements 

and licensee commitments remain in these procedures. 

02.04 Additional Inspection. Additional inspections may be conducted in the 

inspection areas covered above if Regional management concludes that the licensee 

performance is determined to have weaknesses requiring extensive corrective action. 

02.05 Inspection of Systems and Components. 

 a. General. 

 1. Inspection of selected components and associated items of the instrument 

systems listed below shall be accomplished by observation and evaluation 

of both in-process and completed work at the appropriate stage of 

completion for the activity to be inspected. 

 2. Sample selection shall be based on importance to operational safety and 

shall include redundant components and a diversity of components and 

locations. 

 3. Before inspection of selected items, review the specifications, drawings, 

work procedures, QA/QC procedures and work schedules applicable to 

the systems and components selected for inspection. If applicable review 

all previously issued NRC inspection reports in the area. The following 

sample sizes are considered to be minimum. 

(a) Before inspection of selected items, review the specifications, 

drawings, work procedures, QA/QC procedures and work schedules 

applicable to the systems and components selected for inspection. 

If applicable review all previously issued NRC inspection reports in 

the area. 

(1) For each periodic inspection of the activities in Section 02.06, 

select several process variables (i.e., safety sensor) in the 

safety control subsystems that are required to be monitored 

for initiation of the system safety function. 

(2) Complete the inspection requirements of subsections 02.06.a 

through 02.06.f below for the selected process variables and 
Issue Date: 04/01/10 5 88140 

associated items in the applicable safety control subsystem. 

The sample shall include redundant components if applicable. 

 (b) Emergency Control System. 

 For each periodic inspection of the activities in Section 02.06, select 

several process variables which are used by the emergency control 

system to mitigate the consequence of a hazardous occurrence. 

(c) IROFS Display Instrumentation. 

 (1) For each periodic inspection of the activities in Section 

02.06.d, select several process variables which are displayed 

to provide information to the operator so that required manual 

safety actions can be taken using the emergency control 

system. 

 (2) Complete the inspection requirements of subsections 02.06.b 

through 02.06.f for components pertaining to the process 

variables selected for that subsection. 

 (b) Emergency Control System. 

 (1) For each periodic inspection of the activities in Section 02.06, 

select one process variable which is used by the emergency 

control system to mitigate the consequence of a hazardous 

occurrence. 

 (2) Complete the inspection requirements of subsections 02.06.a 

through 02.06.f for the instrument components and associated 

items pertaining to the emergency control system variable 

selected. The sample shall include redundant components if 

applicable. 

 (c) IROFS Display Instrumentation. 

 (1) For each periodic inspection of the activities in Section 

02.06.d, select one process variable which is displayed to 

provide information to the operator so that required manual 

safety actions can be taken using the emergency control 

system. 

 (2) Complete the inspection requirements of subsections 02.06.b 

through 02.06.f for components pertaining to the process 

variable selected for that subsection. 
Issue Date: 04/01/10 6 88140 

02.06 Inspection Activities. 

 a. Receipt Inspection. Observe and evaluate portions of receipt inspection 

activities pertaining to instrumentation components and associated items 

selected in the appropriate subsections of Section 02.05. Determine whether 

receiving inspection activities are being controlled and performed in a manner 

which will ensure that applicable requirements are satisfied in the following 

areas: 

 1. Components and receiving documents are properly identified. 

 2. Physical condition (damage, deterioration, etc.). 

 3. Documentation relative to quality requirements (e.g., results of functional 

and qualification testing) received with components and associated items 

is reviewed and meets the requirements. Where qualification testing of 

components to be placed in a harsh environment is not a requirement of 

the specification, review existing documentation that establishes 

acceptance criteria and environment requirements that define what means 

will be used to assure that applicable environmental qualification will be 

satisfied. 

 4. Control of nonconforming components. 

 5. Adequate number of qualified personnel are available to perform the 

receiving inspection function. 

 b. Storage. Observe and evaluate storage activities and conditions for the 

inspection samples selected in appropriate subsections of Section 02.05. 

Determine whether: 

 1. Components are stored in the proper storage level designation. 

 2. Components are properly identified. 

 3. Storage conditions (temperature, humidity, cleanliness, etc.) are controlled 

and monitored as specified. 

 4. Licensee and contractor inspection and monitoring activities are being 

performed in accordance with procedural requirements. 

 5. Nonconforming items placed in storage are identified and/or segregated, 

as required. 

 6. In-place storage requirements are satisfied. 
Issue Date: 04/01/10 7 88140 

 7. An adequate number of qualified personnel are available to perform the 

required storage functions. 

 c. In-Process Installation. Observe and evaluate portions of the in-process 

installation activities for the inspection sample selected in appropriate 

subsections of Section 02.05. Determine whether: 

 1. The latest approved revision of applicable construction specifications, 

drawings, and/or procedures are available and used by the installers. 

 2. The components are as specified, such as: type, range, proof 

pressure/rating and material. Wiring and terminations associated with the 

components are observed and evaluated per IP 88137. 

 3. Associated mounting hardware and supports are of the type and material 

specified and properly located. 

 4. The components are installed in the proper location and orientation by 

qualified craft personnel using suitable equipment and tools. 

 5. The required component identification is properly maintained or 

established. 

 6. Licensee and contractor inspections are performed, or scheduled to be 

performed, before closing out the work to be inspected. 

 7. Inspection activities are timely and properly completed by qualified 

personnel. 

 8. Installed components are adequately protected from damage by adjacent 

construction activities. 

