Issue Date: 08/19/08 1 65001.03

ATTACHMENT 65001.03 

INSPECTION OF ITAAC-RELATED INSTALLATION OF PIPING 

 

PROGRAM APPLICABILITY: 2503 

65001.03-01 INSPECTION OBJECTIVES 

01.01 To determine whether work activities related to piping systems met all requirements 

for the purchase, receipt inspection, storage, handling, installation, inspection, and testing 

in accordance with design specifications, approved drawings and procedures, Final Safety 

Analysis Report (FSAR), and applicable codes and standards. 

01.02 To verify that the appropriate records support the receipt, storage, installation, 

examination, testing, and material traceability of piping systems. 

01.03 To determine if the inspections, tests, and analysis completed for ITAAC-related 

piping met the acceptance criteria for those ITAAC. 

01.04 To evaluate whether the appropriate quality assurance (QA) program requirements 

are implemented for the installation and testing of all piping activities, and to ensure any 

identified problems are entered into the corrective action process and resolved. 

65001.03-02 INSPECTION REQUIREMENTS AND GUIDANCE 

This inspection procedure (IP) shall be implemented at the construction site where 

ITAAC-related piping is finally installed and any location where such piping is first 

assembled into piping modules prior to installation. After the initial inspection at a given 

location, any subsequent inspections will be scheduled as necessary to complete the 

overall sample for the review of ITAAC-related piping. Note that some inspection 

requirements listed in this IP are not required to be performed each time it is implemented. 

 The focus of this IP is to verify that piping ITAAC have been met, and piping systems 

important to safety have been installed and tested in accordance with the provisions of 

design specifications, drawings, and FSAR. Installation of piping supports and mechanical 

equipment, such as, pumps and valves are not covered by this procedure. 

02.01 Purchase and Receipt of Materials: Select at least seven purchase orders for 

materials, such as, welding consumables, piping, including pre-fabricated spool pieces, 

and fittings, then verify the following. 

a. The selected materials and their purchase orders met design requirements and 

verify conformance with design requirements. 

b. The documentation of site receipt inspections for the selected materials conforms 

to their purchase orders. 
Issue Date: 08/19/08 2 65001.03

Guidance: The sample should be a representative cross section of materials and vendors 

and include several different components as well as welding consumables. The sample 

should be of various types materials and sizes of piping, e.g., small bore - 2 inch diameter 

and under and large bore - greater than 2 inch diameter. When comparing the materials 

purchased against their purchase orders, direct observation of the actual materials in the 

field is preferred even though the review of receipt inspection reports is permissible. 

Generally, receipt inspections include the following inspection items: 

• The selected materials conform with their purchase specifications, e.g., all piping is 

the correct size, material type, thickness, seamless or with seams, the specified 

length and quantity, and with the ends of the piping suitable for welding. 

• Documented involvement of engineering staff in the procurement and product 

acceptance process to identify and prevent potential use of fraudulent materials. 

 

• Quality documentation is the type required by the purchase order (e.g., Certified 

Material Test Report (CMTR) or Certificate of Compliance). 

• Any chemical and physical test results, including heat treatment, as applicable, for 

a CMTR comply with the material specification required by the design documents. 

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

• There is no evidence of damage to the materials, e.g., excessive corrosion, 

gouges, chemical damage, etc. 

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

• The necessity of surface protection, closures, and packaging for the materials is 

stated in purchase order. 

• Receipt inspection reports were generated and conform to the licensee=s 

procedures. 

• Nonconformances affecting the integrity of the materials were properly addressed 

in accordance with the licensee=s procedures. 

02.02 Storage and Handling: Select at least five types of materials from the purchase 

orders in the sample selected in 02.01, then perform the following: 

a. Verify that the materials such as, welding consumables, piping, including 

pre-fabricated spool pieces, and fittings are being properly stored and handled in 

accordance with approved procedures. 

b. For the selected materials, verify that their storage procedures comply with the 

contractor=s (vendors) storage requirements. 

