Issue Date: 09/20/13 1 65001.F

ATTACHMENT 65001.F

INSPECTION OF THE ITAAC-RELATED DESIGN AND FABRICATION REQUIREMENTS

PROGRAM APPLICABILITY: 2503

65001.F-01 INSPECTION OBJECTIVES 

01.01 To verify that design and fabrication activities have been completed in accordance with 

applicable specifications, drawings, and approved procedures.

01.02 To determine whether licensee records establish an adequate basis for the acceptance 

of ITAAC with design and fabrication attributes.

01.03 To verify design and fabrication activities have been performed by qualified personnel.

65001.F-02 INSPECTION REQUIREMENTS 

This inspection is performed to demonstrate that structures, systems and components (SSCs)

are designed and fabricated in conformance with requirements in the facility license,

applicable codes and standards, licensing commitments, the Final Safety Analysis Report 

(FSAR), and regulations. All dimensions and related tolerances of the components must be 

in accordance with design drawings and specifications. 

Design/Fabrication requirements include specific ITAAC that refer to applicable codes and 

standards, such as the American Society of Mechanical Engineers (ASME) and the American 

Society for Testing and Materials (ASTM). The design and fabrication documentation of

SSCs should demonstrate adequacy of design by reference to analyses, calculations, 

bounding condition checks, functional assessments, engineering evaluations and/or other 

design reports. Licensee reports that analyze the functional capabilities of the SSCs should 

be reviewed for compliance with applicable documents, codes, standards and regulations

referred to in this procedure. Fabrication requirements also include the application of service 

level I, II, and III protective coatings defined by Regulatory Guide 1.54 and inspections of 

coatings should focus on materials inside containment.

02.01 Design Document Review: Review the applicable SSC design documents associated 

with ITAAC to determine whether the documents adequately define the final design and 

arrangement of these SSCs. The inspectors should review applicable construction 

specifications, installation specifications, shop and field drawings, and construction 

procedures to verify SSC attributes associated with ITAAC are correctly identified and 

documented for review and approval by responsible engineering personnel. 

Inspection Plan/Scoping: Review the ITAAC Matrix to determine the ITAAC residing in 

families along Column F for Design and Fabrication Requirements. The inspector may 

then select specific criteria based on or related to those ITAAC and the inherent 

characteristics of any engineering program to verify whether a program controlling 
Issue Date: 09/20/13 2 65001.F

design and fabrication activities for those ITAAC has been established and is being 

correctly implemented. For the selected ITAAC criteria or attributes, the inspector 

should verify that the design and fabrication inputs were correctly identified and 

documented, and that their selection was reviewed and approved by the responsible 

engineering group. 

Some critical attributes may not be clearly specified in the ITAAC table, but are included 

by reference to fabrication or test codes, and/or reference to requirements contained in 

the Design Control Document (DCD) or the FSAR. It is expected that the inspector will 

exercise judgement not only in the selection of the critical attributes, but also in 

determining how much inspection is necessary to confirm that the ITAAC have been 

satisfied.

The ITAAC, should provide sufficient details for guidance in the selection of critical 

attributes and in establishing what needs to be inspected to verify adequate licensee 

completion, compliance, and acceptance.

02.02 Fabrication Records Review: Review a sample of SSCs fabrication records for selected 

ITAAC to verify compliance with applicable documents, codes, standards, regulations,

and quality and technical requirements.

a. Review a sample of purchase orders and verify that they appropriately specify 

acceptable quality, technical, and 10 CFR Part 21/10 CFR 50.55(e) requirements.

b. Review a sample of fabrication records and verify that they are adequate to 

furnish evidence of activities affecting quality and SSCs conform to applicable 

codes, standards, regulations, and quality and technical requirements. Review 

certified material test reports to verify that materials meet the specified 

mechanical testing requirements. The inspectors should review applicable ASME 

materials code data reports furnished by the vendor for acceptability.

 

c. If applicable, the inspectors should review a sample of nonconformance reports 

and other design deviation documents associated with SSCs that were

dispositioned as “repair” or “use-as-is”.

i. Review “repair” item reports and associated documents to verify the repair 

was performed in accordance with applicable codes, standards, regulations, 

and quality and technical requirements. The inspectors should also verify the 

repaired condition complies with the final design.

ii. Review “use-as-is” item reports and associated documents to verify that the

condition was adequately evaluated by the responsible design organizations 

and that any design change was completed in accordance codes, standards, 

regulations, and quality and technical requirements. The inspectors should 

verify that the accepted condition complies with the final design.

d. If possible, the inspectors should perform an observation of the item(s) selected 

for review above.
Issue Date: 09/20/13 3 65001.F

i. The inspectors should observe the storage of the item and determine 

whether the storage conditions meet applicable quality and technical 

requirements. 

ii. The inspectors should review the markings on the item(s) to determine 

whether the markings are in accordance with the applicable quality and 

technical requirements. NOTE: For ASME pressure boundary items, the 

ASME Code specifies material marking requirements, including the 

location of markings, and the method used to make the markings.

e. Verify the licensee, vendor, and fabrication personnel have established an 

effective method for tracking completion of design and test acceptance criteria at 

vendor manufacturing facilities.

f. Verify the licensee, vendor and fabrication personnel have established an 

effective method for tracking, evaluating, and dispositioning changes or 

modifications, and that they were appropriately resolved, including completion of 

any changes to design and test acceptance criteria. 

g. For components subject to industrial standards outside of the ASME Code, see 

Inspection Procedures for ITAAC rows (1) through (15). These will include 

references to industrial standards for seismic or environmental qualification, fire 

protection standards, etc. (One exception would be the ASTM requirements for 

protective coatings as designated by Regulatory Guide 1.54.)

