Issue Date: 08/05/09 1 65001.09

ATTACHMENT 65001.09 

INSPECTION OF ITAAC-RELATED INSTALLATION 

OF ELECTRIC AND FIBER OPTIC CABLE 

PROGRAM APPLICABILITY: 2503 

65001.09-01 INSPECTION OBJECTIVES 

References to “cable” denote Electrical and Fiber Optic cables. 

01.01 To determine whether ITAAC-related installation, tests and verification activities of 

electric/fiber optic cable are being conducted in accordance with approved design criteria, 

design specifications, and approved procedures, and that the ITAAC attributes for electrical 

cable have been met. 

01.02 To determine by inspection that electrical/fiber optic cables are properly installed in 

accordance with industry standards and the requirements described in the licensee’s 

electrical installation specifications. 

01.03 To determine whether required records associated with electric/fiber optic cable 

installation are being maintained. 

01.04 To evaluate the adequacy of the implementation of the specific quality assurance 

program requirements related to electric/fiber optic cable installation activities and ensure 

that nonconforming conditions are entered into the corrective action program. 

65001.09-02 INSPECTION REQUIREMENTS AND GUIDANCE 

General Guidance. 

The objective of this inspection procedure is to independently confirm by sampling 

inspections that the ITAAC attributes for electrical/fiber optic cable have been met. For 

designs certified under 10CFR Part 52 those attributes generally consist of achieving 

required cable separation and proper identification of Class 1E cables by color coding. 

 

The inspector should review the ITAAC Matrix for plant design of the inspected facility to 

determine the ITAAC residing in Afamilies@ along Row (09) for AElectric Cable.@ Then 

obtain the NRC approved Design Control Document (DCD) for that design and review the 

electrical cable ITAAC to determine the attributes requiring inspection for that design. 

From that information an individual inspection plan can be formulated. This inspection 

procedure presents methods for inspection of those attributes. 

The inspectors should review drawings of the overall physical plant layout regarding the 

design for the routing and separation of cables of various classes (e.g. voltage level, signal 
Issue Date: 08/05/09 2 65001.09

type, division designation, safe shutdown train) to understand the cable separation 

methodology. Particular attention should be paid to routing of cables in the control room, 

cable spreading room, remote shutdown control locations and post-fire safe shutdown 

designated divisions. The purpose of this review is to confirm that division physical 

separation is maintained and to guide the inspection sampling of physical separation to 

critical areas. 

A simultaneous objective is to confirm from visual inspection of in progress and completed 

cable installation that the work was done in accordance with industry standards and the 

requirements described in the electrical/fiber optic installation specification. Section 02.02 

of this document presents cable installation attributes that inspectors should look for. 

Deficiencies in these attributes may not constitute ITAAC findings but must be brought to 

the licensee’s attention for corrective action and be dealt with as with other construction 

findings. 

The inspectors should maintain complete records of cable samples selected for inspection. 

The inspection report should record the rationale for selecting the sample and document 

the attributes inspected. 

Inspections should be performed on samples of ongoing work and completed work. These 

observations will verify adequate procedural implementation and confirm proper cable 

identification and routing. Inspections should also be made on a larger sample of 

completed work to independently verify correct cable identification and separation. 

Samples should include cables inside containment and other areas where harsh 

environments might exist in accident conditions. Samples should include work of different 

subcontractors and work performed at various times throughout the project. 

02.01 Physical Separation of Cables. It is intended that this inspection activity be 

performed repeatedly during plant construction. For each of these inspections, the sample 

selection should include as many examples of completed work products as practical during 

the available time frame. 

Inspection Requirements. 

Inspection of in-process work. 

a. From the licensee work planning schedules determine what cable installation work 

is currently in progress. From that population select tasks for inspection that are 

installing Class 1E electrical cable. 

b. Go to the job site and observe work in progress. Verify that work control 

documents are at the job site and being used. Examine available paper work to 

determine it appears current and accurate. 

c. Interview the job supervisor and craftsmen to confirm that they have adequate 

instructions and knowledge of the design specified routing of the cable being 

installed. Determine their planned/expected actions if problems, uncertainties or 

anomalies are encountered in the work. 
Issue Date: 08/05/09 3 65001.09

d. Record the in-process cable designation and its actual route. If visual inspection of 

completed work is not sufficient to confirm cable routing, the inspector may need to 

request licensee to perform signal tracing. Compare the as-installed route to that 

specified in the engineering control cable routing program. 

