Issue Date: 07/29/08 1 65001.07 

ATTACHMENT 65001.07 

INSPECTION OF ITAAC-RELATED INSTALLATION OF VALVES 

PROGRAM APPLICABILITY: 2503 

65001.07-01 INSPECTION OBJECTIVE 

01.01 To verify that the design bases and vendor design information are correctly 

translated into the installation of the valve. 

01.02 To determine whether the valve installation and related licensee quality control 

activities are being performed in accordance with Design Control Document (DCD), design 

specifications, Code requirements, procedures, and regulatory requirements. 

01.03 To determine whether the technical requirements in the facility Safety Analysis 

Report (SAR) associated with safety-related valve testing have been adequately translated 

to the construction specifications, drawings, and work procedures as evidenced by the 

installed results, and the related quality assurance activities are being performed in 

accordance with design specifications, Code requirements, procedures, and regulatory 

requirements. 

01.04 To determine whether valve installation welding is being conducted in accordance 

with the DCD, design specifications, American Society of Mechanical Engineers (ASME) 

Code requirements, and procedures. 

01.05 To confirm proper setup of switches for the actuators for power-operated valves to 

verify that the valves are capable of performing their safety functions under design-basis 

conditions. 

01.06 To determine, through independent observation and evaluation, that the safetyrelated valve general records, welding records, and the test and verification records reflect 

that work was accomplished in accordance with the design specifications, Code 

requirements, and procedures. Also to evaluate whether the records for the valves indicate 

any other potential weaknesses such as generic problems or management control 

inadequacies that could have safety significance. 

01.07 To evaluate the adequacy of the implementation of the quality assurance program 

requirements related to installation activities and assure problems are entered into the 

corrective action process. 

65001.07-02 INSPECTION REQUIREMENTS AND GUIDANCE 

The scope of this procedure includes most valves, regardless of the type of operator (e.g., 

motor, hydraulic, air, squib, self actuating, etc.), as a separate category of mechanical 

components because of the unique nature in which they are described in the ITAAC. 
Issue Date: 07/29/08 2 65001.07 

Check valves are included. Those valves related to containment isolation are covered in IP 

65001.11, "Containment Integrity and Penetrations." 

NUREG-0800, Standard Review Plan, Section 17.5, "Quality Assurance Program 

Description - Design Certification, Early Site Permit and New License Applications," and 

ASME Boiler and Pressure Vessel Code (BPVC) Section III, NQA-1 "Quality Assurance 

Requirements for Nuclear Facility Operations" provide guidance concerning all phases of 

this procedure. The ASME Code for Operation and Maintenance of Nuclear Power Plants 

also includes requirements for safety-related valves. The NRC regulations in Section 55a 

of 10 CFR Part 50 incorporate by reference the ASME BPVC and Operations and 

Maintenance (OM) Code with specific limitations and modifications. 

The regulatory basis for safety-related valves is found in 10 CFR 50, Appendix B; for 

example, Criterion III, Design Control, Criterion IV, Procurement Document Control, and 

Criterion XI, Test Control. In addition, the ASME BPVC, Section III, Parts NB, NC, and ND, 

and the ASME OM Code contain requirements for fabrication, installation, testing and 

certifying capacities, and tagging the safety-related valves. 

The requirements apply to both installed and on the shelf safety-related valves and risk 

significant valves. The ASME BPVC Code and OM Code contains detailed information on 

testing and tagging the valves. 

02.01 General Installation. Select a sufficient number of valves and components, to 

include all targeted valve ITAACs, covering general installation requirements for review. 