Guidance: Welding consumables, such as, coated electrodes, bare weld rod and spools, 
Issue Date: 08/19/08 3 65001.03

and inserts require special handling and storage considerations because these materials 

are melted during the welding process and become part of the welded joint. Welding 

material storage procedures must contain requirements for control of contaminants like dirt, 

grease, and moisture. Contaminants can cause weld defects, such as, lack of fusion, 

porosity, and cracking due to hydrogen embrittlement. When determining whether the 

selected materials are stored correctly, the storage conditions of some of the materials 

should be directly observed in the field. 

Piping and fittings are often stored outside, exposed to the elements in lay-down areas at 

the construction site. As such, carbon steel components may develop a light coating of 

oxidation (rust). This condition is generally acceptable; however surfaces such as 

machined or ground bevels must have the rust completely removed prior to the welding 

operation. All carbon steel components, including chains, should be kept from contact with 

stainless steel components to prevent surface rusting of the stainless steel components. 

Only tape containing low levels of halogens and chlorides should be used on stainless 

steel to help avoid cracking. 

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

stored. 

• Proper storage classification of materials. 

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

• Soundness of dunnage or packing material. 

• Soundness and correct placement of such things as end caps for piping and 

protective coverings for weld preparation areas. 

• Soundness and correct placement of weather protection in the form of canvas or 

plastic coverings. 

• Protective storage measures to prevent salt water damage (chloride 

contamination), e.g., near oceans. 

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

• Correct and readily visible material identification, in accordance with the purchase 

order, and with no damage incurred by handling and/or environment. 

• Controls against the use of fire retardants near stainless steel piping to prevent any 

exposure to excessive halogens or chlorides. 

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

02.03 Installation and Welding: Select at least ten in-process welds, then verify that 

those welds and the installation of associated piping components are accomplished in 

accordance with approved drawings, qualified procedures, construction specifications, and 
Issue Date: 08/19/08 4 65001.03

applicable codes and standards by qualified welders as specified in the design documents 

by verifying the following as applicable. 

a. The piping is being installed at the proper location in the plant, at the slope 

specified, and with the proper clearances from other piping and obstructions in 

accordance with approved drawings. 

b. Welding procedures are in accordance with the codes and standards specified in 

the design documents (See guidance for clarification of when this should be 

performed). 

c. Welder(s) are qualified for the piping material, electrode/process, and their 

positions. 

d. Welding procedures, detailed drawings and instructions, if applicable, and weld 

data sheets are at the work station or readily available. 

e. Surfaces to be welded have been prepared, cleaned, and inspected in accordance 

with applicable procedures. 

 

f. Weld joint geometry is as specified in the drawings. 

g. Examinations, e.g., by visual (VT) or dye penetrant (PT), of the surfaces to be 

welded have been performed, and the surfaces were found acceptable in 

accordance with the specified codes. 

h. Components to be welded are assembled at specified gap and alignment within the 

limits allowed by the drawings or codes. 

i. Piping material and welding consumables are of the specified type and grade and 

are uniquely identified (such as by heat number) preferably by markings on the 

material or at least in the traveler or accompanying documentation. 

j. Tack welds and temporary attachments, such as, bridging bars or fit-up clips have 

been performed by qualified welders, in accordance with qualified welding 

procedure specification (WPS). 

k. Gas purging, if specified, is used in accordance with the applicable procedure and 

is provided to shield the welding operation from adverse environmental conditions. 

l. Preheat and interpass temperature, if specified, is maintained in accordance with 

applicable procedure requirements by observing welder=s instrumentation. 

m. Welding equipment, including power cables and gas lines, are in good condition, 

and ammeters and voltmeters used for automatic welding have been calibrated in 

accordance with applicable procedure requirements. 

n. Procedures specify appropriate holding and baking temperatures and out-of-oven 

exposure time for each class of coated electrode. 
Issue Date: 08/19/08 5 65001.03

o. Welding consumable cleanliness is maintained, and electrode moisture pickup is 

limited in accordance with procedures. 

p. Control and identification of welds rods after being issued to the welder are 

maintained in accordance with procedures. 

q. Rod stubs are controlled and disposed of in accordance with procedures. 

r. Interpass cleaning, grinding (especially starts and stops) and backgouging, if 

applicable, are conducted in accordance with the applicable procedures. 

s. Temporary attachments, arc strikes and weld splatter are removed and inspected 

in accordance with specified procedures. 

t. A welder=s identity is recorded by stamping the weld or by other means, such as, 

documentation. 

u. Repairs performed after the weld is completed and found acceptable by visual 

inspection or other NDE method shall be accomplished in accordance with 

approved repair procedures and shall be documented. 

v. Any repairs or modifications to ASME Code-stamped components shall be properly 

documented in the applicable Code data report as required by ASME Sections III 

and XI. 

