Issue Date: 08/13/13 1 65001

NRC INSPECTION MANUAL CCIB

INSPECTION PROCEDURE 65001

INSPECTIONS OF INSPECTIONS, TESTS, 

ANALYSES AND ACCEPTANCE CRITERIA (ITAAC) 

RELATED WORK

PROGRAM APPLICABILITY: 2503

This procedure provides guidance for the direct inspection of work activities for structures, 

systems, and components (SSCs) that are associated with inspections, tests, analyses, and 

acceptance criteria (ITAAC). 

65001-01 INSPECTION OBJECTIVES

01.01 To determine, by direct inspection, whether ITAAC related construction activities were 

conducted in accordance with applicable quality, technical, and regulatory requirements.

01.02 To evaluate licensee compliance with construction related requirements associated with 

the acceptance criteria of specific ITAAC. 

65001-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 BACKGROUND

02.01.a This procedure provides guidance for the direct inspection of work activities 

for structures, systems, and components (SSCs) that are associated with 

inspections, tests, analyses, and acceptance criteria (ITAAC). 

02.01.b The NRC will focus on direct inspections of construction activities related to 

targeted ITAAC. The overall ITAAC inspection philosophy is described in 

detail in Inspection Manual Chapters 2503, “Construction Inspection 

Program: Inspections of Inspections, Tests, Analyses and Acceptance 

Criteria (ITAAC) Related Work,” and 2506, “Construction Reactor Oversight 

Process General Guidance and Basis Document.”
Issue Date: 08/13/13 2 65001

02.01.c During the inspection planning process, the inspector should review the 

applicable site data in the Construction Inspection Program Information 

Management System (CIPIMS) to determine if any previously identified open 

issues, findings, or observations are relevant to the process or program 

inspection being planned.

02.01.d As a part of the planning process, inspectors should ensure that the SSC 

selected for inspections of targeted ITAAC are representative of similar 

ITAAC work in the same family (An ITAAC family is a grouping of ITAAC that 

are related through similar construction processes, resulting products, and

general inspection attributes). This is accomplished by determining whether 

multiple contractors or different programmatic controls are involved in the 

same process or program for the given inspection. If the same licensee 

programmatic controls govern all construction activities being inspected, the 

targeted ITAAC selected for review should be representative of these 

activities. However, if different contractors using their own unique program 

controls are performing similar work, NRC inspection planning should 

consider inspecting some additional SSCs from the different contractors as 

another independent inspection sample.

02.02 Direct Inspection: Inspectors should perform direct inspections as prescribed by 

the attached inspection procedures to determine whether the ITAAC related SSC 

construction activity was completed in accordance with applicable quality, technical, 

and regulatory requirements. NRC inspections should include one or more of the 

following direct inspection techniques: (1) Observation of in-process work activities, 

(2) Review of completed records of work activities, or (3) Independent assessment 

or inspection of completed work activities. 

Guidance:

02.02.a Guidance for each of the direct inspection techniques indicated above is 

provided in Appendix 1 of this IP.

02.02.b Technical requirements are established by the final design of the facility. The 

final design is prescribed by a “flow-down” of technical requirements from the 

NRC-approved safety analysis report to design specifications and drawings. 

These design output documents will usually reference industry codes and 

standards that provide specific requirements for the design, fabrication, 

assembly, and testing of the SSC. 

02.02.c Quality requirements are first defined by 10 CFR 50, Appendix B. The 

applicant/licensee is required by 10 CFR Part 50 and Part 52 to describe how 

they intend to meet the requirements of 10 CFR Part 50, Appendix B in their 

quality assurance program description (QAPD). The QAPD is reviewed and 

approved by the NRC staff. The applicable quality assurance program 

requirements are further defined by the licensee’s quality assurance program 

implementing documents. 
Issue Date: 08/13/13 3 65001

02.02.d The IP 65001 procedures are not intended to implement a programmatic 

evaluation of Quality Assurance program effectiveness. This will be 

accomplished as part of inspections directed by IMC-2504. However, the

Inspectors should familiarize themselves with the quality assurance program 

requirements that apply to the work activity they are inspecting and, as 

applicable, evaluate the implementation of QA requirements directly 

applicable to the work activity being inspected. Generic guidance on QA 

inspection is included in Appendix 2. Additional guidance on evaluating QA 

Program implementation can be found in IP 35007, “Quality Assurance 

Program Implementation during Construction and Pre-Construction 

Activities.” Some of the attached IPs may also include specific QA program 

inspection requirements.

NOTE: When the licensee subcontracts the work activity to another 

organization, the requirements of 10 CFR 50, Appendix B must 

be appropriately passed down to the contractor. The licensee is 

always ultimately responsible for the quality of the SSC; 

therefore, the licensee should be providing an adequate level of 

quality assurance oversight of the contractor, even if the 

contractor has a QAPD that has been reviewed and approved by 

NRC staff. The inspectors should be cognizant of the adequacy 

of the licensee’s oversight. The inspectors, when appropriate, 

should review (or observe) applicable licensee audits and 

surveillances of their contractors. 

