Issue Date: 07/29/08 1 65001.12 

ATTACHMENT 65001.12 

INSPECTION OF ITAAC-RELATED INSTALLATION OF 

HEATING, VENTILATING, AND AIR CONDITIONING SYSTEMS 

PROGRAM APPLICABILITY: 2503 

65001.12-01 INSPECTION OBJECTIVES 

01.01 To determine whether the installation of heating, ventilating, and air conditioning 

(HVAC) systems and related licensee quality control activities are being performed in 

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

approved procedures. 

01.02 To determine whether HVAC components, ductwork, and piping installation welding 

is being conducted in accordance with Code requirements, design specifications, and 

approved procedures. 

01.03 To determine whether HVAC system installation general records, welding records, 

and test/verification records reflect work accomplished in accordance with design 

specifications, Code requirements, and approved procedures. 

01.04 To determine whether ITAAC-related HVAC system/component test and verification 

activities are being conducted in accordance with design specifications and approved 

procedures. 

01.05 To determine whether HVAC components have been properly qualified in 

accordance with regulatory requirements, design specifications, and program 

requirements. 

01.06 To determine whether HVAC components have been designed and fabricated to 

conform with design specifications. 

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

requirements related to HVAC installation and testing activities, and to assure problems are 

entered into the corrective action process. 

65001.12-02 INSPECTION REQUIREMENTS AND GUIDANCE 

For the purposes of this procedure, HVAC includes the air distribution and environmental 

control systems, thereby including all mechanical, electrical, and I&C equipment that is 

directly related to HVAC function or performance. Examples of inspectable HVAC 

components include, but are not limited to: air handling units, dampers, valves, operators, 

piping, ducts, filters, chillers, fans, pumps, compressors, refrigerant piping, insulation, 

access doors, supports, sensors, air storage tanks, etc. 

02.01 General Installation. Select several HVAC components from at least 2 different 
Issue Date: 07/29/08 2 65001.12 

HVAC systems, including targeted HVAC ITAAC as much as practical. Through direct 

inspection, confirm the following attributes, as applicable, have been met: 

a. Installation requirements such as proper location, placement elevation, volume, 

quantity, material type/shape/size, special features such as coatings and insulation, 

orientation, alignment, seismic and other mounting requirements (including torquing 

of bolts and expansion anchors), flow direction, leak testing, pressure testing, flow 

volume verification, tolerances, and electrical features such as proper grounding 

and terminations, are met. The inspector must be aware of the testing schedule, 

as HVAC testing is frequently performed on a section of the system in a sequential 

method. 

 

b. Precautions to prevent damage during storage, handling, placement, and mounting 

of components are taken. 

c. Properly trained personnel and the correct specified equipment are available and 

utilized to meet manufacturer=s instructions, engineer's specifications, and/or Code 

requirements. 

d. Installation requirements, work procedures, construction drawings, and 

specifications are available to installers and are of the latest issue. 

e. Hold points are observed and quality inspections are conducted in accordance with 

standards and procedures. 

f. Lifting and rigging activities are in accordance with established procedures and 

requirements. 

g. Preparation of installation and inspection records meets quality program 

requirements. 

h. Design changes or field modifications relevant to the work being observed have 

been processed in accordance with the applicable program requirements. 

i. All temporary connections or jumpers are removed after testing to allow proper 

operation in normal mode. 

Guidance: This inspection should be performed as often as possible when significant 

HVAC system/component installation activities are taking place but no less than necessary 

during the construction period to meet the objectives stated. Inspectors are reminded that 

the targeted ITAAC set should not limit the scope of inspections, but complement it. This is 

especially important to note for HVAC as there may be a small population of targeted 

ITAAC for these systems. 

Generic QA implementation activities such as receiving inspections, equipment storage, 

and records storage are inspected under separate Inspection Procedures (IPs), the 

inspector should keep informed of these generic areas that effect HVAC equipment 

performance. Any generic area problems uncovered while performing this inspection 

should be reported to NRC management. 
Issue Date: 07/29/08 3 65001.12 

For HVAC systems, the inspector should pay particular attention to the traceability of 

material and equipment. The inspector should check that incorrect, defective, or 

unqualified materials, parts, and/or components have not been used. The inspector should 

verify that identification of the item is maintained by part number, heat number, serial 

number, or other means, either on the item or on records traceable to the item, and that 

unique markings are on the item. In the case of fasteners, compliance with the material 

specification (e.g. ASTM or ASME material and grade) should be verified by markings 

present on the bolts or nuts and certified material test reports or Certificates of 

Conformance as required by the procurement drawings and specifications and/or by the 

codes. In the case of vendor-supplied equipment assemblies containing fasteners, 

samples should be inspected to verify compliance with the vendor drawings, specifications, 

and other information such as materials used for equipment qualification tests and/or 

analyses. 

Field observations should consist of independent evaluation and verification of work 

activities, and observation of licensee/contractor inspections. While all applicable 

attributes do not need to be reviewed for each sample, the majority should be. Those 

samples or attributes reviewed should include all facets of installation activities. 

Records should document the status of installed systems. They should confirm that 

required inspections have been performed and that the inspector’s qualification is current 

and correct for the inspection. Records should also confirm that all critical installation 

requirements and ITAAC requirements have been met. Record storage must be in 

accordance with quality assurance program requirements. 