Through direct inspection, confirm that the following attributes, as applicable, have been 

met: 

Valve Installation

a. Installation requirements for valves include: proper location or placement; quantity; 

valve and actuator orientation; alignment; material type/shape/size; volumetric flow 

rate; flow direction; special features such as coatings and insulation; seismic and 

other mounting and support requirements; torquing of bolts; proper lubrication for 

each valve and actuator (including stem, gearbox, and limit switch, as applicable); 

and compliance with tolerance/clearance requirements. 

b. All packaging material is removed at the time of installation in accordance with the 

installation procedure. Once the safety and pressure relief valves are installed, the 

valve gags should not be used to keep the valve from opening. Verify that all 

foreign matter is removed and is excluded from re-entering the valve and its 

operator. Verify that the method of protection and or exclusion is in accordance 

with the manufacturer’s guidance. Remove caps from grease reliefs for actuators 

on motor-operated valves. 

c. Precautions to prevent valve damage during placement and mounting are used. 

d. Availability and utilization of specially trained personnel and special tools or 

equipment which conform to the manufacturer's instructions. 
Issue Date: 07/29/08 3 65001.07 

e. Correct drawings and work procedures are available to installers. Installation 

requirements, construction drawings, specifications, and work procedures are of 

the latest issue. 

f. Hold points are observed and quality inspections are properly conducted, in 

accordance with standards and procedures. 

g. Heavy loads, lifting, and rigging are in accordance with procedures and 

requirements. 

h. Preparation, installation, and inspection records meet quality program 

requirements. 

i. Field changes for the work being observed have been processed in accordance 

with the program requirements. 

j. Design features to prevent potential pressure locking and thermal binding of safetyrelated power-operated gate valves are satisfied as appropriate for the valve 

application and performance. 

k. Design requirements for environmental qualification of valves and their actuators 

are satisfied. For example, motors used on motor-operated valves must be 

appropriately designed with moisture relief T-drains as applicable to their 

environmental application. 

Guidance: This inspection should be performed as often as significant valve installation 

activities are taking place, but no less than every six months during the component 

installation construction period, which is expected to be about 30 months. 

While generic QA implementation such as receiving inspections, component storage, and 

records storage are inspected separately, the inspector should remain mindful of any 

problems that reflect on performance in these areas and report these to appropriate NRC 

personnel. The inspector should pay particular attention to the traceability of material and 

equipment to prevent the use of incorrect materials and parts. The inspector should 

ensure that required identification of the valve is maintained by vendor tags or other 

appropriate means, either on the valve or on records traceable to the valve, as required, 

and that required markings are on the valve. The valves shall conform, as required, to the 

procurement drawings and specifications and to the applicable codes. Some specific 

areas to inspect are as follows: 

a. Verify that the code plate required by the ASME Boiler and Pressure Vessel Code, 

Section III, Part NB 7000, on the pressurizer safety valves contains a pressure and 

temperature rating greater than or equal to the system set-pressure. Verify that the 

sum of the rated capacities recorded on the safety valve ASME Code plates 

exceeds the max generation rate plus a safety factor. 

b. During a walk-down, inspect the elevation of the Automatic Depressurization 
Issue Date: 07/29/08 4 65001.07 

System stage 4 valve discharge to verify that the minimum elevation of the bottom 

inside surface of the outlet conforms to the level indicated on the design drawings. 

Verify that the isometric drawings show the same elevation. Verify that the 

discharge of the stage 4 valves is directed into the steam generator compartments. 

c. Verify that the passive core cooling system's accumulator discharge check valves 

and core makeup tank discharge check valves are a different check valve type and 

are different from each other by reviewing the data on the vendor tags on the 

valves. While walking down the system, ensure that the valves are installed in the 

correct direction. 

Field observations can include independent measurement/observation or observation of 

licensee/contractor inspections of the valves. While all attributes do not need to be 

reviewed for each sample, the majority should be reviewed and samples/attributes 

reviewed should include all facets of installation activities. 

Records should document status of the installed valves and confirm that required 

inspections have been performed by qualified personnel. They should also confirm that all 

installation requirements and ITAAC requirements have been met. The records should be 

properly stored in accordance with quality assurance requirements. 

Typical problems which can occur in this area include, but are not limited to: 

a. Inadequate or unclear guidance for installers and inspectors. 

b. Use of inadequate/ uncalibrated tools for installation and measurement. 

c. Weak management/coordination resulting in skipped hold points or other errors in 

installation. 

d. Record retrieval/storage problems. 

