Issue Date: 05/09/14 1 65001.D

ATTACHMENT 65001.D

INSPECTION OF THE ITAAC-RELATED OPERATIONAL TESTING PROGRAM

PROGRAM APPLICABILITY: 2503

65001.D-01 INSPECTION OBJECTIVES

01.01 To provide guidance for inspection of all types of operational testing at a new nuclear 

power plant licensed under 10 CFR 52 to accomplish Inspections, Tests, Analyses and 

Acceptance Criteria (ITAAC) as required by the facility license.

01.02 To ensure that the testing is technically adequate, consistent with regulatory 

requirements, and licensee commitments.

65001.D-02 INSPECTION REQUIREMENTS

Operational testing involves testing activities to verify operational performance of structures, 

systems and components (SSCs) prior to fuel load, and includes pre-operational testing 

activities. The NRC inspection plan for operational testing will select a representative sample of 

tests for evaluation. This evaluation process will include the performance of detailed procedure 

review, test witnessing, and test results review. Additionally, it is anticipated that some 

operational tests will be used to accomplish ITAAC. The inspector must review the NRC 

approved Design Control Document (DCD) pertaining to the specific plant being inspected to 

determine which ITAAC are accomplished by operational testing. 

02.01 Procedure review.

a. Obtain a current revision of the selected test procedure(s) and associated 

documentation (e.g., calculations, diagrams, drawings, calibration records, etc.) in 

sufficient time to allow a procedure review to be completed prior to the date scheduled 

for the test. Review the procedure(s) for technical adequacy and completeness. Notify 

the licensee of all test deficiencies in a timely manner.

b. Review the current licensing basis, such as the DCD, FSAR, SER, Technical 

Specifications, docketed correspondence, and facility license. Verify that the test 

procedure adequately addresses licensee commitments and NRC requirements relating 

to ITAAC.

c. Review the test procedure(s) in accordance with the guidance provided in Attachment A 

of this procedure. The review should ensure that important equipment performance 

attributes are adequately confirmed by the operational test program. The focus of this 

review should be on the technical adequacy of the test to accomplish the ITAAC rather 

than the format of the document. 
Issue Date: 05/09/14 2 65001.D

02.02 Test Witnessing.

a. The inspector shall review the following attributes for each of the tests selected for 

witnessing:

1. Before witnessing a test, the inspector shall have completed a content review of 

the test procedure. The inspector must be familiar with the test procedure in 

order to adequately witness the testing described in the procedure. 

Communication must be maintained between the inspector and the licensee so 

that the licensee's test dates are known far enough in advance for the inspector 

to be ready to witness the selected tests. The inspector should determine the 

current procedure revision by examining the licensee's document control system. 

Confirm that a current revision of a technically adequate procedure is available at 

the test location and in use by test personnel. Ensure by observation and 

discussions that test personnel are using the current procedure revision and are 

familiar with the procedural requirements, especially the limitations and 

precautions. If a pre-test brief is conducted, the inspectors should attend.

2. Confirm that test personnel minimum staffing requirements are met. The

procedure may include the responsibilities and qualifications of test personnel.

The inspector should ensure that both requirements are met.

3. All test prerequisites and initial conditions are met and/or those which are waived 

are reviewed and approved in accordance with current approved administrative 

procedures. Verification should be performed by the inspector's review of the 

required records (valve lineup list, instrumentation calibration procedure, system 

checklist, or signoff item in the test procedure) or by direct observation 

(monitoring instrumentation indications, valve positions, equipment status, etc. or 

observation of personnel actions). 

4. All measuring and test equipment (M&TE) required by the procedure is calibrated

and in service at the time of the test. Test data recording equipment required by 

procedure is calibrated to a common time base. Test equipment with possibly 

greater accuracy than installed control instrumentation is normally required for 

measuring important parameters to demonstrate equipment performance in 

accordance with design criteria. This M&TE must be properly calibrated within 

the prescribed time period. If the M&TE was calibrated in the appropriate time 

period, it does not normally need to be recalibrated each time that piece of 

equipment is used.

5. Confirm that the testing personnel have the required level of training necessary 

to conduct the test. Pretest briefings are conducted and appropriate shift 

turnover is performed to ensure continuity in ongoing test activities. Test 

personnel actions and coordination activities are adequately performed. 

Specifically, coordination can be an important aspect of a test if several 

personnel are involved in performing procedural steps. Many of these steps may 

involve coordinated activities between two or more personnel. 
Issue Date: 05/09/14 3 65001.D

The inspector should confirm through observation that the assigned individual 

directing the test activities is knowledgeable and that time sequencing, when 

required, is performed appropriately. On a sampling basis, the inspector should 

verify adherence to the procedural limitations and precautions, and the individual 

test steps.