Typical problems discovered by inspection include: inadequate or unclear 

guidance/instructions for installers and/or inspectors, the use of improper/uncalibrated tools 

for installation and measurement, weak management coordination leading to skipped hold 

points in installation, inadequate personnel qualification records, field changes not being 

processed properly, and record storage and retrieval problems. 

02.02 Welding. If welding is required for HVAC installation, select a sufficient sample of 

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

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

Guidance: This inspection should be coordinated with IP 65001.B and IMC 2504 “NonITAAC Inspections” 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 HVAC systems, which may include control 

room habitability systems, Class 1E and safety related equipment rooms, and battery room 

cooling and ventilating systems. 

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 
Issue Date: 07/29/08 4 65001.12 

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. 

02.03 Post Installation Activities. Select a sufficient number of HVAC components to 

allow a demonstration of the inspection objectives. The selected components should be 

from at least 2 different HVAC systems and, if possible, by different subcontractors. The 

selection should emphasize, but must not be limited to, the targeted ITAAC-related 

components previously selected for Section 02.01. Confirm these components are 

properly protected and if necessary, serviced considering the following attributes, as 

applicable: 

a. Licensee surveillance activities are being performed according to instructions. 

b. Protection is provided as required, including protection against such conditions as 

adverse temperature, humidity, flooding, and foreign materials (e.g. dirt, dust, 

cans, and general debris). 

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

required. 

d. Records are being maintained, indicating the status of installed components. 

e. Recording methods such as stamps, tags, markings, etc. are being used to 

prevent oversight of licensee inspections, record the completion of tests, record 

the acceptances, and to prevent inadvertent operation. 

Guidance: Post-installation activities should be observed throughout the construction 

period every 2-3 months to assure HVAC components, equipment, ducts, and supports are 

properly maintained until final turnover. 

02.04 Testing and Verification. Select ITAAC-related HVAC testing activities to assure 

testing is conducted in accordance with approved procedures and that test acceptance 

criteria have been met. 

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 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 HVAC systems, which may include control 

room habitability systems, Class 1E and safety related equipment rooms, and battery room 
Issue Date: 07/29/08 5 65001.12 

cooling and ventilating systems. 

02.05 Component Qualification. Select several ITAAC-related HVAC components up to a 

sufficient number to verify that qualification criteria are met. 

Guidance: This inspection should be coordinated with IP 65001.E “Qualification Criteria”, 

which contains more detailed inspection guidance and the attributes that should be 

considered for this inspection. The sample size will be dependent on guidance from this 

coordinating procedure, the targeted ITAAC set, and inspector judgment. 

HVAC components may be subject to seismic, environmental, or other such qualification 

criteria. The inspector should review the design specifications to determine the specific 

qualification criteria for a selected component. For example, an HVAC electrical 

component may be specified to be environmentally qualified in accordance with IEEE-323-

1974 or a similar standard. Such qualification may consist of type tests, analyses, or a 

combination of both. 

02.06 Component and System Design/Fabrication. Select several HVAC ITAAC-related 

activities up to a sufficient number to assure that tests, analyses, calculations, functional 

assessments, and bounding condition checks for HVAC systems and/or components 

demonstrate conformance with design specifications for the as-installed conditions. 

Guidance: This inspection should be coordinated with IP 65001.F “Design/Fabrication 

Requirements,” which contains more detailed inspection guidance and the attributes that 

should be considered for this inspection. The sample size will be dependent on guidance 

from this coordinating procedure, the targeted ITAAC set, and inspector judgment. 

Although the inspection of HVAC design is covered by other procedures, some ITAAC 

applicable to HVAC exist that test, analyze, or otherwise assess and confirm that asinstalled structures, systems, and/or components are within design specifications. For 

example, the ITAAC with the highest prioritization ranking for HVAC for the AP1000 falls 

into this section because it involves an analysis that must demonstrate that the heat up of 

vital equipment rooms and the main control room is within design basis assumptions. 

Since such an analysis relies on the as-built condition for accurate inputs to the analysis, 

the inspector can verify that equipment or structures are actually installed as analyzed. 

02.07 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. 
Issue Date: 07/29/08 6 65001.12 

65001.12-03 RESOURCE ESTIMATE 

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

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

65001.12-04 REFERENCES 

Regulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and 

Adsorption Units of Post Accident Engineered Safety Feature Atmosphere Cleanup 

Systems in Light Water Cooled Nuclear Power Plants 

Regulatory Guide 1.78, Evaluating the Habitability of a Nuclear Power Plant Control Room 

during a Postulated Hazardous Chemical Release 

Regulatory Guide 1.84, Design, Fabrication, and Materials Code Case Acceptability, ASME 

Section III 

Regulatory Guide 1.140, Design, Inspection, and Testing Criteria for Air Filtration and 

Adsorption Units of Normal Atmosphere Cleanup Systems in Light Water Cooled Nuclear 

Power Plants 

ASME/ANSI AG-1-1997, Code on Nuclear Air and Gas Treatment 

ASME N509-1989, Nuclear Power Plant Air-Cleaning Units and Components 

ASME N510-1989, Testing of Nuclear Air-Cleaning Systems 

SMACNA, HVAC Duct Construction Standards Metal and Flexible 

NFPA 90A, Standard for Installation of Air Conditioning and Ventilation Systems 

END 

Attachment 1: Revision History for IP 65001.12 
Issue Date: 07/29/08 Att1-1 

Attachment 1 

Revision History For IP 65001.12

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