Issue Date: 12/14/15 1 69020

NRC INSPECTION MANUAL CCIB

INSPECTION PROCEDURE 69020

INSPECTIONS OF SAFETY-RELATED ITEMS (AND SERVICES) DURING CONSTRUCTION 

OF NON-POWER PRODUCTION AND UTILIZATION FACILITIES

PROGRAM APPLICABILITY: 2550

This procedure provides guidance for inspection of work activities associated with the 

construction of Non-power Production and Utilization Facilities (NPUFs). 

69020-01 INSPECTION OBJECTIVES

01.01 To determine if on-site construction of NPUFs is being accomplished in accordance 

with the construction permit, licensing basis, and other applicable quality, technical, and 

regulatory requirements.

01.02 To determine if the records reflect work accomplishment consistent with the 

construction permit, licensing basis, and construction specifications.

01.03 To determine if there are any potentially generic quality program problems that may 

warrant a follow-up quality assurance (QA) inspection.

69020-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 BACKGROUND

02.01.a The NRC will focus on direct inspections of construction activities at NPUFs

when practical. The items listed in the appendices of this inspection procedure 

(IP) may be inspected via records review and observation of the as-built 

condition of the items when direct observation of construction activities is not 

practical. Each of the appendices to this IP may be performed separately and 

should be performed at the appropriate time during plant construction for the 

items being inspected. However, to gain efficiency, 2 or more appendices may 

be performed concurrently. Some portions of the appendices may not be 

applicable to some NPUFs. Additionally, efficiency gains may be realized by 

performing QA program implementation inspections (IP 69021) in conjunction 

with this IP. The overall NPUF inspection philosophy is described in detail in 

Inspection Manual Chapter 2550, “non-power production and utilization facilities

(NPUF) licensed under 10 CFR Part 50: construction inspection program (CIP).”
Issue Date: 12/14/15 2 69020

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

applicable portions of the construction permit, licensing basis including the Safety 

Analysis Report (SAR), the final design, and the construction specifications. 

Inspectors should also review the Quality Assurance Program (QAP) and the 

licensing basis for the QAP. Most NPUFs are expected to commit to ANS/ANSI 

15.8, “Quality Assurance Program Requirements for Research Reactors.”

02.01.c As a part of the planning process, inspectors should ensure that the items

selected for inspections are safety-related. If construction of safety-related items

(and services) cannot be directly observed, then inspectors may conduct record 

review and observation of the as-built condition of safety-related items to fulfill 

the inspection requirements. If there are no safety-related items within the item

type for the facility, then the associated appendix in this IP for that item type need 

not be completed. 

02.02 INSPECTION GUIDANCE

02.02.a NRC inspections should include one or more of the following inspection 

techniques: (1) Direct inspection of in-process work activities, (2) Review of 

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

inspection of completed work activities. 

02.02.b Guidance for each type of item is provided in the appendices of this IP.

02.02.c 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 (SAR) to design specifications and 

drawings. The SAR and design output documents will usually reference industry 

codes and standards that provide specific requirements for the design, 

fabrication, assembly, and testing. Note that some facilities may use the term 

“license application,” or “LA” instead of SAR. These terms are considered 

synonymous for this inspection procedure.

02.02.d Quality requirements are first defined by the licensee’s QAP. The QAP

description is reviewed and approved by the NRC staff. The applicable quality 

assurance program requirements are identified in the licensee’s quality 

assurance program implementing documents. NPUFs will generally commit to 

and use ANSI/ANS 15.8, “Quality Assurance Program Requirements for 

Research Reactors,” to develop their QAP description.

02.02.e This IP is not intended to implement a programmatic evaluation of Quality 

Assurance program effectiveness. This will be accomplished as part of QA 

inspections directed by IMC 2550. However, inspectors should familiarize 

themselves with the quality assurance program requirements in the facility’s QAP 
Issue Date: 12/14/15 3 69020

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. 

02.03 ADDITIONAL GUIDANCE

02.03.a Direct Observation Techniques

Direct observation includes observing in-process construction-related activities 

such as fabrication, qualification, assembly, installation, inspection, examination, 

and testing to determine if the activity was performed in accordance with work 

control documents (e.g., applicable instructions, procedures, and/or drawings).

02.03.b Record Review:

Record review includes review of 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 asbuilt item conforms with the final design, construction documents, and the 

records reviewed. 

02.03.c Independent Assessment/Inspection:

The inspectors may also conduct an independent assessment or inspection 

(walk-down, measurement, etc.) to determine whether the as-built item conforms 

to the final design. 

02.04 INSPECTION COMPLETION

This inspection procedure is complete when the applicable appendices are completed once for 

the facility. Inspectors are not expected to complete every activity in the appendices of this IP. 

Instead, inspectors shall prioritize inspection activities during their visit to the site based on 1) 

importance of the activity to safety, 2) availability of the activity at the time of the inspection, and 

3) available inspection resources. Inspectors may consult with their supervisor and/or NRC 

headquarters technical staff, if necessary, to prioritize inspection activities. It is not anticipated 

that multiple site visits will be necessary to complete an appendix to this IP. An appendix to this 

IP need not be completed if there are no safety-related items (or services) covered by that 

appendix at an NPUF, and the value of inspection in the area is low compared to the amount of 

resources required for inspection. This decision should be documented 
Issue Date: 12/14/15 4 69020

69020-03 REFERENCES 

NOTE: Additional references specific to Appendix A through Appendix M are included in the 

Reference section of that appendix.

10 CFR Part 21, “Reporting of Defects and Noncompliance.”

10 CFR 50.55, “Conditions of construction permits, early site permits, combined licenses, and 

manufacturing licenses.”

69020-04 PROCEDURE COMPLETION

The implementation of this IP will be complete when each of the applicable portions of

applicable IP appendices has been completed once for the facility. Additional samples may be 

performed if NRC management has significant concerns regarding the quality of construction of 

the facility. Appendices that address items that are not applicable to a facility need not be 

performed for that facility. 

69020-05 RESOURCE ESTIMATE

Each of the appendices of this IP contains resource estimates for execution of that appendix.

END

Appendices:

Appendix A: Foundations and Buildings

Appendix B: Structural Concrete

Appendix C: Structural Steel and Supports

Appendix D: Piping Systems

Appendix E: Pipe Support and Restraints

Appendix F: Mechanical Components

Appendix G: Electrical Cable

Appendix H: Electrical Components and Systems

Appendix I: Ventilation and Confinement Systems

Appendix J: Instrumentation and Control Systems

Appendix K: Structural Welding

Appendix L: Nuclear Welding

Appendix M: Fire Protection Systems

Attachment

Revision History for IP 69020
Issue Date: 12/14/15 A-1 69020

APPENDIX A

INSPECTION OF FOUNDATIONS AND BUILDINGS AT NON-POWER PRODUCTION AND 

UTILIZATION FACILITIES

69020.A1-01 INSPECTION OBJECTIVES

01.01 To determine whether foundation work and related quality control activities for Seismic 

Category I (SC-1) and Seismic Category 2 (SC-2) structures are being performed in accordance 

with the licensing basis, construction specifications, drawings, and work procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to foundation and building activities is functioning properly, and to determine 

whether the records reflect work accomplishment consistent with specifications and procedures.

01.03 To verify that the as-built condition of SC-1 and SC-2 buildings meets the specified design 

requirements, specifications and drawings. For installation of concrete structures, also refer to 

Appendix B of this inspection procedure (IP). For structural steel components, also refer to 

Appendix C of this IP.

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with foundations and buildings is effective and to verify that deviations from 

requirements are appropriately resolved.

69020.A1-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the SC-1 and SC-2 buildings being constructed at the site. 

Inspectors should also be familiar with the licensee’s Quality Assurance Program (QAP) 

and the licensing basis for the QAP (NPUF licensees are expected to commit to the QAP 

requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for foundation and building work on-site at 

the time of the inspection, with SC-1 work being preferable to SC-2 work when available. 

Inspectors should also coordinate this appendix with inspection of structural concrete 

(Appendix B of this IP), and structural steel and steel supports (Appendix C of this IP) for 

efficiency, if possible. 

Inspectors should contact the licensee prior to the on-site inspection to help determine 

which building(s) are to be inspected. Observation during in-progress construction of the 

buildings is desirable but not required. If necessary, inspectors may select completed 

foundations and buildings for inspection. Inspectors should not attempt to inspect all of 

the buildings on the site, but may expand the inspection if time allows, or if significant 

concerns with the licensee’s control of foundation and building construction arise. 
Issue Date: 12/14/15 A-2 69020

Inspectors should collect licensee procedures, building specifications, and work 

completion records in advance, if possible. If unable to review these documents in 

advance of the on-site inspection, then the licensee should be notified that these 

documents, and any other relevant documents, should be available when the inspector(s) 

arrives at the site.

Inspectors should choose one or more SC-1 buildings and review the areas listed in 

02.02 through 02.06 to the extent practical, and may use their judgment in determining 

which areas to concentrate on, if time is limited. However, inspectors should gain an 

understanding of the licensee’s program to the extent necessary to determine if the 

licensee conforms to regulatory requirements.

02.02 For the building(s) selected for inspection, review construction procedures, construction 

specifications, drawings, and other relevant design documents to ensure that they 

conform to the commitments contained in the licensing basis. Determine whether 

appropriate and adequate procedures in the following areas are compatible with the QA 

program and prescribe adequate methods to meet the construction specifications, where 

applicable.

a. Excavation and subgrade preparation.

b. Foundation verification.

c. Placement of engineered fill and backfilling.

d. Dewatering.

e. QC inspection and testing.

f. Instrumentation and settlement monitoring.

g. Surveying.

h. Engineering direction.

i. Soil compaction and testing

02.03 If applicable to the project, perform a review of the results of the test-fill program before 

reviewing the implementing construction procedures, to verify that the fill procedures 

have been qualified. The implementing procedures should reflect the methods, 

equipment, materials, and conditions of the test-fill program.

02.04 Determine whether the licensee has an established audit program (including plans, 

procedures, and audit schedule) for assessing the adequacy of SC-I and SC-II work 

control functions, in the area of geotechnical/foundation activities, and for ensuring that 

examination, inspection, and test personnel associated with performing tests and 

inspections of geotechnical/foundation activities are qualified and/or certified to perform 

their assigned work.

02.05 Ascertain whether the following activities, if applicable, are being controlled and 

accomplished in accordance with the requirements of the documents reviewed in 02.02, 

above:

a. Excavation and Subgrade Preparation. 

1. The excavation methods and sequence of operations should not be detrimental 

to the final foundation subgrade materials.
Issue Date: 12/14/15 A-3 69020

2. Unusual or changed conditions encountered during excavation of cavities, faults, 

pockets of unsuitable material, springs, seeps, boils, and protrusions, are noted, 

investigated, evaluated, and taken into consideration.

3. The foundation subgrade should be free of organic or soft unsuitable material. 

Depressions or holes left by grubbing and stripping or excavation should be 

backfilled with suitable materials compacted and tested to the specified density 

and moisture content. Soil classification at the depth excavated for foundations 

should be verified and compared with the soil profile determined during subgrade 

explorations (bore holes, exploratory excavations, etc.). The occurrence of 

extraneous detrimental or unexpected soil may necessitate further investigation 

or evaluation/redesign. The finished grade should be as specified, meet 

compaction and density requirements, be protected from the elements, and be 

tested and inspected.

4. Determine whether the stockpiling and segregation of excavated materials which 

are to be used as SC-I fill material are in accordance with specifications.

5. The foundation subgrade treatment such as compaction, installation of 

foundation drains, or other methods should be properly controlled.

6. Determine whether QC inspections are adequate with regard to scope, 

frequency, and inspector qualifications.

7. The record-keeping activities should reflect the actual conditions encountered in 

the field and provide adequate documentation of work and inspections. 

Determine whether records are being maintained, reviewed, and approved as 

specified.

b. Foundation Verification.

Verify that geotechnical engineering direction is available. Foundation subgrades 

should be approved by an experienced geotechnical engineer before placement 

of engineered fill, mud mats, or structural concrete. Determine whether records 

are maintained to document approval of the final foundation subgrade. Records 

should include elevation, actual conditions, methods to achieve acceptable 

conditions, and inspection and test acceptance criteria and final acceptance 

results. 

c. Backfilling (Fill Materials and Compaction Control). 

1. Specified lift thicknesses are adhered to and specified equipment is being used 

with the correct number of roller passes.

2. Source material being used is identified and is traceable to an approved borrow 

source. The approved source material should meet design and earthwork 

specification requirements and have been properly qualified by an approved soils 

laboratory.

3. Ensure that engineered fill or backfill is placed at the proper location and on 

approved foundation materials.
Issue Date: 12/14/15 A-4 69020

4. Verify that in-place density tests are being performed at the required frequency 

with properly calibrated instruments (including moisture content tests). If a 

nuclear density test is performed using a nuclear density gauge or Troxler, verify 

that the instrument has been calibrated and radioactive source leak checks have 

been performed.

5. Samples for laboratory tests are being taken at the required frequency, chain-ofcustody established, and the samples are adequately identified. Review the 

results of the required tests and compare results to design specification requirements and applicable standards.

6. Inspection activities (QA and QC) are being performed as required by qualified 

and/or certified personnel. Review inspection documentation and verify that the 

records quantitatively define actual construction conditions and QC qualitative 

test results.

d. Dewatering Systems. Note that 1 and 2 below represent good practice, but are 

not requirements unless specified in the site specifications.

1. Emergency power supply to ensure continuous dewatering system operation is 

being maintained and tested.

2. Open excavations are protected from flooding by an adequate sump pump 

system.

3. Piezometric surfaces are being defined by monitoring performed at the required 

frequency.

4. Inspection and testing of system discharge should assure that sediment material 

is not being removed from the foundation.

e. QCl Inspection and Onsite Testing Laboratory. 

1. If applicable, the onsite laboratory has performed verification of laboratory 

personnel qualifications (education and experience) of testing and inspection 

personnel. Personnel qualification verifications must be supported by objective 

evidence documenting education and experience.

2. Test results are being evaluated at an appropriate level and evaluation includes 

trend analysis.

3. Observed testing standards conform to the procedures specified in the American 

Society for Testing and Materials.

4. Testing apparatuses are calibrated at the required frequency and calibration 

traceable to a nationally recognized standard and calibration is in accordance 

with approved procedures.

5. Records reflect the results of inspections, the actual field conditions, testing 

frequency requirements, acceptance criteria, and data calculations are checked.
Issue Date: 12/14/15 A-5 69020

f. Instrumentation and Settlement-Monitoring Program.

1. Number, location, and type of instruments are appropriate.

2. Instrumentation and settlement-monitoring systems installed before start of 

activity being monitored.

3. Instrumentation and settlement-monitoring systems are installed as specified, 

functioning properly, and protected against construction hazards.

4. Operation and monitoring: operations are monitored at specified frequency to 

assure that construction activities have not made installed instrumentation 

inoperable.

5. Calibration of measuring and testing equipment is maintained, logged and 

functionally checked.

6. Recordkeeping activities: records reflect specified frequency of monitoring, data 

checks (e.g., supervisory review, engineering review), data evaluated and 

accepted. This is important in activities such as settlement monitoring. A 

comparison of the actual settlement data with those predicted can reveal 

problems at an early stage, enable the cause to be determined relatively early in 

the construction phase, or can cause design changes to be incorporated before 

the completion of extensive construction work.

g. Surveying. The instruments are properly calibrated, and calculations are checked 

to assure accurate results.

h. Engineering Direction. Engineering direction is available onsite to monitor 

geotechnical/foundation construction activities. The onsite engineering staff should 

be supplemented by an experienced geotechnical engineer to approve final 

foundation subgrade materials, monitor and review QC inspection and test results, 

and identify changed field conditions. The onsite engineering staff should be 

involved in disposition of nonconformance reports, and prepare engineering field 

change requests for approval by the engineering design agent or organization. 

i. Personnel Interviews. Informal interviews with field-craft and inspection personnel 

may be randomly conducted to determine how well employees know the 

requirements of their work activity. Ascertain whether a sufficient number of 

adequately qualified QA and inspection (QC) personnel are at the construction site, 

commensurate with the work in progress, and adequately performing their 

assigned duties through the established organizational structure.

02.06 Review the documentation generated for the geotechnical/foundation activities. 

Determine whether the licensee/contractor system for documenting safety-related work is 

functioning properly. Records should be legible, complete, reviewed by QC and/or 

engineering personnel, and readily retrievable. 

a. Receipt Inspection and Material Certification (if applicable). Applicable for 

materials purchased from offsite suppliers such as drainage materials, 
Issue Date: 12/14/15 A-6 69020

geosynthetic fabrics, select fill materials, sand and gravel, instrumentation, and 

dewatering system components. Records confirm that required material 

characteristics, performance tests, civil soil tests, nondestructive tests, and other 

earthwork specification requirements were met.

b. Installation Inspection. Records confirm that specified materials and components 

were installed as specified and that the required inspections were performed and 

acceptance criteria are defined.

c. Nonconformance/Deviation Record. Records include current status of these items. 

Nonconformance reports include the status of corrective action or resolution, (e.g., 

determine whether adequate corrective action is being taken when moisture 

density test results are not within tolerance or acceptance criteria.

d. Training/Qualification Records of Craft, QA, and Inspection (QC) Personnel. 

Records establish that QA/QC personnel are adequately qualified for their 

assigned duties and responsibilities and that craft personnel have been trained in 

their assigned tasks.

e. QA Audits. Records establish that the required audits were performed and that 

deficiencies identified during audits were corrected, and that corrective action was 

such that repetition of the deficiency, or similar deficiencies, would be precluded.

69020.A1-03 ADDITIONAL GUIDANCE

03.01 Prevalent Errors and Concerns. Prevalent errors and recent concerns are areas in which 

the inspector should be alert to potential generic issues. These areas include:

a. Insufficient compaction of foundation and backfill materials was identified at several 

sites, as described in IE Circular 81-08.

b. Placement of fill for control of compaction requires control of ground-water levels.

c. QC test results need to be reviewed and trended to assure that tests are performed in 

accordance with specification requirements, that the results are reasonable, that the 

results meet requirements, and that locations where samples/tests were obtained 

(location and elevation) can be accurately identified. Test deficiencies need to be 

entered into the corrective action program and evaluated by engineering personnel.

d. QA audits should identify procedural inadequacies or the cause of repetitive 

nonconforming conditions.

03.02 Background Information. This information is to be used as reference material; however, 

the site specifications govern. The information may be valuable in discussions about the 

adequacy of the specifications.
Issue Date: 12/14/15 A-7 69020

a. Foundation Subgrade

1. Excavation. Unexpected conditions are frequently encountered, ranging from 

unfavorable deposits of materials not found in the exploratory program, to 

problems not identified in previous site studies.

Where unfavorable conditions are encountered, further exploration by test pits, 

borings, or other means are necessary to define the extent and nature of 

conditions. The effect of the unexpected conditions must be evaluated in relation 

to the original design. Examples of common unfavorable conditions frequently 

encountered are:

(a) Highly compressible and low-strength soils;

(b) Collapsible soils - low-density soils that collapse when saturated;

(c) Old river channels;

(d) Cavities and solution features;

(e) Overhangs and surface depressions;

(f) Springs or artesian conditions; and

(g) Unstable excavation slopes because of unanticipated conditions.

2. Excavation materials are frequently used as engineered fill or backfill around and 

under SC-I and SC-II structures. The inspector should determine whether these 

materials have been qualified through explorations and testing by a soils testing 

laboratory and whether they are stockpiled in designated areas. Excavated 

materials to be used as SC-I and SC-II structural fill, should be excavated in 

layers, so that widely varying soil classes are not mixed. Some of the more 

common tests used for qualifying soils materials, and their associated standards, 

are:

(a) Moisture/density relationships, ASTM D-698 or D-1557;

(b) Soil-classification tests, ASTM D-2487;

(c) Particle-size analysis, ASTM D-422;

(d) Test for plastic limit and plasticity index, ASTM D-424; and

(e) Other Codes and Standards, as listed in ASME NQA-1.

A geotechnical engineer should control acceptance and qualification of 

excavated materials.

b. Foundation Verification - Undisturbed Soil. A geotechnical engineer should approve 

soil subgrades before placement of engineered fill, mud mats, or structural concrete. 

Compaction is the usual method to treat or stabilize loose, disturbed, or unsuitable 
Issue Date: 12/14/15 A-8 69020

c. areas in soil subgrades. The inspector should determine whether appropriate 

sampling and testing procedures are included to verify the material in place is as 

specified. Common tests used to verify that foundation subgrades meet design 

specifications are listed in Appendix B, “Methods of Subsurface Exploration”, of 

Regulatory Guide 1.132, “Site Investigations for Foundations of Nuclear Power 

Plants.”

d. Backfilling. In some instances, preparation for foundations may consist merely of 

excavation and grading to appropriate dimensions. However, in many locations, the 

top layer of native site material may be too soft, or otherwise unsuitable, to properly 

support the structures. In this case, some special comp active effort may be required. 

Occasionally, adequate compaction may be achieved on the native material in place 

in conjunction with careful control of groundwater level. More typically, it will be 

necessary to remove the native material and fill the resultant excavation under 

carefully controlled procedures, in relatively thin layers, sequentially compacted.

Before placing engineered fills, materials and compaction requirements should be 

qualified by laboratory tests and test fills. Required moisture/density relationships for 

each material should be determined in accordance with either ASTM D-698 or ASTM 

D-1557. The inspector should be assured that the specified method is being used. 

Where impervious materials are used, qualification tests should include determination 

of the Atterberg Limits (“Liquid Limit, Plastic Limit and Plasticity Index”, ASTM 

D-4318). Particle-size analysis should also be made, as specified by test methods in 

ASTM D-422 and ASTM D-1140.

Test fills for each material type should be made to determine lift thickness, type of 

compaction equipment, and number of passes to be used in compacting fills to 

specified densities.

In-process testing used to control fill placement, for the most part, will be density tests 

and moisture tests. Acceptance will be in terms of some percentage of the maximum 

dry density (usually 95 percent) and a moisture content within some percentage of 

optimum (usually 2 percent) as determined by ASTM D-698 or ASTM D-1557. 

Density tests may be made by test methods ASTM D-1556 (most common method 

used); ASTM D-2167; ASTM D-2922, or ASTM D-2937. Test-method ASTM D-2922, 

the nuclear method, must be calibrated against a reliable direct method. 

Control of moisture content at time of compaction is extremely important, especially 

with materials having more than 12 percent passing a No. 200 sieve. Testing and 

research has demonstrated that variation of the moisture content of a material, at time 

of compaction, even though it has been compacted to the same dry density, has a 

wide-ranging effect on the shear strength, permeability, and consolidation 

characteristics of the material. Ultimate control of moisture should be by test-method 

ASTM D-2216, “Laboratory Determination of Moisture Content of Soil”. Rapid 

methods, such as the "Speedy" and field stoves, are sometimes used to expedite 

operations, because of the time required for test-method ASTM D-2216. Where rapid 

methods are used, they should be calibrated against ASTM D-2216, and their 

variation taken into consideration in controlling moisture content of the fill. For 

example, if the specified moisture control is 2 percent of optimum and calibration 

checks show that the rapid method varies by 1 percent from ASTM D-2216, then field 
Issue Date: 12/14/15 A-9 69020

control using the rapid method should be held to 1 percent of optimum. Field-stove 

methods should be limited to granular materials, with little or no fines, since 

experience shows results with impervious materials are erratic (probably because of 

driving off the water of hydration).

d. Dewatering Systems. Some degree of groundwater control will be required, at least 

during site preparation and foundation placement. Groundwater removal may be 

required to properly compact the soil-bearing area. The design may require that 

groundwater be permanently maintained below some specified elevation.

Excavations and placement of fill and foundations must be in the dry state. Discharge 

outlets of dewatering systems should be monitored for sediment content, to assure 

that subgrades are not being undermined. Dewatering systems, if not properly 

designed, installed, and operated, can have an adverse effect on foundations. 

Improper design and operation can, and have, resulted in undermining of foundations 

through removal of sediment with the discharge water. The inspector should assure 

himself that careful consideration has been given to the impact that the installation, 

operation, shutting down, and decommissioning of the system will have on foundation 

design. Through observations, the inspector should satisfy himself that the system 

has been installed and is being monitored as specified. Piezometers or observation 

wells should be used in conjunction with the dewatering system, to monitor the 

groundwater surface and pore pressure beneath the subgrade and adjacent ground.

Acceptable methods for installation and maintenance of piezometers and observation

wells are presented in the U.S. Army Corps of Engineers Manual, EM 1110-2-1908, 

1972.

e. Testing Laboratory. Acceptance of all earthwork onsite, including verification of soil 

foundations, engineered fill and backfill, for the most part, will be based on testing 

done by the site-soil laboratory. The inspector should routinely check the soils 

laboratory during inspections. The inspector should ensure that work is being done in 

accordance with specified methods and with specified equipment that is periodically 

calibrated for accuracy. Testing personnel should check data calculations for 

accuracy and the inspector should spot check them.

Qualifications of testing personnel should be checked by personal interviews, 

examination of certification records, and licensee's procedures and records, to verify 

contractor's qualification records.

f. Instrumentation- and Settlement-Monitoring Programs. Instrumentation will, for the 

most part, consist of settlement monuments for monitoring settlement and 

piezometers, or well points for monitoring the groundwater surface and pore pressure. 

Specific guidance regarding their use, installation, and maintenance is presented in 

the U.S. Army Corps of Engineers Manual EM 1110-2-1908. The inspector should 

ensure that the instrumentation is installed as specified, is adequate for the intended 

use, and that accuracy of the data recorded is sufficient to provide needed 

information. The instruments should be monitored periodically, throughout 

construction, and, if needed, post-construction.
Issue Date: 12/14/15 A-10 69020

69020.A1-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate.

69020.A1-05 REFERENCES

Office of Inspection and Enforcement, IE Circular No. 81-08, “Foundation Materials”, May 29, 

1981.

U.S. Army Corps of Engineers, “Instrumentation of Earth and Rock-Fill Dams (Groundwater and 

Pore Pressure Observations)”, Engineer Manual EM 1110-2-1908.

U.S. Army Corps of Engineers, “Soil Sampling”, Engineer Manual EM 1110-2-1907.

U.S. Department of the Army, “Dewatering and Groundwater Control for Deep Excavations”, 

Technical Manual TM 5-818-5.

U.S. Department of the Army, “Grouting Methods and Equipment”, Technical Manual TM 

5-818-6.

American Society of Testing and Materials, ASTM D-422, “Particle Size Analysis of Soils”.

American Society of Testing and Materials, ASTM D-653, “Terms and Symbols Relating to Soil 

and Rock”

American Society of Testing and Materials, ASTM D-698, “Moisture-Density Relations of Soils”.

American Society of Testing and Materials, ASTM D-1140, “Test for Amount of Material in Soils 

Finer than No. 200 Sieve”.

American Society of Testing and Materials, ASTM D-1143, “Testing Piles under Axial 

Compressive Load”.

American Society of Testing and Materials, ASTM D-1452, “Practice for Soil Investigations and 

Sampling by Auger Borings”.

American Society of Testing and Materials, ASTM D-1556, “Test for Density of Soil in Place by 

the Sand-Cone Method”.

American Society of Testing and Materials, ASTM D-1557, “Moisture-Density Relations of 

Soils”.

American Society of Testing and Materials, ASTM D-1586, “Penetration Test and Split-Barrel 

Sampling of Soils”.

American Society of Testing and Materials, ASTM D-2049, “Test for Relative Density of 

Cohesion less Soils”.
Issue Date: 12/14/15 A-11 69020

American Society of Testing and Materials, ASTM D-2167, “Test for Density of Soil In place by 

the Rubber-Balloon Method”.

American Society of Testing and Materials, ASTM D-2216, “Laboratory Moisture Content of 

Soil”.

American Society of Testing and Materials, ASTM D-2487, “Classification of Soils for 

Engineering Purposes”.

American Society of Testing and Materials, ASTM D-2488, “Practice for Description and 

Identification of Soils”.

American Society of Testing and Materials, ASTM D-2922, “Tests for Density of Soil and 

Soil-Aggregate In place by Nuclear Methods (Shallow Depth)”.

American Society of Testing and Materials, ASTM D-2937, “Test for Density of Soil In place by 

the Drive-Cylinder Method”.

American Society of Testing and Materials, ASTM D-3017, “Moisture Content of Soil and 

Aggregate in Place by Nuclear Methods”.

American Society of Testing and Materials, ASTM D-4253, “Test Methods for Maximum Index 

Density of Soils and Calculation of Relative Density”

American Society of Testing and Materials, ASTM D-4318, “Test Method for Liquid Limit, Plastic 

Limit, and Plasticity Index of Soils”.

END
Issue Date: 12/14/15 B-1 69020

APPENDIX B

INSPECTION OF STRUCTURAL CONCRETE AT NON-POWER PRODUCTION AND 

UTILIZATION FACILITIES

69020.A2-01 INSPECTION OBJECTIVES

01.02 To determine whether structural concrete work and related quality control activities for 

Seismic Category I (SC-1) and Seismic Category 2 (SC-2) structures are being performed in 

accordance with the licensing basis, construction specifications, drawings, and work 

procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to structural concrete activities is functioning properly, and to determine whether 

the records reflect work accomplishment consistent with specifications and procedures.

01.03 To verify that the as-built condition of structural concrete structures meets the specified 

design requirements, specifications and drawings. For foundations and buildings, also refer to 

Appendix A of this inspection procedure (IP). For steel components, also refer to Appendix C of 

this IP.

01.04 To determine if the implementation of the quality assurance program related to

work activities associated with structural concrete is effective and to verify that deviations from 

requirements are appropriately resolved.

69020.A2-02 INSPECTION REQUIREMENTS

02.01 Inspectors should review the facility description in the safety analysis report (SAR) and be 

familiar with structural concrete construction activities at the site. Inspectors should also 

be familiar with the licensee’s Quality Assurance Program (QAP) and the licensing basis 

for the QAP (NPUF licensees are expected to commit to the QAP requirements of 

ANS/ANSI 15.8, “Quality Assurance Program Requirements for Research Reactors”). It 

is not the objective of this IP to verify the adequacy of the licensee’s QAP, but inspectors 

should be prepared to identify any weaknesses in the licensee’s QAP for future 

inspections. Inspectors should complete this appendix by inspecting the attributes listed 

in this appendix for structural concrete work on-site at the time of the inspection, with SC1 work being preferable to SC-2 work when available. Inspectors should also coordinate 

this appendix with inspection of foundations and buildings (Appendix A of this IP), and 

structural steel and supports (Appendix C of this IP) for efficiency, if possible. 