6. Review the Test Engineers Log (or equivalent), the Control Room Log, and the 

Shift Supervisor's Log, as applicable. Test anomalies, problems, interruptions, 

and/or deficiencies should be recorded in the logs and reviewed for inclusion in 

the licensee’s corrective action program. 

7. Cognizant test personnel should perform a preliminary review of test results to 

determine that the observed test results meet the established acceptance criteria 

and that the test does not need to be repeated. The acceptance criteria shall be 

clearly stated in the test procedure. If practicable, verify by direct observation 

that overall test acceptance criteria have been satisfied. Review the preliminary 

test results to ensure that the licensee's initial test evaluation is consistent with 

inspector observations. The inspector should also, independent from the 

licensee evaluation, observe and evaluate certain critical events or data 

gathering during and following testing activities. These events or data gathering 

activities should be selected during the inspector's preparatory review of the 

procedure.

8. For inspection of reactor internals testing, the Standard Review Plan calls for a 

test program to demonstrate the design adequacy of the reactor internals to 

withstand the effects of flow-induced vibration. This consists of verifying the 

applicant’s vibration test measurement and inspection results meet the 

acceptance criteria for flow-induced vibration. First determine the test 

measurement and verification scope for the prototype or non-prototype reactor 

internals is in accordance with Regulatory Guide (RG) 1.20, “Comprehensive 

Vibration Assessment Program for Reactor Internals during Preoperational and 

Initial Startup Testing” guidance. According to RG 1.20, the verification of the 

prototype reactor internals to withstand flow-induced vibration consists of 

vibration measurement and inspection; while the verification of non-prototype 

reactor internals relies only on measurement or inspection. Given this option in 

RG 1.20, most applicants for non-prototype reactor internals have chosen to 

perform only inspection. For the ITAAC related to inspection, review the 

inspection results to determine that the internals have no damage or loose parts 

after the flow test. It would be best to be on site for the inspections to verify first 

hand that there is no damage or loose parts.

02.03 Test Results Review.

a. The inspector should evaluate the following attributes for each test selected for results 

review. Two alternate levels of inspection are provided in this procedure for test results 

review:
Issue Date: 05/09/14 4 65001.D

The first level involves NRC detailed review of test results: For the tests for which the 

inspection plan requires evaluation detailed review of test results, complete steps 1 - 5

below in their entirety.

The second level involves Verification of Licensee Evaluation of Tests Results: For the 

remainder of the tests the inspection plan only requires verification that the licensee has 

successfully evaluated the test results, and only steps 4 and 5 below need to be 

completed.

1. Following test completion, test data packages are assembled by licensees. 

Review the "as-run" copy of the test procedure. Verify that individual test steps 

and data sheets have been properly initialed and dated. Verify that data sheets 

have been completed. Verify that all data is recorded where required and is

within acceptance tolerances. Verify that test deficiencies and test procedure 

changes are properly identified in accordance with established administrative 

procedures.

2. Review all test changes made during the performance of the test, including 

testing deletions. Verify that each was approved in accordance with the pertinent 

administrative procedures. Verify that the procedure is annotated to identify test 

changes. Verify that none of the changes have altered the basic objectives of

the test.

3. Review all test anomalies and deficiencies. Verify that these conditions have

been documented, resolved, that the resolution has been accepted by 

appropriate management, and that retest requirements, if any, have been 

completed. Verify that all system performance problems identified by a test 

deficiency have been properly documented and reviewed. Verify that all

deficiencies which constitute a reportable occurrence as defined in 10CFR 

50.55e and/or 10CFR50 Part 21 have been properly reported.

4. Review the licensee’s test summary and results evaluation. The inspector 

should apply independent technical analysis and judgment to ensure that the 

licensee's evaluation of test results has been performed correctly. Verify that 

those personnel, responsible for review and acceptance of test results, have 

documented their review and acceptance of the data package and the results 

evaluation. Verify that the licensee’s engineering staff has evaluated the test 

results and concluded that the testing demonstrated that the equipment met 

design requirements. Verify that the evaluation, specifically, compared test 

results with established acceptance criteria.

5. Verify that the Test Review Committee or equivalent group has examined the 

results in accordance with established administrative requirements. Verify that 

the Quality Assurance group or other independent review of test results has been 

accomplished as prescribed in the FSAR or other licensee commitments.
Issue Date: 05/09/14 5 65001.D

b. For the ITAAC related to the reactor internals flow-induced vibration test for the 

prototype, verify that the test measurements of the reactor internals components meet 

the vibration acceptance criteria stated in the reactor internals comprehensive vibration 

assessment program and the ASME Code Section III high cycle fatigue stress limit. 