 

e. Incorrect orientation of valve or actuator. For example, gate valves should have 

their valve stems in a vertical orientation because of the potential for excessive 

valve disc drag if stem is in a horizontal orientation. Motors and limit switch 

compartments for motor-operated valves should not be oriented below the actuator 

gearbox because of the potential for grease leakage into the motor or switch 

compartment. 

 

f. Improper switch settings for valve actuators that can lead the valve being incapable 

 of performing its safety function or damaging the valve. 
Issue Date: 07/29/08 5 65001.07 

Squib Valves

a. Verify squib valve to be installed is consistent with design requirements and 

specific application. 

b. Verify that squib actuator design has been qualified for its application. 

c. Verify that the squib valve orientation is proper for the flow direction. 

d. Verify that electrical wiring is consistent with design requirements, and continuity of 

actuation circuitry with control room is established. 

Guidance. 

Squib valves are designed to remain closed and leaktight until necessary to perform their 

safety function. Upon receiving an electrical signal to perform its safety function, the squib 

valve actuator initiates an explosive charge to open the valve and allow unrestricted fluid 

flow through pipeline. Squib valves cannot be reclosed and must be replaced following 

their opening. 

On a sample basis, the inspector should verify that the squib valve being installed satisfies 

the design specification for the particular application. There are different sizes and types of 

squib valves that could be used at an individual nuclear power plant. Each squib valve 

design must be qualified to perform the safety function for which the squib valve is 

intended. The inspector should verify that the squib valve being installed has been 

qualified for its intended application. The squib valve must be installed so that the flow 

path is not blocked by valve internal parts following actuation. The inspector should verify 

that the orientation of the squib valve is appropriate for the direction of fluid flow upon 

actuation. The squib valve must have proper electrical connections to ensure actuation 

when required to perform its safety function. The inspector should verify that the electrical 

connections are consistent with the design drawings and that continuity of the actuation 

circuitry is established with the control room. Alarm circuitry should also be in place in the 

event that continuity is lost. Proper operation of the squib valve position indication should 

be manually tested with confirmation from the control room. 

02.02 Component Welding. If welding is required for valve installation, select a sufficient 

sample of welds to review so that the inspection objectives will be demonstrated. Confirm 

the attributes listed in IP 65001.B “Welding,” have been met. 

Guidance. This inspection should be coordinated with IP 65001.B “Welding” and IMC 2504 

guidance. Sample size will be dependent on guidance from these procedures and the 

targeted ITAAC set. 

The inspector should determine what specific acceptance criteria are established and 

select those for observation that are best confirmed through observation. Others should be 

confirmed through record/data review. The inspector should try to focus on those testing 

activities related to the more safety significant valves. 
Issue Date: 07/29/08 6 65001.07 

The samples should include sufficient variety to assure the different welding processes and 

material combinations are observed for each sub-contractor, group or division performing 

ITAAC-related welding. This scope applies to both observations and record reviews. A 

variety of non-destructive examination processes should also be included in the inspection 

sample. 

Records should provide traceability to all aspects of the welding activity including weld 

procedures used, welders, material certifications, inspections performed and their results, 

inspectors, and qualification records for procedures and personnel. These records, 

including radiographs, should be retained and stored in accordance with QA requirements. 

If welding is required for valve installation (other than pipe welding), select one or two 

welds for a minimum of five of the valves for review. Through direct observations and/or 

record reviews, confirm the attributes listed in IP 65001.B “Welding,” as applicable, have 

been met. 