02.02.e The inspectors should document the specific quality assurance program 

elements that are inspected during each inspection within the scope section 

of the IP used. For example, if the inspector reviews a sample of corrective 

action documents associated with SSCs that are within the scope of a 

particular inspection, the inspectors should document the scope of that 

review under the applicable IP 65001 attachment.

02.03 ITAAC Acceptance Criteria Verification: The inspector should review the licensee’s 

plan for completion of the applicable ITAAC associated with the work activities that are within 

the scope of this IP. The inspectors should review this plan, and verify that the activities that the 

licensee intends to credit for future ITAAC closure were reviewed during the inspection. For 

example, if the licensee intends to rely on a specific QC observation during the installation of a 

SSC, the inspector should review a sample of these QC observations to determine whether the 

activity was performed in accordance with applicable quality and technical requirements. 

Guidance:

02.03.a The successful implementation of section 02.02 of this IP should ensure that the 

NRC has adequately inspected the activities which the licensee will rely on to 

support the closure of ITAAC; however, the NRC inspector should also verify that 

the inspected activities appropriately support ITAAC closure, and that they were 
Issue Date: 08/13/13 4 65001

adequate to ensure that the as-built facility satisfies the top level design and 

performance standards specified in the COL. 

02.03.b Inspectors should be aware that several ITAAC may have performance criteria and 

technical details related to more disciplines than just the IP being implemented. 

Accordingly, the inspection procedures may guide the inspectors to other related 

IPs. For example, if inspecting MOVs using the Valves IP, the guidance for 

performing an inspection of the motor will be found in the Electrical Components IP. 

Thus the inspector should reference the Electrical Components procedure as 

needed to support the specific inspection being performed. 

65001-04 RESOURCE ESTIMATE

There is no resource estimates associated with this portion of this procedure. All planning, 

coordination, and inspection resources expended in the conduct of IP 65001 activities should be 

allocated to one of the IPs attached to this procedure.

Inspections of ITAAC or related construction activities should be recorded in CIPIMS. The 

CIPIMS entry should identify the selected ITAAC and the specific IP(s) linked to the ITAAC.

END
Issue Date: 08/13/13 5 65001

Appendix:

Appendix 1: Additional Guidance on Direct Inspection Techniques

Appendix 2: Guidance on the Evaluation of QA Program Implementation

Additional Inspection Procedures associated with the ITAAC Matrix as listed in IMC 2503 AppA

65001.01 Inspection of ITAAC-Related Foundations and Buildings

65001.02 Inspection of ITAAC-Related Installation of Structural Concrete

65001.03 Inspection of ITAAC-Related Installation of Piping

65001.04 Inspection of ITAAC-Related Installation of Pipe Supports & Restraints

65001.05 Inspection of ITAAC-Related Installation of Reactor Pressure Vessel & Internals

65001.06 Inspection of ITAAC-Related Installation of Mechanical Components

65001.07 Inspection of ITAAC-Related Installation of Valves

65001.08 Inspection of ITAAC-Related Installation of Electrical Components & Systems

65001.09 Inspection of ITAAC-Related Installation of Electric and Fiber Optic Cable

65001.10 Inspection of ITAAC-Related Installation of Instrument Components & Systems

65001.11 Construction Inspection Program Inspection of ITAAC-Related Containment 

Integrity & Containment Penetrations

65001.12 Inspection of ITAAC-Related Installation of Heating, Ventilating, and Air 

Conditioning Systems

65001.13 Inspection of ITAAC-Related Installation of Load Handling Equipment & Fuel 

Racks

65001.14 Inspection of ITAAC-Related Installation of Complex Systems with Multiple 

Components

65001.15 Inspection of ITAAC-Related Installation of Fire Protection Equipment

65001.16 Inspection of ITAAC-Related Engineering

65001.17 Inspection of ITAAC-Related Security Structures, Systems, and Components

65001.18 Inspection of Emergency Planning ITAAC

65001.19 Inspection of Installation of ITAAC-Related Radiation Monitoring Components 

and Systems

65001.20 Inspection of Safety-Related Piping DAC-Related ITAAC

65001.21 Inspection of Pipe Rapture Hazard Analysis Design Acceptance Criteria (DAC) –

Related ITAAC

65001.22 Inspection of Digital Instrumentation and Control (DI&C) System/Software Design 

Acceptance Criteria (DAC) – Related to ITAAC

65001.23 Inspection of Human Factors Engineering Integrated System Validation ITAAC

65001.A ITAAC Attributes for As-Built Inspection

65001.B Inspection of the ITAAC-Related Welding Program

65001.C Inspection of the ITAAC-Related Construction Test Program

65001.D Inspection of the ITAAC-Related Operational Testing Program

65001.E Inspection of the ITAAC-Related Qualification Program

65001.F Inspection of the ITAAC-Related Design and Fabrication Requirements

Attachment 1: Revision History for IP 65001
Issue Date: 08/13/13 App1-1 65001

Appendix 1

Additional Guidance on Direct Inspection Techniques

Direct Observation:

- Observe in-process construction-related activities (fabrication, qualification, assembly, 

installation, inspection, examination, and testing) to determine whether the activity was 

performed in accordance with work control documents (e.g., applicable instructions, 

procedures, and/or drawings).

