Issue Date 08/19/08 1 65001.11

ATTACHMENT 65001.11 

CONSTRUCTION INSPECTION PROGRAM 

INSPECTION OF ITAAC RELATED CONTAINMENT INTEGRITY AND 

CONTAINMENT PENETRATIONS 

65001.11-01 INSPECTION OBJECTIVES 

01.01 Verify that materials such as welding consumables, plate material, including prefabricated plate sections, and major prefabricated containment penetration assemblies 

were purchased in accordance with the approved design. . 

01.02 Verify that materials such as welding consumables, plate material, and 

prefabricated containment penetrations are being properly stored and handled in 

accordance with approved procedures. 

01.03 Verify that the installation and welding of plate material for the containment and 

containment penetration assemblies is accomplished in accordance with approved 

drawings, qualified procedures, and applicable codes and standards by qualified welders 

as specified in the design documents. 

01.04 Verify that post-weld heat treatment (PWHT) is performed in accordance with the 

design specifications and applicable code requirements. 

01.05 Verify that final NDE has been performed and found acceptable, in accordance with 

the applicable code. 

01.06 For PWRs, upon completion of the containment liner and installation of all 

containment penetrations and major offsite manufactured assemblies, verify and monitor 

the process for erecting reinforcing bars and the placing of concrete. 

01.07 Verify that major offsite fabricated assemblies have been fabricated and installed in 

accordance with the manufacturer=s instructions and design engineering specifications. 

01.08 Verify that all electrical and I&C penetrations are installed per their design 

specifications. 

01.09 Verify that the exterior of the containment is treated in accordance with design 

engineering specifications. 

01.10 Verify that the testing of the containment and the installed containment 

penetrations have been successfully completed to fulfill the requirements as specified in 

the design specification. 

01.11 Verify that problems identified during the inspection are entered into the 

licensee/constructor corrective action program in accordance with program requirements. 
Issue Date 08/19/08 2 65001.11

65001.11-02 INSPECTION REQUIREMENTS AND GUIDANCE 

This inspection procedure shall be performed prior to and during containment construction 

and containment penetration installation and during final testing of the completed 

containment including certification testing. 

02.01 Verify that materials such as welding consumables, plate material, including prefabricated plate sections, and major prefabricated containment penetration assemblies 

were purchased in accordance with the approved design. Review a sample of Purchase 

Orders for these materials and verify conformance with design requirements and 

purchasing specifications. The inspector should inspect Purchase Orders for containment 

plate material and Purchase Orders for containment penetration assemblies and major 

prefabricated assemblies. For those items selected, review the documentation of site 

receipt inspections to ensure conformance with the Purchase Order. 

Guidance. For containment plate material select the sample from a representative cross 

section of vendors and include plate material and any prefabricated plate assemblies. For 

containment penetrations the sample selection should include various sizes of electrical, 

I&C and mechanical penetrations from different vendors. 

In the case of major prefabricated assemblies (containment opening hatch and personnel 

air lock) the inspector should verify the Purchase Order for each assembly for conformance 

with purchase order and design engineering specifications. 

The Purchase orders should explicitly state the type of quality documentation required 

(e.g., Certified Material Test Report (CMTR) or Certificate of Compliance) in accordance 

with the design requirements. If a CMTR was required, the inspector should verify that 

chemical and physical test results, including heat treatment as applicable, comply with the 

material specification required by the design documents. Typical attributes included in 

receipt inspections are: 

$ Plate material or containment penetration assemblies are in conformance with 

purchase specification 

$ Marking and identification 

$ Evidence of damage 

$ Cleanliness at time of receipt 

$ Surface protection, closures and packaging and storage requirements 

$ Disposition of non-conforming items 

02.02 Verify that materials such as welding consumables, plate material, and 

prefabricated containment penetrations are being properly stored and handled in 

accordance with approved procedures. From the sample selected in 02.01, verify that 

onsite storage is adequate and in accordance with applicable procedures. 
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Guidance. Welding consumables such as coated electrodes, bare weld rod and spools, 

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 environmental cleanliness and 

moisture control as contaminants like dirt, grease, and moisture can cause weld defects 

such as lack of fusion, porosity, and cracking due to hydrogen embrittlement. 