 9. Nonconformance issues are identified and handled in accordance with 

established procedures. Where corrective action is being taken, 

determine whether it meets the appropriate requirements. 

 d. Completed Work. Observe and inspect the completed installation of I&C system 

components for the samples selected in subsections of Section 02.05. 

Determine whether: 

 1. Location, configuration and installation (including mounting and anchoring) 

are in accordance with the latest approved design or construction 

specifications and drawings. 

 2. Specified instrument components and associated items have been used. 

 3. Components have been correctly and permanently identified. 
Issue Date: 04/01/10 8 88140 

 4. Cleanliness requirements have been maintained or otherwise satisfied. 

 5. Installed equipment is adequately protected from adjacent construction 

activities and protective coatings, plugs, bushings, and other materials 

have been used as specified. 

 6. Instrument components and associated items, such as sensing lines and 

power supplies; maintain physical and electrical independence between 

redundant parts. 

 7. IROFS protection systems and normal plant control systems are 

adequately separated and isolated from each other. 

 8. Nonconforming components or conditions have been identified and 

controlled in accordance with approved procedures. 

 9. Status of completion, maintenance, and readiness for pre-operational 

testing is indicated or otherwise documented. 

 10. Adequate actions or provisions have been taken or maintained (as 

needed) to ensure that the validation of the environmental qualification of 

instrument components is maintained. 

 11. Wiring and terminations, including grounding, are installed in compliance 

with construction drawings and specifications. 

 e. As-Built Verification. 

 1. When I&C system components as selected in appropriate subsections of 

Section 02.02, are installed and inspected, obtain the latest revision (asbuilt, if available) of instrument and installation drawings. 

 (a) Review construction specifications and other applicable documents 

referenced by drawing or otherwise. 

 (b) Compare the actual installation of the components selected with the 

drawings. 

 (c) Select several additional components from drawings and determine 

whether they are of the correct specified type (i.e., function, range, 

accuracy, qualification, material, etc.) and whether they have been 

installed, located, oriented, supported, protected, etc. in accordance 

with the drawing. 

 2. Before performing items (a), (b), and (c), above, verify the status of any 

outstanding design changes on the selected drawings (or related 

specifications). 
Issue Date: 04/01/10 9 88140 

 3. Discrepancies observed may result from in-process changes, such as 

those initiated in the field. If in-process changes are involved, determine 

whether the licensee has properly controlled and documented these 

changes for engineering review, approval, and subsequent incorporation 

into the final as-built drawings. 

 f. Construction Testing and Calibration. Observe construction testing and 

calibration activities for applicable components from the sample selected in 

subsections of Section 02.02. Determine whether: 

 1. The latest revision of applicable procedures and/or specifications are 

available at the work location and used by personnel performing the 

testing and calibration. 

 2. Properly identified, traceable and calibrated measuring and test 

equipment are used. 

 3. Equipment or components calibrated are able to obtain the set point, 

degree of accuracy, and/or tolerance specified or otherwise noted. 

 4. Required testing and calibration results are recorded during the activity, 

not after the work has been completed. 

 5. Components are adequately identified as having been tested or calibrated. 

 6. Personnel performing the testing and calibration are properly qualified. 

 7. Test and calibration personnel adhere to any special handling or removal 

requirements. 

02.07 Additional Inspection. Additional inspections may be conducted in the 

inspection areas covered above, if Regional management concludes that the licensee 

performance is determined to have weaknesses requiring extensive corrective action. 

02.08 Record Control and Review. Review licensee and contractor requirements 

covering the scope of records for IROFS I&C system components. 

 a. Determine who prepares each quality-related record, who reviews the records 

for accuracy and who ensures that the recorded information meets 

requirements. 

 b. Evaluate the information obtained above and determine whether the established 

record management system satisfies QA Program and licensing document 

commitments. 

02.09 Inspection Records. Review and evaluate pertinent quality records. Determine 

whether: (1) adequate preparation, control, review, and evaluation of these records 

have been made; (2) they reflect that regulatory requirements have been met and (3) 
Issue Date: 04/01/10 10 88140 

the system of records is functioning properly. The selection shall include records of 

components in the safety control subsystems (e.g. MP and AP), emergency control 

system, sensors, and safety parameter displays, if applicable. 

 a. Receipt Inspection Records. 

 1. Receipt inspection documents properly and uniquely identified received 

instrument components and associated items. 

 2. Applicable engineering and functional specifications (regarding size, type, 

material, etc.) of received items were met or otherwise noted. 

 3. The required instrument component characteristics, material, performance 

tests, environmental and seismic qualification tests, nondestructive tests, 

and other specification requirements were met or otherwise noted. 

 4. Original records or certification system met requirements of applicable 

criteria. 

 b. Storage Records. 

1. Required storage conditions were maintained. (Note: Verification of these 

conditions may require verification of log sheets recording the ambient 

conditions or through the use of recorders. 

 

2. Storage inspections were properly made at specified intervals. 

3. Records of nonconforming items in storage areas were properly 

maintained. 

c. Installation Records. 

 1. Most recent and approved design and construction documents were used 

during installation. 

 2. Specified instrument components and associated items were installed in 

the location specified or otherwise noted. 

 3. Materials and methods used for supports and anchors (including welds) 

met applicable specifications. 

 4. Required inspections were performed, recorded, reviewed, and evaluated 

by qualified personnel. 

 5. Inspection records were complete and satisfied documentation 

requirements. 

 6. Physical separation and independence requirements were met. 
Issue Date: 04/01/10 11 88140 

 7. Required protection was provided after installation. 

 8. Verify that required special installation procedures were implemented. 

 d. Construction Testing and Calibration Records. 