Inspectors should contact the licensee prior to the on-site inspection to determine what 

work activities are to be inspected. Observation during in-progress construction is 

desirable but not required. If necessary, inspectors may select completed work activities

for inspection. Inspectors should not attempt to inspect all structural concrete on the site, 

but may expand the inspection if time allows, or if significant concerns with the licensee’s 

control of structural concrete work activities arise. 
Issue Date: 12/14/15 B-2 69020

Inspectors should collect licensee procedures, work activity specifications and work 

completion records in advance, if possible. If unable to review them in advance of the onsite inspection, then the licensee should be notified that these documents, and any other 

relevant documents, should be available when the inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.06 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Review construction specifications related to structural concrete construction and 

ascertain whether the specified technical requirements conform to the commitments 

contained in the licensing basis. Review concrete construction procedures and verify that 

they specify provisions for adequate on-site engineering direction, are appropriate and 

adequate related to procurement and use of materials, specify adequate control of hold 

points, and provide adequate controls for design changes and incorporation of design 

changes into as-built drawings. Determine if appropriate and adequate procedures in the 

following areas are compatible with the QA program, and prescribe adequate methods to 

meet the construction specifications, where applicable:

a. Qualification of materials (cement, water, aggregate, and admixtures).

b. Concrete mix design.

c. Concrete batch plant.

d. Preplacement activities (concrete forms, rebar and splices, embedded items, 

cleanliness, and inspection).

e. In-process testing of plastic concrete (slump, entrained air, temperature, unit weight, 

and cast cylinders).

f. Concrete placement activities and inspection of concrete placement activities.

g. Post-placement activities (adequate curing and identification and repair of defects).

h. Evaluation and review of concrete test results.

i. Engineering direction.

j. Qualifications of QC personnel.

02.03 Ascertain whether the following applicable structural concrete construction activities are 

being controlled and accomplished in accordance with the requirements of the 

documents reviewed in 02.02, above:

a. Qualification of materials - Review the qualification testing for the materials (cement, 

water, aggregate, and admixtures) selected for use in the concrete. Review the 

qualification tests for other hardware associated with structural concrete, such as 

reinforcing steel, rebar splices, curing compounds, embedded items, etc.

b. Concrete mix design - Review the concrete mix designs, supporting material 

qualifications, and testing to be used in SC-I and SC-II structures. If more than three 

concrete mix designs are used, review a sample of the highest strength or most-used 

mixes, and the associated material qualifications.
Issue Date: 12/14/15 B-3 69020

c. Concrete batch plant. Verify the following:

1. Batch plant has been inspected and certified to the appropriate standards. 

Scales and meters are calibrated at necessary frequency and to specified 

tolerances. Mixer-efficiency tests are being performed in accordance with 

American Society for Testing and Materials (ASTM) C-94 (or the committed 

standard in the licensing basis), at proper intervals. Batch plant is inspected to 

verify equipment performs properly - rotation speed, timing, and blade wear are 

not excessive. There should be no contamination of materials or concrete mix. 

Batch records are generated, controlled, and indicate placement location, mix, 

volume, date, time, and special instructions.

2. Materials are properly qualified and traceable to approved sources. Storage and 

handling of materials are controlled:

(a) Cement (and fly ash, if used) are protected from moisture;

(b) Aggregate is not subject to excessive segregation of sizes or

contamination from debris, dirt, other materials, or mixing with other sizes 

of aggregates;

(c) Admixtures are prevented from freezing; and

(d) There are provisions for production of concrete in hot weather (replacing 

water with ice in concrete mix) and cold weather (heating mix water).

3. Batch water-quality requirements are met and water is adjusted to account for 

moisture-content of aggregates. Aggregate moisture-content tests are 

representative of actual stockpile conditions and are taken periodically, during 

daily concrete production.

4. Concrete transporting equipment is suitable and in an acceptable condition.

d. Preplacement activities (concrete forms, rebar and splices, embedded items, 

cleanliness, and inspection). Verify the following items have been implemented:

1. Reinforcing steel and embedment’s, such as anchor bolts, water stops, or 

embedded plates, are installed in accordance with specifications, codes, 

drawings, and procedures. Reinforcing steel size, spacing, lap and mechanical 

splices, and embedment’s, are located properly within the forms, are secured 

and clean (i.e., free from oil, paint, weak dried mortar, dried mud, loose rust, etc.) 

and have proper clearances. The areas where embedded plates with anchors 

such as Nelson studs are to be set in concrete should have sufficient concrete to 

provide bond and should not be excessively congested with reinforcing steel. 

Reinforcing steel bending is properly performed and controlled. Piping or conduit 

embedment’s in or through concrete should be capped or plugged before to 

concrete placement.

2. Mechanical Rebar Splices. Verify the following:

(a) Process (e.g., cadweld or bar-lock couplers) and crews are qualified.
Issue Date: 12/14/15 B-4 69020

(b) Each splice is defined by materials used, location, crew, type of splice, and 

heat number (if applicable).

(c) Sampling and testing are performed at proper frequency and acceptance 

criteria are defined.

(d) Inspections are performed during and after splicing by qualified inspection 

personnel.

3. Preplacement planning and training have been completed, as required, to ensure 

good-quality construction, and to protect against unplanned construction joints.

4. The placement has been cleaned and joint preparation is as specified in the 

construction specification. Locations of construction joints are as shown on the 

drawings. Forms are secure, leak-proof, and free from water, ice, or snow. 

The QC pre-placement inspection should be completed before any concrete is 

placed. Records should document that all preplacement inspections have been 

completed.

5. The equipment to deliver concrete to the actual placement location is suitable 

and in an acceptable condition - conveyors, lines, pumps, buckets, etc. Ensure 

that there are enough concrete vibrators on hand, with extras on standby, for 

consolidating concrete. Sufficient access available to placement location for 

vibrator operators, concrete placement equipment, inspection personnel, and 

other craftsman. Adequate preparations for curing, protection from rain, and hot 

or cold weather protection are completed before the start of concrete placement 

activities.

e. In-process testing of plastic concrete. The following items should be verified in the 

review of the testing program conducted during concrete placement:

1. Concrete is sampled at the proper frequency for determination of temperature, 

slump, air content, and unit weight. 

2. Taking of a sample and testing techniques conform to the procedures specified in 

applicable ASTM standards. Samples for pumped concrete are required to be 

obtained from the end of pump line, at point of placement. 

3. Test specimens (cylinders), for concrete strength testing are sampled at the 

required location and frequency. Cylinders are molded, handled, and cured in 

accordance with specified requirements. Curing boxes are available to properly 

store and cure cylinders for the first 24 hours, per the requirements of ASTM C31 (if applicable).

4. Testing apparatuses in the onsite laboratory used to perform testing on materials 

and plastic concrete are being calibrated at the required frequency. Observed

testing conforms to the procedures specified in the applicable ASTM standards.
Issue Date: 12/14/15 B-5 69020

5. Personnel performing sampling and testing are trained and qualified.

6. Concrete-testing personnel have authority to reject concrete batches not meeting 

specification requirements.

f. Concrete placement activities. 

1. Concrete batch tickets are reviewed for verification of proper mix, placement 

location, and amount of water, if any, withheld from the batch. The quantity of 

withheld water, also referred to as retempering water, is determined based on the 

maximum water-cement ratio. Time limit (normal maximum of 1.5 hours) 

between mixing and delivery has not been exceeded, and the total number of 

revolutions of the truck mixer does not exceed 300. (See ASTM C-94.)

2. Specification temperature limits have been met.

3. Addition of super water-reducing (super plasticizers) admixturers to concrete 

batches are controlled. When admixtures or withheld water are added after 

concrete is discharged from batch plant, remixing in the truck for a minimum of 

an additional 30 revolutions of the truck mixer is required to conform to ASTM 

C94, on uniformity of mix. After addition of super plasticizers or withheld water 

and remixing, slump tests should be performed to confirm the slump is within 

specification limits.

4. Placement drop distances do not exceed specification requirements and do not 

result in segregation.

5. Vibrators are approved, tested for frequency, and are used properly by trained 

individuals.

6. Special attention is given to areas of high reinforcing or embedment steel 

congestion, to preclude areas of voids or honeycombing.

7. Inspections during placement are performed as required and by qualified 

personnel.

8. Records are produced, reviewed, and indicate mix, location, time placed, water 

additions, and temperature of the concrete mix and ambient conditions. Records 

reflect the results of inspections, the actual field conditions, testing frequency 

requirements, and that data calculations are checked.

g. Post-placement Activities (adequate curing and identification and repair of defects)

1. Verify that curing is performed in accordance with specifications and procedures 

with regard to the method, materials, duration, and temperature (concrete and 

ambient). Verify that inspections (during curing and after form removal) are 

performed and documented in QC records.
Issue Date: 12/14/15 B-6 69020

2. Verify that concrete placements are inspected after form removal to identify any 

defects in concrete. Examples of defects are voids (honey comb), cold joints, 

excessive cracking, delamination’s, excessive entrapped air voids (bug holes), or 

evidence of form-related defects such as sand streaking or inadequate bracing. 

All identified defects require documentation, evaluation, and repair, in 

accordance with the licensee’s QA program. 

h. Evaluation and Review of Concrete Test Results

Verify that the final inspection results after form removal, test results, and other 

information related to the placement (including deficiencies, defects, etc.) have been 

reviewed before acceptance of the placement, and that the as-built documentation is 

complete. Verify test results are evaluated at an appropriate level and evaluation 

includes trending analysis. All non-conforming conditions identified during concrete 

construction activities require documentation, evaluation, and repair, in accordance 

with the licensee’s QA program. 

i. Engineering Direction. 

Verify that engineering direction is available, onsite, to monitor structural concrete 

construction activities. The onsite engineering staff should be supplemented by an 

experienced structural engineer to approve design changes, monitor and review QC 

test results, and identify changed conditions. The onsite engineering staff should be 

involved in disposition of nonconformance reports, and preparation of field change 

requests, for approval by the design-engineering organization. 

j. Qualifications of QC Personnel

Verify that personnel qualifications (education and experience) of testing and inspection

personnel have been verified by the employing organization. Personnel qualifications 

must be supported by documentation. Informal interviews may be conducted with QC 

inspection personnel to determine how well the QC inspectors know the requirements 

of their work activity. Ascertain whether a sufficient number of adequately qualified QC 

personnel are at the construction site, commensurate with the work in progress, and 

adequately performing their assigned duties through the established organizational 

structure.

02.04 Special Considerations - The following items should be incorporated in the inspection of 

concrete placements when appropriate (refer to American Concrete Institute standards 

for additional guidance):

a. Hot and Cold Weather - Provisions for maintaining concrete temperature within 

specification must be provided. Hot and cold weather conditions must be defined, to 

avoid confusion.

b. Pumping Concrete - Slump and air-content losses must be monitored to ensure 

placement and adequate consolidation. Samples for pumped concrete are required to 

be obtained from end of pump line, at point of placement.
Issue Date: 12/14/15 B-7 69020

c. Large Placements - Planning sessions must assure consideration of all contingencies, 

[e.g., adverse weather, loss of power, concrete production delays (batch plant 

breakdowns)].

02.05 Determine whether the licensee has an established audit program (including plans, 

procedures, and schedule) covering the SC-I and SC-II work control functions, in the area 

of structural concrete construction activities. An audit program should review by 

examination of objective evidence that construction personnel who perform structural 

concrete construction work are qualified to perform their assigned work.

02.06 Review the documentation generated for structural concrete construction activities. 

Determine whether the licensee/contractor system for documenting safety-related work is 

functioning properly. The record-keeping activities should reflect the actual conditions 

encountered in the field and provide adequate documentation of work and inspections. 

Determine whether records are being maintained, reviewed, and approved, as specified. 

This is important in activities such as review of concrete strength. A comparison of the 

actual concrete strength can help in determining the reason for low strengths relatively 

early in the construction phase, before the completion of extensive concrete work. 

Records should include sufficient detail to document that: (1) rebar installation met 

requirements; (2) the concrete strength meets design requirements; (3) curing was 

adequate; and (4) repairs, if necessary, completed in accordance with design 

requirements. Records should be legible, complete, reviewed by QC and/or engineering 

personnel, and readily retrievable. Review a sample of the following records:

a. Receipt Inspection and Material Certification. 

Applicable for materials purchased from offsite suppliers, such as cement, concrete 

aggregate (sand and gravel), concrete admixtures, and reinforcing steel, splices, and 

other components. Records confirm that required material characteristics, performance 

tests, nondestructive test, and other specification requirements were met.

b. Installation Inspection.

1. Records confirm that concrete production, concrete placement, and installation of 

components were performed as specified.

2. Records confirm that the required inspections (including concrete form removal) 

were performed and acceptance criteria defined.

3. Records indicate specified concrete strength was obtained.

c. Nonconformance/Deviation Record - Records include current status of these items. 

Nonconformance reports include the status of corrective action or resolution e.g., if 

adequate corrective action were taken when concrete vibration was determined to be 

inadequate, or concrete strength-test results were not within acceptance criteria.

d. Training/Qualification Records of Craft, QA, and QC Personnel - Records establish that 

QA/QC personnel are adequately qualified to perform their assigned duties and 
Issue Date: 12/14/15 B-8 69020

responsibilities and that craft personnel have been trained in their assigned tasks. 

Records are complete and current and show which activities inspectors are qualified to 

perform.

e. QA Audits - Records establish that the required audits were performed and that 

deficiencies identified during audits were corrected, and that corrective action was such 

that repetition of the deficiency, or similar deficiencies, would be precluded.

69020.A2-03 ADDITIONAL GUIDANCE

03.01 General Guidance.

The American Concrete Institute "Manual of Concrete Inspection" is a good reference, 

which may be used during the conduct of this inspection. However, the licensee's 

specific documents, which include specifications, drawings, and procedures, specify and 

control the construction and inspection processes.

Before any concrete placement, a specific technical review of concrete-mix designs and 

supporting material qualifications should be performed. The inspectors should also verify 

that the batch plant has been inspected and certified before placement of any safetyrelated concrete. QA/QC inspection and construction procedures should be reviewed 

and compared with the requirements of the applicable codes and construction 

specifications. The technical adequacy of implementing construction and QC procedures 

must be determined. For these reasons, this inspection procedure should be performed 

by an inspector who is able to evaluate civil engineering activities. 

The licensee is responsible for implementing, or having implemented, the approved QA 

program and the commitments described in the licensing basis and construction 

application. The inspector must determine if this program is implemented in an adequate 

and manner for the work that is important-to-safety. QA/QC procedures must provide for 

effective inspections which will ensure that work is performed in accordance with 

specification requirements. Laboratory and field-testing procedures must provide for 

verification of correct material usage and correct selection of reference standards. The

testing procedures should include a prohibition against contractor QC personnel from 

making a discretionary selection of inspection and testing parameters. Qualified 

personnel should review test results and determine if results are acceptable. 

Construction procedures must reference the required inspection hold points and must 

also address the QA/QC department stop-work authority.

Specific information about the licensee's plans and schedules for performing 

comprehensive audits and on-going surveillance of concrete construction activities should 

be reviewed during this inspection. Information should be obtained concerning audit 

procedures, schedules, scope, and auditor qualifications. Licensee onsite QA staffing 

and surveillance plans should ensure that QC activities are sufficiently monitored and 

evaluated. QA audits should identify procedural inadequacies and the root-cause of 

repetitive nonconforming conditions. Inspections should require verification of specified 

controls and should not be accomplished merely by surveillance. Evaluations should 
Issue Date: 12/14/15 B-9 69020

result in an indication that all quality-related construction and inspections will be 

adequately performed by qualified personnel and will be based on appropriate criteria 

and further, that the results of inspections will be transmitted to responsible QA and 

management personnel. 

03.02 Specific Guidance

Note: The numbering of the guidance below refers to specific subsections of 02, above.

02.01 Specific attention should be given to the QA program needs that may result from 

distribution of design and construction responsibilities. Examples of these needs may be: 

provisions for adequate onsite engineering direction; appropriate and adequate 

procedures related to procurement and use of materials; and adequate control of hold 

points.

02.02 The construction specification must translate design requirements into details 

sufficient to define the technical requirements for concrete construction activities. The 

specifications should provide for control of design changes and the issuance of design 

change notices. The review of procedures, specifications, and drawings should ensure 

that concrete construction and inspection activities are controlled and performed in 

accordance with applicable requirements. QA/QC procedures should specify 

acceptance-testing requirements and should specify the personnel and interface 

responsibilities required to define, control, and resolve field problems or design problems 

that are evidenced during construction. QA/QC procedures must provide for effective 

inspections that will assure that work is performed in accordance with specification 

requirements. The procedures should require verification of specified controls and should 

not be accomplished merely by surveillance. Laboratory and field-testing procedures 

must provide for verification of correct material usage, correct selection of reference 

standards, and should prohibit discretionary selection of inspection and testing 

parameters. Construction procedures must reference the required inspection hold points 

and must also address the QA department authority to stop work.

02.03a. Qualification of Materials 

Chemical and physical tests for all materials used must indicate that 

specifications have been met. Testing should be performed at the required 

frequencies. Tests results may be provided by the manufacturers via certified 

materials test reports, or may be performed at an independent or in the onsite 

testing laboratory. Test results should be reviewed for the following materials: 

(a) Concrete-mix materials (cement, fly ash, sand, aggregate, water, 

admixtures, etc.) and all constituents used in other cement-like materials, 

such as gunite, grout, dry pack or manufactured materials such as epoxy;

(b) Reinforcing steel;

(c) Reinforcing splicing materials;

(d) Waterproof membranes, water stops, joint materials and sealants;
Issue Date: 12/14/15 B-10 69020

(e) Embedded mechanical items such as piping, conduit, mechanical and 

electrical penetrations (sleeves), sumps, drains, and grating material, etc.;

(f) Off-the-shelf anchorage components and embedment’s (bolts, hangers, 

inserts, etc.), and embedded structural steel items (shear connectors, 

embedded plates, etc.);

(g) Materials used during construction such as for construction joint 

preparation, form-release agents, and curing compounds; and

(h) Other structural concrete materials that may be used.

0203b. Concrete-Mix Design

A concrete-mix design must be completed for each type/strength of concrete mix 

to be used in SC-I and SC-II structures. The mix design must be completed 

using the qualified materials (see 02.03a, above), sufficiently in advance of the 

planned concrete-placement start dates, to demonstrate that the concrete mix 

will satisfy the job requirements for slump, air entrainment, strength and any 

other specified parameters. Test cylinders need to be molded, cured and tested 

to demonstrate that the required design requirements will be achieved within the 

specified time period (e.g., 7, 28, or 90 days). It is not an acceptable practice to 

attempt to base the final concrete design strength on incomplete test results 

(e.g., estimating the 28-day strength, based on results of test cylinders tested at 

ages of 7 and 14 days). If the sources of materials used in the concrete are 

changed, new mix designs need to be qualified, before placement into SC-1 and 

SC-2 structures.

02.03c. Concrete Batch Plant

Concrete batch plants providing concrete for use at nuclear facilities must be 

certified under the NRMCA program. This certification provides evidence that a 

registered professional engineer has reviewed the facility and has seen evidence 

that certain necessary capabilities exist to produce quality concrete. Any other 

batch-plant certification should include the inspection attributes, listed in the 

NRMCA checklist, which are used to inspect the facility before any 

recommendation for certification. As part of the certification process, concrete 

uniformity testing must be performed in accordance with ASTM C-94, at periodic 

intervals. Verify that the batch plant scales have been calibrated through their 

full range of use on the project. Water meters and admixture dispensers also 

require calibration. During observation of concrete batching operations, verify 

that the scales rezero after each batch. 

Materials need to be properly stored at the batch plant. Non-conforming or 

unqualified materials are required to be segregated from qualified materials. 

Storage of cement and admixtures require control so that shelf life is controlled 
Issue Date: 12/14/15 B-11 69020

and older materials are used before recently received materials. Cement and fly

ash are required to be protected from moisture. Generally, cement should be 

used within 180 days of manufacture. Admixtures must be used within the shelf 

life specified by the vendor. 

Admixtures need to be protected from freezing. An adequate supply of all 

materials needs to be available at the batch plant, to complete the placement, 

with sufficient reserves of materials to make up for concrete batches that may be 

rejected because of noncompliance with specification requirements.

Potable water is generally suitable for making concrete. However testing 

(chemical analysis) of the water should be performed to verify that it does not 

contain impurities that may be detrimental to the concrete or reinforcing steel. 

Also, concrete should be batched using site water and compared to concrete 

batched using distilled water. In this test, the normally accepted standard is that 

the site water is deemed acceptable if samples batched from site water do not 

result in a reduction in strength of more than 10 percent less than samples 

batched using distilled water. The moisture content determination of aggregates 

is an important test to accurately calculate the total water in each batch of 

concrete. Fine and coarse-aggregate-moisture-content testing needs to be 

performed periodically, throughout daily concrete production. Frequency of 

testing will be determined based on weather conditions and variations in the 

moisture content.

Trucks used to transport concrete from the batch plant to the job site need to be 

inspected to ensure that they are clean and free from dirt/debris and/or water 

which could become mixed with, and contaminate, the concrete. Truck mixers 

need to be certified in accordance with NRCMA standards. The certification 

process also requires concrete uniformity testing in accordance with ASTM C-94, 

at periodic intervals, if mixing of the concrete is performed in the trucks, or water 

or other ingredients are added to the concrete batch after the concrete is 

discharged from the batch plant. Verify that the drum revolution counters are 

operable and reset after each batch is discharged.

02.03d. Preplacement Activities

Storage of reinforcing steel should be examined to verify that storage conditions 

are adequate to ensure that rebar will not become contaminated with materials 

such as mud, excessive rust, grease, oil, etc., which could affect the bonding of 

the rebar and concrete. Completed reinforcement placement should be checked 

for size, spacing, splice locations, bending, proper clearances from face of forms 

or excavated surfaces (i. e., verify rebar will have minimum required cover, in 

addition to the correct “d” distance), and anchorage. Reinforcing steel needs to 

be free from oil, grease, paint, loose rust, dried mud, weak mortar, etc. The steel 

needs to be firmly held within the forms (usually tie wire is used), to prevent the 

rebar from being displaced by movement of the plastic concrete, or by other 

construction activities, such as concrete vibration, or by movement of 

construction personnel in the form areas. Particular attention needs to be 
Issue Date: 12/14/15 B-12 69020

directed to installation of column ties, stirrups, and dowels. Verify that other 

hardware items to be embedded in the concrete placement are clean, properly 

located, and firmly anchored. Verify that pre-placements of electrical and 

instrument grounding grids and embedded connection plates are correct. Also, 

verify proper testing of the building ground mat.

Review the mechanical splicing instructions issued by the vendor. This 

document usually specifies the proper performance of all mechanical splicing 

operations. Ascertain whether it is being used.

1. Cadwelding

When Cadwelding operations are being performed, verify that specified materials 

(sleeves, powder, and packing) are properly stored, and that Cadwelding fixtures 

are in good condition. The reinforcing steel to be Cadwelded should be cleaned 

shortly before Cadwelding, to remove all non-adherent rust. The reinforcing steel 

ends should be aligned and butted within the tolerances specified, using the 

spacers provided with the cadweld kits. 

Observe the placement of sleeves and the use of a marking system to ensure 

centering. When the firing is completed and packing removed, examine the 

sleeve and reinforcing steel to ensure that metal is showing at the vent (no slag 

at the tap hole), and each end of the sleeve shows proper fill (allowable void area 

not exceeded).

Ascertain whether each Cadweld sleeve is identified. By interviews with two 

Cadwelding inspectors, ascertain whether they are familiar with the details of 

Cadwelding requirements; also determine whether inspection of Cadwelding 

conforms to the specified frequency, whether inspection (QC) records are being 

maintained, and whether records are traceable to installation location, and 

identification of the cadwelder (craftsman).

2. Other types of mechanical splices, (e.g., Bar-Lock splices, if used)

Verify that the NRC has approved use of the type splice. Review the CAR, SER, 

and manufacturer’s instructions to determine specific installation and testing 

requirements. Review the laboratory test data used to qualify the splices and 

verify that the licensee’s installation procedures will result in an installed 

configuration that will reflect the laboratory testing conditions. Typical inspection 

parameters for all types of mechanical splices require cleanliness of the ends of 

the rebar to be spliced, verification of adequate embedment of the rebar ends, 

within the splicing sleeve, and verification that the sleeve is centered over the 

ends of both bars to be spliced. Identification of each splice and the 

craftsman/crew who completed the splice is also generally required. All 

craftsmen are required to be trained. All splices require inspection and 

acceptance by qualified QA/QC inspectors. A testing program will normally be 

specified to ensure the splices fabricated at the job site meet design 

requirements. 
Issue Date: 12/14/15 B-13 69020

The area where concrete is to be placed needs to be clean and free of debris. 

Materials such as sawdust, wood, dried mortar, tie wire, and other debris need to 

be removed from the forms before placement of concrete. Access ports are 

usually provided in the forms to permit cleaning and inspection. Water jets 

and/or compressed air should be used for cleaning. 

Forms must be well secured and braced so they will not be displaced by the 

fresh concrete or concrete-placement activities. The permitted rate of rise of the 

fresh concrete needs to be specified to avoid excessive loads on the forms 

caused by hydraulic forces from the fresh concrete. 

Otherwise, there could be form failures (blow-outs) resulting in injuries to 

construction personal and/or damage to safety-related structures or components. 

Inspection personnel must inspect pre-placements within a timeframe that 

represents the actual conditions before the placement. Quality control 

pre-placement inspections must not be unnecessarily rushed by advancing 

concrete work, especially during large slab or basemat placements. When 

possible, verify the actual as-built condition of reinforcing steel, with respect to 

the engineering drawings. If deviations exist, verify that proper engineering 

evaluations have been performed. Records need to document that all preplacement construction and inspection activities have been completed. Concrete 

surfaces (joints) on which additional concrete is to be placed should be 

roughened, and all loose materials removed to ensure good bonding of the new 

concrete to existing concrete. 

The joints should be kept damp for a specified period, usually 12 to 24 hours, 

before concrete placement. There should be no standing water in the forms.

In addition to having adequate equipment available to complete the concrete 

placement, extra equipment, such as vibrators, concrete trucks, and concrete 

pumps need to be available. Enough personnel need to be available, to fill in; 

and to keep concrete placement personnel from becoming fatigued by long work 

hours, which could lead to errors and substandard construction. Necessary 

equipment needs to be available to form construction joints on short notice, in 

case of an unforeseen stoppage of the concrete placement. Equipment needs to 

be available to protect the new concrete from all weather conditions, including 

rain, heat and cold. 

02.03e. Placement Activities

The practice of withholding water at the batch plant and then tempering at the 

point of placement should take into account the results of air content and slump 

measurements taken at the point of placement. Efficient radio communications 

between the batch plant and field QC testing personnel will minimize the need for 

water tempering at the point of placement and thus result in more uniform 

batching. Check time (90 minutes max) of concrete receipt for truck transported, 

centrally mixed concrete, and number of truck-mixer revolutions (300 max). Also, 

verify the amount (quantity should be documented) of water added, if permitted, 
Issue Date: 12/14/15 B-14 69020

and re mixing (minimum 30 revolutions). 

Concrete should not strike forms or bounce against reinforcing bars causing 

segregation of aggregates from the mix.

There should be a sufficient number of vibrator operators and, preferably, some 

spare vibrators, should be checked for proper operation, before starting to place 

concrete. Vibrators less than (3 inches) diameter are generally designed to 

operate at about 7000-8000 vibrations per minute, when immersed in concrete. 

Large vibrators, used in heavy-section concrete placement, operate at about 

6000 vibrations per minute. Vibrators less than (3 inches) in diameter can be 

operated by one man; (4 inches) or larger vibrators are two-man tools. 

Proper vibrator operation involves duration of vibration, distance between vibrator 

insertions, and depth of insertions. The vibrators should be handled and 

operated vertically and never "cast" away from the operator horizontally and then 

retrieved. Concrete should be placed horizontally, in about (12 inch) layers, and 

never allowed to pile much higher in one area of the form than another. The 

vibrator should penetrate through the new concrete well into the previously 

placed layer, to avoid any "layer-cake" effect. Occasional contact of a vibrator 

with the forms is permissible, and with the reinforcement is desirable. Form 

vibration is generally not desirable, and care should be taken that reinforcement 

is not displaced by vibrators, or by people walking on the steel. Vibrators should 

not be used to move concrete laterally. Any excess water in the forms should be 

removed and not permitted to mix with the concrete. 

02.03f. Post-placement Activities

The concrete needs to be protected from damage and properly cured. Proper 

curing requires keeping the surface of the concrete moist, and, in cold weather, 

warm, so that hydration of the cement continues until the concrete achieves 

design strength. Curing can be accomplished using moisture (water sprays, etc.) 

or by use of a curing compound. However curing compounds should not be used 

on construction joints unless they are removed prior to the next placement. 

Curing compounds used on construction joints may act as a bond breaker and 

result in successive placements not achieving good bond. Minimum curing times 

should be specified in the construction records. Formation of ice (freezing of the 

curing water) on surfaces of the concrete during the curing period should not be 

permitted. Forms need to remain in place for the period specified in the 

procedures. The time to remove the concrete forms is often based on achieving 

a minimum concrete strength. 

Defective areas in concrete should be repaired as soon as possible after the 

forms are removed. Design engineering approval should be obtained for all 

concrete repair methods. It is not acceptable to repair concrete defects by 

merely plastering over them with mortar. Concrete defects need to be cut to a 

depth to expose sound concrete and filled with concrete of the same strength as 

that in the structure. Repair of defects are usually classified as cosmetic if they 

are shallow surface defects, and structural if they extend to a depth below the 
Issue Date: 12/14/15 B-15 69020

outer layer of rebar. Locations of concrete defects and repair methods need to 

be documented in licensee inspection records. Note that areas repaired are 

required to be protected from the elements and cured to achieve adequate 

design strength. 

02.03g Evaluation and Review of Concrete Test Results

This portion of the inspection may require subsequent follow-up, to determine 

that final inspection, evaluation, and acceptance are being controlled and 

accomplished in accordance with QA/QC requirements. Final inspection 

procedures should include verifying embed locations and identification of any 

defects and required repairs. Review the results of compressive strength 

determinations. Verify that results are being evaluated in accordance with ACI 

214, Recommended Practice for Evaluation of Compression Test Results of Field 

Concrete”. During this portion of the inspection, also review the results of 

strength tests on mechanical reinforcing steel splices.