Plate material, prefabricated containment penetrations and penetration materials and 

valves are often stored outside, exposed to the elements in lay-down areas located around 

the construction site. The surface to be welded should be reasonably smooth, and free of 

rust, scale, oil, grease, and other deleterious foreign materials, including moisture. 

Stainless steel components should be stored separately from carbon steel components as 

contact with carbon steel can contaminate the stainless steel and cause surface rust to 

appear. Likewise, contact with carbon steel chains should be avoided when rigging to lift 

stainless components. Any tape used on stainless steel material and components should 

be certified as containing low halogen and chlorides as these are known to promote 

cracking. 

Typical considerations for inspecting adequacy of storage areas are as follows: 

$ Improper storage classification. 

$ Determination of the status of protective mechanisms at the time of site receipt and 

initial storage. 

$ Adequacy of dunnage for plate material, containment penetration assembly 

components, and major prefabricated assemblies during storage. 

$ Continued adequacy of end caps for containment penetration assemblies 

protective coverings for weld preparation areas. 

$ Weather protection in the form of canvas or plastic coverings. (In most 

deficiencies, the original protective covering was adequate, but inattention to 

damage and normal "wear and tear" led to substandard or unacceptable protective 

provisions.) 

$ Sites near salt water should receive special attention to assure that protective 

storage measures are considerate of salt water damage (Chloride Contamination). 

$ Storage areas located on sandy soil or near sandy beaches require special 

attention to avoid the entry of wind-driven sand particles into plate material and 

containment penetration assemblies and assembly components. 

$ Inadequate or illegible material identification (damage by handling and/or 

environment). 

$ Storage of stainless steel pipe on dunnage treated with fire retardants may expose 

the piping to excessive halogens or chlorides. 
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$ Fire-retardant coatings applied to structural steel may have high halogen or 

chloride contents. Adjacent stainless steel materials and components should be 

protected from these compounds. 

02.03 Verify that the installation and welding of plate material for the containment and 

containment penetration assemblies is accomplished in accordance with approved 

drawings, qualified procedures, and applicable codes and standards by qualified welders 

as specified in the design documents. Select several in-process welds for detailed review. 

 Further guidance on welding can be found in IP 65001.B. 

Guidance. The combination of welds selected should represent various stages of the 

welding process (e.g., weld joint preparation, fit-up, root pass, final pass), various weld 

processes (e.g., SMAW, GTAW, GMAW), and various material types and pipe size 

(generally those materials designated in the applicable edition of the ASME Boiler and 

Pressure Vessel Code, Section IX). Emphasis should also be given to welds that, because 

of their physical location are difficult to accomplish. 

The inspector should review the applicable welding procedures in detail to verify that the 

procedures are properly qualified in accordance with the codes and standards specified in 

the design documents. For those welds selected, verify that the welder(s) is properly 

qualified for the piping material, electrode / process, and position and that the welder=s 

identity is recorded via stamping the weld or by other means such as documentation. 

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 QC inspections and 

step completion. Verify that welding procedures, detailed drawings and instructions if 

applicable, and weld data sheets are at the work station or readily available. Material 

traceability has been a significant issue at some construction sites in the past. The 

inspector should verify that the containment plate material and the containment penetration 

assemblies and/or materials and welding consumables are of the specified type and grade 

and are adequately and uniquely identified (such as by heat number) in the traveler or 

accompanying documentation. 

The inspector should verify the following: 

$ The containment liner plate sections are being installed at the proper location in the 

plant in accordance with approved drawings. If a plate joint fit-up is specified, verify 

the installation is within in the tolerance provided in the specification. Inspection 

should include verification that plate-to-plate gap and overall structure requirements 

are in compliance with drawing and code requirements. 

$ Weld joint geometry is as specified in the drawings and surfaces to be welded have 

been prepared, cleaned, and inspected in accordance with applicable procedures. 

$ NDE such as visual inspection, magnetic particle (MT) or dye penetrant (PT) 

examination of the surfaces to be welded has been performed and found 

acceptable in accordance with the specified code. 