02.03 Post Installation Activities. Select a sufficient number of valves and components, to 

include all targeted valve ITAACs, but concentrating on the more significant ITAAC-related 

components previously selected for Section 02.01. Do not limit the sample to those 

previously selected. Through direct inspection, confirm these valves are properly protected 

and maintained considering the following attributes, as applicable: 

a. Licensee surveillance activities are being performed. 

b. Protection is provided from adverse conditions, such as: protection against 

adverse temperature, humidity, flooding, and foreign materials such as dirt, dust, 

bottles, cans, and general debris. 

c. Lubrication, rotation, and electrical resistance checks are being performed. Verify 

that proper lubricant is used for valve stems, gearboxes, and limit switches, as 

applicable. Stem lubrication procedure for motor-operated valves should provide 

for removal of old lubricant and replacement with new lubricant over the entire 

stem, including the stem nut area. 

d. Valve status records are maintained. 

e. Stamps, tags, markings, etc. are in use to prevent the oversight of required 

inspections, completion of tests, or acceptance. Methods of prevention of 

inadvertent operation are maintained. 

f. Periodic continuity checks for the squib valve initiator, actuator internals 

inspections, and valve position indication are performed. Valve manufacturer 

maintenance recommendations are being implemented. Squib valve initiator and 

booster assembly replacement program is established to ensure that qualified life 

for explosive charge is maintained with removal and installation of replacement 

assemblies at proper time intervals. 

Guidance: Post-installation activities should be observed often enough throughout the 

construction period to support a conclusion that the valves are properly serviced and 
Issue Date: 07/29/08 7 65001.07 

managed until final turnover from construction management to operations management. 

The actuators for squib valves include explosive charges that have a limited qualified life. 

The squib valve initiator and booster assembly must be periodically replaced to ensure that 

the explosive charge will be available to perform its safety function to open the valve upon 

initiation of a safety signal. The inspector should verify that the squib valve initiator and 

booster assembly replacement program is being implemented to ensure that the 

assemblies remain capable of performing their safety functions. The inspector should 

verify that the procurement program maintains an adequate supply of squib valve initiator 

and booster assemblies for the replacement program. 

02.04 Testing and Verification. Select a sufficient number of valve ITAAC-related testing 

and verification activities to assure testing and verification are conducted in accordance 

with established procedures and acceptance criteria have been met. 

Inspection requirements include: 

a. Verify proper test and verification activity and frequency in accordance with postinstallation, pre-service, or inservice test program, as applicable. 

b. Verify use of appropriately signed and dated test and verification procedures for 

valve testing and verification. 

c. Verify calibration of test equipment. 

d. Verify qualification of test and other personnel participating in testing and 

verification activities. 

e. Confirm safety of personnel and equipment during test and verification activities. 

f. Verify that preconditioning of valve performance is not specifically or inadvertently 

occurring in preparation for the test and verification activity. 

g. Review licensee evaluation of test data and verification results in comparison to 

acceptance criteria. 

h. Review corrective action in response to test data and verification results that do not 

satisfy acceptance criteria. 

Guidance: This inspection should be coordinated with IP 65001.C “Construction Testing,” 

IP 65001.D “Operational Testing’” and IMC 2504 guidance. Sample size will be dependent 

on guidance from these procedures and the targeted ITAAC set. 

The inspector should determine what specific acceptance criteria are established and 

select those for observation that are best confirmed through direct observation. Others 

should be confirmed through record/data review. 

A sample of some of the valves to be reviewed is as follows: 
Issue Date: 07/29/08 8 65001.07 

a. The pressurizer safety valves provide over-pressure protection in accordance with 

Section III of the ASME Boiler & Pressure Vessel Code. Verify that testing and 

analysis was conducted in accordance with the ASME Code, Section III, to verify 

the valve set pressure. Review the paperwork that came from the vendor and was 

shipped with the valves. Verify that a set pressure test was conducted that verified 

that the set pressure was correctly set. 

b. Exercise testing of the check valves with active safety function will be performed 

under pre-operational test pressure, temperature, and fluid flow conditions. Each 

check valve shall change positions as required by specifications and procedures. 