Guidance: The sample of welds should represent various stages of welds in progress 

(e.g., weld joint preparation, fit-up, root pass, final pass), types of welding processes (e.g., 

SMAW, GTAW), pipe sizes, and material types (generally those materials designated in 

the applicable edition of the ASME Boiler and Pressure Vessel Code, Section IX as P1, P5, 

and P8) to the extent possible. Consideration should also be given to welds that, because 

of their physical location or other reason, are difficult to accomplish. The total weld sample 

after the inspections for this IP are completed should include at least one weld from each 

major risk component or its associated large bore piping, such as, reactor vessel nozzles, 

steam generator, pressurizer, etc. 

The welding process is generally controlled by a traveler which will specify the steps in 

completing the weldment, materials to be used, and will also document QA inspections and 

step completion. Material traceability should be maintained since it has been a significant 

issue at some construction sites in the past. Cold springing of pipe should be avoided. 

Any observed cold spring of piping during installation must be in accordance with 

allowance provided in the approved procedures. The interpass temperature for welding 

austenitic stainless steels and high nickel alloys should not exceed 350o

 F. Weld material 

removal, such as, by light grinding and rewelding is generally permissible during the 

welding process. Any chain, cable, or brace should not apply anything other than a vertical 

load on any component of a piping assembly ready for welding. 

"Qualified welders" means those employees who have achieved suitable proficiency to do 

specific welds, to use certain welding processes, and to employ certain welding techniques 
Issue Date: 08/19/08 6 65001.03

based on their training and/or previous experience, and who understand the welding 

procedures, drawings, and specifications necessary for their work. The licensee must have 

qualification records that indicate the welder=s experience and education. 

If welding records were reviewed under IP 65001.B, then do not duplicate that review here 

to determine if the procedures meet the applicable codes and standards. 

02.04 Post Weld Heat Treatment. Select three welds requiring post weld heat treatment 

(PWHT) over the course of the piping installation phase of construction, then verify that 

PWHT is performed in accordance with the design specifications and applicable code 

requirements. The inspector should also verify that when Charpy impact qualification is 

required for welds requiring PWHT, that both the base metal and the weld material were 

properly qualified in accordance with the applicable code. 

Guidance. The need for PWHT is generally determined by the material type and thickness. 

 For example, carbon steel, low alloy piping such as ASME SA106 typically requires PWHT 

when the thickness is 1-1/2" or greater when ASME is the applicable code however, PWHT 

is required when the thickness is greater than 3/4" when B31.1 is the applicable code. 

The PWHT procedure shall be in accordance with the applicable code and specify 

essential parameters such as number and placement of thermocouples, heat up and cool 

down rate, and soak time and temperature. The PWHT documentation should support that 

these variables were controlled throughout the process. Typically, chart recorders are 

used to demonstrate that the heat treat operation was successfully completed. 

Governing codes generally require that final NDE of the weld joint be performed after 

PWHT. Direct observation of PWHT is preferred; however, since most welds do not 

require PWHT, a review of records is acceptable. 

02.05 Pressure Testing. Observe the hydrostatic tests (hydros) of piping installations 

during the construction phase, then verify that the hydros are in accordance with the 

applicable codes ,as specified, in the design specifications. 

Guidance. The sample size selected for this inspection requirement should be 

representative of the total sample of hydros associated with the ITAAC selected for review. 

 The inspection of the hydrostatic tests should be in accordance with IP 65001.C. 