$ Components to be welded are assembled and held in place within specified gap 
Issue Date 08/19/08 5 65001.11

and alignment tolerances and that alignment is within limits allowed by the 

drawings or code. Cold springing of plate sections should be avoided. Any 

observed cold spring of containment plate sections during installation must be in 

accordance with allowance provided in the approved procedures, or by engineering 

evaluation and analysis. 

$ Tack welds and temporary attachments such as bridging bars or fit-up clips have 

been performed by qualified welders, in accordance with qualified WPS. 

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

that protection is provided to shield the welding operation from adverse 

environmental conditions. 

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

applicable procedure requirements. The interpass temperature for welding 

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

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

and that ammeters and voltmeters used for automatic welding have been 

calibrated in accordance with applicable procedure requirements. 

$ Procedures specify appropriate holding and baking temperatures and out-of-oven 

exposure time for each class of coated electrode. Procedures for maintaining 

welding consumable cleanliness and limiting electrode moisture pickup are strictly 

adhered to. 

$ Procedures for weld rod control maintain identification after the welding materials 

are issued to the welder and are strictly adhered to. Rod stubs are controlled and 

disposed of in accordance with the procedures. 

 

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

applicable are conducted in accordance with the applicable procedure. 

$ Temporary attachments, arc strikes and weld splatter are removed and inspected 

in accordance with specified procedures. 

$ Minor weld material removal such as by light grinding and rewelding is generally 

permissible during the welding process. Repairs performed after the weld is 

completed and as a result of final visual or other NDE method finding the weld 

unacceptable shall be accomplished in accordance with approved repair 

procedures and shall be documented. Any repairs or modifications to ASME Codestamped components shall be properly documented in the applicable Code data 

report as required by ASME Sections III and XI. 

$ The welding process preheat and interpass temperatures do not damage 

degradable materials (e.g., cable or instrumentation lines) inside containment 

penetrations. 

02.04 Verify that post-weld heat treatment (PWHT) is performed in accordance with the 
Issue Date 08/19/08 6 65001.11

design specifications and applicable code requirements. Select several welds requiring 

post-weld heat treatment over the course of the containment plate installation and the 

containment penetration installation phase of construction. Direct observation is preferred 

however, since most welds do not require post weld heat treatment, a review of records is 

acceptable. 

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. 

Often, Charpy impact qualification is required for weldments requiring PWHT. It is 

essential that the inspector verify that both the base metal and weld material were properly 

qualified in accordance with the applicable code for PWHT. Governing codes generally 

require that final NDE of the weld joint be performed after PWHT. 

02.05 Verify that final NDE has been performed and found acceptable, in accordance with 

the applicable code. Observe NDE in progress on several welds when this procedure is 

performed. Examiners must be qualified for the method and procedure that they are 

performing. If NDE is not being performed during the inspection, perform a record review. 

In addition, review the radiographs of three welds. 

Guidance. The inspector should verify the following: 

• The sample should contain a range of NDE methods such as liquid penetrant (PT), 

magnetic particle (MT), ultrasonic (UT), and radiography (RT). 

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

design specification. 

• The NDE is performed in strict accordance with the procedure. Typical issues with 

NDE performance are: 

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

surface contaminants are present. Verify adequate dwell time for penetrant 

application and that the temperature of the weld surface is within that qualified for 

the procedure. 

• Inadequate magnetic field due to a defective yoke. Yoke strength should be 

demonstrated at intervals specified in the procedure. If prods are utilized, verify 

that the spacing and current are in accordance with the procedure. Any arc marks 

caused by prods must be removed. 
Issue Date 08/19/08 7 65001.11

• UT is the method most sensitive to examiner performance and interpretation. The 

inspector should verify that those doing UT are properly qualified by training, 

experience and test demonstration; and the UT equipment complies with the 

procedure and that all variables are strictly controlled. 

• For RT, verify that isotope source strength, film type, source to film distance, and 

exposure times are in accordance with the procedure. Verify that image quality 

indicators are the correct type and thickness and that the required sensitivity and 

radiograph density meet the applicable code requirement. 