c. Licensees must perform post-installation testing, preservice testing, and inservice 

testing for the safety-related power-operated valves. Post-installation tests confirm 

that the power-operated valve is operating consistent with the functional design and 

qualification for the valve and its actuator. Preservice tests establish baseline 

reference performance of the valve and its actuator. Inservice tests provide for the 

assessment of operational readiness of the power-operated valve to perform its 

safety function. The licensee must demonstrate that the power-operated valve is 

capable of performing its safety function under design-basis conditions through the 

functional design and qualification program, and flow tests following installation of 

the power-operated valve. IP73756.52 provides inspection guidance for evaluating 

the functional design, qualification, and inservice testing program for pumps, 

valves, and dynamic restraints. In addition, testing of the as-installed motor 

operated valves will be performed under pre-operational flow, differential pressure, 

and temperatures conditions. Verify that a test report exists which concludes that 

each valve changes position under design conditions. After loss of power, the 

remotely operated valves assume the indicated loss of motive power position. 

Verify that testing of these installed valves is performed under the conditions of 

loss of motive power. 

d. The automatic depressurization valves perform an active safety-related function to 

change position. Tests will be performed that demonstrate the valve to operate 

under design conditions. Verify that a test report exists which concludes that each 

motor operated valve changes position under design conditions. 

e. Qualification reports should be available for each squib valve design to be used at 

the nuclear power plant. The inspector should review those qualification reports 

and verify that conditions and recommendations of those reports have been 

addressed by the licensee. If squib valves cannot be tested in situ because of 

potential damage to the valve or piping, the licensee should implement a laboratory 

program to test the squib valve initiator and booster assembly following its removal 

to confirm that the replacement frequency is appropriate. The licensee should 

establish a corrective action process to expand the scope of removal of squib valve 

initiator and booster assemblies if a tested assembly fails to operate properly. 

Tests of squib valves will be performed that demonstrate the capability of the valve 

to operate under its design conditions. Testing and verification of squib valves 

should include initiator continuity checks, and removal of actuator internal 
Issue Date: 07/29/08 9 65001.07 

subassemblies for visual inspection and manual confirmation of smooth operation. 

The squib valve position indication should be manually tested with confirmation 

from the control room. Verify that a test report exists which concludes that each 

squib valve changes position under design conditions. 

f. The Reactor Coolant System provides automatic depressurization during design 

basis events. Tests and analyses should be performed to determine the effective 

flow area through each stage 1, 2, 3 ADS valves. Verify a report exists which 

concludes that the effective flow area through each stage ADS valves are greater 

than or equal to the minimum area specified in the design documents. 

02.05 Problem Identification and Resolution. The inspector should confirm that problems 

identified during the inspection are entered into the licensee/constructor corrective action 

program in accordance with program requirements. The inspector may review licensee 

actions to address similar or related problems that were previously identified, in order to 

check the extent of condition and confirm the effectiveness of the licensee=s corrective 

measures. 

Guidance: This inspection is to assure that problems are entered into the applicable 

process to assure corrective actions appropriate to the circumstances are developed and 

prioritized. Inspections of Quality Assurance Program implementation, effectiveness of 

Problem Identification and Resolution, and Self-Assessment will be performed under the 

IMC 2504 process. 

65001.07-03 RESOURCE ESTIMATE 

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

1040 hours of direct inspection effort over the course of plant construction. 

65001.07-04 REFERENCES 

NUREG-0800, Standard Review Plan, Section 17.5, "Quality Assurance Program 

Description - Design Certification, Early Site Permit and New License Applications," 

ASME BPVC Section III, NQA-1 "Quality Assurance Requirements for Nuclear Facility 

Operations". 

10 CFR 50, Appendix B, Criteria III, Design Control, Criteria IV, Procurement Document 

Control, and XI, Test Control. 

ASME Boiler and Pressure Vessel Code, Section III, Parts NB, NC, and ND. 
Issue Date: 07/29/08 10 65001.07 

ASME Code for Operation and Maintenance of Nuclear Power Plants. 

Attachment 1: Revision History for IP 65001.07 

 
Issue Date: 07/29/08 Att1-1 

Attachment 1 

Revision History For IP 65001.07 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training CompleDate 

N/A 07/29/08 

CN 08-021 

Researched commitments for 4 years and found none. Initial issuance to support ITAAC related inspections under 10CFR52. 

N/A N/A