 1. Required tests and calibrations were performed as required. 

 2. Records indicate that approved procedures and equipment were used. 

 3. Test equipment was periodically checked and calibrated as specified. 

 4. Test data and results were properly documented and evaluated, and 

corrective action, if required, was taken. 

02.10 Training/Qualification Records. Review and evaluate a selected sample of 

personnel qualification records and determine whether: 

 a. A system of craft and inspection personnel qualification records meets stated 

requirements and is being maintained in a current status. 

 b. The records are sufficient to reasonably support qualification in terms of 

certification, experience, proficiency, training, testing, etc., as applicable. 

 c. Action has been taken by responsible licensee organizations to independently 

authenticate the record material. 

02.11 Nonconformance and Deviation Reports. Review and evaluate a selected 

sample of nonconformance and deviation reports, and determine whether: 

 a. Records are legible, complete and promptly reviewed by qualified personnel. 

 b. Reporting requirements of 10 CFR Part 21 and Part 70 were recognized during 

evaluation and appropriate action was taken where necessary. 

 c. Records have been routinely processed, timely evaluated, and controlled 

through established channels for resolution of the root cause as well as the 

immediate problem. 

 d. Records are properly identified, stored, indicate current status, and can be 

retrieved in a reasonable time. 

 e. Nonconformance reports include the status of corrective action or resolution, 

and adequate justification is provided for use-as-is disposition. 

02.12 Change Control Records. Review and evaluate a selective sample of five 

change control records, and determine whether: 
Issue Date: 04/01/10 12 88140 

 a. Records associated with design and field changes, as well as related work and 

inspection procedure changes, reflect timely review and evaluation by qualified 

personnel and are of the type approved for that purpose. 

 b. Records of periodic inspections assure that only the most recently approved 

documents, including design changes, were used in the field. 

 c. Design changes are subject to adequate design control, including consideration 

of the impact of the change on the overall design and on as-built records. 

 d. Records of nonconformity to design requirements include preparation of a 

nonconformance report even if the nonconformance is resolved through the 

design change process. 

02.13 Audit Records. Review and evaluate licensee and instrument contractor(s) audit 

records in general and two recent audits associated with instrumentation in detail (one 

licensee audit and one contractor audit, if available) and determine whether: 

 a. Audits have been performed in accordance with the schedule and functional 

areas established in the audit plan. 

 b. Audit records are sufficient to verify that the intended purpose and scope of the 

audits were achieved. 

 c. Audit findings have been reported in sufficient detail to permit a meaningful 

assessment by those responsible for corrective action, final disposition, and 

trending. 

 d. The licensee and contractor has taken proper and timely follow-up action on 

those matters in need of correction. 

 e. Auditing organizations and personnel are independent of the work being 

audited. 

 f. All elements of the QA program are being audited periodically. 

02.14 Additional Inspection. Additional inspections may be conducted in the 

inspection areas covered above if Regional management concludes that the licensee’s 

performance is determined to have weaknesses requiring extensive corrective action. 

88140-03 INSPECTION GUIDANCE 

03.01 General Guidance. 

a. I&C system components consist of those elements that are designed to 

measure, monitor, transmit, modify, display, alarm, record and/or control various 
Issue Date: 04/01/10 13 88140 

plant variables or conditions. This IP, and other instrumentation IPs, apply, but 

are not limited, to the following IROFS instrument components and associated 

items: sensors, transmitters, isolators, signal conditioners, controllers and other 

actuating devices, recorders and other printing devices, indicators, alarms, 

switches, logic devices, interlocks, bypasses, instrument valves, fittings, tubing, 

instrument air supplies, internal power supplies or regulators, protective devices, 

control boards, racks, panels, cabinets, supports, anchor and mounting 

hardware, communication devices, multiplexers, data concentrators, engineering 

workstations, human-machine interface devices (e.g., displays), interconnecting 

means for integrity and applicability, and network management devices and 

tools. 

b. During inspection preparation, applicable portions of the licensing documents 

should be reviewed by the inspector to determine specific licensee procedural 

and work instruction commitments relative to construction and inspection (QA) 

requirements for I&C system components. The inspector should then utilize the 

above information during review of the licensee's construction specifications, 

drawings, work, and IPs to determine whether licensing document requirements 

are adequately translated into the appropriate documents. 

c. Procedures that control activities such as receipt, storage, installation, 

inspection, calibration, testing, and software modification, upgrading, and/or 

patching must contain sufficient detail to assure that the specific work steps 

which affect the functioning of the installed equipment will be performed 

properly. These work steps are to be identified and adequately controlled. 

While reviewing procedures, be aware of and look for inadequacies that could 

lead to construction deficiencies and/or indicate an inadequate management 

control system. 

d. If a contractor utilized procedures and personnel for activities covered by the 

other IPs, it is not necessary to repeat similar inspection requirements for each 

of these IPs. It should be noted that software validation is covered by IP 88112. 

e. The inspector should bear in mind that the procedures selected for detailed NRC 

review cover only a representative sample of the procedures involved. Thus, 

substantive errors or departure from requirements identified in NRC’s sample 

raises the concern of whether the licensee is maintaining adequate control of the 

process, and whether the NRC inspector and/or the licensee should conduct 

additional examinations to determine the extent of the identified problem. 

f. Findings from this inspection activity should address each functional area as 

being satisfactory, unresolved and requiring resolution, or in violation and 

requiring correction. When significant inadequacies are identified indicating 

weakness within the responsible organization, the inspector should inform 

cognizant NRC management. The issue should be addressed also at the 

appropriate level of licensee management. 
Issue Date: 04/01/10 14 88140 

g. Because the instrumentation is so important and extensive, inspection activities 

are to be conducted periodically. In-process installation inspections should be 

scheduled to match appropriate installation activities. 

h. It is expected that the scope of periodic inspections will vary with construction 

progress, problems encountered, etc. Additional inspections should be made 

when and where conditions warrant. 

i. Any installation activity that has been delayed or suspended for more than one 

year, or has been subject to significant procedural, design, or personnel change, 

should be re-evaluated immediately after resumption of the work or after the 

above changes have been made. Determine whether additional NRC inspection 

is required. 

j. The inspector may not be able to observe all facets of all work activities in 

progress relative to instrument components and systems selected for inspection. 