Guidance. 

a. The inspectors should select samples for inspection that will be representative of 

as many different separation criteria and plant areas as possible. The inspection 

sample should include cables in trays, conduits, duct banks, etc., to achieve a 

varied sample of cable configurations. The sample should include some completed 

cable work inside panels since separation criteria will be different. Effective 

inspection of cable separation may involve examining areas that are physically 

difficult to access. 

b. The correct and current work control documents should be at the job site and in 

actual use. Review the plant work control procedures during inspection preparation 

to determine the licensee specified practices. 

c. The workers should have enough knowledge and information to know clearly the 

intended correct cable routing. They should also know to stop and resolve any 

anomalies before continuing with cable installation. 

d. Once the as-installed cable route is recorded, the inspector should compare it to 

the engineering specified cable routing program. There should be no 

discrepancies. If there are any differences, there should be an established method 

to document them and return the discrepancies to engineering for resolution and 

approval. 

Inspection of completed work. 

a. Review and understand the licensee=s method of determining and specifying to the 

field the design intended cable routing. Discuss the methods and their success 

and failures with engineers to determine any system weaknesses. Confirm that 

these methods appear to implement and enforce the cable separation criteria 

specified in the ITAAC. 

b. Select a sample of Class 1E cables from each of the Divisions and use the 

licensee=s computerized cable routing system to determine the design specified 

route of the cables. The sample should be primarily power supply cables but may 

include some control, instrumentation, and communication (copper/fiber optic) 

cables if available. Verify that the records show that the Divisions are separated 

and do not come together in a common raceway. 

c. For that same sample of Divisional powered cables determine the raceway cable 

routes. Review the cable routing system to see if there are any other cables in the 

same raceway. There should be no other Division or non-Divisional cables in this 

same raceway. 
Issue Date: 08/05/09 4 65001.09

d. Select a subset of the sample for field observation and, with the assistance of 

licensee engineers as necessary, visually inspect the cables in the plant to confirm 

that the cable routing system information is complete and accurate. During the 

field inspections also observe that the physical separation between Class 1E 

raceways of different Divisions and between Class 1E raceways and non-Class 1E 

raceways is consistent with that specified in the ITAAC. The inspection sample 

should include free-air cables, as well as cables in raceways. Also during the field 

inspections verify that the different Division cables and raceways are identified by 

an appropriate color coding scheme as specified in the ITAAC. 

e. The ITAAC will typically require that separation is maintained between Class 1E 

Divisions in accordance with an identified fire area plan. Select a sample of the 

specified fire areas for field inspection. Visually verify for each fire area that only 

cables and raceways for the specified Division pass through that fire area. 

f. For AP1000, the ITAAC will typically require that Class 1E communication cables 

which interconnect two Divisions are routed and separated such that the Protection 

and Safety Monitoring System (PSMS) voting logic is not defeated by the loss of 

any single raceway or fire area. Examine the cable routing system to locate a 

sample of such communication cables that interconnect two Divisions. Verify that 

the cable routing system reflects that no two of these interconnecting cables pass 

through the same raceway or fire area such that the loss of any single raceway or 

fire area could defeat the PSMS logic. For a subset of these interconnecting 

cables, perform visual field inspections to confirm the accuracy of the cable routing 

system information. 

Guidance. 

a. The licensee will establish an administrative control system to track and specify asinstalled cable routing in the plant. The licensee will normally utilize a computer 

software program to manage the cable and raceway schedule. With the assistance 

of licensee engineers, the inspectors should gain access to the system, and 

become familiar with its methods of operation. Typically this type of software 

performs certain checks related to cable separation. For example the software 

would block a designer from routing a Division 1 cable in a Division 2 raceway. 