Records should be verified to show that mix specified was delivered and placed. 

Structural drawings or specifications will indicate the design concrete strength. 

Evaluate the licensee's trending analysis of nonconforming items and determine 

if generic items are being identified and corrected.

02.03h Qualification of QC Personnel

Particular attention should be directed toward the qualification of personnel and 

their work performance. In the past, at some projects, there was a tendency for 

some organizations to hire untrained personnel residing near the site who had no 

prior work experience in concrete materials testing or inspection, train them, and 

certify them. Although the individuals were trained and certified, in some 

instances inexperience of personnel and the lack of depth of knowledge was 

been found to be detrimental to an effective QA/QC program. Changing of 

personnel between different jobs and turnover of personnel can also result in 

problems.

In determining the adequacy of QA/QC staffing; the effectiveness of their 

activities must be considered. Insufficient or unqualified personnel, or 

inadequate management, may result in inadequate inspections of concreteconstruction activities. Capabilities and effectiveness, rather than only the 

number of personnel, are the principal criteria to be used.

02.04a During periods when concrete is to be placed or cold weather is expected during 

the curing time, provisions must be made to keep the concrete above [40

degrees Fahrenheit (F)], preferably in the range of [(50 to 60 degrees F)]. If 

concrete is being mixed or transported in weather below (40 degrees F), the 

ingredients may be pre-warmed so that the temperature of the concrete after 

placement is elevated to account for losses. Heating the water is the most 

effective and most easily controlled technique, but the aggregate must not be 

frozen. The water should not be so hot as to cause "flash set" of the cement 
Issue Date: 12/14/15 B-16 69020

during mixing; that is, the temperature of the mortar should not exceed (100

degrees F). If hotter water is required to warm the aggregate, the water and 

aggregate may be mixed before addition of cement. If the aggregate is heated, 

close control must be exercised, and the aggregate must be frequently checked 

for variations in moisture content caused by local variations in heating. 

Direct fired heaters may produce carbon dioxide, in the exhaust fumes, forming 

calcium carbonate on the surface of fresh concrete. Also, use of chemicals 

should not be permitted to accelerate the concrete set times in cold weather.

Where the ambient temperature during concreting rises much above (70 degrees 

F), consideration must be given to the effect of high temperatures on the 

concrete. Although concrete cured at temperatures up to (100 degrees F) gives 

higher early strength, with little degradation of long-term strength, high 

temperatures during mixing, transportation, and placement can be seriously 

detrimental. The most obvious effect is that the concrete requires more water for 

work ability or the use of additives. A less obvious effect is the need for special 

attention to curing, because the higher temperature increases water evaporation 

from the concrete.

Exposure to strong summer sun can raise the temperature of ingredients, 

equipment, forms, etc., far above the air temperature. If this occurs, provisions 

should be made for appropriate shades or screens, and the equipment, forms, 

and metallic embedment’s, etc., should be wetted just before concrete 

placement. If the ambient temperature is high enough so that the bulk 

temperature of freshly mixed concrete exceeds (80 degrees F or 90 degrees F), 

consideration should be given to some method of cooling the ingredients, such 

as chilling the water, or using ice. If ice is used, it must be crushed or flaked so 

that all the ice is melted by the time mixing is completed.

03.02 Prevalent Errors and Recent Concerns

a. This section is included to provide background, for inspectors, on past structural 

concrete problems that have been identified and on certain areas that should be more 

closely scrutinized, so as to give NRC early information on potential problems. The 

following are potential problems identified as concrete-related violations at previous 

projects. (Note - These are not listed in order of their perceived importance to safety.)

1. Inadequate QA/QC records documenting concrete work activities.

2. Improper use of vibrators.

3. Exceeding allowable time to place concrete.

4. Improper sampling of aggregates.

5. Improper curing of concrete test cylinders.

6. Exceeding allowable concrete temperatures.

7. Materials improperly certified.

8. Concrete cylinder compression test records exceed allowable coefficient of 

variation.
Issue Date: 12/14/15 B-17 69020

9. Improper splicing practices (reinforcement cleaning, alignment, gage marks, 

thread damage, and inadequate swaging force, etc.).

10. Inadequate concrete curing.Samples of concrete not taken where and when 

required.

11. Excessive doses of concrete admixtures.

12. Inadequate cleanliness of placement.

13. Omission of reinforcing steel, incorrect spacing of reinforcing steel, and/or 

improper anchorage (failure to firmly tie the rebar) of the steel.

14. QC inspections not done conscientiously.

15. Excessive drop of concrete.

16. Batch plants improperly qualified.

17. Improper repair of concrete defects.

18. Intentional violation of work procedures by craft personnel to avoid rejection of 

their work, or to simplify their work. Examples included melting of tie wire into 

ends of completed cadwelds, unauthorized addition of water to concrete, and 

covering concrete defects (honeycomb) with mortar to prevent detection by 

QA/QC inspectors 

19. Construction personnel and supervision intimidation of QA/QC inspectors. 

69020.A2-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A2-05 REFERENCES

ANSI/ANS 15.8-1995, “Quality Assurance Program Requirements for Research Reactors.”

Code of Federal regulations 10 CFR Part 21, “Reporting Defects and Noncompliance.”

American Concrete Institute (ACI)

ACI 116, “Cement and Concrete Terminology.”

ACI 117, “Standard Specification for Tolerances for Concrete Construction and Materials.”

ACI 211.1, “Recommended Practice for Selecting Proportions for Normal and Heavyweight 

Concrete.”

ACI 212.1, “Admixtures for Concrete.”

ACI 212.2, “Guide for Use of Admixtures in Concrete.”

ACI 212.4, “Guide for Use of High-Range Water-Reducing Admixtures (Superplasticizers) in 

Concrete.”
Issue Date: 12/14/15 B-18 69020

ACI 214, “Evaluation of Strength Test Results of Concrete.”ACI 221,”Guide for Use of Normal 

Weight and Heavyweight Aggregates in Concrete.”

ACI 301, “Specifications for Structural Concrete.”

ACI 304, “Guide for Measuring, Mixing, and Placing Concrete.”

ACI 304.2, “Placing Concrete by Pumping Methods.”

ACI 305, “Hot Weather Concreting.”

ACI 306, “Cold Weather Concreting.”

ACI 308, “Guide to Curing Concrete.”

ACI 309, “Guide for Consolidation of Concrete.”

ACI 311, “Recommended Practice for Concrete Inspection.”

ACI 311.1, “ACI Manual of Concrete Inspection.”

ACI 311.4, “Guide for Concrete Inspection.”

ACI 311.5, “Guide for Concrete Plant Inspection and Testing of Ready Mixed Concrete.”

ACI 315, “Details and Detailing of Concrete Reinforcement.”

ACI 318, “Building Code Requirements for Structural Concrete.”

ACI 347, “Guide to Formwork for Concrete.”

ACI 349, “Code Requirements for Nuclear Safety-Related Concrete Structures.”

ACI 359, “Code for Concrete Reactor Vessels and Containments, Section III, Division 2."

ACI 503, “Use of Epoxy Compounds with Concrete”

ACI 503.4, “Standard Specification for Repairing Concrete with Epoxy Mortar.”

ACI 504, “Guide to Sealing Joint in Concrete Structures.”

ACI 530-02, “Building Code Requirements for Concrete Masonry Structures.”

American Welding Society (AWS)

AWS D1.1, “Structural Welding Code.”

AWS D1.4, “Structural Welding Code - Reinforcing Steel.”
Issue Date: 12/14/15 B-19 69020

American Society for Testing and Materials

ASTM A-615, “Deformed Billet-Steel Bars for Concrete Reinforcement.”

ASTM A-706, “Standard Specification for Low-Alloy Steel Deformed Bars for Concrete 

Reinforcement”.

ASTM C-29, “Test for Unit Weight of Aggregate.”

ASTM C-31, “Making and Curing Concrete Compressive and Flexural Strength Test Specimens 

in the Field.”

ASTM C-33, “Standard Specification for Concrete Aggregates.”

ASTM C-39, “Test for Compressive Strength of Molded Concrete Cylinders.”

ASTM C-94, “Standard Specification for Ready Mixed Concrete.”

ASTM C-109, “Standard Method of Test for Compressive Strength of Hydraulic Cement Mortar 

(Using 2-in. Cube Specimen).”

ASTM C-117, “Test for Materials Finer Than No. 200 Sieve in Mineral Aggregates by Washing.”

ASTM C-127, “Test for Specific Gravity and Absorption of Coarse Aggregate.”

ASTM C-128, “Test for Specific Gravity and Absorption of Fine Aggregate.”

ASTM C-136, “Test for Sieve or Screen Analysis of Fine and Coarse Aggregates.”

ASTM C-143, “Test for Slump of Portland Cement Concrete.”

ASTM C-150, “Specification for Portland Cement.”

ASTM C-171, “Specification for Sheet Materials for Curing Concrete.”

ASTM C-172, “Sampling Fresh Concrete.”

ASTM C-173, “Test for Air Content of Freshly Mixed Concrete by the Volumetric Method.”

ASTM C-192, “Making and Curing Concrete Test Specimens in the Laboratory.”

ASTM C-231, “Test for Air Content of Freshly Mixed Concrete by the Pressure Method.”

ASTM C-260, “Standard Specifications for Air Entraining Admixtures for Concrete.”

ASTM C-309, “Specification for Liquid Membrane - Forming Compounds for Curing Concrete.”

ASTM C-494, “Standard Specification for Chemical Admixture for Concrete.”
Issue Date: 12/14/15 B-20 69020

ASTM C-566, “Standard Method of Test for Total Moisture Content of Aggregate by Drying”

ASTM C-642, “Test for Specific Gravity, Absorption, and Voids in Hardened Concrete.”

ASTM D-512, “Test for Chloride Ion in Industrial Water and Industrial Waste Water.”

ASTM D-1888, “Tests for Particulate and Dissolved Matter in Water.”

U. S. Army Corps of Engineers, Handbook for Concrete and Cement, Published by US Army 

Corps of Engineers Waterways Experiment Station, Vicksburg, Miss.

NRC Publications

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.29, “Seismic Design Classification”.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.136,”Materials, Construction, and 

Testing of Concrete Containments”.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.142, “Safety-Related Concrete 

Structures for Nuclear Power Plants (Other Than Reactor Vessels and Containments)”.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.199, “Anchoring Components and 

Structural Supports in Concrete.”

National Ready Mixed Concrete Association (NRMCA)

NRMCA, “Concrete Plant Standards of the Concrete Plant Manufacturers Bureau.”

NRMCA, “Truck Mixer and Agitator Standards of the Truck Mixer Manufacturers Bureau.”

Others

Concrete Manual, published by the Bureau of Reclamation.

Publications of the Portland Cement Association.

For information and standards for studs (proprietary name: Nelson Studs), which are used to 

secure embedded item such as pipe sleeves and plates, to concrete structures, refer to Chapter 

8, “Stud Welding”, Volume 2 of the Welding Handbook, Seventh Edition, published by the 

American Welding Society.

END
Issue Date: 12/14/15 C-1 69020

APPENDIX C

INSPECTION OF STRUCTURAL STEEL AND SUPPORTS AT NON-POWER PRODUCTION 

AND UTILIZATION FACILITIES

69020.A3-01 INSPECTION OBJECTIVES

01.01 To determine whether work related to structural steel and supports for Seismic 

Category I (SC-1) and Seismic Category 2 (SC-2) structures are being performed in accordance 

with the licensing basis, construction specifications, drawings, and work procedures.

01.02 To determine whether the licensee’s system for preparing, reviewing, and maintaining 

records relative to structural steel and supports activities is functioning properly, and to 

determine whether the records reflect work accomplishment consistent with specifications and 

procedures.

01.03 To verify that the as-built condition of SC-1 and SC-2 structures meets the specified 

design requirements, specifications and drawings. For work related to foundations and 

buildings, also refer to Appendix A of this inspection procedure (IP). For work related to 

concrete structures, also refer to Appendix B of this IP. 

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with structural steel and supports is effective and to verify that deviations 

from requirements are appropriately resolved.

69020.A3-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Inspectors should review the facility description in the safety analysis report (SAR) and be 

familiar with structural steel and supports activities at the site. Inspectors should also be 

familiar with the licensee’s Quality Assurance Program (QAP) and the licensing basis for 

the QAP (NPUF licensees are expected to commit to the QAP requirements of ANS/ANSI 

15.8, “Quality Assurance Program Requirements for Research Reactors”). It is not the 

objective of this IP to verify the adequacy of the licensee’s QAP, but inspectors should be 

prepared to identify potential weaknesses in the licensee’s QAP for future inspections. 

Inspectors should complete this appendix by inspecting the attributes listed in this 

appendix for structural steel and supports work on-site at the time of the inspection, with 

SC-1 work being preferable to SC-2 work when available. Inspectors should also 

coordinate this appendix with inspection of foundations and buildings (Appendix A of this 

IP), and structural concrete (Appendix B of this IP) for efficiency, if possible. 

Inspectors should contact the licensee prior to the on-site inspection to determine what 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all structural steel and supports on the site, but 

may expand the inspection if time allows, or if significant concerns with the licensee’s 

control of structural steel and supports work activities arise. Inspectors should collect 

licensee procedures, work activity specifications and work completion records in 

advance, if possible. 
Issue Date: 12/14/15 C-2 69020

If unable to review them in advance of the on-site inspection, then the licensee should be 

notified that these documents, and any other relevant documents, should be available 

when the inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.06 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Review the construction specifications related to structural steel and supports activities 

and ascertain whether the specified technical requirements conform to the commitments 

contained in the licensing basis. Determine whether appropriate and adequate 

procedures in the following areas are compatible with the QA program and prescribe 

adequate methods to meet the construction specifications, where applicable:

- Receipt inspection and storage

- Use of specified materials and components;

- Installation and erection; and

- Inspection, testing, non-destructive examination (NDE), and records.

02.03 Determine whether the licensee has an established audit program (including plans, 

procedures, and schedule) covering the SC-I and SC-II work and control functions in the 

area of structural steel and supports activities and for ensuring that examination and 

inspection personnel associated with structural steel and supports activities are qualified 

to perform their assigned work.

02.04 Ascertain whether the following applicable structural steel and supports activities are 

being controlled and accomplished in accordance with the requirements of the 

documents reviewed in Section 02.02, above:

a. Receipt Inspection and Storage. Verify that the following items have been 

implemented:

1. Receipt inspections: Verify the acceptability of specification requirements.

2. Storage: Verify that controls, markings, protection, and segregation are 

maintained.

b. Use of Specified Materials and Components. Verify the following:

1. Type and grade of materials are as indicated in specifications and drawings.

2. Certificates of conformance or mill test reports meet the proper specifications or 

physical and chemical requirements, including impact tests, if required.

c. Installation and Erection. Verify that the following items are implemented:

1. The component or support is being erected in accordance with the most current 

specifications and drawings.

2. The layout crew’s instruments and tapes are calibrated.
Issue Date: 12/14/15 C-3 69020

3. Fit-up and alignment meet the tolerances in the specifications and drawings.

4. Components are being properly handled (including bending or straightening).

5. Specified clearances are being maintained.

6. Edge finishes and hole sizes are within tolerances.

7. Anchor bolts, embedded weldments, liner plate anchors, concrete anchors, and 

studs are of the proper material and grade and have been properly located, and 

tested and examined.

8. For bolted connections: bolts, nuts, and washers are of the specified type and 

grade; torque wrenches are calibrated in accordance with approved procedures; 

other test and measuring equipment used in the bolting process are calibrated; 

and thread engagement is as specified.

For friction type connections, ensure that the craft personnel follow the 

procedures properly, so that the bolts will have the required bolt tension. For 

instance when the turn-of-nut method is used, make sure enough bolts are 

brought to a “snug tight” condition, to ensure that the parts of the joint are 

brought into good contact with each other.

For sliding-type connections, ensure the craft personnel follow the procedures 

properly so that the bolts are not over-tightened and so that bolts are not at the 

end of slots, preventing movement of the connection.

d. Inspection, Testing, NDE, and Records. For inspection, testing, NDE, and records, 

verify the following items:

1. Inspections are performed at the specified frequency, in accordance with 

appropriate codes, specifications and procedures, and adequate acceptance 

criteria are specified.

2. Accurate records are developed in accordance with procedures.

3. Proper and calibrated equipment is used as required.

4. Personnel conducting testing and NDE are qualified as required.

02.05 Review the documentation generated for the structural steel and supports activities. 

Determine whether the licensee/contractor system for documenting safety-related work is 

functioning properly. Records should be legible, complete, reviewed by QC and/or 

engineering personnel, and readily retrievable. Review a sample of the following records:

a. Receipt Inspection and Material Certification (if applicable). Applicable for materials 

purchased from offsite suppliers. Records confirm that required material 

characteristics, performance tests, nondestructive test, and other specification 

requirements were met.

b. Installation Inspection. Records confirm that specified materials and components were 

installed as specified and that the required inspections were performed and acceptance 

criteria are defined.

c. Nonconformance/Deviation Record. Records include current status of these items. 

Nonconformance reports include the status of corrective action or resolution.
Issue Date: 12/14/15 C-4 69020

d. Training/Qualification Records of Craft, QA, and Inspection (QC) Personnel. Records 

establish that QA/QC personnel are adequately qualified for their assigned duties and 

responsibilities and that craft personnel have been trained in their assigned tasks.

e. QA Audits. Records establish that the required audits were performed and that 

deficiencies identified during audits were corrected, and that corrective action was such 

that repetition of the deficiency, or similar deficiencies, would be precluded.

02.06 Review the construction and QC procedures generated from the specifications and 

determine their adequacy with respect to prescribing adequate methods for achieving the 

construction specification requirements, including handling and storage of materials.

69020.A3-03 ADDITIONAL GUIDANCE

03.01 General Guidance. 

QA/QC procedures must provide for effective inspections that will ensure that work is 

performed in accordance with specification requirements. QA audits should identify 

procedural inadequacies and the root cause of repetitive nonconforming conditions. 

Inspections should require verification of specified controls and should not be 

accomplished merely by surveillance. Laboratory and field testing procedures must 

provide for verification of correct material usage, correct selection of reference standards, 

and should prohibit contractor or QC personnel from discretionary selection of inspection 

and testing parameters. Qualified personnel should review and determine if the results of 

testing are acceptable. Construction procedures must reference the required inspection 

hold points and must also address the QA/QC department stop-work authority.

03.02 Specific Guidance

Note: The numbering of the guidance below refers to specific subsections of 02, above.

02.04a The licensee may perform varying degrees of acceptance inspection, as part of 

its vendor shop-surveillance program. Results of these inspections should be 

reviewed.

02.04c Connection joints in structures are usually the area of installation problems and 

also are generally not given the same engineering attention as other structural 

steel items. Therefore, it is important to select, for review, a few connections in 

each structure or support reviewed in Section 02.04, above.

02.06 QA/QC procedures must provide for effective inspections that will ensure that 

work is performed in accordance with specification requirements. QA/QC 

inspection should require verification of specified controls and should not be 

accomplished merely by surveillance. Construction procedures must reference 

the required inspection hold points and also must address the QA Department’s 

authority to stop work.
Issue Date: 12/14/15 C-5 69020

The items selected for review during this inspection should include the following, 

as appropriate for the specific site design:

1. Control of Specific Materials.

(a) Steel plates and shapes;

(b) Pipes and tubes;

(c) Forgings and castings;

(d) Bolts and studs;

(e) Weld filler-metal

(f) Coatings; and

(g) Other related materials.

2. Control of Specific Processes or Activities.

(a) Heat treatment;

(b) Impact testing;

(c) Examination;

(d) Repair;

(e) Cutting, forming, bending, and aligning;

(f) Erection and bracing;

(g) Welding (for cross flange welding on loaded members, be sure that 

the procedures or engineering evaluations ensure that the structural 

integrity of the loaded beams or columns affected will not be 

compromised.);

(h) Radiography;

(i) Other NDE methods;

(j) Bolting (ensure that the procedures will provide the required bolt 

tension. For instance, when the turn-of-nut method is used, the 

procedures should make sure enough bolts are brought to a “snug 

tight” condition so that the parts of the joint are brought into good 

contact with each other.);

(k) Post weld heat treatment;

(l) Local leakage testing;

(m) Inspection; and

(n) Documentation of inspection and testing.

03.03 Prevalent Errors and Concerns

Prevalent errors and recent concerns are areas in where the inspectors should be alert to 

potential generic issues. These areas include:

a. Storage of structures and support components should ensure that contact with ground 

surfaces is avoided.

b. Inattention to damage and normal wear and tear of protective coverings may lead to 

substandard or unacceptable weather protection. The licensee’s maintenance of 

protection (canvas or plastic covering) should be reviewed.
Issue Date: 12/14/15 C-6 69020

c. In the area of maintenance of material identification, damage by handling or weather 

frequently makes paper tags illegible. Paper tags are usually considered to be 

inadequate.

d. The use of galvanized bolts and nuts in bolted connections may require thread 

lubricant, to ensure that minimum torque or pretension requirements are met. There 

may be frequent adjustments of the minimum torque value.

e. Piece-work traceability of structural steel and American Society of Testing and Materials 

(ASTM) A325/A490 bolting material has been a problem in the recent past.

f. Deficient alignment or fit-up for welded connections has caused improper welding 

practices.

g. There have been instances of cutting or edge finishes not being in accordance with 

specifications or drawings.

h. Instances of weld undercut have gone undetected by QC inspections.

i. Uncalibrated torque wrenches have been used. There should be provisions for the 

evaluation or reverification of the activities performed by the uncalibrated torque wrench 

since the last calibration.

j. Difficulties in using the turn-of-nut method, for bolted connections, in defining the initial 

“snug-tight” condition, and inadequate gauge marks to determine amount of additional 

turns after “snug-tight.” Actual observation may be the only means of verifying the 

proper implementation the turn-of-nut method.

k. NRC personnel, through independent sampling of bolted connections using calibrated 

torque wrenches, found that high strength bolted connections do not meet project 

requirements for proper bolt tension.

l. Welding across the flange of loaded members without engineering evaluation is only to 

be done under controlled conditions.

69020.A3-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A3-05 REFERENCES

American Concrete Institute (ACI), ACI 349.1R-91, “Reinforced Concrete Design for Thermal 

Effects on Nuclear Power Plant Structures.”
Issue Date: 12/14/15 C-7 69020

ACI 349-97, “Code Requirements for Nuclear Safety-Related Concrete Structures.”

ACI 349.2R-97, “Embedment Design Examples.”

American National Standards Institute/American Institute of Steel Construction (ANSI/AISC), 

ANSI/AISC N690-1994, “Specifications for the Design, Fabrication, and Erection of Steel 

Safety-Related Structures for Nuclear Facilities.”

American Society of Civil Engineers (ASCE), ASCE 4-98, “Seismic Analysis of Safety- Related 

Nuclear Structures and Commentary.”

ASCE 7-98, “Minimum Design Loads for Buildings and Other Structures.”

American Welding Society (AWS) D1.1, “Structural Welding Code.”

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.122, “Development of Floor Design 

Response Spectra for Seismic Design of Floor- Supported Equipment or Components.”

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.92, “Combining Modal Responses 

and Spatial Components in Seismic Response Analysis.”

ANSI/AISC N690, Specification for Safety-Related Steel Structures for Nuclear Facilities 

END
Issue Date: 12/14/15 D-1 69020

APPENDIX D

INSPECTION OF PIPING AT NON-POWER PRODUCTION AND UTILIZATION FACILITIES

69020.A4-01 INSPECTION OBJECTIVES

01.01 To determine whether work associated with safety related piping is being performed in 

accordance with the licensing basis, construction specifications, drawings, and work 

procedures.

01.02 To determine whether the licensee’s system for preparing, reviewing, and maintaining 

records relative to piping activities is functioning properly, and to determine whether the records 

reflect work accomplishment consistent with specifications and procedures.

01.03 To verify that the as-built condition of piping meets the specified design requirements, 

specifications and drawings. For pipe supports and restraints, also refer to Appendix E of this 

inspection procedure (IP).

01.04 To determine that the implementation of the quality assurance program related to work 

activities is effective and to verify that deviations from requirements were appropriately resolved.

69020.A4-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report 

and be familiar with the safety-related piping systems being constructed at the site. 

Inspectors should also be familiar with the licensee’s Quality Assurance Program (QAP) 

and the licensing basis for the QAP (NPUFs are generally expected to commit to the QAP

requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for piping work being conducted on-site at 

the time of the inspection. Inspectors should also coordinate this appendix with Appendix 

E, “Pipe Supports and Restraints.” 

Inspectors should contact the licensee prior to the on-site inspection to determine which

work activities are to be inspected. If necessary, inspectors may select completed work 

activities for inspection. Inspectors should not attempt to inspect all piping on the site, but 

may expand the inspection if time allows, or if significant concerns with the licensee’s 

control of piping work activities arise. Inspectors should collect licensee procedures, 

work activity specifications and work completion records in advance, if possible. If unable 

to review them in advance of the on-site inspection, then the licensee should be notified 

that these documents, and any other relevant documents, should be available when the 

inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.11 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 
Issue Date: 12/14/15 D-2 69020

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Determine whether licensing basis and Quality Assurance Program commitments relating 

to the following specific activities associated with safety-related piping are adequately 

addressed in procedures included or referenced in the QA manual(s).

a. Purchase documents identifying material specifications and any special requirements, 

including material test reports/certification of the following (as applicable):

1. chemical composition

2. physical characteristics

3. nondestructive examination results

4. heat treatment history (if applicable)

5. welding of prefabricated sections

b. Receipt inspections, including provisions for ensuring:

1. piping materials are in conformance with purchase specifications, including 

special requirements

2. marking, identification, and storage level classifications

3. as-received cleanliness and protection

4. receipt inspection reports are generated as required

5. disposition of nonconforming items

c. Inspections covering storage and issuance of the piping and related appurtenances 

including provisions for:

1. segregation of sizes and types of material

2. storage identification

3. storage conditions/protection

4. confirmation of issue of specified material

d. Handling of the piping and related appurtenances to ensure protection from physical 

damage or contamination while handling.

e. Installation of the piping and related appurtenances to verify that the following meet 

applicable requirements:

1. location

2. grinding, cutting, bending, etc.

3. piping system tolerances

4. cold spring

5. installation records to be generated during installation

6. type, size, location and adjustment of hangers, bellows, restraints, snubbers

7. clearances to prevent interference

8. hydrostatic testing (where required)

9. hold points
Issue Date: 12/14/15 D-3 69020

10. removal of arc strikes

f. Design changes, including field changes, to ensure proper review and coordination 

among participating design organizations.

g. Inspection and work performance for cleaning piping, including provisions for:

1. cleaning materials - conformance to specifications, concentration, temperature, 

and use

2. cleanliness criteria and measurement methods

3. removal and installation of metering devices, orifice plates, valve internals, etc., 

that are removed from system to facilitate flushing

4. installation and removal of fine strainers, blind flanges, temporary piping and

dams

5. record-keeping requirements

02.03 Review the licensee/contractor's plans and schedules to audit compliance with and 

effectiveness of the QA/QC requirements associated with safety-related piping, including 

(but not limited to) design, procurement, receipt/storage, installation, and testing.

02.04 Determine whether licensee/contractor management has an established program for 

ensuring that all personnel involved in the above mentioned activities are suitably 

proficient, skilled, or otherwise qualified by experience or training to perform their 

assigned duties.

02.05 If possible, observe activities relative to safety-related piping, such as handling; 

cleanliness control; installation of pipe spools, fittings, and bellows; cutting; grinding; 

bending; supporting; cleaning and flushing; hydrostatic testing; and quality-related 

inspections.

02.06 For those activities selected for observation (in 02.05, above) determine whether the 

following requirements, as applicable, are met:

a. conformance with construction/installation specifications

b. personnel are adequately qualified by certification, experience or training

c. conformance with inspection (QC) and work performance procedures

d. conformance with record-keeping requirements

e. identification and control of material

f. control of nonconforming items

02.07 Determine whether piping runs are (or are being) installed as required by applicable 

specifications, field drawings, and procedures.

02.08 Determine whether there have been significant design changes subsequent to the 

issuance of approved installation drawings. Review the implementation of the 

licensee's/contractor's design control measures, including the necessity for a revised 

stress analysis, as appropriate, to determine whether design control procedures were 

properly followed.
Issue Date: 12/14/15 D-4 69020

02.09 Determine whether records meet requirements related to:

a. Confirming that required material characteristics, performance tests, environmental 

qualification tests, nondestructive tests, and other specification requirements were met.

b. Confirming that the selected components were installed as specified.

c. Confirming that the required inspections were performed.

02.10 Review a nonconformance/deviation report to sample system effectiveness and 

determine if the procedures are being adequately implemented. 

02.11 Determine whether appropriate qualification requirements are in place for 

licensee/contractor craft and inspection personnel being employed on safety-related

piping installation work. 

69020.A4-03 ADDITIONAL GUIDANCE

03.01 General Guidance

The purpose of the inspection requirements in Section 02 of this procedure is to 

determine whether the licensee/contractor(s) activities, other than welding and NDE, 

have met QA program requirements for piping receipt, fabrication, erection, inspection, 

and testing of safety-related piping systems. 

The license/contractor procedures involved may vary from contractor to contractor, and 

may take many forms, such as formal procedures, instructions, checklists, drawings, etc. 

Review the inspection procedures/lists and compare with the requirements in the 

applicable codes and construction specifications. Evaluation should indicate whether 

adequate quality-related inspections are established and are based on appropriate 

criteria, and further, whether the results of the licensee/contractor's inspection will be 

transmitted to responsible quality assurance and management personnel. The NRC 

inspector must determine if the licensee controls are adequate and are properly 

implemented in a timely manner.

03.02 Specific Guidance

For clarification, "Material Test Report" is a generic expression meaning a report of test 

results to confirm that material, chemical and physical properties are consistent with the 

applicable specification. Vendor terms used, which can be identified with the expression 

"Material Test Report," include:

a. Ladle analysis (sample of molten metal)

b. Check analysis (sample of solidified metal)

c. CTR (Chemical Test Report or Certified Test Report)

d. MTR (Material Test Report - usually includes chemical and physical tests)
Issue Date: 12/14/15 D-5 69020

03.03 The generic terms CTR and MTR should not be confused with the term "Certification." A 

"Certification" is a document issued in lieu of actual quality documentation records stating 

that the quality requirements contained in specifications and purchase orders have been 

met.