However, portions of activities directly affecting plant safety must be covered. 

k. In addition to observing whether specific instrument components and associated 

devices are as specified (properly identified, located, mounted, etc., as 

required), it is important also to ascertain whether certain components or 

conditions do not exist where prohibited. For example, instrument components 

are not exposed to potential hazards from other construction activities. Because 

of the complexity of digital components, and the potential for interconnection 

between safety components and between safety and non-safety components, 

the inspector should consider these issues during the inspection. Although the 

safety sensor may be hardwired to the controller, the controller may be 

communicating over a digital bus with other controllers, the operator, or and 

annunciator system. Also, some sensors are “smart” in that they have on-board 

diagnostics and calibration tables, so, even though they are “hardwired,” they 

could still be using some communication link with the controller (e.g., HART 

superimposes digital monitoring and command signals on an analog 4-20mA 

signal). 

03.02 Specific Guidance. 

 a. Inspection Requirement 02.01. The expertise of the inspector is important for 

the proper completion of the inspection. The individual selected to perform 

Section 02.01 should have a general knowledge of and background in QA, and 

the individual selected for Section 02.02 should be thoroughly knowledgeable of 

the technical requirements associated with instrumentation systems. One 

individual may perform both requirements if he/she possesses appropriate 

knowledge in both areas. 

 b. Inspection Requirement 02.02. For the purpose of this IP, the term “procedures 

covering work” includes construction specifications, drawings, and work 

instructions. (Procedures describing methods of fabrication, construction or 

installation are sometimes called construction procedures.) 
Issue Date: 04/01/10 15 88140 

 c. Inspection Requirement 02.02.a. 

1. Receiving IPs should reflect the requirements that the licensee has 

committed to for example, of Nuclear Quality Assurance (NQA)-1-1994, 

Supplement 7S-1 and/or Subpart 2.2, or equivalent requirements. 

2. The licensee should identify and describe all I&C components with IROFS 

which must operate in a hostile environment (e.g., high radiation, 

temperature, humidity) during or after an accident. 

3. Where environmental qualification testing, or other qualification provisions 

(such as seismic) are specified, the licensee shall establish means to 

assure that the results of this testing are documented, reviewed, and 

determined to be acceptable. If this is not performed when components 

are received, the procedures should specify the organization that will be 

performing this review and the controls to ensure that all such 

documentation requirements are satisfied before the component is placed 

in use. 

4. The inspector should also be aware of memory-related integrated circuit 

chips (Programmable read only memory (PROMs), flash memory, etc.) 

that have certain versions of application code (i.e., specific version of 

firmware). The inspector should verify that the configuration management 

program is tracking these versions - not just firmware, but all electronic 

devices that may have embedded processors, memory, etc. In addition, 

for safety-related electronic components, the inspector should verify that 

the supplier or licensee followed the supply chain to ensure no 

unauthorized replacements have occurred. 

5. Instrument components may be released for installation on the merits of 

certifications of conformance if the organization involved has established a 

satisfactory program control and audit requirements in this area (NQA-1-

1994, Supplement 7S-1 Subpart 8.2.1). However, certifications of 

conformance do not release the licensee from having other records (such 

as environmental or seismic qualification records) for operation and for the 

life of the plant. 

 d. Inspection Requirement 02.02.b. 

1. Special storage requirements are typically specified by the manufacturer 

or an industry standard, such as NQA-1-1994 Subpart 2.2. The 

requirements should include such things as identification and markings on 

I&C components, protective covers, preservatives, etc. 

2. The inspector should verify that the storage procedures have provisions 

for initial and periodic inspection of storage conditions for components 

which have special storage requirements. Procedures should be available 
Issue Date: 04/01/10 16 88140 

for conducting periodic “storage inspections” of components which have 

been installed during the time period between installation and turnover to 

the operations staff. 

3. The inspector should consider verifications of proper firmware, component 

versions, and verify that unauthorized substitutions have not been made 

(This is over and above certain environmental considerations, e.g., 

humidity and temperature for electronic components.) 

 e. Inspection Requirements 02.02.c. Procedures should be reviewed to ensure 

that technical requirements in the licensing document are reflected in 

construction specifications, drawings, work instructions, and work procedures. 

Areas to review shall include, but are not limited to, the following: 

 1. I&C system components (type, range, accuracy, materials, etc.) are 

identified, located, oriented, and supported as specified by design. 

 2. Physical separation and independence requirements of redundant 

components are met. 

3. Instrument sensing lines are sloped to meet applicable requirements. 

Instruments connected to chemical processes for which it is not feasible to 

use direct sensing lines are might be connected via armored capillary 

tubing and/or diaphragm seals which have been appropriately protected 

from potential damage from construction or operating activities. 