Usually an error message is also provided stating the reason the attempted routing 

of a cable was blocked. Similarly, it would recognize and supervise voltage levels 

and associated separation criteria. For example, it would block routing a 5,000 V 

cable in cable tray designated for low-voltage power or block conducive fiber optic 

cable routing through any A.C. cable tray. The inspector should perform tests of 

these cable separation criteria checks and blocks provided by the software to 

confirm that they work as designed. But any automatic block provided by software 

will also have an override feature, so this should be addressed in the inspection to 

verify the override is properly used and administratively controlled. In addition, the 

cable and raceway software may check that raceways carrying a separation code 

designator cannot be Aconnected@ in the raceway schedule. 
Issue Date: 08/05/09 5 65001.09

Again this should be tested by the inspector or demonstrated to the inspector by 

licensee personnel. 

b. The intent is to select a sample of Class 1E powered cables and query the 

computer routing system for their routing. Then verify that the cable routing system 

information reflects that there are no intersections of the various class 1E Division 

cable routes. 

c. The intent is once the cable routes of the selected sample cables have been 

determined, then query the cable routing system to verify that the system 

information reflects that there are no other cables in the same raceway. There 

should be no instances of different Class 1E Divisions or non-Division powered 

cables routed in the same raceway. Inspectors should pay particular attention to 

“non-safety” cables which could be routed in redundant 1E division raceways. 

d. The licensee should administratively control access to completed cable runs so the 

inspectors will need to arrange the assistance of licensee engineers to gain access 

to electrical cabinets, cable trays, junction boxes, pull boxes, patch panel, etc. for 

visual inspection of cable routing. Licensee representatives should be requested to 

take the actions necessary so that the inspectors can perform the needed visual 

inspections. Following inspections the licensee should promptly take the actions 

required to restore the equipment to its former configuration. Also be aware that 

proper separation seen in a particular room can be later invalidated by cable 

installation work performed after the inspection or placement/removal of cable tray 

covers. 

e. The ITAAC will typically specify which fire areas are to contain only certain Division 

cable runs. The intent is to select a sample of these fire areas and to verify by 

record review and visual observation that no other Division cables run through the 

designated fire areas. 

f. The intent is to verify by a combination of record review and visual observation that 

this ITAAC requirement has been met. 

02.02 Attributes of Electrical Cable installation. 

Inspection Requirements. 

While performing observations of in-process cable installations and inspection of 

completed cable installations as required by section 02.01, inspectors should be alert for 

the following attributes of cable installation. Any observed substandard work should be 

brought to the licensee’s attention so that non-conforming conditions can be documented 

in their corrective action system and corrected. 

Guidance. 

Before commencing inspection the inspector should become familiar with the plant work 

procedures. The term work procedures is intended to include construction specifications, 

installation procedures, written instructions, drawings, sketches and any approved 
Issue Date: 08/05/09 6 65001.09

document which is being used to control the construction work or used by craftspersons. 

This includes procurement, receipt, and storage of materials; and quality control 

inspections. Procedures used by sub-contractors involved in the project shall be consistent 

with each other and the licensee’s QA program. Review the results of any previous NRC 

Procedure Review inspections for past performance weaknesses. Any inadequacies 

concerning completeness, level of detail or correctness of the work procedures should be 

brought to the licensee’s attention for resolution as soon as possible. At about the 50 

percent completion point of cable and raceway installation, the inspectors should review 

the work procedures again for adequacy of any changes that were made since project 

start. 

For samples of installed cable raceway, verify that the size, material (i.e. steel, aluminum, 

galvanized), and style (i.e. ladder type, solid bottom, etc.) are as specified on the design 

documents and work procedures. Verify that cable tray covers are installed correctly at the 

specified locations. 

Determine that the location of the raceway is as specified on the construction drawing. 

Check for generally correct dimensions from column line, from floor or ceiling, and between 

raceways installed in banks or arrays. 

Verify that raceway supports are located at points specified on approved drawings or 

instructions and that maximum distance between supports is not exceeded. Also verify 

that raceway supports are constructed according to the approved drawings or instructions. 

Verify that raceway identification labels and tray section markers are affixed at locations 

specified in approved instructions and that they are accurate. Verify that the physical 

separation criteria are maintained. 

Verify that all fittings, clamps, bushings, condulets, flexible conduit, grounding wire and 

clamps are installed according to approved work procedures. There should be electrical 

ground grid pads in floors and walls to allow convenient grounding of raceways. 

Check that the electrical raceways were included in the pipe whip and jet impingement 

design studies. Look for instances of safety important cable installed in proximity to steam, 

feed, or other high energy pipes that could be damaged if the line leaked or ruptured. Look 

for safety important cables run in the vicinity of high heat sources, such as steam lines, that 

will accelerate cable aging. 