- During the observation of in-process construction-related activities, the inspectors should 

document relevant information to support other elements of their inspection. 

- For example, during the observation of a construction test, the inspectors should note 

the following: (1) name of person performing test, (2) version of test procedure, (3) serial 

numbers of measuring and testing equipment, (4) component serial number or other 

unique identifier, etc. This information can then be used to verify that test personnel 

were adequately qualified, that the correct version of the testing procedure was used, 

that the measuring and test equipment was properly calibrated, and that the equipment 

met the proper qualification requirements. 

Record Review:

- The inspectors should review a sample of completed records to determine whether the 

construction-related work activity was performed in accordance with applicable 

instructions, procedures, and/or drawings. For the records reviewed, the inspectors 

should determine whether the records were (1) adequate to furnish identifiable and 

retrievable evidence of activities affecting quality, and (2) met other requirements 

prescribed by the licensee’s record management program. 

- If possible, the inspectors should also perform a walk-down of the completed work 

activity associated with the records reviewed, to determine whether the as-built SSC 

conforms with the final design, construction documents, and the records reviewed. 

Independent Assessment/Inspection:

The inspectors may also conduct an independent assessment or inspection (walk-down, 

measurement, etc.) to determine whether the as-built SSC conforms to the final design. 
Issue Date: 08/13/13 App2-1 65001

Appendix 2

Guidance on the Evaluation of QA Program Implementation

The following inspection requirements do not represent all of the quality assurance 

requirements that apply to construction-related work activities, but are a general list of those 

requirements that can be reviewed during most routine inspections. As applicable, verify the 

following quality requirements:

a. QA Program (Criterion II): 

o Personnel Training and Qualification: Review a sample of training and 

qualification records for personnel involved with the installation, fabrication, 

assembly, and testing of SSCs to determine whether personnel were adequately 

qualified. 

o Controlled Conditions: For activities inspected, verify that the licensee has taken 

appropriate actions to assure that the activity was accomplished under suitably 

controlled conditions. Specifically, the inspectors should observe or review 

construction activities to determine whether the licensee used appropriate 

equipment; maintained suitable environmental conditions for accomplishing the 

activity, such as adequate cleanness; and verified that all prerequisites for the 

given activity have been satisfied.

b. Instructions, Procedures, and Drawings (Criterion V): During the observation and/or 

review of construction activities, the inspectors should verify that that appropriate 

implementing documents are available and being used in the performance of work 

activities.

c. Qualification and Certification of Material, Equipment, and Services (Criterion VII): The 

inspectors should review records to determine whether purchased material, equipment, 

and services conform to the procurement documents. 

d. Identification and Control of Materials, Parts, and Components (Criterion VIII): During 

the observation and/or review of construction activities, the inspectors should verify that 

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

or other appropriate means, either on the item or on records traceable to the item, as 

required.

e. Calibration of Measuring and Testing Equipment (M&TE) (Criterion XII): For the M&TE 

used, review calibration records to determine whether the equipment was properly 

controlled, calibrated, and adjusted at specified periods to maintain accuracy within 

necessary limits.
Issue Date: 08/13/13 App2-1 65001

f. Handling, Storage and Shipping (Criterion XIII): The inspectors should observe (e.g., 

walk-down) the licensee’s storage or work area to determine whether the licensee 

adequately controlled the handling, storage, shipping, cleaning and preservation of 

material and equipment in accordance with work and inspection instructions to prevent 

damage or deterioration. 

g. Nonconforming Materials, Parts, or Components (Criterion XV): The inspectors should 

review a sample of nonconformance reports associated with the work activity inspected 

to determine whether the nonconforming items were reviewed and accepted, rejected, 

repaired or reworked in accordance with documented procedures.

h. Corrective Action (Criterion XVI): The inspectors should review a sample of corrective 

action documents to determine whether the conditions adverse to quality were properly 

identified and corrected. 

i. Quality Assurance Records (Criterion XVII): For the records reviewed above, the 

inspectors should determine whether the records were (1) adequate to furnish 

identifiable and retrievable evidence of activities affecting quality, and (2) met other 

requirements prescribed by the licensee’s record management program.
Issue Date: 08/13/13 Att1-1 65001

Attachment 1 - Revision History For 65001

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

10/03/07

CN 07-030

Researched commitments for 4 years and 

found none.

Initial Issuance.

N/A N/A

N/A ML13182A233

08/13/13

CN 13-017

Complete re-write to address current 

inspection program policies.

Periodic update.

N/A ML13182A234