03.04 "Quality Release Form" and "Certificate of Equipment" are examples of generic 

designations for forms used by manufacturers to serve as certifications of quality (in lieu 

of original quality documentation) for components and equipment.

03.05 The inspector should bear in mind that NRC's sample covers only a very small portion of 

the records involved. Thus, substantive errors or departure from requirements raise the 

issue of whether the licensee is adequately controlling the process.

03.06 The qualifications of those engaged in quality sensitive or special processes related to 

pipe installation, inspection and testing work should be sampled for an assessment of 

compliance with licensee commitments. Also, depending on the type and extent of 

design engineering work being performed at the site, it may be appropriate to review the 

qualifications of certain key individuals assigned to this design area.

03.07 A piping run, for purposes of this procedure, is meant to be a particular section of piping, 

for example: a piping section between components or major supports or relief valve 

discharge piping. The intent of requirement 02.07 is to determine whether piping is being 

installed according to properly approved drawings; either the original design drawings or 

properly approved revisions; and, if revisions are in process, that these changes are 

properly handled in accordance with established procedures.

03.08 Prevalent errors and concerns. This section is included to provide background for 

inspectors on what past problems of a generic nature have been identified and is for 

information only.

a. The status of protective measures at the time of site receipt and initial storage of piping 

and piping system components.

b. Adequacy of dunnage for piping and piping system components during storage. 

Dunnage treated with fire retardants may expose pipe to excessive levels of halogens 

and chlorides.

c. Continued adequacy of such things as end caps for piping and protective coverings for 

weld prep areas.

d. Weather protection in the form of canvas or plastic covering. (In most deficient cases, 

the original protective covering was adequate, but inattention to damage and normal 

"wear and tear" led to substandard or unacceptable protective covers.

e. Storage areas located on sandy soil require special attention to avoid the entry of 

wind-driven sand particles into piping components.
Issue Date: 12/14/15 D-6 69020

f. Improper location of storage. In some instances, storage locations are selected without 

consideration for construction traffic patterns, or possible falling objects and/or missiles. 

g. Inadequate or illegible piping identification. (Damaged by handling and/or 

environment.)

h. Stability of work force or QA/QC personnel and the attitudes in work crews and relations 

between construction personnel and QA/QC personnel.

i. Power grinders used for weld preparation of pipe that result in violation of minimum wall 

thickness.

j. Piping runs containing mud, sand, and other foreign material.

k. Incorrect size orifices installed in pump recirculation lines.

l. Surfaces for welding not properly free of paint, oil, rust, or other material that is 

detrimental to welding.

m. Drawings or other records fail to show evidence of actual piping components installed in 

pipeline or are not a current revision.

n. Piping changes without proper design change authorization.

o. Repairs of linear indications on pipe spool pieces not properly performed as to testing 

for wall thickness and blending uniformly into the surrounding surfaces.

p. Controls over the installation/removal of cleaning and flushing devices are inadequate.

q. Refer to IE Bulletin 79-14 for additional concerns relating to as-builts.

69020.A4-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A4-05 REFERENCES

10 CFR Part 21, “Reporting Defects and Noncompliance”

ASME B31.3-2002, Process Piping

END
Issue Date: 12/14/15 E-1 69020

APPENDIX E

INSPECTION OF PIPING SUPPORTS AND RESTRAINTS AT NON-POWER PRODUCTION 

AND UTILIZATION FACILITIES

69020.A5-01 INSPECTION OBJECTIVES

01.04 To determine whether work activities associated with safety-related pipe supports and 

restraints is being performed in accordance with the licensing basis, construction specifications,

drawings, and work procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to pipe supports and restraints activities is functioning properly, and to 

determine whether the records reflect work accomplishment consistent with specifications and 

procedures.

01.03 To verify that the as-built condition of pipe supports and restraints meets the specified 

design requirements, specifications, and drawings. For installation of safety-related piping, also 

refer to Appendix D of this inspection procedure (IP). 

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with pipe supports and restraints is effective and to verify that deviations 

from requirements are appropriately resolved.

69020.A5-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related piping systems being constructed at the site. 

Inspectors should also be familiar with the licensee’s Quality Assurance Program (QAP) 

and the licensing basis for the QAP (NPUFs are generally expected to commit to the QAP 

requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for pipe supports and restraints work onsite at the time of the inspection. Inspectors should also coordinate this appendix with 

inspection of safety related piping (Appendix D of this IP) for efficiency, if possible. 

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the pipe supports and restraints on the site, 

but may expand the inspection if time allows, or if significant concerns with the licensee’s 

control of pipe supports and restraints construction arise. Inspectors should collect 

licensee procedures, construction specifications, and work completion records in 

advance, if possible. 
Issue Date: 12/14/15 E-2 69020

If unable to review these documents in advance of the on-site inspection, then the 

licensee should be notified that these documents, and any other relevant documents, 

should be available when the inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.05 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Review of QA Implementing Procedures

Review QA Manual and implementing procedures associated specifically with pipe 

supports and restraints, to determine whether the commitments in the approved QAP

are being implemented as follows:

a. Adequate QA audit procedures have been established for this activity, in accordance 

with, the approved QA Plan including: (1) scope and frequency of audits; (2) audit 

criteria; (3) reporting requirements; (4) follow-up action; and (5) resolution of findings by 

those audited.

b. Provisions have been made to ensure that those engaged in conducting audits are 

qualified and have been adequately trained. Provisions must ensure that auditors do 

not have direct responsibility in the areas being audited.

c. Means have been established to verify that technical requirements, including material 

and component specifications (including traceability and marking requirements for nuts, 

bolts and other fastener items), acceptance criteria, and required documentation are 

specified in design and procurement documents.

d. Means have been established to verify that any significant design and field changes 

from approved drawings are adequately controlled and processed commensurate with 

the original design.

e. Provisions have been established to ensure that quality requirements are met (including 

documentation that quality requirements of materials and components are met before 

installation or use) and that deviations, nonconformance’s, and defects are adequately 

documented and processed through to complete resolution.

f. The licensee has established a program for ensuring that all craft, nondestructive 

examination (NDE), and inspection personnel associated with the installation of pipe 

supports and restraints have been trained, or otherwise qualified to the work 

procedures involved. Specific attention should be directed toward those engaged in the 

installation and testing of concrete expansion anchors, if these are used.

02.03 Review of Work Procedures.

a. Determine whether procedures and instructions (e.g., drawings, specifications, 

manufacturers' instructions, etc.) pertaining to pipe supports and restraints have been 
Issue Date: 12/14/15 E-3 69020

reviewed and approved. Make this determination by reviewing an appropriate sample 

of work procedures.

The sample should include procedures and instructions for supports on various-size 

piping, and instrumentation lines.

b. Determine whether work procedures incorporate the following:

1. Controls to ensure that the type and classification of pipe supports and restraints 

comply with approved drawings and/or specifications and meet licensee 

commitments.

2. Instruction and precautions to ensure that welding, cutting, forming, heat treating, 

and machining are performed in a manner that will prevent the impact properties 

of the material from being degraded below specified values.

3. Provisions for ensuring that required pre-installation and in-process inspections, 

as discussed in Section 02.03a, are performed at the appropriate time.

4. Means to ensure that bolts, nuts, and washers (including lubricant, if used) are of 

the proper type, size, and material, with required identification-markings; are 

correctly installed; and, where required, bolt pre-loading (torquing), minimum bolt 

embedment, and thread engagement criteria are imposed.

02.04 Observation of Work and Work Activities

By direct observation, interviews, or independent evaluation of work performance, works 

in progress, and/or completed work, determine whether activities regarding pipe support 

and restraint systems are being accomplished, in accordance with NRC requirements, 

the licensing basis, and licensee procedures.

a. Pre-installation Activities. 

1. Pre-installation checks are made to ensure hydraulic units are not installed if 

there is evidence of excessive leakage of hydraulic fluid (possible damage or 

deterioration of seals), physical damage, or corrosion of polished sliding 

surfaces. (Not required if hydraulic snubbers are not used.)

2. Pre-installation check on variable type supports are performed for obvious 

damage, rust, or other conditions that may interfere with their proper operation.

3. Pre-installation checks are made to ensure that bolts, nuts and other fastener 

items are available and are of the correct type, size, and material with required 

identification markings.

4. Any pre-installation field repairs or adjustments to the units are performed in 

accordance with the manufacturers' instructions and specifications, to ensure that 

performance requirements are met.
Issue Date: 12/14/15 E-4 69020

5. Installation equipment such as torque wrenches and other testing and measuring 

devices are properly controlled, calibrated, and adjusted at specified periods.

6. Personnel engaged in the installation of pipe supports and restraints have 

received adequate training to perform special processes contained in relevant 

work performance and inspection procedures.

b. Installation Activities

1. If installation activities are on-going at the time of the inspection, observe

portions of the installation activities to verify the following:

(a) The latest issue (revision) of applicable drawings or procedures is 

available to the installers.

(b) Appropriate personnel approve significant modifications to supports, 

before implementation.

(c) The use of jacks or rigging to pull piping into position for hanger installation 

or welding does not exceed cold-spring allowances for that particular 

material, size, and length of pipe run.

(d) Clearances existing between the pipe and restraints are as specified.

2. If installation activities are on-going at the time of the inspection, observe

portions of the installation and testing of concrete anchor bolts for componentsupport elements to verify that anchor-bolt type, diameter, embedment length, 

shoulder-to-cone measurements, and torque requirements meet installation 

requirements.

c. Dynamic Pipe Supports

Inspect installed restraints (if possible, select different load classifications and at various 

degrees of accessibility) and determine, by visual examination, whether the following 

conditions meet applicable requirements:

1. Components are free from corrosion or other signs of deterioration.

2. Support plates, extension rods, and connecting joints are not bent, deformed, 

loose, or otherwise out of specification.

3. Bolts, nuts, washers, locking devices, and other fasteners are tight and secure 

and are of the correct type, size, and material, with required identification 

markings. Where required, bolt-tension specification requirements have been 

met through the use of properly calibrated bolt-torquing wrenches and torque 

multipliers.

4. Bleed holes are open and free from foreign material.
Issue Date: 12/14/15 E-5 69020

5. Lubricants and sealants are applied as specified and there does not appear to be 

excessive leakage.

6. Seals are not deteriorated (if visually observable without dismantling).

7. Connecting joints, moving parts, piston shafts, seals, etc., are free from foreign 

material such as concrete, dropped paint, excessive dust and dirt, or other 

material that may obstruct proper operation.

d. Rigid, Constant, and Variable-Type Supports

1. Inspect installed spring-hanger assemblies covering different load ratings and 

observe the following:

(a) Hanger rods for supporting (2-inch) pipe are not less than (3/8-inch) 

diameter, and for (2-1/2-inch) pipe or larger, not less than (1/2-inch) 

diameter.

(b) Spring hangers are provided with indicators to show the approximate “hot”

or “cold” position, as appropriate.

(c) Spring hangers enclosed in spaces that will be subjected to high ambient 

temperatures during facility operation have suitable service ratings to 

accommodate the expected operating-temperature range.

2. Inspect installed pipe supports of different sizes (load rating) and at various 

degrees of accessibility. Determine, by visual examination, whether the following 

conditions exist:

(a) No deformation or forced bending is evident.

(b) No deterioration or corrosion is evident.

(c) Where pipe clamps are used to support vertical lines, shear lugs are 

welded to the pipe (if required by installation drawings) to prevent 

slippage.

(d) Movements of pipe from vibration, thermal expansion, etc., will most likely 

not cause contact with other pipes, supports, equipment, nor components. 

(As best as can be determined after installation, but before initial 

operation.)

(e) Sliding or rolling supports are provided with material and/or lubricants 

suitable for the environment and compatible, sliding-contact surfaces.

3. Inspect small-bore or instrumentation lines that have been designed by a 

simplified seismic criterion. Determine, by visual examination, whether the 

following conditions meet applicable requirements:
Issue Date: 12/14/15 E-6 69020

(a) The functional restraint direction is proper and in accordance with the 

design drawings.

(b) The gaps between the piping and support appear adequate to allow 

thermal axial expansion.

(c) The gaps between the piping and support are not excessive for dynamic 

loads.

e. Component Supports

Inspect installed component supports, including, if possible, multiple pipe supports, and 

ascertain, by visual examination, whether the following conditions exist:

1. Component-support elements are located and installed as specified on the 

drawings.

2. The surfaces of welds meet applicable Code requirements. Check weld surfaces 

for grooves, abrupt ridges, valleys, undercuts, cracks, discontinuities, or other 

detrimental indications that appear to exceed Code limitations.

3. Materials used in the construction of the component supports have been certified 

by reviewing material-test reports or a certificate of compliance.

4. Where special bolting materials are specified, check for compliance with 

specifications including preload (torquing) requirements.

5. Support clearances are as specified.

f. As-Built Configuration

1. Obtain as-built/final design-pipe-support structural drawings and compare several 

selected supports with the actual installation.

Discrepancies observed may result from in-process changes, such as those 

initiated in the field. If in-process changes are involved, determine whether the 

licensee has properly controlled and documented these changes on a current 

basis for engineering review, approval, and subsequent incorporation into final 

as-built drawings.

2. Determine pipe-anchor locations on the as-built drawings [piping (2-1/2 inches) in 

diameter and greater]. These anchor locations are designed to restrict individual 

pipe movement in all directions. Visually examine these anchors and compare 

them with the drawings, to ensure agreement as to their location and function.
Issue Date: 12/14/15 E-7 69020

02.05 Review of Records.

a. Review licensee and contra00ctor requirements covering the span of records for piping 

supports and restraints. Determine the initiation point for those records sampled and, 

importantly, the effectiveness of those responsible for reviewing the records for 

accuracy and completeness and ensuring that the recorded information meets 

documentation requirements. To determine the effectiveness of the licensee or 

contractor system for documenting work in this area, verify that:

1. Type and classification of pipe support or restraint comply with appropriate 

drawings and specifications.

2. Location, spacing, and critical clearances meet licensee’s specifications and 

have been verified by licensee QA/quality control (QC) inspection.

3. The required scope of licensee QA/QC inspections was met.

4. Weld identification/location corresponds to respective weld card, drawing, work 

order, or other welding documentation.

5. Welding material used corresponds to the material specified.

6. Welders were qualified to the welding procedures used and welding procedures 

were qualified in accordance with Code requirements.

7. The records confirm that for welding activities where attachments are welded 

directly to piping, the welding specifications used are the same or equivalent to 

the ones used for pipe welding, including preheat, post weld-heat treatment, and 

NDE examinations.

8. The examination records are complete and meet the inspection and/or NDE 

procedure requirements.

b. Review the licensee/contractor system for reporting and dispositioning non-conforming 

materials, parts, and components, and their process for installation deficiencies, 

associated with pipe supports and restraints. Determine whether:

1. The records adequately document current status of nonconformance’s and 

deviations.

2. The records are legible, complete, and indicate that reports are promptly 

reviewed by qualified personnel for evaluation, disposition, and prioritization.

3. The records are routinely being processed through established channels for 

resolution of the immediate problem, as well as for generic implications.

4. The records are being properly identified, stored, and can be retrieved in a 

reasonable time.
Issue Date: 12/14/15 E-8 69020

5. Nonconformance reports include the status of corrective action or resolution.

6. Resolution of nonconformances is appropriate and demonstrates good 

engineering practice.

c. To determine whether qualified licensee, contractor, craft, and inspection personnel are 

being used on those special processes associated with pipe support and restraint 

installation work, review a sampling of personnel qualification records covering several 

different disciplines as follows:

1. Determine whether a system of personnel qualification records, meeting stated 

requirements, exists and is being maintained in current status.

2. Determine if the records are sufficient to reasonably support qualification in terms 

of certification, experience, proficiency, training, testing, etc., as applicable.

3. Review the action taken by responsible licensee/contractor organizations to 

independently authenticate the employment, training, and qualification history of 

newly hired personnel.

d. Review relevant portions of licensee and contractor audit reports concerning the 

installation of pipe supports and restraints. Determine whether:

1. The required audits have been performed in accordance with schedule and 

functional areas in established audit plans.

2. Audit findings have been reported in sufficient detail to permit a meaningful 

assessment by those responsible for corrective action, final disposition, and 

trending.

3. The licensee/contractor has taken proper follow-up action on those matters in 

need of correction.

69020.A5-03 INSPECTION GUIDANCE

03.01 General Guidance.

This procedure pertains to pipe supports and restraints in SC-I and SC-II systems. Pipe 

supports include pipe hangers, restraints, supports, shock and sway suppressors, etc. that

directly support the pipe. Pipe whip restraints, such as structural steel or concrete barriers 

that do not normally contact the pipe, are not covered by this procedure. 

Considerable impact on the development and structure of this IP has resulted from a series 

of problems NRC has encountered at nuclear power plants in the area of pipe supports and 

restraints. These problems and concerns are best summarized in Inspection and 

Enforcement (IE) bulletins, circulars, and information notices that have been issued over the 

years. These documents are listed in the reference section below. Information contained in 
Issue Date: 12/14/15 E-9 69020

these issuances may be beneficial to the inspectors during implementation of this IP.

The inspectors should assure that required 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, and that required markings are on the item.

The inspectors should note markings on material and equipment and verify that the markings 

represent material and equipment as specified by the design drawings and specifications. In 

the case of fasteners, compliance with the applicable material specification [e.g., (American 

Society for Testing and Materials or American Society of Mechanical Engineers (ASME)), 

material and grade] should be verified by required markings on bolts and nuts and certified 

material test reports or certificates of conformance, as required by the applicable 

procurement drawings and specifications, and/or by the applicable codes and specifications. 

In the case of vendor-supplied equipment assemblies containing fasteners, samples should 

be inspected to verify compliance with approved vendor drawings and specifications, and 

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

Caution should be exercised to ensure that the required markings on material and equipment, 

including fasteners, not only exist, but that the markings indicate the correct material and 

grade, as specified.

03.02 Specific Guidance

a. Sections 02.02a and b. Audit procedures and/or checklists for pipe supports and 

restraints systems should provide for checks of each type of system used and should, if 

possible, include representative samples from all suppliers of components. Audit 

procedures or criteria should address the qualifications needed by those performing the 

audits.

b. Section 02.02f. The inspectors should determine specific steps the licensee has taken, 

or plans to take, to ensure that only qualified personnel are permitted to perform work 

associated with the installation of pipe supports and restraints. This effort may tie in 

with the review of the licensee’s audit plans specific to this area of work.

c. Section 02.03b2. Most of the welding, cutting, and forming operations covered by this 

procedure pertain to component-support structures, support members, and brackets, 

and do not require pre-heat-treatment or post-weld heat treatment. However, those 

pipe supports, support flanges, or support brackets that are directly welded to safetyrelated piping may be subject to preheat and/or post-heat treatment. Applicable heat

treatment procedures are necessary for this type of installation. Records of heat 

treatment (time, temperature) must be generated and reviewed for Code compliance.

d. Section 02.04b2. Refer to IE Bulletin No. 79-02 (and revisions), “Pipe Support Base 

Plate Designs Using Concrete Expansion Anchor Bolts,” for general information.

e. Section 02.04e3. The material certificate and identification should meet the 

requirements of the applicable Code/Standard.
Issue Date: 12/14/15 E-10 69020

f. Section 02.04f. The intent is to determine whether pipe supports and restraints are 

being installed according to properly approved drawings -- either the original design 

drawings or properly approved revisions. If revisions are in process, these changes are 

properly handled in accordance with established procedures.

Appropriate standards can be used as a guide in this area. In general, where changes 

to previously verified designs have been made, design verification shall be required for 

the changes, including evaluation of the effects of those changes on the overall design.

For example, ANSI/ANS 15.8 states that “changes to verified designs shall be 

documented, justified, and subject to design control measures commensurate with 

those applied to the original design.” 

Changes may be made to these supports, during construction, that are different from 

the original design. Such changes will result in the accumulation of various types of 

design-change documents and/or marked-up drawings. Since these changes reflect 

as-built conditions, they should be adequately controlled so they will be readily 

available for use with affected original design documents during future evaluation on 

the effect other design changes have on the overall design. Additionally, the as-built 

process should result in proper and timely updating of the original/master drawings and 

specifications to incorporate such changes.

g. Section 02.05. The inspectors should bear in mind that the NRC’s inspection sample 

covers only a small portion of the records involved. Thus, substantive errors, or 

departure from requirements identified in the NRC’s sample, raise the issue of whether 

the licensee is adequately controlling the process. In this connection, particular 

attention should be given to reviewing the adequacy of those records dealing with the 

qualification of personnel and QA audits. Problems noted in these two areas should be 

viewed as prime indicators of the licensee’s involvement in the work and the 

effectiveness with which the licensee maintains control over the work in progress.

03.03 Prevalent Errors and Concerns

This section is included to provide background on past problems of a generic nature 

that have been identified at nuclear power facilities. This section is for information only.

a. Welders not properly qualified to applicable Code, and records not properly maintained.

b. Personnel-qualification records, including indoctrination, training, examinations, and 

certifications, either not being maintained, invalid, or nonexistent for some employees.

c. Field-design work (redesign, modifications) not being processed through appropriate 

review and approval route.

d. Nonconformance reports not being processed fully in accordance with established 

procedures.

e. Personnel assigned to licensee audit function not appropriately trained in the assigned 

audit areas nor independent from areas audited.
Issue Date: 12/14/15 E-11 69020

f. Licensees and contractors conduct some audits on schedule, but may postpone or omit 

others entirely. Although audits are carried out to some extent and may be adequately 

performed, in many instances the audit findings and recommendations are ignored or 

are filed without appropriate consideration or follow-up action.

g. Refer to Appendix A of IE Bulletin 79-14, for additional problem areas. Other IE 

bulletins, circulars, and information notices listed below in the reference section of this 

IP contain additional information about problem areas.

03.04 Definitions

Dynamic Pipe Supports. A pipe-support assembly or restraint, with a hydraulic or 

mechanical control unit-designed to prevent unrestrained pipe motion during an 

earthquake or vibratory pipe movements brought on by the actuation of a water 

hammer, steam hammer, pump/start/stop, or safety and relief valve. Thermal 

expansion of piping is not restrained by dynamic supports (snubbers, shock 

suppressors, etc.).

Rigid, Constant, and Variable Type Supports. Pipe support assemblies used for 

mounting pipes without hydraulic or mechanical control units (hangers, base supports, 

saddle supports, spring hangers, sliding and rolling supports, etc.).

Component Supports. Metal elements that transmit loads between plant components 

and the building structure whose function includes carrying the weight of components or 

providing them with structural stability.

Component Standard Supports. Pipe-support assemblies consisting of one or more 

units usually referred to as catalog items and generally mass-produced (anchors, 

guides, restraints, rolling or sliding supports, spring hangers, snubbers, sway braces, 

vibration dampeners, clamps, etc.).

69020.A5-05 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate.

69020.A5-06 REFERENCES

U.S. Code of Federal Regulations, Title 10, Part 21, “Reporting of Defects and 

Noncompliance.”

American Society of Mechanical Engineers, ASME B31.3-2002, “Process Piping.”

American Welding Society, AWS D1.1, “Structural Welding Code.”
Issue Date: 12/14/15 E-12 69020

American Society of Civil Engineers, ASCE 4-98, “Standard Seismic Analysis of 

Safety-Related Nuclear Structures.”

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.61, “Damping Values for 

Seismic Design of Nuclear Power Plants,” October 1973.

American National Standards Institute/American Institute of Steel Construction, 

(ANSI/AISC) N690-1994, “Specification for the Design, Fabrication, and Erection of 

Steel Safety-Related Structures for Nuclear Facilities (SC I).”

The following references describe problems at nuclear power facilities and are for 

background information only:

Inspection and Enforcement Bulletin, (IE) Bulletin 73-03 (and revision), “Defective 

Hydraulic Shock Suppressors and Restraints.”

Inspection and Enforcement Bulletin, (IE) Bulletin 73-04 (and revision), “Defective 

Bergen-Paterson Hydraulic Shock Absorbers.”

Inspection and Enforcement Bulletin, (IE) Bulletin 73-07, “Failure of Structural or 

Seismic Support Bolts on Class 1 Components.”

Inspection and Enforcement Bulletin, (IE) Bulletin 74-03, “Failure of Structural or 

Seismic Support Bolts on Class 1 Components.”

Inspection and Enforcement Bulletin, (IE) Bulletin 75-05, “Operability of Hydraulic 

Shock and Sway Suppressors.”

Inspection and Enforcement Bulletin, (IE) Circular 76-05, “Hydraulic Shock and Sway 

Suppressors.”

Inspection and Enforcement Bulletin, (IE) Circular 76-07, “Damaged Components of 

Bergen-Paterson Hydraulic Test Stand.”

Inspection and Enforcement Bulletin, (IE) Bulletin 78-10, “Bergen-Patterson Hydraulic 

Shock Suppressors Accumulator Spring Coils.”

Inspection and Enforcement Bulletin, (IE) Information Notice 79-01, “Bergen-Paterson 

Hydraulic Shock and Sway Arrestors Reported Failures.”

Inspection and Enforcement Bulletin, (IE) Bulletin 79-02 (and revisions), “Pipe Support 

Base Plate Designs Using Concrete Expansion Anchor Bolts.”

Inspection and Enforcement Bulletin, (IE) Bulletin 79-07, “Seismic Stress Analysis of 

Safety-Related Piping.”

Inspection and Enforcement Bulletin, (IE) Information Notice 79-10, “Nonconforming 

Pipe Support Struts.”
Issue Date: 12/14/15 E-13 69020

Inspection and Enforcement Bulletin, (IE) Bulletin 79-14 (and revisions), “Seismic 

Analysis for As-Built Safety-Related Piping Systems.”

Inspection and Enforcement Bulletin, (IE) Circular 79-25 (and supplement), “Shock 

Arrestor Strut Assembly.”

Inspection and Enforcement Bulletin, IE Information Notice 79-28, “Overloading of 

Structural Elements Due to Pipe Support Loads.”

Inspection and Enforcement Bulletin, (IE) Bulletin 81-01 (and revision), “Surveillance of 

Mechanical Snubbers.”

Inspection and Enforcement Bulletin, (IE) Circular 81-05, “Self-Aligning Rod End 

Bushing for Pipe Supports.”

Inspection and Enforcement Bulletin, (IE) Information Notice 82-12, “Surveillance of 

Hydraulic Snubbers.”

END
Issue Date: 12/14/15 F-1 69020

APPENDIX F

INSPECTION OF MECHANICAL COMPONENTS AT NON-POWER PRODUCTION AND 

UTILIZATION FACILITIES

69020.A6-01 INSPECTION OBJECTIVES

01.05 To determine whether work activities associated with safety-related mechanical 

components is being performed in accordance with the licensing basis, construction 

specifications, drawings, and work procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to mechanical component activities is functioning properly, and to determine 

whether the records reflect work accomplishment consistent with specifications and procedures.

01.03 To verify that the as-built condition of mechanical components meets the specified design 

requirements, specifications, and drawings. 

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with mechanical components is effective and to verify that deviations from 

requirements are appropriately resolved.

69020.A6-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related mechanical components being constructed 

at the site. Inspectors should also be familiar with the licensee’s Quality Assurance

Program (QAP) and the basis for the QAP (NPUF licensees are expected to commit to 

the QAP requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for mechanical components work on-site 

at the time of the inspection. 

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the mechanical components on the site, but 

may expand the inspection if time allows, or if significant concerns with the licensee’s 

control of mechanical component construction arise. Inspectors should collect licensee 

procedures, construction specifications, and work completion records in advance, if 

possible. If unable to review these documents in advance of the on-site inspection, then 

the licensee should be notified that these documents, and any other relevant documents, 

should be available when the inspector(s) arrives at the site.
Issue Date: 12/14/15 F-2 69020

Inspectors should review the areas listed in 02.02 through 02.08 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Review construction documentation (specifications, drawings, and work procedures) and 

QA procedures to determine whether they appropriately and adequately assure that 

specific activities associated with safety-related mechanical components are controlled 

and performed according to NRC requirements, the licensing basis, and the approved QA 

Plan. In particular, ascertain whether provisions have been established to assure that:

a. Procurement documents incorporate the technical and quality requirements in the 

material requisition. This includes identification of material specifications and, if 

required, performance test requirements.

b. Receipt inspections are adequate and capable of detecting damage or 

out-of-specification conditions, including adequacy of performance testing, etc. Also, 

provisions are in place to prevent nonconforming equipment and materials from being 

installed and used.

c. Installation, testing, and inspection activities meet applicable specifications and 

established procedures.

d. Specially trained personnel are used whenever complex or unusual activities are 

involved.

e. Specifications and installation procedures for motor-operated valves provide detailed 

information relative to the setting of torque switches, limit switches, and limit-switch 

bypasses.

f. Post-inspection cleaning, preservation, and inspection requirements have been 

established before needed.

g. Record-keeping requirements are established and clearly indicate those responsible for 

record generation; and provisions exist for their review by appropriate management 

personnel.

h. Design changes, including field changes, are properly reviewed and coordinated among 

affected design and engineering organizations.

02.03 Select representative safety-related mechanical components to inspect. The sample may

contain materials handling, fluid transport, or fluid systems components (including, 

process vessels, tanks, and enclosures). Observe work performance, partially completed 

work, and/or completed work on these components, as appropriate. Review the pertinent 

quality-related records for the components selected, or a similar selection of components 

if more appropriate. Determine whether the following activities, for each of the above 

selected components, meet applicable QAP requirements:
Issue Date: 12/14/15 F-3 69020

a. Receipt Inspection.

1. Adherence to receipt inspection procedures. Records confirm that required 

material characteristics, performance tests, nondestructive tests, environmental 

qualification tests, and other specification requirements are met.

2. Receipt inspection and storage records indicate that, where appropriate, 

defective or incorrect components, parts, and materials are controlled and 

prevented from installation and possible use.

3. Documentation has been prepared and maintained as required by receipt 

inspection and documentation storage instructions.

b. Storage, Handling, and Protection.

1. Storage environment and protection of components (protective covers, caps, 

preservatives, desiccants, heaters, inert gas blankets, etc.) are in accordance 

with manufacturer’s instructions and/or established procedures.

2. Implementation of special storage and maintenance requirements such as 

rotation of motors, pumps, lubrication, insulation testing (electrical), cleanliness, 

etc.

3. Performance of licensee/contractor surveillance activities and documentation 

thereof are being accomplished at required frequency.

c. Installation.

1. Installation requirements such as proper location, placement, orientation, 

alignment, mounting (torqueing of bolts and expansion anchors), flow direction, 

tolerances, and expansion clearance are met.

2. Precautions to prevent damage during placement/mounting are adhered to, 

where appropriate.