Observe that raceways are installed such that the specified minimum cable bend radius will 

not be exceeded. To avoid cable pull damage no more than 360 degrees of conduit bends 

should be included between cable pull points. 

Underground ducts and concrete embedded conduits should be installed in a manner to 

provide for automatic water drainage and/or pump out. Underground ducts should be 

adequately sealed at entry points to buildings to prevent water intrusion. 

Cable installation inspection samples should include power, control, and instrumentation 

cables from each manufacturer supplying cable. Verify that the correct cable type is 

installed. This inspection should use all available data such as pull tickets, mark number 
Issue Date: 08/05/09 7 65001.09

descriptions, manufacturer’s data, equipment qualification files, jacket marking information, 

work procedures, design control documents, purchase specifications, dimensional checks 

and visual examination of the cable. Verify that approved permanent type cable 

identification tags are installed at specified locations and that they have the correct 

information. 

Verify to the extent possible that installed cables were not damaged during the shipping, 

storage, or installation activities. This should be accomplished through examination of 

cables at the receiving/storage locations, installation staging locations, pulling locations and 

observation of installed cables. 

When observing cable pulling activities checks should be made of the following attributes: 

minimum bend radius should not be exceeded, cable pulling lubrication should be used as 

specified in work procedures, cable pulling tension limits should typically be calculated 

before the pull begins and monitored during the pull, and conduit fill limitations should not 

be exceeded. In field observations, select conduits that appear to be filled to the limit. 

Then verify that these cables installed in conduits do not exceed ampacity, fill guidelines, 

nor jamming ratio. Inspections should pay particular attention for situations where licensees 

might install new cables in existing conduits which already have cables installed. Such 

“cable pullbys” can damage existing cables due to the pull rope cutting the already installed 

cables and are an unacceptable practice. Due to the fragile nature of fiber optic cable 

these attributes are especially sensitive and should be examined closely. 

When observing cable tray installations for instances of densely packed trays it should be 

verified that cables installed meet the design criteria from the ampacity, weight and depth 

of fill attributes. In cases where power cables are installed in a single layer, check that 

proper spacing is maintained. Verify that seals and fire stops are qualified for the 

application and are correctly installed at the specified locations. 

Plastic tie wraps do not have a strength rating and experience embrittlement over time and 

should not be used in a load bearing manner outside of panels. Inspection samples of 

installed cables should include any special configurations such as long vertical runs and 

vertical cable supports. There inspectors should verify that appropriate cable supports are 

installed as prescribed by both copper and fiber optic cable installation procedures. Verify 

that any cable ties installed inside containment are qualified for the environment. 

When inspecting terminations verify that correct lug size and type are used and lugs are 

properly installed and crimped on the wire. Check whether lugs are compatible with the 

terminal blocks or bus bar to which they are connected. Also verify that lugs are 

compatible with cable type (i.e., solid or stranded conductor) and cable system voltage 

rating. Inspection sample should include all the different generic type terminal blocks and 

wire types being utilized. Also confirm that terminal block markings match wiring diagram. 

When inspecting fiber optic splices and termination connectors on patch panels, verify that 

the testing procedures for optical power and loss are adequate. The test results should be 

within an acceptable range indicated by the manufacturer specifications. The test should 

be recorded and documented with the results from the test equipment. Splices and 

connectors should be protected to the same degree as the jacket specification on the fiber. 
Issue Date: 08/05/09 8 65001.09

When inspecting small wire terminations some of the important inspection points are: wire 

protrudes specified dimension beyond barrel, “signature” dimple of the crimp tool indicates 

that proper compression has been achieved, and hold down screws are torqued to 

recommended value. Also verify that lugs are compatible with cable type (i.e., solid or 

stranded conductor) and in accordance with lug manufacturer recommendations (e.g., 

cable type and voltage rating). When multiple wires are terminated on the same terminal 

point, check that the installation is in accordance with approved work procedure details and 

the electrical installation specification requirements. Verify that the maximum number of 

terminations allowed by procedure on a terminal is not exceeded. 

Verify the cable shield wires are grounded at points specified in the design output 

documents or work procedures and not grounded at any other points. Include drain wire 

shielded and tape shielded cable in the sample if these both are utilized at the plant 

inspected. 