02.06 For PWRs, upon completion of the containment liner and installation of all 

containment penetrations and major offsite manufactured assemblies, verify and monitor 

the process for erecting reinforcing bars and the placing of concrete. Ensure that control of 

construction debris and liquids is in effect. Ensure that the owner has control of foreign 

materials (wood, rags, liquids, etc.) which could cause corrosion of the steel liner. Prior to 

placing concrete ensure that the containment liner is coated on the exterior surface in 

accordance with the design specifications. The inspector should verify that any exterior 

coatings or treatments are applied if required in accordance with the owner=s guidance and 

engineering design specifications. 

02.07 Ensure that major offsite fabricated assemblies, such as personnel airlock 

assemblies and equipment hatch assemblies, have been fabricated and installed in 

accordance with the manufacturer=s instructions and design engineering specifications. 

After installation and prior to testing of these assemblies, ensure that the assembly has 

been protected from damage and is maintained in operable condition. 

02.08 Ensure that all electrical and I&C penetrations are installed per their specifications, 

reference Inspection Procedures 65001.8, 65001.9 and 65001.10. Ensure that installed 

electrical and I&C penetrations have no visible damage and are ready to function in 

accordance with manufacturer=s instructions and design engineering specifications. 

02.09 Ensure that the exterior of the containment is treated in accordance with design 

engineering specifications. Ensure that any required coatings and preservatives on all 

containment surfaces are applied in accordance with design specifications and 

manufacturer=s instructions. 

02.10 Upon completion of containment construction, including all penetrations and major 

offsite fabricated assemblies, verify that the testing of the containment and the installed 

containment penetrations have been successfully completed to fulfill the requirements of 

10 CFR 50, Appendix J Type A, Type B and Type C testing requirements and as specified 

in the design specification. The inspector should observe the performance of the Type A , 

B, and C tests, if used, during the construction and testing phases. These reviews should 

examine the final test results and the technical resolution of any observed or documented 

anomalies. 

Guidance. The inspector should verify the following: 

• That the local leakage testing procedure contains provisions which comply with the 

governing code (e.g., temperature requirements, test pressure, hold time, and 
Issue Date 08/19/08 8 65001.11

inspection methods). 

• Pressure gages, recorders, and other test equipment are within the pressure range 

specified by the code and that calibration is current. 

02.11 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 should also confirm that 

licensee construction and testing procedures contain appropriate criteria defining what 

constitutes a non-conforming condition and what requires documentation in the corrective 

action process. 

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. Ensure that the licensee=s program procedures 

address the extent of condition for similar problems in other areas to avoid repetition of 

problem conditions. 

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 processes. 

65001.11-03 RESOURCE ESTIMATE 

Due to the length and complexity of the construction of the containment and the 

importance of the component, the average resource expenditure for this procedure is 

estimated to be 300 inspection hours per Unit. 

65001.11-04 REFERENCES 

Inspection Procedure 65001.B.01 Programmatic ITAAC Attributes for Welding 

10 CFR 50, Appendix A, General Design Criteria 50, Primary Containment 

10 CFR 50, Appendix J, Primary Containment Leakage Testing for Water-Cooled Power 

Reactors 

10 CFR 50.55a Codes and Standards 

NUREG/CR-5096, "Evaluation of Seals for Mechanical Penetrations of Containment 

Buildings." August 1988 

NUREG/CR-3855, "Characterization of Nuclear Reactor Containments," June 1984 

NUREG/CR-6154, "Experimental Results from Containment Piping Bellows Subjected to 
Issue Date 08/19/08 9 65001.11

Severe Accidents," Sept. 1994. 

NUREG-1273, "Technical Findings and Regulatory analysis for GI II.E.4.3, "Containment 

Integrity Check," April 1988. 

END 

Attachment 1: Revision History for IP 65001.11
Issue Date 08/19/08 Att1-1 

Attachment 1 

Revision History For 65001.11 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CoAc

08/19/08 CN 08-024 

1. Initial issuance to support ITAAC related inspection under 10CFR52. 2. Researched commitments for 4 years and found none. 

None N/A N/A