3. Availability and usage of specially trained personnel and equipment where 

required to meet component manufacturer=s instructions.

4. Torque switches, limit switches, and bypass switches on valves have been 

properly installed, adjusted and checked out, in accordance with established 

instructions and procedures. Integrated system checks could be a potential 

focus of inspection.

5. Appropriate drawings and work procedures are available to installers. Installation 

requirements, construction drawings, specifications, and work procedures are 

technically adequate and of the latest approved issue.

6. Hold points are observed, when required.
Issue Date: 12/14/15 F-4 69020

7. Design changes relevant to the work being observed have been appropriately 

processed through required review and approval routes.

8. Preparation and maintenance of installation and inspection records are 

adequate.

d. Protection and Maintenance after Installation.

1. Inspection activities, including scope and frequency, are being performed 

according to instructions.

2. Protection provided as required, including protection against adverse 

temperature, humidity, flooding, and foreign materials, such as dirt, dust, bottles, 

cans, and general debris.

3. Lubrication, rotation, and electrical resistance checks are being performed, as 

required.

4. Records are being maintained on the status of installed components.

5. Appropriate stamps, tags, markings, etc., are in use to prevent oversight of 

required inspections, completion of tests, acceptance, and the prevention of 

inadvertent operation.

02.04 Select representative as-built/final design system drawings and compare portions of these 

drawings with the actual installation. Discrepancies observed may be caused by 

in-process changes, such as those initiated by the design organization, or those initiated 

in the field. If in-process changes are involved, determine whether the licensee has 

properly controlled and documented these changes on a current base or engineering 

review, approval, and subsequent incorporation in final as-built drawings.

02.05 Select one or more workers engaged in work activities associated with installation and 

inspection of mechanical components and confirm or discuss the following:

a. Qualifications of those engaged in component installation and inspection work appear 

adequate and commensurate with the work in progress.

b. Ability to perform their assigned duties and assume their assigned responsibilities.

c. There is adequate time allocated to the QC function to study installation specifications 

and instructions and to perform the required component inspections.

d. An appropriate level of independence exists between QA/QC and construction (i.e., 

organizational freedom to identify nonconforming conditions and document their 

existence).

e. Adequate management support for QA/QC functions.
Issue Date: 12/14/15 F-5 69020

f. Effectiveness of management’s control over component installation work as may be 

evidenced through the performance of audits (or their arrangements to have others 

conduct audits) including follow-up of audit findings.

02.06 Determine whether qualified licensee/contractor, engineering, craft, and inspection 

personnel, associated with safety-related component installation work are being used, by 

reviewing a sampling of personnel qualification records, including different disciplines, as 

follows:

a. Determine whether a system of personnel qualification records meeting stated 

requirements exists and is being maintained in current status.

b. Determine if the records are sufficient to reasonably support qualification in terms of 

certification, experience, proficiency, training, testing, etc., as applicable.

c. Review the actions taken by responsible licensee/contractor organizations to 

independently authenticate the validity of critical qualification statements.

02.07 Review the licensee/contractor system for reporting and dispositioning nonconformances

associated with the procurement, installation, and testing of safety-related mechanical 

components, to determine whether:

a. Records adequately document current status of nonconformance and deviations. 

b. The sample of records is legible and complete, and indicates that reports are promptly 

reviewed by qualified personnel.

c. Records are routinely being processed through established channels, for resolution of 

the immediate problem, as well as generic implications.

d. Corrective actions are appropriate to the circumstances and are appropriately 

prioritized.

e. Records are being properly identified and stored, and can be retrieved in a reasonable 

time.

f. Nonconformance reports include the status of corrective actions or resolutions and 

actions to prevent recurrences.

02.08 Determine whether the licensee has an established audit program (including audit plans, 

procedures, and schedules) covering work and control functions in the area of safetyrelated component installation. Sample the audit output for the components, processes, 

and work being followed in the inspection effort.
Issue Date: 12/14/15 F-6 69020

69020.A6-03 INSPECTION GUIDANCE

03.01 General Guidance

Particular attention should be given to the traceability of material and equipment, to 

prevent the use of incorrect or defective materials, parts, and components. The 

inspectors should review the QAP procedures associated with “Identification and 

Control of Materials, Parts, and Components,” and applicable codes and specifications, 

for additional guidance. The inspectors should verify that the licensee has established 

measures for identification and control of materials, parts, and components, and for 

traceability, to the approved design basis and to the source. The inspectors should 

ensure that required 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, and that required markings are on the item.

The inspectors should note markings on material and equipment and verify that the 

markings represent material and equipment as specified by the design drawings and 

specifications. In the case of fasteners, compliance with the applicable material 

specification [e.g., (American Society for Testing and Materials) or (American Society 

for Mechanical Engineers) material and grade] should be verified by required markings 

on bolts and nuts and certified material test reports or certificates of conformance, as 

required by the applicable procurement drawings and specifications, and/or by the 

applicable codes and specifications. In the case of vendor-supplied equipment 

assemblies containing fasteners, samples should be inspected to verify compliance 

with approved vendor drawings and specifications and other information, such as 

materials used for equipment-qualification tests and/or analyses. Caution should be 

exercised to ensure that the required markings on material and equipment, including 

fasteners, not only exist, but that the markings indicate the correct material and grade, 

as specified.

03.02 Specific Guidance.

Note: The numbering of the guidance below refers to specific subsections of 02, above.

02.02b Material-storage procedures should include the requirements that components 

be identified; properly segregated by type; provided protection from physical or 

contamination damage, during handling and storage; and that controls for 

component withdrawal are provided, to ensure proper issuance.

02.03 Components selected should be representative of the type of plant components 

involved in materials-handling, fluid transport, and fluid systems.

02.07 Review selected nonconformance and deviation reports in detail. Specifically, 

determine whether the corrective action initiated appears likely to preclude 

repetition. The reviewer should be particularly watchful for nonconformance 

reports signed off without adequate explanation, or reports that have been closed 

before being fully processed in accordance with procedures. 
Issue Date: 12/14/15 F-7 69020

Also, if components with reported nonconforming conditions are permitted to be 

installed, NRC inspectors should confirm that the licensee’s control system 

effectively tracks the condition until resolved.

02.08 Inspectors should determine if audits have been planned and carried out in 

accordance with an announced schedule. Qualification of auditors should be 

verified to ensure that they are fully qualified for the assigned areas.

03.03 Prevalent Errors/Concerns.

This section is included to provide background for inspectors on past problems of a 

generic nature.

a. Documentation not kept current.

b. Inspection documentation signed off by persons other than the inspectors actually 

responsible for the recorded information.

c. Nonconformance report system deficient in that reports could be destroyed, filed away, 

or otherwise signed off, without proper resolution or accountability of action taken.

d. Weather protection degradation due to inattention to damage and normal “wear and 

tear,” leading to substandard or unacceptable protection provisions.

e. Improper installation and adjustment of motor-operated valve torque switches, limit 

switches, and bypass switches. Applicable specifications and instructions have not 

been adequate to ensure proper installation, adjustment, and check-out.

f. Inspection procedures, instructions, and acceptance criteria lack clarity, and in some 

cases are difficult to find and use.

g. Licensee audit reports containing adverse findings and recommendations without 

appropriate follow-up and resolution.

69020.A6-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A6-05 REFERENCES

U.S. Code of Federal Regulations, Title 10, Part 21, “Reporting of Defects and Noncompliance.”

END
Issue Date: 12/14/15 G-1 69020

APPENDIX G

INSPECTION OF ELECTRICAL CABLE AT NON-POWER PRODUCTION AND UTILIZATION

FACILITIES

69020.A7-01 INSPECTION OBJECTIVES

01.06 To determine whether work activities associated with safety related electric cable is

being performed in accordance with the licensing basis, construction specifications, drawings, 

and work procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to electric cable activities is functioning properly, and to determine whether the 

records reflect work accomplishment consistent with specifications and procedures.

01.03 To verify that the as-built condition of electric cables meets the specified design 

requirements, specifications, and drawings. For installation of electric components and 

systems, also refer to Appendix H of this inspection procedure (IP).

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with electric cables is effective and to verify that deviations from 

requirements are appropriately resolved.

69020.A7-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related electric cable systems being constructed at 

the site. Inspectors should also be familiar with the licensee’s Quality Assurance

Program (QAP) and the basis for the QAP (NPUF licensees are expected to commit to 

the QAP requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for electric cable work on-site at the time 

of the inspection. This appendix may be coordinated with Appendix H of this IP for 

efficiency, if possible.

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-work is desirable but not required. 

If necessary, inspectors may select completed work activities for inspection. Inspectors 

should not attempt to inspect all of the electric cables on the site, but may expand the 

inspection if time allows, or if significant concerns with the licensee’s control of electric 

cable installation arise. Inspectors should collect licensee procedures, construction

specifications, and work completion records in advance, if possible. If unable to review 

these documents in advance of the on-site inspection, then the licensee should be 

notified that these documents, and any other relevant documents, should be available 

when the inspector(s) arrives at the site.
Issue Date: 12/14/15 G-2 69020

Inspectors should review the areas listed in 02.02 through 02.10 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Procedure Review. Review the construction specifications and procedures for electrical 

cable and ascertain whether the specified technical requirements conform to the 

statements contained in the licensing documents. Determine whether the commitments 

in the approved QAP are being implemented, as follows:

a. Adequate QA audit procedures have been established for this activity in accordance 

with the approved QAP including: (1) scope and frequency of audits; (2) audit criteria; 

(3) reporting requirements; (4) follow-up action; and (5) resolution of findings by those 

audited.

b. Provisions have been made to ensure that those engaged in conducting audits are 

qualified and have been adequately trained. Provisions must ensure that auditors do 

not have direct responsibility in the areas being audited.

c. Means have been established to verify that technical requirements, acceptance criteria, 

installation methods, and required documentation are specified in design and 

procurement documents.

d. Means have been established to verify that any significant design and field changes 

from approved drawings are adequately controlled and processed commensurate with 

the original design.

e. Provisions have been established to ensure that quality requirements are met and that 

those deviations, non-conformances, and defects are adequately documented and 

processed through to complete resolution.

f. Provisions have been established to ensure that construction drawings incorporate the 

most recent design requirements. (Note: Field change requests should be reviewed to 

determine if there are field conditions that have not been adequately anticipated during 

the design process.)

g. The licensee has established a program for ensuring that all craft, nondestructive 

examination, and inspection personnel associated with the installation of electrical cable 

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

02.03 Specific Technical Review Areas. Determine if procedures covering work and inspection 

activities in the following areas are appropriate to the activity and are technically 

adequate:

a. Receipt Inspection Procedures (IPs). Receipt inspection and related procedures 

provide means to ensure the following:
Issue Date: 12/14/15 G-3 69020

1. Received components are as specified, properly identified and controlled or 

otherwise noted.

2. Input from other groups or other organizations to be used during receiving 

inspection activities are obtained and properly used, such as the results of 

source inspections, environmental qualification tests, and other required quality 

tests.

3. Procurement requirements, such as qualification tests (seismic, environmental, 

etc.), functional tests, certificate of conformance, and other quality tests (material, 

physical, and chemical), have been successfully completed, or status of how and 

when such requirements will be satisfied is documented and adequately 

controlled.

b. Storage Procedures. Storage procedures provide means to ensure the following:

1. The proper storage environments (as specified by the construction specifications 

and the manufacturers) are established for the various types of electrical 

components and meet applicable storage-classification levels, regardless of the 

location of the stored component.

2. Storage inspection procedures require initial verification of storage conditions and 

periodic verifications for the duration of the storage period. They must also 

ensure that special and in-place storage requirements are met.

c. Work Procedures. Work procedures are established to ensure the following:

1. NRC requirements and licensing document commitments are properly translated 

into the work procedures (construction specifications, drawings, and work 

instructions) for adequate control and installation of electrical cable and 

associated items. Areas to review should include, but are not limited to, the 

following:

(a) Raceway completion (edge softeners, bushings, supports, grounding, 

routing location, pull fittings, pull cords, identification, sharp edges, etc.) 

and condition (free of debris) before use.

(b) Cable/ busway type and size.

(c) Cable temperature (if stored in cold weather).

(d) Cable splices (where allowed).

(e) Pulling attachments, lubricating compounds, and tension (including 

calibration of tension devices).

(f) Bending radius (during and after installation).
Issue Date: 12/14/15 G-4 69020

(g) Cable identification/ color coding/ imprinted information.

(h) Cable routing.

(i) Separation and independence.

(j) Segregation (power, control, data instrument).

(k) Cable supports (grips).

(l) Handling of cable and termination materials to ensure protection from 

damage and contamination (includes protection of cable ends from 

moisture).

(m) Protection of cables from adjacent construction activities.

(n) Hold points.

(o) Termination activities such as:

(1) Application of materials (lugs, tapes, stress cones, connectors, 

punch down blocks, terminal blocks, etc.).

(2) Use of calibrated torque wrenches and crimping tools.

(3) Termination preparation procedures (insulation stripping, 

compression tools, labeling, polishing (fiber optics)).

(p) Raceway loading.

(q) Fire barriers and seals as required.

(r) Less than maximum tensile force applied pulling (cable tensile 

rating).

(s) Shield grounding (as applicable).

2. Interface controls are adequate when multiple contractors are involved.

d. Inspection Procedures. Inspection procedures have been established to ensure the 

following:

1. Positive identification of the cable system and/or activity to be inspected and the 

specific inspection method(s) to be used.

2. All safety-related aspects of construction specifications, drawings, and work 

instructions are included in the scope of planned inspections.
Issue Date: 12/14/15 G-5 69020

3. The technical aspects of inspection requirements and acceptance criteria are 

sufficient to determine whether installation, testing, maintenance, and protection 

conform to applicable design and construction specifications.

4. Records of initial and follow-up inspections include the specific results of the 

inspection. This should include the specific characteristics being inspected (or 

the actual measured values), the inspectors’ determination of acceptability, and 

identification of any non-conformances found.

e. Construction Testing Procedures Inspection Guidance. Procedures for safety-related 

cable system and component testing provide means to ensure that:

1. Cable systems and components to be tested and the related test procedures are 

properly identified and controlled. Procedures specify which construction tests 

are to be performed on each component requiring testing.

2. Proper type of test equipment (range, accuracy, etc.) is specified.

3. Type of data to be recorded and method of reporting results.

4. Review and evaluation of test results by qualified personnel.

5. Resolution of discrepancies.

6. Special conditions or testing, prerequisites, sequence, precautions, etc., and 

acceptance criteria are specified and meet requirements.

f. Personnel Qualifications Verification. A program has been established for ensuring that 

all craft, examination and inspection personnel associated with safety-related electric 

cable systems are trained and qualified to perform their assigned duties. The program 

includes:

1. The proper use of installation equipment (tension devices, pulling compounds, 

etc.).

2. The proper handling, supporting and protection of cables and cable segments 

stored in place.

3. Approved methods for cable end protection.

4. Identification of requirements for the installation of safety-related cables.

5. Approved methods for cable termination and splices.

6. Approved methods for fiber optic/data cable termination and inspection.

g. Change-Control Procedures. Procedures have been established to control design and 

field changes for cable systems and ensure the following:
Issue Date: 12/14/15 G-6 69020

1. Retrieval of voided drawings and specifications at work sites is controlled.

2. Field changes are subject to adequate design control and are incorporated into 

the as-built records.

3. Coordination among participating design and construction organizations is 

adequate.

02.04 Inspection of Cable Systems and Components.

Choose a sampling of safety-related cables. The sampling may include power, control, 

and data cables (fiber optic, communications, coax, twisted, multi-conductor, twisted, and 

shielded). The sampling may also be from a variety of locations, uses and types (e.g.: 

(1) large motors; (2) diesel generators; (3) motor-operated valves; (4) solenoid valves; (5) 

control centers; (6) control room panels and cabinets; (7) local panels and cabinets; (8) 

coaxial and triaxial connectors; (9) fiber optic connectors; and (10) stress-cone 

terminations).

02.05 Inspection Activities.

a. Receipt Inspection. Evaluate portions of receipt inspection activities pertaining to the 

electric power, control, data cables and associated items selected for inspection. 

Determine whether receipt inspection activities are being controlled and performed in 

accordance with the licensee’s commitments and procedures. 

1. Components and receiving documents are properly identified.

2. Physical conditions (damage, deterioration, etc.) are documented.

3. Documentation related to quality requirements (e.g., results of functional and 

qualification testing) received with cables and associated items is reviewed and 

meets the requirements. Where qualification testing of cables and associated 

items to be placed in a harsh environment is not a requirement of the 

specification, determine what means will be used to ensure that applicable 

environmental qualification will be satisfied.

4. Control of nonconforming cables and associated items, is conducted in 

accordance with applicable procedures and meets requirements.

5. Adequately, qualified personnel are available to perform the receipt inspection 

function.

b. Storage. Observe and evaluate storage activities and conditions for the selected 

components. Determine whether:

1. Electric power, control, data cables and associated items are stored in the proper 

storage level designation.
Issue Date: 12/14/15 G-7 69020

2. Cables, busways and associated items are properly identified.

3. Storage conditions (temperature, humidity, cleanliness, etc.) and requirements 

are controlled and monitored as directed by the applicable procedures and by the 

manufacturer’s specifications.

4. Licensee and contractor inspection and monitoring activities are being performed 

in accordance with procedural requirements.

5. Nonconforming cables and associated items placed in storage are identified 

and/or segregated as required.

6. In-place storage requirements are satisfied.

7. Adequately qualified personnel are available to perform the required storage 

functions.

c. In-Process Installation. If installation is in progress during the inspection, evaluate inprocess installation to determine if the licensee is following their procedures pertaining 

to the components and associated items selected in the appropriate subsections of 

Section 02.02. Inspect a sampling of the following attributes:

1. The latest approved revision of applicable construction specifications, drawings, 

and/or construction procedures are available and used by the installers. (Verify 

later that pull card data are consistent with the latest cable tabulation sheets.)

2. Cables, busways, associated materials, and pulling compounds are as specified. 

3. Pulling attachments and tensions used are acceptable. 

4. Cable temperature is acceptable before handling and installation.

5. Raceway completion and condition are adequate before cable is installed.

6. Cables are protected from sharp edges, hostile environments, and adjacent 

construction activities (especially welding and cutting activities).

7. Cable routing is correct.

8. Separation criteria for physical independence are maintained.

9. Segregation is maintained (e.g. power, control, and instrument).

10. Cable identification is preserved.

11. Proper bending radius is maintained (during and after installation).
Issue Date: 12/14/15 G-8 69020

12. Less than maximum tensile force is applied for pulling based on cable tensile 

rating

13. Cable and other conductor supports are provided.

14. Cable entry to terminal point is acceptable.

15. Shields are grounded per construction drawings and specifications.

16. Torque wrenches and crimping tools are in proper working order and properly 

calibrated.

17. Jumpers are controlled.

18. Terminations are of the correct type and properly located. 

19. Shield terminations for I&C cables are installed in accordance with the 

appropriate detail drawing requirements, using the appropriate lead connections. 

20. Shields for cables rated 5KV and above are terminated with appropriate 

materials, including voltage stress relief devices that do not compromise the 

integrity of the cable’s shield or insulation system, in accordance with project 

design standards. 

21. All cable shields are grounded appropriately per the project document 

requirements.

22. Tightness of connections is acceptable.

23. Appropriate scaffolding, walkways, and climbing aids are used in lieu of cable 

trays, conduits, etc.

24. Cabinets, control centers, cable trays, junction boxes, etc. are maintained free of 

debris (periodically cleaned).

25. Coiled cables are properly secured (i.e., not draped from cable trays, lying on 

floor, coil supported by single tie wire, etc.).

26. Un-terminated cable ends or un-terminated instrument cable shielding are 

properly protected (i.e., moisture protection), if required.

27. Specified fire barriers, compartment boundary seals, and fire-retardant materials 

are being installed or applied, where specified.

28. Electricians are properly qualified. 

29. QC inspectors are properly qualified and are present and performing their 

assigned tasks, when required, during handling and installation activities.
Issue Date: 12/14/15 G-9 69020

30. Non-conformances are identified and handled in accordance with procedures, 

including adequate justification for use-as-is disposition.

31. Installation and inspection activities are being documented during the activity.

d. Completed Work. Evaluate the completed installation of cables and associated 

selected items. 

1. Busway, cable, wire, and termination materials (lugs, tapes, stress cones, splice 

kits, connectors, terminal blocks, etc.) are as specified.

2. Cable routing is as specified on latest approved drawings.

3. Cable identification is preserved and located where specified.

4. Bending radius is as required.

5. Required separation criteria for physical independence are maintained.

6. Segregation is maintained (power, control, and instrument).

7. There is no evidence of damage to cable.

8. Terminations are properly located and made (entry, tightness, etc.) and are of the 

correct type.

9. Cable supports are provided and are adequate.

10. Cables are protected from sharp edges, hostile environments, and adjacent 

construction activities (welding, etc.).

11. Cable tray, conduit, etc. are adequately protected and not being used as ladders, 

walkways, etc.

12. Clearances between cable and adjacent components such as piping, ducts, and 

supports are as specified.

13. Cabinets, panels, cable trays, junction boxes, etc. are maintained free of debris 

(periodically cleaned).

14. Specified fire barriers, compartment boundary seals and fire-retardant materials 

are installed or applied, where required.

15. Specified inspections are made by qualified personnel.

16. Documentation of completed installation and inspection activities is properly 

completed, in a timely manner.
Issue Date: 12/14/15 G-10 69020

17. Nonconforming conditions are identified and handled in accordance with 

approved procedures, including adequate justification for use-as-is disposition.

18. Conductive grease and electrical contact lubricant (NO-OX-ID) has been applied 

to power connectors as required by construction drawings and specifications.

e. As-Built Verification. When electrical power, control, and data cables, and associated 

items, as selected in appropriate subsections of Section 02.02, are completely (or 

essentially) installed and inspected, the latest revisions (as-built, if available) of 

installation drawings pertaining to the cables and items selected for verification. Review 

construction specifications and other applicable work instructions referenced by the 

drawings. Compare the actual installation with the above drawings and associated 

documents. 

1. Before performing the above, verify the number and status of outstanding design 

changes on the selected drawings and related specifications.

2. Discrepancies observed may result from in-process changes, such as those 

initiated in the field. If in-process changes are involved, determine whether the 

licensee has properly controlled and documented these changes for engineering 

review, approval, and subsequent incorporation into the final as-built drawings.

f. Cable Testing. If possible, observe a sampling of the following cable-testing activities 

applicable for the sample selected in the appropriate subsections of Section 02.02:

1. High potential tests on high-voltage power cables and 4160-volt cables.

2. Insulation resistance tests.

3. Continuity tests.

4. Connector termination opacity test on...after cable.

5. Connection resistance testing on DC battery connectors.

6. Fiber optic cable testing

(a) Acceptance testing prior to installation

(b) Pre-installation: continuity test

(c) Post-installation: continuity test

7. Determine whether the following requirements are being met for the above tests 

(as applicable):

(a) Use of and compliance with the proper procedure
Issue Date: 12/14/15 G-11 69020

(b) Calibration of the test equipment is current and test personnel qualified to 

use the equipment.

(c) Results are properly and accurately recorded.

(d) Test results are within specifications limits or discrepancies are identified 

for resolution.

02.06 Record Control and Review. Review licensee and contractor requirements covering the 

control of records for safety-related electrical cable, terminations and associated items.

a. Ensure requirements determine who prepares each quality-related record, who reviews 

the records for accuracy, and who ensures that the recorded information meets 

requirements.

b. Evaluate the information obtained above and determine whether the established recordmanagement system satisfies licensing document commitments.

02.07 Work and Inspection Records. Review and evaluate pertinent quality records in a 

sampling of the areas listed below. Determine whether: (1) adequate preparation; 

control, review, and evaluation of these records have been made; (2) they reflect that 

appropriate requirements have been met; and (3) the system of records is functioning 

properly. If possible, the selection should include records associated with: (1) various 

safety related power, control, signal, data and instrument cables (including thermocouple 

wire); (2) cable connectors, splices, and support grips; (3) terminations, lugs, NO-OX-ID 

compound tapes, and pulling compounds; and (4) fire barriers, seals and retardants. The 

records selected should represent a diversity of cable and associated items and include 

some cable and terminations located inside the process facility.

a. Receipt Inspection Records. Select records applicable to the receipt of lots or 

shipments. 

b. Storage Records. Select records applicable to the storage, and storage inspection of 

lots or groups of cables and associated items.

c. Installation Records. Select records applicable to the installation and inspection of 

several cables and associated terminations for risk important components. 

d. Cable-Testing Records. Select records applicable to the testing of cables, several of 

which shall be located inside process buildings.

e. Raceway Loading Records. Review and evaluate records applicable to raceway 

loading for cable trays and cable conduits.

f. Personnel Qualification Records. Review and evaluate records applicable to the 

qualification and training of inspectors and craftsmen.

g. Change-Control Records. Review and evaluate design field change records. 
Issue Date: 12/14/15 G-12 69020

02.08 Nonconformance and Deviation Reports. For the inspection, review and evaluate a 

sampling of reports applicable to non-conformances or deviations in cables, terminations 

and cable system installation. Determine whether:

a. Records are legible, complete, and promptly reviewed by qualified personnel.

b. Reporting requirements of 10 CFR Part 21 were recognized during evaluation and 

appropriate action was taken where necessary.

c. Records have been routinely processed, evaluated in a timely manner and controlled 

through established channels, for resolution of the root-cause as well as the immediate 

problem.

d. Records are properly identified and stored, indicate current status, and can be retrieved 

in a reasonable time.

e. Non-conformance reports include the status of corrective action or resolution, and 

adequate justification is provided for use-as-is disposition.

02.09 Audit Records. Review and evaluate licensee and electrical contractor audit records. 

Determine if:

1. Audits have been performed in accordance with the schedule and functional 

areas established in the audit plan.

2. All elements of the QA program applicable to cable systems are being audited 

periodically.

3. Auditing organizations and personnel are independent of the work being audited.

4. Licensee is informed of the results of the electrical contractor(s) audits.

5. Audit records are sufficient to verify that the intended purpose and scope of the 

audits were achieved.

6. Audit findings have been reported in sufficient detail to permit a meaningful 

assessment by those responsible for corrective action, final disposition, and 

trending.

7. The licensee and contractor have taken proper and timely follow-up action on 

those matters in need of correction.

69020.A7-03 INSPECTION GUIDANCE

03.01 General Guidance.

a. The term “cable” includes all conductors such as fiber optics wires, cables, and bus 
Issue Date: 12/14/15 G-13 69020

bars. The term “termination” refers to all electric-conductor terminations such as lugs, 

splices, connectors, and terminal strips that directly contribute to the electrical continuity 

of the circuit. Terminations also include potheads, bushing, stress cones, taping, 

compounds, and other devices or techniques that directly contribute to the continuity of 

the electrical insulation system. 

b. Determine specific licensee procedural and work-instruction commitments relative to 

construction and inspection (QC) requirements for electric cables and terminations. 

The inspector should then utilize the above information during review of the licensee’s 

construction specifications, drawings, work, and inspection procedures to determine 

whether the licensing document requirements are adequately translated into the 

appropriate documents.

c. To be adequate, procedure control activities such as receipt, storage, installation, 

inspection, calibration and testing should contain sufficient detail to ensure that the 

specific work steps which affect the functioning of the installed equipment will be 

performed properly. These work steps are to be identified and adequately controlled. 

While reviewing procedures, be aware of, and look for, inadequacies that could lead to 

construction deficiencies and/or indicate an inadequate management-control system.

03.02 Specific Guidance.

Note: The numbering of the guidance below refers to specific subsections of 02, above.

a. Section 02.03. For the purpose of this IP, the term “work procedures” includes 

construction specifications, drawings, and work instructions. (Procedures describing 

methods of fabrication, construction, and/or installation are sometimes called 

construction procedures.)

b. Section 02.03.a.

1. Verify that requirements contained in the approved quality assurance program 

document, or other applicable licensing commitments, have been adequately 

translated into the licensee’s receipt inspection procedures, including provisions 

assuring that:

(a) Cable, busways (power, control, and data), and termination materials are 

in conformance with purchase specifications including special 

requirements. 

(b) Adequate marking and identification are provided.

(c) As-received cleanliness and protection are adequate.

(d) Receiving inspection reports are complete.

(e) Control and disposition of non-conforming items are adequate.
Issue Date: 12/14/15 G-14 69020

2. The licensee should identify and describe all safety-related cables and 

associated items that must operate in a hostile environment (e.g., high radiation, 

temperature, humidity) during or subsequent to an accident. Where 

environmental qualification testing or other qualification provisions are specified, 

the licensee shall establish means to ensure that the results of this testing are 

documented, reviewed, and determined to be acceptable. This is a particularly 

significant area for NRC review. 

3. Inputs from other groups or other organizations (e.g., source inspection results or 

other required quality tests) to be used during receiving inspection activities are 

properly used.

4. Procurement requirements such as qualification tests, certificate of conformance, 

functional tests and other quality tests (material, physical, and chemical) have 

been successfully completed or status of how and when such requirements will 

be satisfied is documented and adequately controlled. Fire barriers and cablepenetration seals may require qualification. The tests and criteria can be found 

in the American Society of Testing and Materials (ASTM) E 814 and/or American 

National Standards Institute/Underwriters Laboratory Inc. (ANSI/UL 1479).

5. Samples of received electric power, control, and data cable, termination material 

and related items are subjected to detailed dimensional checks or other 

inspection to ensure conformance with the purchase specification.

c. Section 02.03.b.

1. Special storage requirements are typically specified by the manufacturer or an 

industry standard, committed to by the licensee. The requirements should 

include such things as taping or sealing cable ends, controlling material and 

cable or cable reel identification, maintaining proper ambient temperature, 

separation form nonconforming items, and placement on dunnage.