Appropriate and adequate construction specifications, procedures and 

other work instructions for a particular activity are required to be approved 

and available before that activity is started. 

 f. Inspection Requirement 02.02.c.3. 

 1. It is not considered adequate identification to include only the instrument 

model number and type. Procedures should specify a unique 

identification number, along with the model number and name of 

manufacturer. Adequate (positive) identification is important because 

similar-looking instrument components can be significantly different with 

respect to range, output signal, etc. Safety-related instrumentation should 

be listed in the licensing document. 

 2. Anchor bolts holding or mounting instrument components should be of the 

type, size and length specified. Provisions should exist to prevent 

indiscriminate cutting of reinforcement steel during the drilling of anchor 

holes. 

 3. Procedures should be established to ensure that independence and 

separation requirements of safety-related functions from normal control 

functions are met, especially safety functions that provide protection 

against normal control system malfunctions. This separation should 
Issue Date: 04/01/10 17 88140 

include electrical and data communication isolation. (Note: Given the high 

automation in the MOX facility, data communication isolation should be 

verified from both a random failure and a cyber security perspective.) 

 4. Means should be established, such as procedures or checklists, to ensure 

that redundant sensing lines are protected from common mode failures. 

That is, redundant lines will not fail from a single accident; especially an 

accident or failure for which they are supposed to provide protection. 

 5. Evaluate sensitivity to grounding connections and lightning protection 

system downcomers. 

 g. Inspection Requirement 02.02.d. 

 1. Inspection Requirement 02.02.d.2. Review the IPs and compare with the 

requirements in the applicable codes and construction specifications. 

Evaluation should indicate whether adequate quality-related IPs are 

established and are based on appropriate criteria, and further, whether the 

results of the licensee's inspection will be transmitted to responsible 

quality assurance and management personnel. 

 2. Inspection Requirement 02.02.d.3. Provisions should include procedures 

for monitoring or surveillance of locally mounted instruments by inspection 

(QC) personnel. They should ensure that maintenance requirements 

while “stored in place” are satisfied and that adequate protection is 

provided against possible damage from adjacent construction activities, 

including construction traffic. (Where protective means used during 

construction may affect proper operation, provisions should be provided 

for timely removal.) 

 h. Inspection Requirement 02.02.e. This area is to be inspected by NRC 

inspectors who are knowledgeable in the area of instrumentation in general and 

calibration and testing in particular. 

The licensee should reference general testing and calibration requirements, and 

work procedures should provide detailed instructions. Additionally, the QA 

manual should include general surveillance procedures relative to the calibration 

of process instruments, i.e., calibration activities should be monitored (inspected 

or audited, as appropriate) in accordance with established procedures. 

 1. These procedures should include verification of the following: 

(a) Calibration data sheets (or equivalent) are being used as specified. 

(b) Calibration ranges and accuracies are current and approved for use. 

(Accuracy requirements should be defined.) 
Issue Date: 04/01/10 18 88140 

(c) Calibration and instrument setting procedures are current and 

approved for use, including identification of any special calibration 

test equipment or test equipment minimum accuracy specifications 

needed for safety related instruments. Such specifications should 

be consistent with the project instrument setpoint and loop accuracy 

procedure requirements. 

(d) Calibration techniques are appropriate for the component to be 

calibrated. For example, if density compensation is required for a 

liquid level instrument, the proper technique or correction for density 

should be included in the calibration procedure. Although density 

compensation is a basic requirement for accurate level 

measurement, it is periodically overlooked for water-calibrated 

instruments. 

(e) Controls for removal and handling of components during calibration. 

2. Calibration data records for process instruments should include 

information and data specified by industry standards which the licensee is 

committed to such as: 

(a) Specific identity of the instrument calibrated. 

(b) The specific identity of the measuring and test equipment used to 

perform the calibration. 

(c) The “as-left” calibration data. 

(d) Date of calibration. 

(e) Identity of the technician performing the calibration. 

(f) Calibration schedule documentation review. 

(g) Approval signature of a responsible individual. Certificates of 

calibration should be available at the site for measuring and testing 

equipment used to perform these calibrations. These certificates 

should show that the standards used to establish the accuracy of the 

test equipment are traceable to a nationally recognized standard. 

Procedures should require that the performance and accuracy of 

test equipment are demonstrated by periodic checking. 

This item does not include pre-operational testing. Construction 

testing generally verifies that certain components perform as 

intended, but it is not a test of system capability. 

 i. Inspection Requirement 02.05.a.3.(c). Examples of process variables used by 

the emergency control system are some manual and automatic controls for 
Issue Date: 04/01/10 19 88140 

power distribution, ventilation, and seismic isolation systems. Associated and 

interrelated devices include signal conditioning components, isolation devices, 

interlocks, bypasses, selector switches, resets, overrides, instrument tubing, 

racks, panels, and their supports, instrument wiring and wiring terminations. 

The licensing documents should include the specific variables, as well as the 

logic and devices, used in the system. 

Examples of sensors which provide information to automatic controllers are 

devices for measuring/monitoring temperature, mass, physical dimension, 

component identification bar codes, and machine tool positions. 

Examples of controllers which are required to mitigate accidents are the safety 

controllers and emergency controls. The licensee should specify the specific 

variables, as well as the logic and logic devices used in the system. 

 j. Inspection Requirement 02.06.a. Receipt inspection activities should be 

inspected for compliance with procedures identified and/or reviewed during 

inspection, Subsection 02-02.a. NQA-1-1994, Subpart 2.2 or equivalent 

requirements are applicable here. 