02.03 Observation of Fabrication Activities: If possible, the inspectors should observe a 

sample of fabrication activities to determine whether the activity meets applicable quality 

and technical requirements established by the procurement documents. 

02.04 General Quality Assurance (QA) Review:

See Section 02.02 of IP 65001.

65001.F-03 INSPECTION GUIDANCE

Generic Inspection Guidance:

03.01 Specific Guidance for Section 02.03 (Observation of Fabrication Activities)

Fabrication specifications include, but are not limited to, component material specifications, 

fabrication techniques, examination techniques, and required dimensions and tolerances. 

Previously identified problems related to component fabrication include incomplete 

documentation of actual fabrication activities in fabrication traveler documents, i.e.: failure to 

explicitly state required critical component dimensions, such as minimum allowable wall 

thickness; failure to require verification of critical component dimensions using a specified 

non-destructive examination technique as required in the design documentation; design 

changes made outside the approved design change process; inadequate oversight of 
Issue Date: 09/20/13 4 65001.F

fabrication activities by the licensee; and, fabrication of a component to a different safety 

classification than that shown in design specifications.

The inspection requirements for fabrication activities include, but are not limited to, the following:

a. Verify that fabrication and procurement specifications are consistent with the 

design commitments and requirements documented in the licensing basis (i.e. 

FSAR, DCD and, if applicable, technical specifications). 

b. Verify that corrective actions for identified fabrication deficiencies have been 

implemented in a timeframe commensurate with their significance, and whether 

nonconformance reports documenting the deficiencies have been resolved. 

c. Verify that individuals performing the quality-related activities are trained and 

certified where required.

d. Verify those materials, components and other equipment received by the 

fabricator meet design procurement specifications.

e. Review NDE procedures, NDE records of welds, NDE personnel qualifications, 

certification of NDE materials penetrants and cleaners used, etc. Review 

protective coating procedures, coating inspection records, coating personnel 

qualifications, and certification of coating materials used. Verify that the NDE 

procedures, personnel qualifications and materials applied are consistent with the 

applicable construction code and design specification. In particular, observe or 

review the final acceptance pressure test for completed pressure boundary 

components and the final radiographs for welded components to confirm Code 

requirements were met. 

f. Verify that components are being fabricated per approved applicable QA and 10 

CFR Part 21 or 50.55(e) implementing procedures and meet fabrication 

specifications.

g. Verify that supervision and quality control (QC)/QA personnel perform appropriate 

oversight during fabrication activities. This can be accomplished by 

observing/reviewing the number and basis for selection of the QA/QC hold points 

in the fabrication work control document (e.g. traveler). For example, an 

appropriate selection criterion for a QC observation hold point could be to 

observe critical fabrication steps that cannot be verified after final component 

assembly. 

h. Verify that requirements have been satisfied for preparation of certified material 

test reports for the various components. Verify that the records of all required 

examinations and tests are traceable by work control travelers to procedures and 

revisions to which they were performed.
Issue Date: 09/20/13 5 65001.F

i. Verify that the required electrical component characteristics, material, 

performance tests, environmental and seismic qualification tests, nondestructive 

tests, and other specification requirements were met or were properly 

dispositioned.

j. Check for adequate foreign material exclusion controls.

k. Observe control of installation, use, and removal of temporary services directly 

related to component fabrication. 

l. Ensure that the contractor has established a program for ensuring that all craft, 

NDE, and inspection personnel associated with the installation of safety-related 

SSCs have been trained, or otherwise qualified to the work procedures involved.

65001.F-03 RESOURCE ESTIMATE

Inspection resources necessary to complete this inspection procedure are estimated to be 640

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

65001.F-04 REFERENCES

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

2. IMC 2503 Appendix B Site Specific ITAAC Matrix.

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

Inspections.

4. IP 35007, Quality Assurance Program Implementation During Construction and 

Pre-Construction Activities.

5. IP 40504, Part 52, Identification and Resolution of Construction Problems.

6. Regulatory Guide 1.84, Design, Fabrication, and Materials Code Case Acceptability, 

ASME Section III.

END

Attachment: 

 Revision History for IP 65001.F
Issue Date: 09/20/13 Att1-1 65001.F

Attachment 1 - Revision History for IP 65001.F

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

08/19/08

CN 08-024

Initial issuance to support ITAAC 

inspections under 10CFR52.

N/A N/A

N/A ML13207A061

09/20/13

CN 13-022

Researched commitments for 4 years 

and found none. 

Complete re-write to address current 

inspection program policies.

N/A ML13207A056