2. Cable and termination materials may be released for installation on the merits of 

certifications if the organization involved has established satisfactory program 

control and audit requirements in this area (ANSI N45.2.1.3). However, 

certifications do not release the licensee from having other records for operation 

and for the life of the facility.

d. Section 02.03.c. Appropriate and adequate construction specifications and other work 

instructions for a particular activity should be approved and available before that activity 

is started.

e. Section 02.03.c.1.(a). The procedure should require QC acceptance of raceway 

installations before routing cable.

f. Section 02.03.c.1.(b). Some method or procedure should be established to assure that 

the cable is properly qualified for the environment in which it is to be located.
Issue Date: 12/14/15 G-15 69020

g. Section 02.03.c.1.(d). Splices in certain locations, such as raceways, may not be 

allowed. Refer to RG 1.75 and licensee commitments.

h. Section 02.03.c.1(i). Refer to the following for information pertaining to separation and 

independence: RG 1.75; and the Institute of Electrical and Electronic Engineers (IEEE) 

Standard (Std) 384.

i. Section 02.03.c.1.(p). Procedures should require verification that loading requirements 

(both thermal and mass) are not exceeded in final cable routings in trays, busways, 

conduits, etc. This verification should include review of actual cable routing, cable 

routing records, and design calculations.

j. Section 02.03.c.1.(q). Only specified materials should be used for fire barriers, fire 

stops, and fire retardants; and installation should be in accordance with approved 

procedures.

k. Section 02.03.d.

1. The licensee or contractor procedures involved will differ from site to site and 

may take various forms, such as formal procedures, instructions, checklists, 

drawings, etc. Review the IPs and compare with the applicable requirements 

and construction specifications. Evaluation should indicate whether adequate 

quality-related IPs are established and are based on appropriate criteria, and 

further, whether the results of the licensee’s inspection will be transmitted to 

responsible QA and management personnel.

2. Provisions should include procedures for monitoring or surveillance of installed 

cables by inspection (QC) personnel. They should ensure that maintenance 

requirements are satisfied and that adequate protection is provided against 

possible damage from adjacent construction activities, including construction 

traffic. (Where protective means used during construction may affect proper 

operation, provisions should be provided for timely removal.)

l. Section 02.03.e. This item does not include preoperational testing. Construction 

testing generally verifies that certain components pass specific tests as required but is 

not a test of system capability, especially systems that include non-electrical equipment. 

The intent of this requirement is to determine whether adequate QA procedures have 

been established to assure that the required testing is satisfactorily completed and 

corrective action, if required, is properly performed. Procedures for cable system and 

component testing provide means to ensure that:

1. Required construction testing is controlled and performed, as specified, using 

qualified personnel.

2. Cable systems and components to be tested are properly identified, along with 

tests to be conducted.

3. Proper type of test equipment (range, accuracy, calibration, etc.) is specified.
Issue Date: 12/14/15 G-16 69020

4. Test parameters (e.g., voltage level) are according to standards and 

manufacturer’s recommendations.

5. Special conditions of testing, prerequisites, sequence, precautions, etc., and 

acceptance criteria, are specified and meet requirements.

6. Type of data to be recorded and method of reporting results are specified.

7. Qualified personnel evaluate test results.

8. Discrepancies are resolved.

03.03 Prevalent Problems and Concerns. The inspector should be alert to problems of a 

generic nature, such as:

a. Adequate procedures or other means have not been established to assure and 

document that all safety-related (and if applicable, IROFS) systems have met applicable 

criteria, or to specifically document non-conformances.

b. IPs does not include adequate inspection requirements and acceptance criteria.

c. Inadequate means to control location and status of electric cable and components -

especially during removal for repair or replacement.

d. Inadequate procedures to control the evaluation, approval and use of field changes. 

(The licensee or contractor also should establish means to assure that only the latest 

approved field changes and other revisions or changes are being used for installation 

and inspection activities.)

69020.A7-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A7-05 REFERENCES

National Electrical Manufacturers Association NEMA WC 55-1992, “Instrumentation Cables and 

Thermocouple Wire.”

National Electrical Manufacturers Association, NEMA WC 57-1995, “Standard (Std) for Control 

Cables.”

National Electrical Manufacturers Association, NEMA WC 70-1999, “Nonshielded Power Cables 

Rated 2000 Volts or Less for the Distribution of Electrical Energy.”
Issue Date: 12/14/15 G-17 69020

National Electrical Manufacturers Association, NEMA WC 71-1999, “Standard for Nonshielded 

Cables Rated 2001-5000 Volts for Use in the Distribution of Electric Energy.”

National Electrical Manufacturers Association, NEMA WC 74-2000, “5-46 kV Shielded Power 

Cable for Use in the Transmission & Distribution of Electric Energy.”

National Electrical Manufacturers Association, NEMA WC 53-2000, “Standard Test Methods for 

Extruded Dielectric Power, Control, Instrumentation and Portable Cables for Test.”

National Fire Protection Association 801, “Standard for Fire Protection for Facilities Handling 

Radioactive Materials.”

Institute of Electrical and Electronic Engineers Std 383-2003, “Qualifying Class 1E Electric 

Cables and Field Splices for Nuclear Power Generating Stations.”

Institute of Electrical and Electronic Engineers Std 384-1992, “IEEE Standard Criteria for 

Independence of Class 1E Equipment and Circuits –Description.”

Institute of Electrical and Electronic Engineers Std 690-1984, “IEEE Standard for the Design 

and Installation of Cable Systems for Class 1E Circuits in Nuclear Power Generating Stations.”

Institute of Electrical and Electronic Engineers Std 400-2001, “IEEE Guide for Field Testing and 

Evaluation of the Insulation of Shielded Power Cable Systems.”

Institute of Electrical and Electronic Engineers Std 1143-1994, “IEEE Guide of Shielding 

Practice for Low Voltage Cables.”

Association of Edison Illuminating Companies CS8-00, “Specification for Extruded Dielectric 

Shielded Power Cables Rated 5 through 46 kV.”

Electrical Training Course for U.S. Nuclear Regulatory Commission Inspectors, Unit III, “Design 

and Installation of Electrical Cable Systems in Nuclear Power Plant.”

Electric Power Research Institute EL-5036, Power Plant Electrical Reference Series, Volume 4 -

Wire and Cable, Section 4.5, “Installation, Termination, and Testing.”

END
Issue Date: 12/14/15 H-1 69020

APPENDIX H

INSPECTION OF ELECTRICAL COMPONENTS AND SYSTEMS AT NON-POWER

PRODUCTION AND UTILIZATION FACILITIES

69020.A8-01 INSPECTION OBJECTIVES

01.07 To determine whether work activities associated with safety related electrical 

components and systems is being performed in accordance with the licensing basis, 

construction specifications, drawings, and work procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to electrical components and systems activities is functioning properly, and to 

determine whether the records reflect work accomplishment consistent with specifications and 

procedures.

01.03 To verify that the as-built condition of electrical components and systems meets the 

specified design requirements, specifications, and drawings. For installation of electric cable,

also refer to Appendix G of this inspection procedure (IP).

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with electrical components and systems is effective and to verify that 

deviations from requirements are appropriately resolved.

69020.A8-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related electrical components and systems being 

constructed at the site. Inspectors should also be familiar with the licensee’s Quality 

Assurance Program (QAP) and the licensing basis for the QAP (NPUF licensees are 

expected to commit to the QAP requirements of ANS/ANSI 15.8, “Quality Assurance 

Program Requirements for Research Reactors”). It is not the objective of this IP to verify 

the adequacy of the licensee’s QAP, but inspectors should be prepared to identify 

potential weaknesses in the licensee’s QAP for future inspections. Inspectors should 

complete this appendix by inspecting the attributes listed in this appendix for electrical 

components and systems work on-site at the time of the inspection. Inspectors should 

also coordinate this appendix with inspection of electrical cable (Appendix G of this IP) for 

efficiency, if possible. 

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the electrical components and systems on 

the site, but may expand the inspection if time allows, or if significant concerns with the 

licensee’s control of electrical components and systems construction arise. Inspectors 

should collect licensee procedures, construction specifications, and work completion 

records in advance, if possible. If unable to review these documents in advance of the 
Issue Date: 12/14/15 H-2 69020

on-site inspection, then the licensee should be notified that these documents, and any 

other relevant documents, should be available when the inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.11 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Review of QA Implementing Procedures. Review QA Manual and implementing 

procedures associated specifically with electrical component and systems, to determine 

whether the commitments in the approved QA Plan are being implemented, as follows:

a. Adequate QA audit procedures have been established for this activity in accordance 

with the approved QA Plan including: (1) scope and frequency of audits; (2) audit 

criteria; (3) reporting requirements; (4) follow-up action; and (5) resolution of findings by 

those audited.

b. Provisions have been made to ensure that those engaged in conducting audits are 

qualified and have been adequately trained. Provisions must ensure that auditors do 

not have direct responsibility in the areas being audited.

c. Means have been established to verify that technical requirements, including material 

and component specifications (including traceability and marking requirements), 

acceptance criteria, and required documentation are specified in design and 

procurement documents.

d. Means have been established to verify that any significant design and field changes 

from approved drawings are adequately controlled and processed commensurate with 

the original design.

e. Provisions have been established to ensure that quality requirements are met (including 

documentation that quality requirements of materials and components are met before 

installation or use) and deviations, nonconformance’s, and defects are adequately

documented and processed through to complete resolution.

f. The licensee has established a program for ensuring that all craft, nondestructive 

examination (NDE), and inspection personnel associated with the installation of 

electrical components and systems have been trained, or otherwise qualified to the 

work procedures involved.

02.03 Specific Technical Review Areas. Review a sampling of procedures as they relate to 

electrical components and systems. Determine whether the procedures cover work and 

inspection activities in the following areas, are appropriate to the activity, and are 

technically adequate:

a. Receiving-Inspection Procedures (IPs). Receiving inspection and related procedures 

provide means to ensure the following:
Issue Date: 12/14/15 H-3 69020

1. Received components are as specified, properly identified and controlled - or 

otherwise noted.

2. Input from other groups or other organizations to be used during receiving 

inspection activities are obtained and properly used, such as the results of 

source inspections, environmental qualification tests, and other required quality 

tests.

3. Procurement requirements, such as qualification tests (seismic, environmental, 

etc.), functional tests, and other quality tests (material, physical, and chemical), 

have been successfully completed, or status of how and when such requirements 

will be satisfied is documented and adequately controlled.

b. Storage Procedures. Storage procedures provide means to ensure the following:

1. The proper storage environments (as specified by the construction specifications 

and the manufacturers) are established for the various types of electrical 

components and meet applicable storage-classification levels, regardless of the 

location of the stored component.

2. Storage-inspection procedures require initial verification of storage conditions 

and periodic verifications (internal preservation, motor and generator-shaft 

rotation, insulation-resistance tests, etc.) for the duration of the storage period. 

They must also ensure that special and in-place storage requirements are met.

c. Work Procedures. Work procedures are established to ensure the following:

1. NRC requirements and licensing commitments are properly translated into the 

work procedures (construction specifications, drawings, and work instructions) for 

adequate control and installation of electrical components and associated items. 

Areas to review shall include, but are not limited to, the following:

(a) Electrical components are identified, located, oriented, and supported as 

specified.

(b) Physical separation and independence requirements of redundant 

components are met.

2. Interface controls are adequate when multiple contractors are involved.

3. Procedures cover special handling, installation, and maintenance requirements, 

including those pertaining to protection, preservation of internal cleanliness, and 

maintenance of component-qualification requirements. For example, all covers, 

seals, plugs, internal preservatives, and protective coatings are left intact until 

installation and/or use, as appropriate.

d. Handling Procedures. Handling procedures are established to ensure that the following 

handling activities and conditions are controlled and performed, as required during 
Issue Date: 12/14/15 H-4 69020

receipt, storage, and installation of large electrical equipment:

1. Attachment points,

2. Use of rigging,

3. Positioning,

4. Special handling requirements, and

5. Temporary covers.

e. Inspection Procedures. “IPs” are established to ensure the following:

1. All safety-related aspects of construction specifications, drawings, and work 

instructions are included in the scope of planned inspections.

2. The technical aspects of inspection requirements and acceptance criteria are 

sufficient to determine whether the components and their installation, testing, 

maintenance, and protection conform to applicable design and construction 

specifications.

3. Records of initial and follow-up inspections include the specific results of the 

inspection. This should include the specific characteristics being inspected (or 

the actual measured values), the inspectors’ determination of acceptability, and 

identification of any nonconformance’s found.

f. Construction-Testing Procedures. Procedures are established to ensure that special 

conditions of testing electrical components (prerequisites, sequence, special handling, 

removal, precautions, etc.) are included and described in proper detail, as required to 

conduct and monitor the work performed, including the following:

1. Equipment and systems to be tested and the related test procedures are properly 

identified and controlled. Procedures specify which construction tests are to be 

performed on each component requiring testing.

2. Proper type of test equipment (range, accuracy, etc.) is specified.

3. Type of data to be recorded and method of reporting results.

4. Review and evaluation of test results by qualified personnel.

5. Resolution of discrepancies.

g. Change-Control Procedures. Procedures have been established to control design and 

field changes and ensure the following:

1. Retrieval of voided drawings and specifications at work sites is controlled.

2. Field changes are subject to adequate design control and are incorporated into 

the as-built records.
Issue Date: 12/14/15 H-5 69020

3. Coordination among participating design and construction organizations is 

adequate.

02.04 Inspection of Electrical Systems and Components.

Select a sample of electrical systems and components for inspection. Inspection should 

be accomplished by observation and evaluations of both in-process and completed 

work if possible. Sample selection should be based on importance to operational 

safety.

Before inspecting selected items, review the specifications, drawings, work procedures, 

QA/QC procedures, and work schedules applicable to the systems or components 

selected for inspection.

02.05 Inspection Activities. Perform a sampling of the following activities as they apply to 

electrical components and systems.

a. Receiving Inspection. Observe and evaluate portions of receiving-inspection activities 

pertaining to the electrical components and systems selected for inspection in the 

appropriate subsections of Section 02.02, above. Determine whether receivinginspection activities are being controlled and performed in a manner that will ensure 

applicable requirements are satisfied in the following areas:

1. Identification appears on components and in receiving documents.

2. Physical conditions (damage, deterioration, etc.) are indicated.

3. Documentation regarding quality requirements (e.g., results of functional and 

qualification testing) received with components is reviewed to, and meets, 

requirements. Where qualification testing of components to be placed in a harsh 

environment (e.g., inside containment) is not a requirement of the specification, 

follow-up with the licensee to determine what means will be used to ensure that 

applicable environmental qualification will be satisfied.

4. Nonconforming components.

5. An adequate number of qualified personnel are available to perform the 

receiving-inspection function.

b. Storage. Observe and evaluate storage activities and conditions for the components 

selected in the appropriate subsections of Section 02.02. Determine whether:

1. Components are stored in the proper storage-level designation.

2. Components are properly identified.

3. Storage conditions (temperature, humidity, cleanliness, etc.) and requirements 
Issue Date: 12/14/15 H-6 69020

are controlled and monitored as directed by the applicable specification and by 

the manufacturer’s specifications.

4. Licensee and contractor inspection and monitoring activities are being performed 

in accordance with procedural requirements, if in progress during NRC 

inspection.

5. Nonconforming items placed in storage are identified and/or segregated as 

required.

6. In-place storage requirements are satisfied.

7. An adequate number of qualified personnel are available to perform the required 

storage functions.

c. Handling. As inspection scheduling permits, determine whether handling activities are 

being controlled and performed as specified when large electrical components are 

being moved during receipt, storage, and installation.

d. In-Process Installation. If possible, observe and evaluate in-process installation 

pertaining to the components and associated items selected in the appropriate 

subsections of Section 02.02. Determine whether:

1. The latest approved revision of applicable construction specifications, drawings, 

and/or construction procedures are available and used by the installers.

2. The components are as specified, such as type, size or rating, and material.

3. The components are installed in the proper location and orientation by qualified 

craft personnel using suitable equipment and tools.

4. Associated mounting hardware, supports, and anchors are of the type (welded, 

bolted, etc.,) and material specified, and are properly located.

5. The required component identification is properly established or maintained.

6. Installed components are adequately protected from damage by adjacent 

construction activities.

7. Licensee and contractor inspections are performed or scheduled to be 

performed, before “covering up” the work to be inspected; QC hold points are 

observed.

8. Inspection activities are completed in a timely and proper manner by qualified 

personnel.

9. Documentation of installation and inspection activities is completed in a proper 

and timely manner.
Issue Date: 12/14/15 H-7 69020

10. Nonconformance’s are identified and handled in accordance with established 

procedures. Where corrective action is being taken, determine whether it meets 

the appropriate requirements.

e. Completed Work. Evaluate the completed installation of electrical components and 

associated items selected in the appropriate subsections of Section 02.02. Determine 

whether:

1. Components are installed in accordance with design, construction specifications, 

and work procedures; components are at the correct location, configuration, and 

orientation.

2. Specified materials are used.

3. Bolts, anchors, weldments, other fasteners, and supports are as specified and 

properly mounted and secured.

4. Protective coatings, softeners, bushings, and other specified materials have been 

used as specified.

5. Equipment and item identifications have been maintained.

6. Equipment and components are protected from hostile environments, such as 

high-pressure pipe, rotating equipment, and non-seismically supported 

equipment.

7. Electrical components, such as conduit, tray, motors, and power distribution 

centers maintain specified physical and electrical separation and independence 

between redundant components.

8. Statuses of completion, maintenance, and readiness for pre-operational testing 

are indicated or otherwise documented.

9. Adequate actions or provisions have been taken and/or maintained (as needed) 

to ensure that the validation of the environmental qualification of components is 

maintained.

f. As-Built Verification. When electrical components and associated items, as selected in 

appropriate subsections of Section 02.02, are completely (or essentially) installed and 

inspected, review construction specifications and other applicable work instructions 

referenced by the drawings or otherwise applicable to the installation. Compare the 

actual installation with the above drawings and associated documents. For each 

drawing selected, determine whether several components shown on the drawing are of 

the type specified (function, range, qualification, material, etc.) and whether they have 

been installed, located, oriented, supported, protected, etc., in accordance with this 

drawing.
Issue Date: 12/14/15 H-8 69020

1. Before performing the above, verify the number and statuses of outstanding 

design changes on the selected drawings (and related specifications).

2. Discrepancies observed may result from in-process changes, such as those 

initiated in the field. If in-process changes are involved, determine whether the 

licensee has properly controlled and documented these changes for engineering 

review, approval, and subsequent incorporation into the as-built drawings.

g. Construction Testing. If possible, observe construction-testing activities for the 

electrical components selected in the appropriate subsections of Section 02.02. 

Determine whether:

1. The latest revisions of applicable test procedures and/or specifications are 

available at the work location and used by personnel performing the testing.

2. Properly identified, traceable, and calibrated measuring and test equipment are 

used.

3. Equipment or components are able to obtain the degree of accuracy and 

tolerance specified, or otherwise meet specified requirements.

4. Required testing results are recorded during the activity; not after the testing has 

been completed. (Where test results are immediately available to the NRC 

inspectors, note whether they are within specified limits.)

5. Components that have been tested are adequately identified as to their statuses, 

(i.e., specified requirements have been met or deficiencies noted).

6. Personnel performing the testing are properly qualified.

7. Test personnel adhere to any special handling or removal requirements.

8. Test discrepancies are properly identified for resolution.

02.06 Record Control and Review. Review licensee and contractor requirements covering the 

span of records for safety-related electrical components and associated items.

a. Determine who prepares each quality-related record, who reviews the records for 

accuracy, and who ensures that the recorded information meets requirements.

b. Evaluate the information obtained above and determine whether the established recordmanagement system satisfies CAR commitments.

02.07 Work and Inspection Records. Review and evaluate pertinent quality records in the areas 

listed below. Determine whether: (1) adequate preparation, control, review, and 

evaluation of these records have been made; (2) the records reflect that requirements 

have been met; and (3) the system of records is functioning properly. The selection shall 

include records of diverse safety-related electrical systems and components, from a 
Issue Date: 12/14/15 H-9 69020

sampling of areas of the plant such as: (1) raceway and raceway supports; (2) switch 

gear and associated breakers; (3) emergency diesel generator and electrical auxiliaries; 

(4) transformers; (5) motors; (6) dc systems; (7) motor control centers; (8) electric valve 

operators; and (9) containment-penetration assemblies. 

a. Receiving-Inspection Records. Review and evaluate a selected sample of receivinginspection records, and determine whether:

1. Receiving-inspection documents properly and uniquely identified received 

electrical components and associated items.

2. Applicable engineering and functional specifications (regarding size, type, 

material, etc.) of received items and components were met or otherwise noted.

3. The required electrical component characteristics, material, performance tests, 

environmental and seismic qualification tests, nondestructive tests, and other 

specification requirements were met or otherwise noted.

4. Original records or certification system met requirements of applicable criteria.

b. Storage Records. Review and evaluate a selected sample of storage records, and 

determine whether the records reflect that:

1. Specified storage conditions and requirements were maintained (e.g., internal 

preservation, shaft rotation, insulation-resistance tests).

2. Storage inspections were properly made at specified intervals.

3. Records of nonconforming items in storage areas were properly maintained.

c. Installation Records. Review and evaluate a selected sample of quality records 

pertaining to installation activities, and determine whether these records reflect the 

following:

1. Most recent and approved design and construction documents were used during 

installation.

2. Specified electrical components and associated items were installed in the 

location specified or otherwise noted.

3. Materials and methods used for supports and anchors (including welds) met 

applicable specifications.

4. Qualified personnel performed, recorded, reviewed, and evaluated required 

inspections.

5. Inspection records were complete and satisfy documentation requirements.
Issue Date: 12/14/15 H-10 69020

6. Physical separation and independence requirements were met.

7. Required protection was provided after installation.

d. Construction-Testing Records. Review and evaluate a selected sample of constructiontesting, and determine whether:

1. Required tests were performed as required.

2. Records indicate that approved procedures were followed.

3. Test equipment was periodically checked and calibrated as specified.

4. Test data and results were properly documented and evaluated, and corrective 

action, if required, was taken.

02.08 Personnel-Qualification Records. Review and evaluate a selected sample of craft and 

QC qualification records and determine whether:

a. The system of craft and inspection personnel qualification records meets stated 

requirements and is being maintained in a current status.

b. The records are sufficient to reasonably support qualification in terms of certification, 

experience, proficiency, training, testing, etc., as applicable.

c. Responsible licensee/contractor organizations have acted to independently 

authenticate the record material.

02.09 Nonconformance and Deviation Reports. Review and evaluate a selected sample of 

nonconformance and deviation reports, and determine whether:

a. Records are legible and complete, and qualified personnel promptly review them.

b. Reporting requirements of 10 CFR Part 21 were recognized during evaluation and 

appropriate action was taken where necessary.

c. Records have been routinely processed, timely evaluated, and controlled, through 

established channels for resolution of the root-cause, as well as the immediate problem.

d. Records are properly identified and stored, indicate current status, and can be retrieved 

in a reasonable time.

e. Nonconformance reports include the status of corrective action or resolution, and 

adequate justification is provided for use-as-is disposition.

02.10 Change-Control Records. Review and evaluate a selected sample of change- control 

records, and determine whether:
Issue Date: 12/14/15 H-11 69020

a. Records associated with design and field changes, as well as related work and IP 

changes, reflect that timely review and evaluation of design and field change 

documents have been performed by personnel who are qualified.

b. Records of periodic inspections ensure that only the most recent approved documents, 

including design changes, were used in the field.

c. Design changes are subject to adequate design control, including consideration of the 

impact of the change on the overall design and on as-built records.

d. Records of nonconformance’s to design requirements include preparation of a 

nonconformance report even if the nonconformance is resolved through the designchange process.

02.11 Audit Records. Review and evaluate a selected sample of licensee and contractor audit 

records pertaining to electrical components. Determine whether:

a. Audits have been performed in accordance with the schedule and functional areas 

established in the audit plan.

b. Audit records are sufficient to verify that the intended purpose and scope of the audits 

were achieved.

c. Audit findings have been reported in sufficient detail to permit a meaningful assessment 

by those responsible for corrective action, final disposition, and trending.

d. The licensee and contractor have taken proper and timely follow-up action, on those 

matters in need of correction.

e. Auditing organization and personnel are independent of the work being audited.

69020.A8-03 INSPECTION GUIDANCE

03.01 General Guidance.

a. Electrical components and systems consist of those elements of the facility that are 

designed to supply, use, control, transform, condition, or interrupt electric power. This 

IP applies, but is not limited, to the following safety-related electrical components and 

associated items: (1) raceways; (2) raceway hangers and other supports; (3) 

switchgear; (4) motor control centers; (5) transformers; (6) batteries and racks; (7) 

battery chargers; (8) inverters; (9) motor-generator sets; (10) circuit breakers; (11) 

relays; (12) electrical penetration assemblies; (13) motors; (14) motor operators on 

valves; (15) electrical-control panels; (16) local cabinets; (17) limit switches; (18) 

solenoid valves; (19) emergency power system for principal safety-related loads, and 

(20) other protective devices.

b. Applicable portions of the licensing basis should be reviewed during inspection 
Issue Date: 12/14/15 H-12 69020

preparation. Determine specific licensee procedural and work instruction commitments 

relative to construction and inspection requirements for electrical components and 

systems. The inspectors should then use the above information during the review of 

the licensee’s construction specifications, drawings, work, and IPs, to determine 

whether the above requirements are adequately translated into the appropriate 

documents.

c. To be adequate, procedure-control activities, such as storage, installation, inspection, 

and testing, must contain sufficient detail to ensure that the specific work steps that 

affect the functioning of the installed equipment will be performed properly. These work 

steps are to be identified and adequately controlled. While reviewing procedures, the 

inspection should be aware of, and look for, inadequacies that could lead to 

construction deficiencies and/or indicate an inadequate management-control system.

d. Penetration assemblies, as covered by electrical IPs, refer to assemblies installed in a 

containment-structure opening (sleeve, nozzle, or barrel) and not to the opening itself. 

The containment opening is considered to be a part of the containment structure.

03.02 Specific Guidance.

Note: The numbering of the guidance below refers to specific subsections of 02, above.

a. Inspection Requirement 02.03. For the purpose of this IP, the term “work procedures”

includes construction-specifications, drawings, and work instructions. (Procedures 

describing methods of fabrication, construction, and/or installation are sometimes called 

construction procedures.)

b. Inspection Requirement 02.03a. The SAR should identify and describe all 

safety-related components that must operate in a hostile environment (e.g., high 

radiation, temperature, humidity) during or subsequent to an accident. Where 

environmental-qualification testing or other qualification provisions (such as seismic) 

are specified, the licensee shall establish means to ensure that the results of this testing 

are documented, reviewed, and determined to be acceptable. If this is not performed 

when components are received, the procedures should specify the organization that will 

be performing this review and the controls to ensure that all such documentation 

requirements are satisfied before the component is placed in use. This is a particularly 

significant area for NRC review.

c. Inspection Requirement 02.03b.

1. U.S. Nuclear Regulatory Commission, Regulatory Guide (RG) 1.38 [American 

National Standards Institute (ANSI) N45.2.2] (or equivalent requirements) relative 

to storage are applicable here.

2. Depending of the licensee’s QAP, electrical components may be released for 

installation on the merits of certifications if the organization involved has 

established satisfactory program control and audit requirements in this area. 
Issue Date: 12/14/15 H-13 69020

However, certifications do not release the licensee from having other records for 

operation and for the life of the plant.

d. Inspection Requirement 02.03c.

1. Appropriate and adequate construction specifications, procedures, and other 

work instructions for a particular activity are required to be approved and 

available before that activity is started.

2. Model number and type (only) are not considered to be adequate identification. 

Procedures should specify a unique identification number, along with the model 

number and name of manufacturer. Adequate (positive) identification is 

important because similar-looking electrical components can be significantly 

different with respect to rating, output, material, etc. Safety-related electrical 

components should be listed in the SAR.

3. Anchor bolts holding or mounting electrical components should be of the type, 

size and length specified. Provisions should exist to prevent indiscriminate 

cutting of reinforcement steel during the drilling of anchor holes.

e. Inspection Requirement 02.03e.

1. The licensee/contractor procedures involved will differ from site to site and may 

take various forms, such as formal procedures, instructions, checklists, drawings, 

etc. Review the IPs and compare with the applicable requirements and 

construction specifications. Evaluation should indicate whether adequate 

quality-related IPs are established and are based on appropriate criteria, and, 

further, whether the results of the licensee’s inspection will be transmitted to 

responsible QA and management personnel.

2. Provisions should include procedures for monitoring or surveillance of locally 

mounted components by inspection (QC) personnel. They should ensure that 

maintenance requirements while “stored in place” are satisfied and that adequate 

protection is provided against possible damage from adjacent construction 

activities, including construction traffic. (Where protective means used during 

construction may affect proper operation, provisions should be provided for 

timely removal.)

f. Inspection Requirement 02.03f. NRC inspectors who are knowledgeable in the area of 

electrical systems, in general, and testing, in particular should inspect this area.

1. The SAR and the QAP should include or reference general testing requirements, 

and work procedures should provide detailed instructions. In addition, the QA 

manual should include general surveillance procedures relative to testing, [i.e., 

activities should be monitored (inspected or audited, as appropriate), in 

accordance with established procedures]. These procedures should include 

verification of the following:
Issue Date: 12/14/15 H-14 69020

(a) Data sheets (or equivalent) are being used as specified.

(b) Testing procedures are current and approved for use; ranges, accuracies, 

etc., are specified.

(c) Testing techniques are appropriate for the component to be tested.

(d) Controls are included for removal and handling of components during 

testing activities.

2. Test data/records should include:

(a) Specific identify of the component tested.

(b) The specific identity of the measuring and testing equipment used to 

perform the testing.

(c) Identity of the technician performing the test and date of test.

(d) Approval signature of responsible individual.

(e) Acceptance criteria.

3. Certificates of calibration should be available at the site for test instruments used 

to perform tests. These certificates should show that the standards used to 

establish the accuracy of the test instruments are traceable to a nationally 

recognized standard. Procedures should require that the performance and 

accuracy of test equipment are demonstrated by periodic checking.

4. This item does not include preoperational testing. Construction testing generally 

verifies that certain components perform as intended, but it is not a test of system 

capability.

5. Typical tests that may be required include insulation resistance, continuity, 

battery load, and breaker trips.

6. The licensee is required to provide information, relative to protection of the 

safety-related portions of the onsite AC power system from certain fault 

conditions. Significant aspects of this protection include: (1) manual and 

automatic interconnections between buses, buses to loads, and buses to 

supplies, and capability of components to withstand anticipated fault conditions; 

(2) interconnections between safety-related and non-safety-related buses; (3) 

circuit protection network (e.g., selective trip), including setting criteria, protection 

for overvoltage, under voltage, and frequency; and (4) load-shedding devices.

One method to determine the adequacy of these protective systems and devices 

includes a relay-coordination study. If applicable, the inspectors should 
Issue Date: 12/14/15 H-15 69020

determine whether provisions are established to ensure that adequate 

procedures are available for this activity. The results of this study should be 

evaluated by qualified personnel to ensure acceptability of the results.