 1. The licensee should identify and describe all instrument components 

which must operate in a hostile environment (e.g., high radiation, 

temperature, humidity) during or subsequent to an accident. Where 

environmental qualification testing, or other qualification provisions (such 

as seismic) are specified, receiving inspection activities should include 

verification that required testing has been satisfactorily completed. 

 2. All required documentation may not be received with the components. If 

not, the inspector should at this time determine that the licensee is 

following their system for identifying, controlling, and maintaining the 

status of the required documentation. This system should ensure 

eventual documentation of satisfactory completion of required testing. 

 k. Inspection Requirement 02.06.b. Storage activities should be inspected for 

compliance with procedures identified and/or reviewed during inspection, 

Subsection 02-02.b. NQA-1-1994, Subpart 2.2 or equivalent requirements are 

applicable here. 

 1. Control of storage conditions for equipment stored in place usually 

requires special effort. The inspector should note whether the 

procedurally required storage conditions are being maintained. 

 2. Readily visible and permanently marked tags or other identifying scheme 

should be used for all nonconforming components and materials, and 

records relative to the nonconformance should be available at the site and 

readily retrievable. 
Issue Date: 04/01/10 20 88140 

 l. Inspection Requirement 02.06.c. Because of the uncertainties associated with 

scheduling of in-process installation inspections, it is expected that the scope of 

these periodic inspections will vary considerably. The intent is to observe the 

more important installation activities for a variety of instrumentation components 

and associated items during the time such activities are in progress. 

 1. Inspection Requirement 02.06.c.1. While reviewing construction 

specifications and drawing, also look for missing or inappropriate 

approvals. 

 2. Inspection Requirement 02.06.c.2. Drawing and construction 

specifications used in the field should be reviewed periodically to ensure 

that the most recent approved revisions are used and components are as 

specified. 

 3. Inspection Requirement 02.06.c.3. For some of the supports and 

anchorages, the inspector should directly measure or otherwise 

independently verify that requirements pertaining to such items as location 

of equipment, location of supports, and bolt size are as specified. 

During installation of equipment, anchorage holes are sometimes drilled in 

concrete structures. Indiscriminate cutting of reinforcing steel should not 

be allowed. Verify the adequacy of procedures to ensure the activity is not 

included 

The inspector should ensure that proper welding requirements, from 

codes and standards that the licensee has committed to, are specified and 

controlled. Standards may include American Welding Society (AWS) 

D1.1, Structural Welding Code, for welding of supports. Instrument tubing 

welds are generally in accordance with welding code requirements 

associated with the system or component being monitored, e.g., American 

National Standards Institute (ANSI) B 31.3, American Society of 

Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, 

as appropriate. The inspector should verify that the construction 

specifications and drawings specify the welding requirements to be used. 

 4. Inspection Requirement 02.06.c.4. “Qualified craft personnel” means 

those employees who have achieved suitable proficiency to do their 

assigned tasks by appropriate training and/or previous experience and 

who understand the installation procedures, drawings, and specifications 

necessary for their work. 

 5. Inspection Requirement 02.06.c.7. The observation of inspection (QC) 

activities should include in-process and final inspections. 

"Timely and properly completed" includes performing the proper 

inspections at the specified frequency and sequence. 
Issue Date: 04/01/10 21 88140 

Two or three QC inspectors should be interviewed to determine whether 

they are familiar with the quality requirements associated with the 

instrumentation being inspected, what construction specifications and 

other criteria are used to determine acceptance, how their inspection 

results are recorded, etc. The intent is to determine the effectiveness of 

instrumentation inspection personnel and management systems for 

indoctrination, training, and qualification of personnel. 

NQA-1-1994, Supplement 2S-1, or equivalent requirements are applicable 

to inspection personnel. 

 m. Inspection Requirement 02.06.d. 

1. Inspection Requirement 02.06.d.1. Some instrument lines, racks, panels, 

and their supports, or other anchoring means are required to meet seismic 

requirements. (The licensing document should indicate where applicable.) 

If specified for lines, racks, or panels selected for inspection, ascertain 

whether these requirements are met. 

 If the installation is different from approved drawings and specifications, 

determine whether the change is adequately documented and forwarded 

for review and approval. 

2. Inspection Requirement 02.06.d.2. Sometimes similar instrument 

components are put in identical cases. The inspector should ascertain 

whether the various components inspected are as specified. This can be 

done by observing the name plate for identification numbers. For 

example, the model number may be the same on two components, but the 

ranges and identifying numbers will be different. 

3. Inspection Requirement 02.06.d.3. The inspector should ascertain 

whether component identification is adequate. The installed instrument 

components should be uniquely identified on the component itself, the 

installation records, calibration records, and inspection records. 

4. Inspection Requirement 02.06.d.5. Temporary protection during construction 

is generally required. Protection from overhead construction activities, 

especially welding and concrete placement, warrants special attention. 

Additionally, protection from inadvertent damage during plant operation 

and maintenance must be adequate and properly installed. Because it 

can be easily damaged, instrument tubing requires special attention. This 

is especially important when instrument tubing runs are part of a safety 

system that may be damaged by an event or accident for which the safety 

system is supposed to provide protection. 

5. Inspection Requirement 02.06.d.7. Safety functions are to be independent 

of normal plant control functions, especially safety functions that provide 

protection against control malfunctions. 
Issue Date: 04/01/10 22 88140 

6. Inspection Requirement 02.06.d.8. The intent is to verify that 

nonconforming conditions are identified and result in the initiation of 

appropriate nonconformance documentation. Where revisions are made, 

verify that they are in accordance with approved corrective action 

dispositions. 

 n. Inspection Requirement 02.06.e. The intent is to determine whether instrument 

components and associated items are being installed according to properly 

approved drawings and changes, such as engineering, design, field change 

requests, and changes to correct nonconforming conditions. As this inspection 

requirement is to verify "as-built" systems, a new sample should be selected if it 

is found that extensive rework is in progress. However, the NRC inspector 

should verify that the changes are properly handled in accordance with 

established procedures. 