02.06 Nondestructive Examination (NDE). Observe three welds with NDE in progress 

and verify that the final NDE has been performed and found acceptable, in accordance 

with the applicable codes by verifying the following as applicable. 

a. The NDE procedure is in accordance with the applicable code as specified in the 

design specification. 

b. The NDE is performed in strict accordance with the procedure by examiners that 

are qualified for that NDE method. 

c. The radiographs of the three welds indicate the welds were acceptable per the 

applicable code. 
Issue Date: 08/19/08 7 65001.03

d. The temperature of the weld surface is within that qualified for the procedure. 

e. For liquid penetrant testing (PT), adequate dwell time was allowed for penetrant 

application. 

f. For magnetic particle testing (MT): 

1. Yoke strength was demonstrated at the intervals specified in the procedure. 

2. The spacing and current for prods are in accordance with the procedure. 

3. Arc marks caused by prods are removed. 

g. For ultrasonic testing (UT), the examiner=s qualifications, the UT equipment used 

complies with the procedure, and all UT process variables were strictly controlled. 

h. For radiography testing (RT): 

1. The type of source, source strength, film type, source to film distance, use of 

intensifying screens, type and thickness of material being radiographed and 

exposure times are in accordance with the procedure. 

2. The image quality indicators are the correct type and thickness. 

3. The required sensitivity and radiograph density meet the applicable code 

requirement. 

4. Applicable radiological safety requirements are met during testing. 

 

Guidance. The sample should include the NDE methods used for piping such as PT, MT, 

UT, and RT. If NDE is not being performed during the inspection, then a record review 

would be acceptable of the welds selected. For RT, refer to standards of American Society 

for Testing and Materials (ASTM) E94-04 and E1032-06. 

Typical issues with the performance of NDE are the following: 

• Inadequate cleaning of the surface for PT and MT. False indications may result if 

surface contaminants are present. 

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

• The sensitivity of UT to equipment condition and examiner=s performance and 

interpretation of results. 

02.07 Review of Records. Select three installed piping sections, then verify that their 

documentation packages are thorough, accurate, and support installation in accordance 

with the provisions of the design specification and applicable codes. 
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Guidance. The final documentation package for piping installation including welds shall 

contain the necessary information and references to support the installation met all design, 

regulatory, and code requirements. The following are examples of where the inspector can 

focus this review of records. 

• Identification of materials, such as, piping, fittings, and welding consumables by, for 

example, heat number to assess material composition, physical characteristics, 

and traceability for their receipt, storage, installation, and testing. 

• Welding and NDE procedures and welders and examiners are identified for each 

weld. 

• NDE results indicate that all acceptance criteria were met. 

• As-built drawings are available and any deviations from original design are 

reconciled with the design documents (e.g., design report). 

• Code data reports are complete and signed off by the assigned Authorized Nuclear 

Inspector. 

• The work or traveler packages conform with the relevant work procedures and 

other requirements. 

02.08 Problem Identification and Resolution. Select 1- 2 problems identified during the 

inspection and then confirm that the problems are entered into the licensee/constructor 

corrective action program in accordance with program requirements. The inspector may 

review licensee actions to address similar or related problems that were previously 

identified, in order to check the extent of condition and confirm the effectiveness of the 

licensee=s corrective measures. 

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

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

prioritized. Inspections of Quality Assurance Program implementation, effectiveness of 

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

MC 2504 process. 

65001.03-03 RESOURCE ESTIMATE 

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

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

65001.03-04 REFERENCES 

American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section III 

(applicable edition) 
Issue Date: 08/19/08 9 65001.03

American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section II 

(applicable edition) 

American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section V 

(applicable edition) 

American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section 

IX (applicable edition) 

American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section 

XI (applicable edition) 

Regulatory Guide 1.38, "Quality Assurance Requirements for Packaging, Shipping, 

Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" 

Regulatory Guide 1.58, "Qualification of Nuclear Power Plant Inspection, Examination, 

and Testing Personnel" 

ASTM E94-04, AStandard Guide for Radiographic Examination@

ASTM E1032-06, AStandard Test Method for Radiographic Examination of Weldments@

ANSI N45.2.2, "Packaging, Shipping, Receiving, Storage, and Handling of Items for 

Nuclear Power Plants" 

ANSI N45.2.6, "Qualifications for Inspection, Examination and Testing Personnel" 

END 

Attachment 1: Revision History for IP 65001.03 
Issue Date: 08/19/08 Att1-1 

Attachment 1 

Revision History for IP 65001.03 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CRA

N/A 08/19/08 

CN 08-024 

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

N/A N/A N