03.03 Prevalent Problems and Concerns. The inspectors should be alert to problems of a 

generic nature, such as:

a. Adequate procedures or other means have not been established to ensure and 

document that all safety-related electrical components and subsystems have met 

applicable acceptance criteria or are nonconforming in specific areas.

b. IPs do not include adequate inspection requirements and acceptance criteria.

c. Inadequate means to control location and status of electrical components; especially 

during removal for repair, modification, or replacement.

d. Inadequate procedures to control the evaluation, approval, and use of field changes. 

(The licensee/contractor should establish means to ensure that only the latest approved 

field changes and other revisions or changes are being used for construction and 

inspection activities.)

69020.A8-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020-05 REFERENCES

Code of Federal Regulations, 10 CFR Part 21, “Reporting Defects and Noncompliance.”

END
Issue Date: 12/14/15 I-1 69020

APPENDIX I

INSPECTION OF VENTILATION AND CONFINEMENT SYSTEMS AT NON-POWER

PRODUCTION AND UTILIZATION FACILITIES

69020.A9-01 INSPECTION OBJECTIVES

01.08 To determine whether work activities associated with safety related ventilation and 

confinement systems is being performed in accordance with the licensing basis, construction 

specifications, drawings, and work procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to ventilation and confinement system activities is functioning properly, and to 

determine whether the records reflect work accomplishment consistent with specifications and 

procedures.

01.03 To verify that the as-built condition of ventilation and confinement systems meets the 

specified design requirements, specifications, and drawings.

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with ventilation and confinement systems is effective and to verify that 

deviations from requirements are appropriately resolved.

69020.A9-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related ventilation and confinement systems being 

constructed at the site. Inspectors should also be familiar with the licensee’s Quality 

Assurance Program (QAP) and the basis for the QAP (NPUF licensees are expected to 

commit to the QAP requirements of ANS/ANSI 15.8, “Quality Assurance Program 

Requirements for Research Reactors”). It is not the objective of this IP to verify the 

adequacy of the licensee’s QAP, but inspectors should be prepared to identify potential 

weaknesses in the licensee’s QAP for future inspections. Inspectors should complete 

this appendix by inspecting the attributes listed in this appendix for ventilation and 

confinement system work on-site at the time of the inspection

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the ventilation and containment systems on 

the site, but may expand the inspection if time allows, or if significant concerns with the 

licensee’s control of ventilation and confinement systems construction arise. Inspectors 

should collect licensee procedures, construction specifications, and work completion 

records in advance, if possible. If unable to review these documents in advance of the 

on-site inspection, then the licensee should be notified that these documents, and any 

other relevant documents, should be available when the inspector(s) arrives at the site.
Issue Date: 12/14/15 I-2 69020

Inspectors should review the areas listed in 02.02 through 02.05 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Adequacy and Effectiveness of Construction-Implementing Work Procedures.

a. Verify that contractor/subcontractors, with responsibilities for installing safety-related 

ventilation and confinement systems, have approved procedures describing the 

administrative controls and work processes to be implemented to ensure construction 

activities have been accomplished according to design requirements.

b. Verify that procedures prescribe adequate methods, of quality control (QC) inspection, 

to ensure that the as-built condition of safety-related ventilation and confinement 

systems meets specified engineering requirements and drawings. As part of the 

assessment of the QC inspection procedures (IPs), ensure the procedures include or 

reference appropriate quantitative or qualitative acceptance criteria for determining that 

the prescribed activities have been accomplished satisfactorily.

c. Verify that contractors have established procedures for ensuring that craft and 

inspection personnel performing construction work on safety-related ventilation and 

confinement systems are qualified to perform their assigned work.

02.03 Adequacy and Effectiveness of Construction Work and Work Activities. By direct 

observation, record review, and/or independent evaluation of work performance, work-inprogress, and/or completed work, determine whether activities regarding ventilation and 

confinement systems are being accomplished in accordance with NRC requirements, the 

licensing basis, SAR commitments, the QAP, and licensee procedures and specifications.

a. Installation Activities.

1. If work is in progress at the time of the inspection, witness a sample of the 

installation activities of safety-related ventilation and confinement systems, to 

verify the following:

(a) The latest issue (revision) of applicable drawings or procedures is 

available to the installers and is being used.

(b) Modifications to supports are approved by appropriate personnel before 

implementation.

2. If work is in progress at the time of the inspection, witness a sample of the 

installation and testing (if required) of concrete anchor bolts, to verify that anchorbolt type, diameter, embedment length, shoulder-to-cone measurement, and 

torque requirements (where applicable), meet installation requirements.

3. Determine whether required inspection activities are in process and observe a 

sample for adequacy. In particular, determine whether QC inspection of welder 
Issue Date: 12/14/15 I-3 69020

qualification procedures and welding of supports is conducted.

b. Major Construction Activities.

1. Receipt.

Review a sample of receipt-inspection reports for major components of 

ventilation and confinement systems and verify receipt-inspection requirements 

have been implemented.

2. Storage.

Review a sample of receipt reports for High Efficiency Particulate Apparatus 

(HEPA) filter system procurement and other types of Heating Ventilation and Air 

Conditioning (HVAC) system material (e.g., scrubbers, fans, dampers, weld filler 

metal, fasteners, and expansion anchors). Verify conformance with storage 

administrative controls and technical requirements.

3. Fit-up and Alignment.

Inspect a sample of bolted connections and verify the following:

(a) The bolted connections conform to procedure- or drawing-established 

tolerances for mutual parallelism and axial alignment.

(b) Layout instruments are calibrated. Equipment and instruments used for inprocess monitoring and inspection should be calibrated to standards 

traceable to industry-recognized criteria. Calibration and control measures 

are not applicable for rulers, tape measures, levels, and other such 

coarse-measurement devices that provide accuracy, as received from the 

manufacturer.

4. Edge Finish.

Inspect a sample of flanges and supports that are ready for welding and verify 

that the flange faces and edges conform to procedure/specification requirements.

5. Anchor Bolts, Embedded Weldments, and Plate Anchors.

Inspect a sample of anchor-bolt installations and verify the installations conform 

to established procedure requirements.

6. Bolted Connections.

Inspect a sample of bolted connections and verify that the installations and 

inspection activities conform to established requirements. Verify that torque 

wrenches used for these bolted connections had been calibrated as required by 

the construction specification.
Issue Date: 12/14/15 I-4 69020

7. Welded Connections.

Inspect a sample of welded connections in an HVAC system and verify they 

conform to established requirements for weld identification, use of appropriate 

welding procedure(s), and control of welding materials, etc.

c. As-Installed Equipment.

Observe a sample of the completed installation of the following equipment for proper 

location, configuration, identification, and damage. The basis for this determination 

shall be the SAR system description, piping and instrumentation diagrams (P&IDs), 

specifications, and installation drawings. Select from the list below.

1. Seismic support for ductwork;

2. Ductwork;;

3. Isolation dampers;

4. Recirculation test loops around fans and isolation dampers;

5. Radiation, smoke, and toxic chemical monitor;

6. Pressure-drop instrumentation across filter banks;

7. Instrumentation for the detection of excess ambient temperature;

8. Fresh air intake elevation from grade level;

9. Fans and motors;

10. Air handling units;

11. Exhaust vents; and

12. Filters.

02.04 Adequacy and Effectiveness of the Training and Qualification of Personnel. Inspect a 

sample of qualification records. Verify that craft, testing, and QC personnel involved in 

performing confinement and ventilation-system construction and inspection activities are 

qualified to perform their job functions.

02.05 Adequacy and Effectiveness of the System of Records. Inspect a sample of records. 

Verify that records for installing and testing safety-related ventilation and confinement 

systems are as specified, reviewed by the contractor for accuracy and assurance; and 

the recorded information meets project requirements, has been approved, and stored 

and maintained sufficient to support technical and contractual requirements.
Issue Date: 12/14/15 I-5 69020

a. Review licensee/contractor documentation requirements covering work performed for 

ventilation and confinement systems. Determine the effectiveness of the document 

review systems by comparing records against requirements for accuracy and 

completeness.

b. Review a sample of nonconformance reports for items of the ventilation and 

confinement systems.

c. Review relevant portions of licensee and contractor audit reports concerning the 

installation of ventilation and confinement systems.

69020.A9-03 INSPECTION GUIDANCE

For each of the inspection elements, the inspectors should: (1) obtain a copy of the contractor’s 

procedures and the related industry codes and standards to which the contractor has 

committed; (2) become familiar with the contents of the procedures and standards; and (3) 

assess whether the procedures and their implementation adequately conform to the applicable 

commitments.

Suggested sample selections are included in the section below. Follow the suggestions or 

choose samples more appropriate for the inspection, based on construction progress, 

completion of contractor’s QA/QC reviews, or inspectors experience. Use judgment in 

determining sample selection, focusing on examining the most important aspects of the 

particular activity being inspected. The intent is to establish a high level of assurance the end 

product meets requirements.

03.01 General Guidance.

a. Description of the ventilation and confinement systems is contained in the facility’s

SAR. The inspectors should then use the SAR sections during the review of the 

licensee’s implementing construction specifications, drawings, work procedures, and 

QA implementing procedures. The inspectors also should review the documents listed 

in the reference section of this procedure for in-depth technical details needed for the 

inspection.

b. Particular attention should be given to the traceability of material and equipment, to 

prevent the use of incorrect or defective materials, parts and components. The 

inspectors should review the licensee’s/contractors implementing procedures that 

correspond with applicable QAP requirements, codes and specifications. The 

inspectors should verify that the licensee has established measures for identification 

and control of materials, parts, and components, and for traceability to the approved 

design basis and to the source. The inspectors should assure that required 

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, and that required markings are on the item.
Issue Date: 12/14/15 I-6 69020

c. The inspectors should note markings on material and equipment and verify that the 

markings represent material and equipment as specified by the design drawings and 

specifications. In the case of fasteners, compliance with the applicable material 

specification (e.g., American Society for Testing and Materials or ASME material and 

grade) should be verified by required markings on bolts and nuts and certified material 

test reports or certificates of conformance, as required by the applicable procurement 

drawings and specifications, and/or by the applicable codes and specifications. In the 

case of vendor-supplied equipment assemblies containing fasteners, samples should 

be inspected to verify compliance with approved vendor drawings and specifications 

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

analyses. Caution should be exercised to ensure that the required markings on 

material and equipment, including fasteners, not only exist, but that the markings 

indicate the correct material and grade as specified.

3.02 Specific Guidance.

a. Adequacy and Effectiveness of Construction-Implementing Work Procedures. The 

inspectors should review the implementing and QC IPs for ventilation and confinement 

construction. Verify the procedures have been approved and specify the work 

processes, adequate QC inspections and methods, and management controls for the 

major construction activities. Ensure the major construction activities are completed 

according to drawing and procedure requirements and include or reference appropriate 

quantitative or qualitative acceptance criteria.

b. Receiving. The inspectors should select a sample of procurement documents 

regarding: (specifications and drawings, various components such as HEPA filters, 

prefilters, and spark arrestors). Verify that these documents specify the shape, size, 

dimension, and material type and grade, and the Certificate of Conformance certifies 

the components meets the construction, material, test, and qualification requirements.

c. Storage. The inspectors should ensure storage and warehousing procedures for 

ventilation and confinement system components, and/or the procurement documents 

reviewed require the following:

1. Access is controlled to the storage area to maintain the quality of the materials 

received.

2. An adequate marking system is used to maintain the identity of material in 

storage.

3. Material is protected from the environment and weather, as appropriate. 

Structural steel for supports is protected from corrosion.

4. Nonconforming material is segregated.

5. Motors, dampers, and heaters are checked to ensure wrappings are not 

disturbed and items are not removed from storage without proper authority.
Issue Date: 12/14/15 I-7 69020

6. HEPA filters and adsorbers are stored in their original cartons in an 

environmentally controlled room.

d. Fit-up and Alignment. The inspectors should ensure construction procedures or 

drawings for ventilation and confinement systems require flange faces to conform to 

established tolerances for mutual parallelism and axial alignment.

e. Edge Finish. The inspectors should ensure construction procedures for ventilation and 

confinement system provide criteria for the following:

1. Flange-face surface finish.

2. Surface finish of weld preparations.

f. Anchor Bolts, Embedded Weldments, and Plate Anchors. The inspectors should 

assess whether the contractor’s construction procedures for ventilation and 

confinement systems adequately address the following:

1. The minimum edge distance for bolts, studs, or bars with shear loading.

2. Expansion-anchor testing.

g. Bolted Connections. The inspectors should ensure construction procedures for 

ventilation and confinement systems require the following:

1. Maximum and minimum-edge distance for slotted, oversized, and standard bolt 

holes for bolted steel-duct support structures.

2. Maximum and minimum hole size for standard, oversized, short-slotted, and 

long-slotted holes for bolted connections for bolted steel-duct support structures.

3. Minimum spacing requirements for bolt holes for bolted steel-duct support 

structures.

4. Installation of locking devices for fasteners and threaded joints (except for highstrength bolts); engagement of the threads of all bolts or studs for the full length 

of the thread in the nut (unless approved by the engineer); and conformance of 

bolting material to drawing requirements.

5. Calibration of torque wrenches.

6. Use of beveled washers to compensate for situations where the surface of the 

bolted part in contact with the bolt head has a slope greater than 1:20 with 

respect to the plane normal to the bolt axis.

h. Welded Connections. The inspectors should review the construction procedures for 

welding material greater than, or equal to 0.125-inches thick. In addition, assess 

whether the contractor’s procedures adequately address the following:
Issue Date: 12/14/15 I-8 69020

1. Identification of welders and weld operators who are welding on steel-duct 

support structures;

2. Weld procedure and welder qualification; and

3. Control of welding material.

i. Material Physical Dimensions and Tolerances. The inspectors should ensure 

construction procedures or drawings for ventilation and confinement systems require 

acceptable dimensioning and tolerances for the following:

1. Length, elevation, material thickness, joint and seam joining, and span for 

ducting and supports.

2. Requirements that the taper of duct transitions be at least five units in length for 

each one unit in diameter change.

j. Nondestructive Examination. The inspectors should review the construction procedures 

for ventilation and confinement systems, in accordance with the applicable IP. In 

addition, assess whether the contractor’s procedures adequately address the following:

1. Visual inspection of production welds according to the visual inspection criteria of 

American Welding Society (AWS) D1.1 or D1.3, or other code or standard as

specified in the licensee’s SAR and/or QAP.

2. Requirements for visual-inspection proximity of view, qualification of visualinspection personnel, and the contents of visual-inspection reports.

3. Inspection sampling for full-penetration and partial-penetration welds on 

structural steel-duct or equipment supports.

03.03 Adequacy and Effectiveness of Construction Work and Work Activities. Before 

performing work observation inspections in the field, review the applicable procedures 

and industry standards to ensure familiarity with the requirements and acceptance criteria 

pertinent to the planned observations. During field observations, the inspectors should 

carry a copy of the appropriate sections of the contractor’s procedures and industry 

standards, pertinent to the planned observations, and verify work is being accomplished 

using procedures of the proper revision.

Examples of the major construction activities for safety-related HVAC systems are listed 

in Section 02.03. Verify the construction work implemented in the field conforms to the 

contractor’s construction and IPs.

During the field observations, the inspectors should interview and obtain the names of a 

sample of the craft and QC personnel performing the observed activities, to assess 

whether their knowledge of the job and procedures is satisfactory. The sample size will 

be determined by the number of contractor personal performing the activity. Information 
Issue Date: 12/14/15 I-9 69020

on these same personnel will be used pursuant to Section 03.04, below, to determine the 

adequacy of their experience, training, and qualification, including documentation.

03.04 Adequacy and Effectiveness of the Training and Qualification of Personnel. The 

inspectors should interview a sample craft and QA/QC personnel involved in activities 

related to the safety-related ventilation and confinement systems and verify the personnel 

are sufficiently knowledgeable of procedure requirements. The inspectors should also 

review the training and qualification records for those individuals to determine if they meet 

the requirements.

03.05 Adequacy and Effectiveness of the System of Records. The inspectors should select a 

sample of records generated during the conduct of HVAC system receiving, storage, fitup and alignment, bolting, welding, and testing activities and records of qualification for 

those craft and QA/QC personnel selected during the performance of Section 02.03, 

above. Verify the records selected for examination were approved by proper authority 

and were stored and maintained in such a manner as to demonstrate conformance with 

procedural requirements.

69020.A9-04 RESOURCE ESTIMATES

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A9-05 REFERENCES

American Society of Mechanical Engineers, (ASME), ASME AG-1, “Code on Nuclear Air and 

Gas Treatment,” (1991).

American Society of Mechanical Engineers, ASME B31.3, “Process Piping,” (1998).

American National Standards Institute, American Society of Mechanical Engineers, ANSI/ASME 

N509, “Nuclear Power Plant Air Cleaning Units and Components,” (1980).

American National Standards Institute, American Society of Mechanical Engineers, ANSI/ASME 

N510, “Testing of Nuclear Air-Cleaning Systems,” (1980).

American Welding Society, AWS D1.1, “Structural Welding Code,” (1998).

American Welding Society, AWS D1.3, “Structural Welding Code - Sheet Steel,” (1998).

American Welding Society, AWS D9.1, “Sheet Metal Welding Code,” (1998).

American National Standards Institute, ANSI N690, “Specification for the Design, Fabrication, 

and Erection of Safety-Related Steel Structures for Nuclear Facilities,” (1994).
Issue Date: 12/14/15 I-10 69020

American National Standards Institute, ANSI/ANS 8.1, “Nuclear Criticality Safety in Operations 

with Fissionable Materials Outside Reactors,” (1988).

American Society for Heating Refrigeration and Air Conditioning Engineers (ASHRAE), “Design 

Guide for Department of Energy Nuclear Facilities,” (1988).

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.100, Rev. 2, “Seismic Qualification of 

Electric and Mechanical Equipment for Nuclear Power Plants,” (1988).

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.12, “General Design Guide for 

Ventilation Systems of Plutonium Processing and Fuel Fabrication Plants,” (1973).

END
Issue Date: 12/14/15 J-1 69020

APPENDIX J

INSPECTION OF INSTRUMENTATION AND CONTROL SYSTEMS AT NON-POWER

PRODUCTION AND UTILIZATION FACILITIES

69020.A10-01 INSPECTION OBJECTIVES

01.01 To determine whether work activities associated with safety related instrumentation and 

control systems is being performed in accordance with the licensing basis, construction 

specifications, drawings, and work procedures.

01.02 To determine whether the licensee system for preparing, reviewing, and maintaining 

records relative to related instrumentation and control system activities is functioning properly, 

and to determine whether the records reflect work accomplishment consistent with 

specifications and procedures.

01.03 To verify that the as-built condition of related instrumentation and control systems meets 

the specified design requirements, specifications, and drawings. 

01.04 To determine that the implementation of the quality assurance program related to work 

activities associated with related instrumentation and control systems is effective and to verify 

that deviations from requirements are appropriately resolved.

69020.A10-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related instrumentation and control systems being 

constructed at the site. Inspectors should also be familiar with the licensee’s Quality 

Assurance Program (QAP) and the basis for the QAP (NPUF licensees are expected to 

commit to the QAP requirements of ANS/ANSI 15.8, “Quality Assurance Program 

Requirements for Research Reactors”). It is not the objective of this IP to verify the 

adequacy of the licensee’s QAP, but inspectors should be prepared to identify potential 

weaknesses in the licensee’s QAP for future inspections. Inspectors should complete 

this appendix by inspecting the attributes listed in this appendix for related

instrumentation and control system work on-site at the time of the inspection.

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the instrumentation and control systems on 

the site, but may expand the inspection if time allows, or if significant concerns with the 

licensee’s control of instrumentation and control system construction arise. Inspectors 

should collect licensee procedures, construction specifications, and work completion 

records in advance, if possible. If unable to review these documents in advance of the 

on-site inspection, then the licensee should be notified that these documents, and any 

other relevant documents, should be available when the inspector(s) arrives at the site.
Issue Date: 12/14/15 J-2 69020

Inspectors should review the areas listed in 02.02 through 02.12 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 QA Procedure Review. Review commitments and procedures covering the scope of 

documents to be prepared for assuring the quality of I&C systems that are designated as 

safety-related 

a. Determine whether the installation procedures for safety related I&C systems are 

consistent with the QA program and licensing document commitments.

b. Determine whether responsibility assignments for procedures preparation, review and 

approval, include groups with necessary technical expertise.

c. Determine whether licensee individuals or contractors that review and approve quality 

records are required to have the necessary technical expertise to ensure that the 

information to be recorded meets applicable requirements.

d. Determine whether construction drawings incorporate the most recent design 

requirements.

02.03 Specific Technical Review Areas. Determine whether procedures covering work and 

inspection activities in the following areas are appropriate for the activity and are 

technically adequate:

a. Receipt Inspection Procedures (IPs). Receipt inspection and related procedures 

provide means to ensure that:

1. Material is in good condition, not damaged in shipment and that shipping and 

handling requirements have been met.

2. Inputs from other groups or other organizations to be used during receiving 

inspection activities are properly utilized; such as the results of source 

inspections, environmental qualification tests, and other required quality tests.

3. Procurement requirements such as qualification tests, certificate of conformance, 

functional tests and other quality tests (material, physical and chemical) have 

been successfully completed or status of how and when such requirements will 

be satisfied is documented and adequately controlled.

b. Storage Procedures. Storage procedures provide means to ensure that:

The proper storage environments (as specified by the construction specifications and 

the manufacturer’s instructions) are established for the various types of I&C system 

components and meet applicable storage classification levels regardless of the location 

of the stored item.
Issue Date: 12/14/15 J-3 69020

c. Work Procedures. Work procedures are established to ensure that:

1. Licensing document commitments are properly translated into the work 

procedures (construction specifications, drawings and work instructions) for 

adequate control and installation of safety-related I&C system components and 

associated items.

2. Interface controls are adequate when multiple contractors are involved.

3. Procedures cover special handling, installation, termination, and maintenance 

requirements, including those pertaining to protection, preservation of internal 

cleanliness, and maintenance of component qualification requirements. For 

example, all covers, seals, plugs, internal preservatives, and protective coatings 

are left intact until installation and/or use, as appropriate.

d. Inspection Procedures. QC IPs is established to ensure that:

1. All safety-related aspects of construction specifications, drawings, and work 

instructions are included in the scope of planned inspections.

2. The technical aspects of inspection requirements and acceptance criteria are 

sufficient to determine whether the components and their installation (including 

terminations and interface seals), calibration, test, maintenance, and protection 

conform to applicable design and construction specifications.

3. Records of initial and follow-up inspections include the specific results of the 

inspection. This should include the specific characteristics being inspected (or 

the actual measured values), the inspector's determination of acceptability, and 

identification of any nonconformance(s) found.

e. Construction Testing and Calibration Procedures. Procedures are established to 

ensure that special conditions of testing and calibration of process instruments 

(prerequisites, sequence, special handling, removal, precautions, etc.) are included and 

described in proper detail as required to conduct and monitor the work performed. For 

example, if density compensation is required for a liquid level instrument, the proper 

technique for density correction should be included in the calibration procedure.

f. Change Control Procedures. Procedures have been established to control design and 

field changes to ensure that:

1. Retrieval of voided drawings and specifications at work sites is controlled.

2. Field changes are subject to adequate design control processes and are 

incorporated into the as-built records.
Issue Date: 12/14/15 J-4 69020

02.04 Follow-up Procedure Review. For work in progress or completed, review a selected 

sample of the procedures addressed in Sections 02.02 and 02.03, above, and note 

significant changes made (revisions, deletions, additions, etc.). Determine whether the 

changes are appropriate and whether regulatory requirements and licensee commitments 

remain in these procedures.

02.05 Inspection of Systems and Components.

a. General.

1. Inspection of selected components and associated items of the instrument 

systems listed below may be accomplished by observation, record review and/or 

independent evaluation of in-process and/or completed work.

2. Sample selection should be based on importance to operational safety and 

should include redundant components and a diversity of components and 

locations if practical.

3. Before inspection of selected items, review the specifications, drawings, work 

procedures, QA/QC procedures and work schedules applicable to the systems 

and components selected for inspection. Below are examples of types of 

samples the inspector(s) may use during this inspection:

(a) Emergency Control System.

(1) For each of the activities in Section 02.06, select process variables 

which are used by the emergency control system to mitigate the 

consequence of a hazardous occurrence.

(2) Complete the inspection requirements of subsections 02.06.b 

through 02.06.f for components pertaining to the process variables 

selected for that subsection.

(b) Safety Related Display Instrumentation.

(1) For each of the activities in Section 02.06.d, select process 

variables which are displayed to provide information to the operator 

so that required manual safety actions can be taken using the 

emergency control system.

(2) Complete the inspection requirements of subsections 02.06.b 

through 02.06.f for components pertaining to the process variables 

selected for that subsection.

(c) Emergency Control System.

(1) Select process variables which are used by the emergency control 

system to mitigate the consequence of a hazardous occurrence.
Issue Date: 12/14/15 J-5 69020

(2) Complete the inspection requirements of subsections 02.06.a 

through 02.06.f for the instrument components and associated items 

pertaining to the emergency control system variable selected. 

(d) Safety Related Display Instrumentation.

(1) Select process variables which are displayed to provide information 

to the operator so that required manual safety actions can be taken 

using the emergency control system.

(2) Complete the inspection requirements of subsections 02.06.b 

through 02.06.f for components pertaining to the process variable 

selected for that subsection.

02.06 Inspection Activities.

a. Receipt Inspection. Observe and evaluate a sample of receipt inspection activities 

pertaining to instrumentation components and associated items selected in the 

appropriate subsections of Section 02.05. Determine whether receiving inspection 

activities are being controlled and performed in a manner which will ensure that 

applicable requirements are satisfied in the following areas:

1. Components and receiving documents are properly identified.

2. Physical condition (damage, deterioration, etc.).

3. Documentation relative to quality requirements (e.g., results of functional and 

qualification testing) received with components and associated items is reviewed 

and meets the requirements. Where qualification testing of components to be 

placed in a harsh environment is not a requirement of the specification, review 

existing documentation that establishes acceptance criteria and environment 

requirements that define what means will be used to assure that applicable 

environmental qualification will be satisfied.

4. Control of nonconforming components.

5. Adequate number of qualified personnel are available to perform the receiving 

inspection function.

b. Storage. Observe and evaluate a sample of storage activities and conditions for the 

inspection samples selected in appropriate subsections of Section 02.05. Determine 

whether:

1. Components are stored in the proper storage level designation.

2. Components are properly identified.
Issue Date: 12/14/15 J-6 69020

3. Storage conditions (temperature, humidity, cleanliness, etc.) are controlled and 

monitored as specified.

4. Licensee and contractor inspection and monitoring activities are being performed 

in accordance with procedural requirements.

5. Nonconforming items placed in storage are identified and/or segregated, as 

required.

6. In-place storage requirements are satisfied.

7. An adequate number of qualified personnel are available to perform the required 

storage functions.

c. In-Process Installation. If in-process work is occurring at the time of the inspection, 

observe and evaluate portions of the in-process installation activities for the inspection 

sample selected in appropriate subsections of Section 02.05. Determine whether:

1. The latest approved revision of applicable construction specifications, drawings, 

and/or procedures are available and used by the installers.

2. The components are as specified, such as: type, range, proof pressure/rating 

and material. 

3. Associated mounting hardware and supports are of the type and material 

specified and properly located.

4. The components are installed in the proper location and orientation by qualified 

craft personnel using suitable equipment and tools.

5. The required component identification is properly maintained or established.

6. Licensee and contractor inspections are performed, or scheduled to be 

performed, before closing out the work to be inspected.

7. Inspection activities are timely and properly completed by qualified personnel.

8. Installed components are adequately protected from damage by adjacent 

construction activities.

9. Nonconformance issues are identified and handled in accordance with 

established procedures. Where corrective action is being taken, determine 

whether it meets the appropriate requirements.

d. Completed Work. Observe and inspect the completed installation of I&C system 

components for the samples selected in subsections of Section 02.05. Determine 

whether:
Issue Date: 12/14/15 J-7 69020

1. Location, configuration and installation (including mounting and anchoring) are in 

accordance with the latest approved design or construction specifications and 

drawings.

2. Specified instrument components and associated items have been used.

3. Components have been correctly and permanently identified.

4. Cleanliness requirements have been maintained or otherwise satisfied.

5. Installed equipment is adequately protected from adjacent construction activities 

and protective coatings, plugs, bushings, and other materials have been used as 

specified.

6. Instrument components and associated items, such as sensing lines and power 

supplies; maintain physical and electrical independence between redundant 

parts.

7. Protection systems and normal plant control systems are adequately separated 

and isolated from each other.

8. Nonconforming components or conditions have been identified and controlled in 

accordance with approved procedures.

9. Status of completion, maintenance, and readiness for pre-operational testing is 

indicated or otherwise documented.

10. Adequate actions or provisions have been taken or maintained (as needed) to 

ensure that the validation of the environmental qualification of instrument 

components is maintained.

11. Wiring and terminations, including grounding, are installed in compliance with 

construction drawings and specifications.

e. As-Built Verification.

1. When I&C system components as selected in appropriate subsections of Section 

02.03, are installed and inspected, obtain the latest revision (as-built, if available) 

of instrument and installation drawings.

(a) Review construction specifications and other applicable documents 

referenced by drawing or otherwise.

(b) Compare the actual installation of the components selected with the 

drawings.
Issue Date: 12/14/15 J-8 69020

2. Before performing items (a) and (b) above, verify the status of any outstanding 

design changes on the selected drawings (or related specifications).

3. Discrepancies observed may result from in-process changes, such as those 

initiated in the field. If in-process changes are involved, determine whether the 

licensee has properly controlled and documented these changes for engineering 

review, approval, and subsequent incorporation into the final as-built drawings.

f. Construction Testing and Calibration. Observe a sample of construction testing and 

calibration activities for applicable components from the sample selected in subsections 

of Section 02.03. Determine whether:

1. The latest revisions of applicable procedures and/or specifications are available 

at the work location and used by personnel performing the testing and 

calibration.

2. Properly identified, traceable and calibrated measuring and test 

equipment are used.

3. Equipment or components calibrated are able to obtain the set point, degree of 

accuracy, and/or tolerance specified or otherwise noted.

4. Required testing and calibration results are recorded during the activity, not after 

the work has been completed.

5. Components are adequately identified as having been tested or calibrated.

6. Personnel performing the testing and calibration are properly qualified.

7. Test and calibration personnel adhere to any special handling or removal 

requirements.