1. Appropriate standards can be used as a guide in this area. For example, 

NQA-1-1994, Supplement 3S-1, requires that where changes to previously 

verified designs have been made, design verification shall be required for 

the changes, including evaluation of the effects of those changes on the 

overall design. Additionally, 10 CFR 50, Appendix B, Criterion III, states in 

part that design and field changes shall be subject to the same design 

control procedures as the original design. 

2. Changes may be made to instrument systems during construction that are 

different from the original design. Such changes will result in the 

accumulation of various types of design change documents. Since these 

changes reflect as-built conditions, they should be adequately controlled 

and available for future evaluations on the effect other design changes 

have on the overall design. 

 Additionally, the as-built process should result in proper and timely 

updating of the master drawings and specifications to incorporate such 

changes. Thus, an excessive number of accumulated changes not 

incorporated into the as-built records and affected analyses should be 

pursued. The NRC inspector should determine how the licensee ensures 

that the affect of each subsequent change will be adequately evaluated. 

3. Obviously, the inspection requirements associated with as-built verification 

cannot be done until the work to be inspected is essentially complete. 

Consequently, this inspection requirement should be scheduled during 

later periodic inspections. 

 o. Inspection Requirement 02.06.f. The inspector should review the specified 

calibration requirements and procedures before observing these activities. If 

special requirements are specified, such as density compensation during liquid 

level instrument calibration, the inspector should determine whether these 

requirements are being adhered to. 
Issue Date: 04/01/10 23 88140 

If calibration activities are in progress, determine whether the most recently 

approved calibration information is being used, and whether required 

procedures are being adhered to. The values of instrument ranges and zero set 

points are sometimes changed after receipt of the instruments at the site. The 

inspector should assure (by selective sampling) that current data are used for 

checking and calibrating instruments, and that these changes are within the 

limits of the instrument components involved. 

As these inspection requirements cannot be done until testing and calibration 

activities are in progress, inspection in this area should be scheduled 

accordingly. 

Final calibration and trip settings may be done later, usually during preoperational testing or during startup preparation. 

The intent of these requirements is to verify that nonconforming conditions 

associated with instrument components and systems are identified by the 

licensee and result in the initiation of the appropriate nonconformance 

documentation and corrective action. 

 p. Inspection Requirement 02.07. The inspection requirements related to 

additional inspection are intentionally general. The extent and type of additional 

inspection should be based primarily on the findings. 

 q. Inspection Requirement 02.09.a. Where environmental qualification testing, or 

other qualification provisions (such as seismic) are specified, records should be 

available to verify that required testing has been satisfactorily completed. If 

these records are not available at the time of component receipt, the inspection 

records should identify the need for subsequent receipt and review of these 

documents. 

It is important to ensure that qualification testing has been successfully 

completed. Qualification documents should be reviewed to substantiate that the 

equipment is qualified to applicable standards and to the appropriate 

environment. 

A variety of terms is used for documentation that confirms that certain 

specifications are met or that specific tests have been satisfactorily performed. 

For the acceptability of these documents, refer to the requirements of NQA-1-

1994, Supplement 7S-1. 

 r. Inspection Requirement 02.09.b. Control of storage conditions for equipment 

stored in place usually requires special effort. The inspector should note 

whether the specified storage conditions are reflected in the storage inspection 

records. Refer to NQA-1-1994, Subpart 2.2 for guidance applicable to in-place 

storage. 
Issue Date: 04/01/10 24 88140 

 s. Inspection Requirement 02.09.c. Licensee and contractor inspection personnel 

should use checklists or other means to ensure proper identification of installed 

equipment. Checklists or records of inspection should be generated during the 

inspection, and these records should be readily retrievable for review by the 

NRC inspector. “Properly installed” means that the installation meets applicable 

NRC requirements and licensee commitments, including specified separation or 

installation of protective barriers. The as-installed inspection records should 

match the applicable requirements. In order for the inspector to ensure that the 

records reflect actual conditions (identification, instrument range, location, etc.), 

some instrument components selected should be the same as those selected in 

Section 02.02 of this procedure. (If the installation differs from the approved 

installation documents, a nonconformance report and a design change should 

have been generated.) 

During installation of equipment or supporting components for the equipment, 

anchorage holes are sometimes drilled in concrete structures. The work and/or 

inspection records should indicate (or at least infer) that no indiscriminate cutting 

of reinforcing steel was done during drilling of anchor holes. 

Installation and inspection records must contain sufficient detail to permit 

identification of the specific revisions or change notices used in these activities. 

Permanent records must provide a clear audit trail to any applicable change or 

nonconformance documentation. See also subsection 02.02.a.3 above. 

 t. Inspection Requirement 02.09.d. In addition to the records indicating 

satisfactory testing and calibration, the records should reflect that the range, 

response time, etc., for instrument components are appropriate for postulated 

accident conditions as well as for normal operating conditions. The procedures 

for testing and calibration should contain the necessary criteria. 

Where special requirements are necessary, such as density compensation 

during liquid level instrument calibration, the records should reflect that such 

requirements were adhered to. 

 u. Inspection Requirement 02.11. The sample size and diversification of selection 

should be sufficient to determine whether the system used to handle and control 

nonconformance issues is working in an effective manner. 