Select and witness a sample of cables during continuity (or ring out) checks. These tests 

serve to show that the wire is not broken, the wire is connected to the correct point at both 

ends and that the end device is powered from the correct train or channel. The continuity 

checks could be used to satisfy an ITAAC for certain type plants. 

Fiber optic cable continuity checks consist of an optical power and optical loss or reflection 

tests. The tests should be conducted across the entire wave length spectrum ratings of the 

cable. The two tests show that the cable has not been damaged during installation and 

connection. The tests should be recorded and documented. 

Select and inspect a sample of Environmentally Qualified wire and fiber optic splices and 

verify that they are correctly made. Inspectors should observe installation of splices and 

not just solely inspect them after they are installed. A mix of direct observation of 

terminations and splices and review of documentation is what is intended. Also verify that 

those EQ splices selected for inspection are made in approved locations. 

Post-fire safe shutdown considerations impose special requirements on the separation of 

cables. A sample of power, control, instrumentation, and communication cables credited 

for safe shutdown systems should be inspected. In addition, a selection of cables which 

are important to safe shutdown due to spurious component operation concerns should be 

inspected. These inspections involve the verification that as-built cable routing meets 

design criteria, flame retardant cable is installed where required and fire barriers installed 

on raceways are correctly qualified and properly installed. 

02.03 Documentation. While performing the inspection activities of 02.01 the inspectors 

should verify the following related to as many cable and raceway systems as practical. 

Inspection Requirements. 

a. All information on the computerized cable and raceway routing system reviewed by 

the inspectors is accurate. The qualified software for the system provides 

adequate version control and ensures the fidelity of the electrical/fiber optic 

installation specification requirements required programmed checks, blocks and 

flags. 
Issue Date: 08/05/09 9 65001.09

b. The required permanent records for the cable and raceway routing will be 

maintained. 

c. Any discrepancies identified during this inspection are documented in the 

licensee’s corrective action program and adequately resolved. 

Guidance. 

The cable and raceway routing system records are very important to confirm that the 

ITAAC cable separation criteria are met at the completion of plant construction and 

throughout the life of the plant. There should be no discrepancies and any identified during 

this inspection should be resolved or placed into the licensee=s corrective action system for 

future resolution. The resolution of any items placed in the corrective action system should 

be confirmed by the NRC during subsequent inspections. 

02.04 Problem Identification and Resolution. 

Inspection Requirements. 

The inspector should confirm that problems identified during the inspection are 

appropriately entered into the licensee/constructor=s 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 

including the proper characterization and classification of the conditions adverse to quality. 

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, prioritized, and 

implemented. Inspections of overall Quality Assurance Program implementation, 

effectiveness of Problem Identification and Resolution, and Self-Assessment will be 

performed under the IMC 2504 processes. 

65001.09-03 RESOURCE ESTIMATE 

It is intended that this inspection procedure will be performed several times during the 

cable installation period to obtain a wide and varied sample of NRC inspection of cable 

separation for ITAAC closure. The repetitive frequency of inspections may vary depending 
Issue Date: 08/05/09 10 65001.09

on whether NRC inspections identify findings. This inspection procedure is estimated to 

use approximately 800 direct inspection hours over the course of facility construction. 

65001.09-04 REFERENCES 

NRC approved Design Control Document for the facility being inspected. 

ANSI/IEEE Std. 422 IEEE Guide for the Design and Installation of Cable Systems in 

Power Generating Stations, has specifics on cable pulling and 

proper bend radii. 

IEEE Std. 690 IEEE Std. for the Design and Installation of Cable Systems for 

Class 1E Circuits in Nuclear power Generating Stations, has 

some information on installation requirements. 

IEEE 1428 IEEE Guide for Installation Methods for Fiber-Optic Cables in 

Electric Power Generating Stations and in Industrial Facilities. 

IEEE 1202 Standard for Flame-Propagation Testing of Wire and Cable. 

These standards apply to both copper and fiber optic cables. 

NFPA 262 Standard Method of Test for Flame Travel and Smoke of Wires 

and Cables for Use in Air-Handling Spaces. 

END 

Attachment 1: Revision History for IP 65001.09 
Issue Date: 08/05/09 Att1-1 

Attachment 1 

Revision History for IP 65001.09 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CRA

N/A 08/05/09 

CN 09-019 

Researched commitments for 4 years and found none. Initial issuance to support ITAAC related inspections under 10 CFR 52 

No N/A N