The scope of the ITAAC differs depending on the reactor technology. For a PWR, the 

vibration measurement and verification can be performed prior to fuel load. 

For a BWR, the ITAAC scope is limited to parts of the vibration measurement and 

verification scope (e.g., lower internals) that can be performed before fuel load. For 

example, for BWRs, the measurement and verification of the steam dryer can only be 

performed after fuel load because steam is needed for the test, hence ITAAC does not 

apply. Natural circulation design can also affect the timing of this test, requiring all 

reactor internals testing be delayed until after fuel load.

02.04 Quality Assurance Program (Problem Identification and Resolution). Evaluate the 

adequacy of the implementation of the specific quality assurance program requirements related 

to operational testing. Confirm that problems identified associated with operational testing are 

entered into the licensee’s 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 ensure that problems are entered into the applicable process to 

ensure 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.D-03 RESOURCE ESTIMATE 

This procedure will be repeated over the period of time when operational testing is in process. 

Therefore no meaningful resource estimate can be made for this procedure. 
Issue Date: 05/09/14 6 65001-D

65001.D-04 REFERENCES

Facility Final Safety Analysis Report (FSAR) and Design Control Document (DCD)

IMC 2503, Appendix B, The ITAAC Matrix

IP 65001, Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Matrix Inspections

IP 35007, Assurance Program Implementation During Construction and Pre-Construction 

Activities

END

Appendix A:

 Procedure Review Guidance

Attachment:

 Revision History
Issue Date: 05/09/14 AppA-1 65001.D

APPENDIX A

PROCEDURE REVIEW GUIDANCE

Each procedure should be reviewed for the following attributes:

a. Appropriate licensee staff and management approval is indicated on the document.

b. Test objectives are clearly stated. Verify that all related FSAR commitments are

included. Ensure that the latest codes and standards, etc. are referenced where 

applicable.

c. All required testing prerequisites are identified, e.g.:

1. Required plant systems availability is specified.

2. Any associated facility procedures are specified.

3. Prior completion of calibration checks, limit switch setting, protective device 

settings, etc. are included where applicable.

4. All special supplies and test equipment needs are specified.

5. Special environmental conditions and hold times, if any, are identified.

6. Test precautions and limitations are specified.

7. If computer software is involved in the testing, inspectors should confirm that the 

software has received the appropriate validation and verification.

d. Test acceptance criteria clearly identified and the procedure requires comparison of 

results with acceptance criteria. The source of the acceptance criteria is also identified 

e.g., ITAAC, FSAR, technical specifications, facility license, etc.

e. Initial test conditions are specified.

1. Valve lineups.

2. Electrical power and control requirements.

3. All temporary installations or equipment modifications (instrumentation, electrical, 

and piping).

4. All necessary special conditions e.g. temperatures, pressures, flows, water 

chemistry, etc.
Issue Date: 05/09/14 AppA-2 65001.D

f. The procedure includes a section listing references to appropriate ITAAC, FSAR 

sections, technical specifications, drawings, design specifications, industry codes, and 

other requirements.

g. Step-by-step instructions for the performance of the procedure, including hold points if 

needed, are included to the extent necessary to ensure that the test is performed 

correctly and the test objectives are met.

h. Blank spaces are provided for initialing that all items, including prerequisites, are 

verified as having been performed.

i. Provisions are made for recording details of the conduct of the test, including all test

anomalies or observed deficiencies, their resolution, and all necessary retesting.

j. Procedure requires that all temporary connections, blind flanges, disconnections or 

jumpers be restored to normal at the end of the test, or references their control by 

another procedure.

k. Procedure provides for the identification of both personnel conducting the testing and

those evaluating the test data. Provision is made for the evaluator to document

acceptability of the data.

l. Procedure provides for quality control or quality assurance verification of critical steps

or test parameters.

m. All special precautions for personnel and equipment safety are specified.

n. Expected performance of all automatic functions or controls, e.g. response to step and 

ramp control changes, is specified.

END
Issue Date: 05/09/14 Att1-1 65001.D

Attachment 1 - Revision History for IP 65001.D

Commitment 

Tracking 

Number

Accession Number

Issue Date

Change Notice

Description of Change Description of 

Training Required 

and Completion 

Date

Comment and 

Feedback Resolution 

Accession Number 

N/A

08/05/09

CN 09-019

Initial issuance to support ITAAC related 

inspections under 10 CFR 52.

Researched commitments for four years 

and found none.

N/A N/A

ML14083A387

05/09/14

CN 14-011

Periodic update.

Researched commitments for four years 

and found none.

N/A ML14083A388