The effectiveness of the management control system in this area can be 

determined, in part, by how adequately and promptly the root cause of 

nonconforming activities are identified and corrected. 

 v. Inspection Requirement 02.13. Audit records should reflect that adverse audit 

findings were promptly evaluated and corrected in an adequate manner. The 

root cause involved should be identified to preclude repetition. 

03.03 Prevalent Problems and Concerns. The inspector should be alert to problems of 

a generic nature, such as: 
Issue Date: 04/01/10 25 88140 

a. Adequate procedures or other means have not been established to assure and 

document that all I&C IROFS components have met applicable acceptance 

criteria or to identify and document non-conformances in specific areas. 

b. IPs do not include adequate inspection requirements and acceptance criteria. 

c. Inadequate means to control location and status of instrumentation components 

- especially during removal for calibration, modification, repair or replacement. 

d. Inadequate procedures to control the evaluation, approval and use of field 

changes. (Means should be established also by the licensee or contractor to 

assure that only the latest approved field changes and other revisions or 

changes are being used for installation and inspection activities.) 

88140-04 RESOURCE ESTIMATE 

This IP is expected to take, on the average, 32 to 40 hours for each review of licensee 

and contractor activities. This IP should be conducted as needed. 

The first inspection should be early in the project and focus on review of procedures and 

work activities involving receipt inspection and storage and process control. The 

second two iterations should focus on observation of work, verification of as-built 

configurations, and review of applicable records. 

Periodic inspections and regional inspectors should focus on observation of work 

activities, protection of installed equipment, and review of documentation, audits, and 

corrective actions involving I&C components and installation activities. 

Additional inspections by specialist inspectors should be scheduled if significant 

problems are identified during specialist or resident inspector’s reviews. 

88140-05 REFERENCES 

American National Standards Institute (ANSI)/Instrument Society of American (ISA). 

ANSI/ISA-67.04.01-2000, “Setpoints for Nuclear Safety-Related Instrumentation.” 

ANSI/ Institute of Electrical and Electronic Engineers (IEEE) Standard (Std.) 336-1985, 

“IEEE Standard Installation, Inspection, and Testing Requirements for Power 

Instrumentation, and Control Equipment at Nuclear Facilities.” 

ANSI/IEEE 802.3 Standards Series, “IEEE Standards for Local Area Networks: Carrier 

Sense Multiple Access with Collision Detection (CSMA/CD) Access Method and 

Physical Layer Specifications.” 
Issue Date: 04/01/10 26 88140 

IEEE Std 384-1992, “Standard Criteria for Independence of Class 1E Equipment and 

Circuits.” 

IEEE Std 344-1987, “IEEE Recommended Practices for Seismic Qualification of Class 

1E Equipment for Nuclear Generating Stations.” 

IEEE Std 338-1987, “IEEE Standard Criteria for Periodic Testing of Nuclear Power 

Generating Station Class 1E Power and Protection Systems.” 

IEEE Std 518-1982, “IEEE Guide for the Installation of Electrical Equipment to Minimize 

Electrical Noise Inputs to Controllers from External Sources.” 

IEEE Std 1023-1988, “IEEE Guide for the Application of Human Factors Engineering to 

Systems, Equipment, and Facilities of Nuclear Power Generating Stations.” 

IEEE Std 1050-1996, “Guide for Instrumentation and Control Equipment Grounding in 

Generating Stations.” 

ISA-S12.13-Part 1-1995, “Performance Requirements, Combustible Gas Detectors.” 

ISA RP12.13-Part II-1987, “Installation, Operation, and Maintenance of Combustible 

Gas Detection Instruments.” 

NUREG-0700, “Human System Design Review Guidelines,” NRC: Washington, D.C. 

NUREG-0800, Standard Review Plan, Branch Technical Position HICB-11, “Guidance 

on the Application and Qualification of Isolation Devices,” NRC: Washington, D.C. 

NUREG-0800, Standard Review Plan, Branch Technical Position HICB-17, “Guidance 

on Self-Test and Surveillance Test Provisions,” NRC: Washington, D.C. 

NUREG-1821, Final Safety Evaluation Report on the Construction of the Mixed Oxide 

Fuel Fabrication Facility at the Savannah River Site, South Carolina. Section 11.6, 

“Instrumentation and Control Systems” including standards referenced therein. 

Regulatory Guide (RG) 1.118, Revision 3, “Periodic Testing of Electric Power and 

Protection Systems,” NRC: Washington, D.C. 

RG 1.180, “Guidelines for Evaluating Electromagnetic and Radio-Frequency 

Interference in Safety-Related Instrumentation and Control Systems,” NRC: 

Washington, D.C., January 2000. 

RG 1.75, Revision 2, “Physical Independence of Electric Systems,” NRC: Washington, 

D.C., September 1978. 

RG 1.100, Revision 2, “Seismic Qualification of Electric and Mechanical Equipment for 

Nuclear Power Plants,” NRC: Washington, D.C., June 1988. 
Issue Date: 04/01/10 27 88140 

RG 3.17-1974, “Earthquake Instrumentation for Fuel Reprocessing Plants.” 

END 
Issue Date: 04/01/10 Att1-1 

ATTACHMENT 1 

Revision History for IP 88140

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CoAc

N/A 04/01/10 

CN 10-010 

IP 88140 is a newly issued procedure. Issued for fuel facility construction inspection program to improve effectiveness and efficiency by incorporating and consolidating vendor inspection requirements. 

None N/A ML