02.07 Record Control and Review. Review licensee and contractor requirements covering the 

scope of records for safety related I&C system components.

a. Determine who prepares each quality-related record, who reviews the records for 

accuracy and who ensures that the recorded information meets requirements.

b. Evaluate the information obtained above and determine whether the established record 

management system satisfies QA Program and licensing document commitments.

02.08 Inspection Records. Review and evaluate a sample of pertinent quality records. 

Determine whether: (1) adequate preparation, control, review, and evaluation of these 

records have been made; (2) they reflect that regulatory requirements have been met and 

(3) the system of records is functioning properly. The selection should include records of 

components in safety control subsystems, emergency control system, sensors, and 

safety parameter displays, if applicable.
Issue Date: 12/14/15 J-9 69020

a. Receipt Inspection Records.

1. Receipt inspection documents properly and uniquely identified received 

instrument components and associated items.

2. Applicable engineering and functional specifications (regarding size, type, 

material, etc.) of received items were met or otherwise noted.

3. The required instrument component characteristics, material, performance tests, 

environmental and seismic qualification tests, nondestructive tests, and other 

specification requirements were met or otherwise noted.

4. Original records or certification system met requirements of applicable criteria.

b. Storage Records.

1. Required storage conditions were maintained. (Note: Verification of these 

conditions may require verification of log sheets recording the ambient conditions 

or through the use of recorders.

2. Storage inspections were properly made at specified intervals.

3. Records of nonconforming items in storage areas were properly maintained.

c. Installation Records.

1. Most recent and approved design and construction documents were used during 

installation.

2. Specified instrument components and associated items were installed in the 

location specified or otherwise noted.

3. Materials and methods used for supports and anchors (including welds) met 

applicable specifications.

4. Required inspections were performed, recorded, reviewed, and evaluated by 

qualified personnel.

5. Inspection records were complete and satisfied documentation requirements.

6. Physical separation and independence requirements were met.

7. Required protection was provided after installation.

8. Verify that required special installation procedures were implemented.
Issue Date: 12/14/15 J-10 69020

d. Construction Testing and Calibration Records.

1. Required tests and calibrations were performed as required.

2. Records indicate that approved procedures and equipment were used.

3. Test equipment was periodically checked and calibrated as specified.

4. Test data and results were properly documented and evaluated, and corrective 

action, if required, was taken.

02.09 Training/Qualification Records. Review and evaluate a sample of personnel qualification 

records and determine whether:

a. A system of craft and inspection personnel qualification records meets stated 

requirements and is being maintained in a current status.

b. The records are sufficient to reasonably support qualification in terms of certification, 

experience, proficiency, training, testing, etc., as applicable.

c. Action has been taken by responsible licensee organizations to independently 

authenticate the record material.

02.10 Nonconformance and Deviation Reports. Review and evaluate a sample of 

nonconformance and deviation reports, and determine whether:

a. Records are legible, complete and promptly reviewed by qualified personnel.

b. Appropriate reporting requirements were recognized during evaluation and appropriate 

action was taken where necessary.

c. Records have been routinely processed, timely evaluated, and controlled through 

established channels for resolution of the root cause as well as the immediate problem.

d. Records are properly identified, stored, indicate current status, and can be retrieved in a 

reasonable time.

e. Nonconformance reports include the status of corrective action or resolution, and 

adequate justification is provided for use-as-is disposition.

02.11 Change Control Records. Review and evaluate a sample of change control records,

and determine whether:

a. Records associated with design and field changes, as well as related work and 

inspection procedure changes, reflect timely review and evaluation by qualified 

personnel and are of the type approved for that purpose.
Issue Date: 12/14/15 J-11 69020

b. Records of periodic inspections assure that only the most recently approved 

documents, including design changes, were used in the field.

c. Design changes are subject to adequate design control, including consideration of the 

impact of the change on the overall design and on as-built records.

d. Records of nonconformity to design requirements include preparation of a 

nonconformance report even if the nonconformance is resolved through the design 

change process.

02.12 Audit Records. Review and evaluate a sample of licensee and instrument contractor(s) 

audit records associated with instrumentation and determine whether:

a. Audits have been performed in accordance with the schedule and functional areas 

established in the audit plan.

b. Audit records are sufficient to verify that the intended purpose and scope of the audits 

were achieved.

c. Audit findings have been reported in sufficient detail to permit a meaningful assessment 

by those responsible for corrective action, final disposition, and trending.

d. The licensee and contractor has taken proper and timely follow-up action on those 

matters in need of correction.

e. Auditing organizations and personnel are independent of the work being audited.

f. All elements of the QA program are being audited periodically.

69020.A10-03 INSPECTION GUIDANCE

03.01 General Guidance.

a. I&C system components consist of those elements that are designed to measure, 

monitor, transmit, modify, display, alarm, record and/or control various plant variables or 

conditions. This IP, and other instrumentation IPs, apply, but are not limited, to the 

following safety related instrument components and associated items: sensors, 

transmitters, isolators, signal conditioners, controllers and other actuating devices, 

recorders and other printing devices, indicators, alarms, switches, logic devices, 

interlocks, bypasses, instrument valves, fittings, tubing, instrument air supplies, internal 

power supplies or regulators, protective devices, control boards, racks, panels, 

cabinets, supports, anchor and mounting hardware, communication devices, 

multiplexers, data concentrators, engineering workstations, human-machine interface 

devices (e.g., displays), interconnecting means for integrity and applicability, and 

network management devices and tools.
Issue Date: 12/14/15 J-12 69020

b. During inspection preparation, applicable portions of the licensing documents should be 

reviewed by the inspector to determine specific licensee procedural and work 

instruction commitments relative to construction and inspection (QA) requirements for 

I&C system components. The inspector should then utilize the above information 

during review of the licensee's construction specifications, drawings, work, and IPs to 

determine whether licensing document requirements are adequately translated into the 

appropriate documents.

c. Procedures that control activities such as receipt, storage, installation, inspection, 

calibration, testing, and software modification, upgrading, and/or patching must contain 

sufficient detail to assure that the specific work steps which affect the functioning of the 

installed equipment will be performed properly. These work steps are to be identified 

and adequately controlled. While reviewing procedures, be aware of and look for 

inadequacies that could lead to construction deficiencies and/or indicate an inadequate 

management control system.

d. In addition to observing whether specific instrument components and associated 

devices are as specified (properly identified, located, mounted, etc., as required), it is 

important also to ascertain whether certain components or conditions do not exist 

where prohibited. For example, instrument components are not exposed to potential 

hazards from other construction activities. Because of the complexity of digital 

components, and the potential for interconnection between safety components and 

between safety and non-safety components, the inspector should consider these issues 

during the inspection. Although the safety sensor may be hardwired to the controller, 

the controller may be communicating over a digital bus with other controllers, the 

operator, or and annunciator system. Also, some sensors are “smart” in that they have 

on-board diagnostics and calibration tables, so, even though they are “hardwired,” they 

could still be using some communication link with the controller (e.g., HART 

superimposes digital monitoring and command signals on an analog 4-20mA signal).

03.02 Specific Guidance.

a. Section 02.02. The expertise of the inspector is important for the proper completion of 

the inspection. Inspectors should have a general knowledge of and background in QA 

and knowledgeable of the technical requirements associated with instrumentation 

systems. 

b. Section 02.03. For the purpose of this IP, the term “procedures covering work” includes 

construction specifications, drawings, and work instructions. (Procedures describing 

methods of fabrication, construction or installation are sometimes called construction 

procedures.)

c. Section 02.03.a.

1. Receiving IPs should reflect the requirements that the licensee has committed to 

in their QAP.
Issue Date: 12/14/15 J-13 69020

2. The licensee should identify and describe all safety-related I&C components 

which must operate in a hostile environment (e.g., high radiation, temperature, 

humidity) during or after an accident. 

3. Where environmental qualification testing, or other qualification provisions (such 

as seismic) are specified, the licensee shall establish means to assure that the 

results of this testing are documented, reviewed, and determined to be 

acceptable. If this is not performed when components are received, the 

procedures should specify the organization that will be performing this review 

and the controls to ensure that all such documentation requirements are satisfied 

before the component is placed in use.

4. The inspector should also be aware of memory-related integrated circuit chips 

(Programmable read only memory (PROMs), flash memory, etc.) that have 

certain versions of application code (i.e., specific version of firmware). The 

inspector should verify that the configuration management program is tracking 

these versions - not just firmware, but all electronic devices that may have 

embedded processors, memory, etc. In addition, for safety related electronic 

components, the inspector should verify that the supplier or licensee followed the 

supply chain to ensure no unauthorized replacements have occurred.

5. Instrument components may be released for installation on the merits of 

certifications of conformance if the organization involved has established a 

satisfactory program control and audit requirements in this area. However, 

certifications of conformance do not release the licensee from having other 

records (such as environmental or seismic qualification records) for operation 

and for the life of the plant.

d. Section 02.03.b.

1. Special storage requirements are typically specified by the manufacturer or an 

industry standard. The requirements should include such things as identification 

and markings on I&C components, protective covers, preservatives, etc.

2. The inspector should verify that the storage procedures have provisions for initial 

and periodic inspection of storage conditions for components which have special 

storage requirements. Procedures should be available for conducting periodic 

“storage inspections” of components which have been installed during the time 

period between installation and turnover to the operations staff.

3. The inspector should consider verifications of proper firmware, component 

versions, and verify that unauthorized substitutions have not been made (This is 

over and above certain environmental considerations, e.g., humidity and 

temperature for electronic components.)

e. Section 02.03.c. Procedures should be reviewed to ensure that technical requirements 

in the licensing document are reflected in construction specifications, drawings, work 
Issue Date: 12/14/15 J-14 69020

instructions, and work procedures. Areas to review shall include, but are not limited to, 

the following:

1. I&C system components (type, range, accuracy, materials, etc.) are identified, 

located, oriented, and supported as specified by design.

2. Physical separation and independence requirements of redundant components 

are met.

3. Instrument sensing lines are sloped to meet applicable requirements. 

Instruments connected to chemical processes for which it is not feasible to use 

direct sensing lines might be connected via armored capillary tubing and/or 

diaphragm seals which have been appropriately protected from potential damage 

from construction or operating activities. Appropriate and adequate construction 

specifications, procedures and other work instructions for a particular activity are 

required to be approved and available before that activity is started.

f. Section 02.03.c.3.

1. It is not considered adequate identification to include only the instrument model 

number and type. Procedures should specify a unique identification number, 

along with the model number and name of manufacturer. Adequate (positive) 

identification is important because similar-looking instrument components can be 

significantly different with respect to range, output signal, etc. Safety-related 

instrumentation should be listed in the licensing document.

2. Anchor bolts holding or mounting instrument components should be of the type, 

size and length specified. Provisions should exist to prevent indiscriminate 

cutting of reinforcement steel during the drilling of anchor holes.

3. Procedures should be established to ensure that independence and separation 

requirements of safety-related functions from normal control functions are met, 

especially safety functions that provide protection against normal control system 

malfunctions. This separation should include electrical and data communication 

isolation. (Note: Given the high automation in new facilities, data communication 

isolation should be verified from both a random failure and a cyber security 

perspective.) 

4. Means should be established, such as procedures or checklists, to ensure that 

redundant sensing lines are protected from common mode failures. That is, 

redundant lines will not fail from a single accident; especially an accident or 

failure for which they are supposed to provide protection.

5. Evaluate sensitivity to grounding connections and lightning protection system 

down comers. 
Issue Date: 12/14/15 J-15 69020

g. Section 02.03.d.

1. Section 02.03.d.2. Review the IPs and compare with the requirements in the 

applicable codes and construction specifications. Evaluation should indicate 

whether adequate quality-related IPs are established and are based on 

appropriate criteria, and further, whether the results of the licensee's inspection 

will be transmitted to responsible quality assurance and management personnel.

2. Section 02.03.d.3. Provisions should include procedures for monitoring or 

surveillance of locally mounted instruments by inspection (QC) personnel. They 

should ensure that maintenance requirements while “stored in place” are 

satisfied and that adequate protection is provided against possible damage from 

adjacent construction activities, including construction traffic. (Where protective 

means used during construction may affect proper operation, provisions should 

be provided for timely removal.)

h. Section 02.03.e. This area is to be inspected by an inspector who is knowledgeable in 

the area of instrumentation in general and calibration and testing in particular.

The licensee should reference general testing and calibration requirements, and work 

procedures should provide detailed instructions. Additionally, the QA manual should 

include general surveillance procedures relative to the calibration of process 

instruments, i.e., calibration activities should be monitored (inspected or audited, as 

appropriate) in accordance with established procedures.

1. These procedures should include verification of the following:

(a) Calibration data sheets (or equivalent) are being used as specified.

(b) Calibration ranges and accuracies are current and approved for use. 

(Accuracy requirements should be defined.)

(c) Calibration and instrument setting procedures are current and approved 

for use, including identification of any special calibration test equipment or 

test equipment minimum accuracy specifications needed for safety related 

instruments. Such specifications should be consistent with the project 

instrument set point and loop accuracy procedure requirements.

(d) Calibration techniques are appropriate for the component to be calibrated. 

For example, if density compensation is required for a liquid level 

instrument, the proper technique or correction for density should be 

included in the calibration procedure. Although density compensation is a 

basic requirement for accurate level measurement, it is periodically 

overlooked for water-calibrated instruments.

(e) Controls for removal and handling of components during calibration.
Issue Date: 12/14/15 J-16 69020

2. Calibration data records for process instruments should include information and 

data specified by industry standards which the licensee is committed to such as:

(a) Specific identity of the instrument calibrated.

(b) The specific identity of the measuring and test equipment used to perform 

the calibration.

(c) The “as-left” calibration data.

(d) Date of calibration.

(e) Identity of the technician performing the calibration.

(f) Calibration schedule documentation review.

(g) Approval signature of a responsible individual. Certificates of calibration 

should be available at the site for measuring and testing equipment used 

to perform these calibrations. These certificates should show that the 

standards used to establish the accuracy of the test equipment are 

traceable to a nationally recognized standard. Procedures should require 

that the performance and accuracy of test equipment are demonstrated by 

periodic checking.

This item does not include pre-operational testing. Construction testing 

generally verifies that certain components perform as intended, but it is not 

a test of system capability.

i. Section 02.05.a.3.(c). Examples of process variables used by the emergency control 

system are some manual and automatic controls for power distribution, ventilation, and 

seismic isolation systems. Associated and interrelated devices include signal 

conditioning components, isolation devices, interlocks, bypasses, selector switches, 

resets, overrides, instrument tubing, racks, panels, and their supports, instrument wiring 

and wiring terminations. The licensing documents should include the specific variables, 

as well as the logic and devices, used in the system.

Examples of sensors which provide information to automatic controllers are devices for 

measuring/monitoring temperature, mass, physical dimension, component identification 

bar codes, and machine tool positions.

Examples of controllers which are required to mitigate accidents are the safety 

controllers and emergency controls. The licensee should specify the specific variables, 

as well as the logic and logic devices used in the system.

j. Section 02.06.a. Receipt inspection activities should be inspected for compliance with 

procedures identified and/or reviewed during inspection.
Issue Date: 12/14/15 J-17 69020

1. The licensee should identify and describe all instrument components which must 

operate in a hostile environment (e.g., high radiation, temperature, humidity) 

during or subsequent to an accident. Where environmental qualification testing, 

or other qualification provisions (such as seismic) are specified, receiving 

inspection activities should include verification that required testing has been 

satisfactorily completed.

2. All required documentation may not be received with the components. If not, the 

inspector should at this time determine that the licensee is following their system 

for identifying, controlling, and maintaining the status of the required 

documentation. This system should ensure eventual documentation of 

satisfactory completion of required testing.

k. Section 02.06.b. Storage activities should be inspected for compliance with procedures 

identified and/or reviewed during inspection.

1. Control of storage conditions for equipment stored in place usually requires 

special effort. The inspector should note whether the procedurally required 

storage conditions are being maintained.

2. Readily visible and permanently marked tags or other identifying scheme should 

be used for all nonconforming components and materials, and records relative to 

the nonconformance should be available at the site and readily retrievable.

l. Section 02.06.c. Because of the uncertainties associated with scheduling of in-process 

installation inspections, it is expected that the scope of these periodic inspections will 

vary considerably. The intent is to observe the more important installation activities for 

a variety of instrumentation components and associated items during the time such 

activities are in progress.

1. Section 02.06.c.1. While reviewing construction specifications and drawing, also 

look for missing or inappropriate approvals.

2. Section 02.06.c.2. Drawing and construction specifications used in the field 

should be reviewed periodically to ensure that the most recent approved 

revisions are used and components are as specified.

3. Section 02.06.c.3. For some of the supports and anchorages, the inspector 

should directly measure or otherwise independently verify that requirements 

pertaining to such items as location of equipment, location of supports, and bolt 

size are as specified.

During installation of equipment, anchorage holes are sometimes drilled in 

concrete structures. Indiscriminate cutting of reinforcing steel should not be 

allowed. Verify the adequacy of procedures to ensure the activity is not included

The inspector should ensure that proper welding requirements, from codes and 

standards that the licensee has committed to, are specified and controlled. 
Issue Date: 12/14/15 J-18 69020

Standards may include American Welding Society (AWS) D1.1, Structural

Welding Code, for welding of supports. Instrument tubing welds are generally in 

accordance with welding code requirements associated with the system or 

component being monitored, e.g., American National Standards Institute (ANSI) 

B 31.3, American Society of Mechanical Engineers (ASME) Boiler and Pressure 

Vessel (B&PV) Code, as appropriate. The inspector should verify that the 

construction specifications and drawings specify the welding requirements to be 

used.

4. Section 02.06.c.4. “Qualified craft personnel” means those employees who have 

achieved suitable proficiency to do their assigned tasks by appropriate training 

and/or previous experience and who understand the installation procedures, 

drawings, and specifications necessary for their work.

5. Section 02.06.c.7. The observation of inspection (QC) activities should include 

in-process and final inspections.

"Timely and properly completed" includes performing the proper inspections at 

the specified frequency and sequence.

A sample of QC inspectors should be interviewed to determine whether they are 

familiar with the quality requirements associated with the instrumentation being 

inspected, what construction specifications and other criteria are used to 

determine acceptance, how their inspection results are recorded, etc. The intent 

is to determine the effectiveness of instrumentation inspection personnel and 

management systems for indoctrination, training, and qualification of personnel.

m. Section 02.06.d.

1. Section 02.06.d.1. Some instrument lines, racks, panels, and their supports, or 

other anchoring means are required to meet seismic requirements. (The 

licensing document should indicate where applicable.) If specified for lines, 

racks, or panels selected for inspection, ascertain whether these requirements 

are met.

If the installation is different from approved drawings and specifications, 

determine whether the change is adequately documented and forwarded for 

review and approval.

2. Section 02.06.d.2. Sometimes similar instrument components are put in identical 

cases. The inspector should ascertain whether the various components 

inspected are as specified. This can be done by observing the name plate for 

identification numbers. For example, the model number may be the same on two 

components, but the ranges and identifying numbers will be different.

3. Section 02.06.d.3. The inspector should ascertain whether component 

identification is adequate. The installed instrument components should be uniquely
Issue Date: 12/14/15 J-19 69020

identified on the component itself, the installation records, calibration records, 

and inspection records.

4. Section 02.06.d.5. Temporary protection during construction is generally required. 

Protection from overhead construction activities, especially welding and concrete 

placement, warrants special attention. Additionally, protection from inadvertent 

damage during plant operation and maintenance must be adequate and properly 

installed. Because it can be easily damaged, instrument tubing requires special 

attention. This is especially important when instrument tubing runs are part of a 

safety system that may be damaged by an event or accident for which the safety 

system is supposed to provide protection.

5. Section 02.06.d.7. Safety functions are to be independent of normal plant control 

functions, especially safety functions that provide protection against control 

malfunctions.

6. Section 02.06.d.8. The intent is to verify that nonconforming conditions are 

identified and result in the initiation of appropriate nonconformance 

documentation. Where revisions are made, verify that they are in accordance 

with approved corrective action dispositions.

n. Section 02.06.e. The intent is to determine whether instrument components and 

associated items are being installed according to properly approved drawings and 

changes, such as engineering, design, field change requests, and changes to correct 

nonconforming conditions. As this inspection requirement is to verify "as-built" systems, 

a new sample should be selected if it is found that extensive rework is in progress. 

However, the NRC inspector should verify that the changes are properly handled in 

accordance with established procedures.

Changes may be made to instrument systems during construction that are different 

from the original design. Such changes will result in the accumulation of various types 

of design change documents. Since these changes reflect as-built conditions, they 

should be adequately controlled and available for future evaluations on the effect other 

design changes have on the overall design.

Additionally, the as-built process should result in proper and timely updating of the 

master drawings and specifications to incorporate such changes. Thus, an excessive 

number of accumulated changes not incorporated into the as-built records and affected 

analyses should be pursued. The NRC inspector should determine how the licensee 

ensures that the effect of each subsequent change will be adequately evaluated.

o. Section 02.06.f. The inspector should review the specified calibration requirements and 

procedures before observing these activities. If special requirements are specified, 

such as density compensation during liquid level instrument calibration, the inspector 

should determine whether these requirements are being adhered to.

If calibration activities are in progress, determine whether the most recently approved 

calibration information is being used, and whether required procedures are being 
Issue Date: 12/14/15 J-20 69020

adhered to. The values of instrument ranges and zero set points are sometimes 

changed after receipt of the instruments at the site. The inspector should assure (by 

selective sampling) that current data are used for checking and calibrating instruments, 

and that these changes are within the limits of the instrument components involved.

As these inspection requirements cannot be done until testing and calibration activities 

are in progress, inspection in this area should be scheduled accordingly.

Final calibration and trip settings may be done later, usually during pre-operational 

testing or during startup preparation.

The intent of these requirements is to verify that nonconforming conditions associated 

with instrument components and systems are identified by the licensee and result in the 

initiation of the appropriate nonconformance documentation and corrective action.

p. Section 02.08.a. Where environmental qualification testing, or other qualification 

provisions (such as seismic) are specified, records should be available to verify that 

required testing has been satisfactorily completed. If these records are not available at 

the time of component receipt, the inspection records should identify the need for 

subsequent receipt and review of these documents.

It is important to ensure that qualification testing has been successfully completed. 

Qualification documents should be reviewed to substantiate that the equipment is 

qualified to applicable standards and to the appropriate environment.

r. Section 02.08.b. Control of storage conditions for equipment stored in place usually 

requires special effort. The inspector should note whether the specified storage 

conditions are reflected in the storage inspection records. 

s. Section 02.08.c. Licensee and contractor inspection personnel should use checklists or 

other means to ensure proper identification of installed equipment. Checklists or 

records of inspection should be generated during the inspection, and these records 

should be readily retrievable for review by the NRC inspector. “Properly installed” 

means that the installation meets applicable NRC requirements and licensee 

commitments, including specified separation or installation of protective barriers. The 

as-installed inspection records should match the applicable requirements. In order for 

the inspector to ensure that the records reflect actual conditions (identification, 

instrument range, location, etc.), some instrument components selected should be the 

same as those selected in Section 02.02 of this procedure. (If the installation differs 

from the approved installation documents, a nonconformance report and a design 

change should have been generated.)

During installation of equipment or supporting components for the equipment, 

anchorage holes are sometimes drilled in concrete structures. The work and/or 

inspection records should indicate (or at least infer) that no indiscriminate cutting of 

reinforcing steel was done during drilling of anchor holes.
Issue Date: 12/14/15 J-21 69020

Installation and inspection records must contain sufficient detail to permit identification 

of the specific revisions or change notices used in these activities. Permanent records 

must provide a clear audit trail to any applicable change or nonconformance 

documentation. See also subsection 02.02.a.3 above.

t. Section 02.08.d. In addition to the records indicating satisfactory testing and 

calibration, the records should reflect that the range, response time, etc., for instrument 

components are appropriate for postulated accident conditions as well as for normal 

operating conditions. The procedures for testing and calibration should contain the 

necessary criteria.

Where special requirements are necessary, such as density compensation during liquid 

level instrument calibration, the records should reflect that such requirements were 

adhered to.

u. Section 02.10. The sample size and diversification of selection should be sufficient to 

determine whether the system used to handle and control nonconformance issues is 

working in an effective manner.

The effectiveness of the management control system in this area can be determined, in 

part, by how adequately and promptly the root cause of nonconforming activities are 

identified and corrected.

v. Section 02.12. Audit records should reflect that adverse audit findings were promptly 

evaluated and corrected in an adequate manner. The root cause involved should be 

identified to preclude repetition.

03.03 Prevalent Problems and Concerns. The inspector should be alert to problems of a 

generic nature, such as:

a. Adequate procedures or other means have not been established to assure and 

document that all safety related I&C components have met applicable acceptance 

criteria or to identify and document non-conformances in specific areas.

b. IPs do not include adequate inspection requirements and acceptance criteria.

c. Inadequate means to control location and status of instrumentation components -

especially during removal for calibration, modification, repair or replacement.

d. Inadequate procedures to control the evaluation, approval and use of field changes. 

(Means should be established also by the licensee or contractor to assure that only the 

latest approved field changes and other revisions or changes are being used for 

installation and inspection activities.)
Issue Date: 12/14/15 J-22 69020

69020.A10-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 64 hours of on-site inspection (Two inspectors for 

one week). Inspection preparation, including SAR review, review of applicable codes and 

standards, and licensee quality assurance procedure review, is not included in this estimate. 

69020.A10-05 REFERENCES

American National Standards Institute (ANSI)/Instrument Society of American (ISA). ANSI/ISA67.04.01-2000, “Set points for Nuclear Safety-Related Instrumentation.”

ANSI/ Institute of Electrical and Electronic Engineers (IEEE) Standard (Std.) 336-1985, “IEEE 

Standard Installation, Inspection, and Testing Requirements for Power Instrumentation, and 

Control Equipment at Nuclear Facilities.”

ANSI/IEEE 802.3 Standards Series, “IEEE Standards for Local Area Networks: Carrier Sense 

Multiple Access with Collision Detection (CSMA/CD) Access Method and Physical Layer 

Specifications.”

IEEE Std 384-1992, “Standard Criteria for Independence of Class 1E Equipment and Circuits.”

IEEE Std 344-1987, “IEEE Recommended Practices for Seismic Qualification of Class 1E 

Equipment for Nuclear Generating Stations.”

IEEE Std 518-1982, “IEEE Guide for the Installation of Electrical Equipment to Minimize 

Electrical Noise Inputs to Controllers from External Sources.”

IEEE Std 1023-1988, “IEEE Guide for the Application of Human Factors Engineering to 

Systems, Equipment, and Facilities of Nuclear Power Generating Stations.”

IEEE Std 1050-1996, “Guide for Instrumentation and Control Equipment Grounding in 

Generating Stations.”

ISA-S12.13-Part 1-1995, “Performance Requirements, Combustible Gas Detectors.”

ISA RP12.13-Part II-1987, “Installation, Operation, and Maintenance of Combustible Gas 

Detection Instruments.”

NUREG-0700, “Human System Design Review Guidelines,” NRC

NUREG-0800, Standard Review Plan, Branch Technical Position HICB-11, “Guidance on the 

Application and Qualification of Isolation Devices,” NRC

NUREG-0800, Standard Review Plan, Branch Technical Position HICB-17, “Guidance on SelfTest and Surveillance Test Provisions,” NRC

Regulatory Guide (RG) 1.118, Revision 3, “Periodic Testing of Electric Power and Protection 

Systems,” NRC
Issue Date: 12/14/15 J-23 69020

RG 1.180, “Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in 

Safety-Related Instrumentation and Control Systems,” NRC

RG 1.75, Revision 2, “Physical Independence of Electric Systems,” NRC

RG 1.100, Revision 2, “Seismic Qualification of Electric and Mechanical Equipment for Nuclear 

Power Plants,” NRC

RG 3.17-1974, “Earthquake Instrumentation for Fuel Reprocessing Plants.”

END
Issue Date: 12/14/15 K-1 69020

ATTACHMENT K

INSPECTION OF STRUCTURAL WELDING AT RADIOISOTOPE PRODUCTION FACILITIES

69020.A11-01 INSPECTION OBJECTIVES

01.01 To determine if the structural welding activities performed at the site are done in 

accordance with safety analysis report (SAR) commitments.

01.02 To determine whether the licensee's structural welding practices, specification, and 

procedures meet the requirements of codes committed to in the licensing basis and contract 

requirements.

01.03 To review a sample of records to determine whether they are prepared, evaluated, and 

maintained in accordance with applicable licensing basis commitments and/or QAP 

requirements.

01.04 To determine that welding practices, specifications, procedures, production equipment, 

and existing licensee quality control systems are adequate for the production of sound welds.

69020.A11-02 INSPECTION REQUIREMENTS

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related structural welding being performed at the 

site. Inspectors should also be familiar with the licensee’s Quality Assurance Program 

(QAP) and the basis for the QAP (NPUF licensees are expected to commit to the QAP 

requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for related instrumentation and control 

system work on-site at the time of the inspection.

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the safety-related structural welding on the 

site, but may expand the inspection if time allows, or if significant concerns with the 

licensee’s control of safety-related structural welding arise. Inspectors should collect 

licensee procedures, construction specifications, and work completion records in 

advance, if possible. If unable to review these documents in advance of the on-site 

inspection, then the licensee should be notified that these documents, and any other 

relevant documents, should be available when the inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.7 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.
Issue Date: 12/14/15 K-2 69020

02.02 Base Material and Filler Metal Compatibility for Welding 

a. Verify that base metals and welding filler materials combinations are as those listed in 

Table 4.1.1 of the AWS D1.1 Code, or other licensing basis and/or QAP commitment.

b. Evaluate base material/filler metal combinations other than those listed in Table 4.1.1, 

or other licensing basis and/or QAP commitment, to determine the suitability of 

application.

c. Verify that welding materials are clearly identified at all times and that the 

contractor/licensee has established adequate controls to assure proper dispersion and 

handling of welding materials.

d. Verify that the contractor/licensee has effective procedures or his practice adequately 

controls moisture pickup of low hydrogen electrodes. The maximum out of oven 

exposure time should conform to the requirements stated in Table 4.5.2 of the AWS 

Code, or other licensing basis and/or QAP commitment.

e. If the contractor/licensee uses a single system for welding material control, verify that 

this system is conservative and meets the requirements for the most restrictive 

application.

02.03 Welding Procedures

a. Verify that the contractor/licensee or fabricator has established procedures or 

instruction for preparation, qualification approval/certification, distribution and revision of 

welding procedure specifications (WPS).

b. If the contractor/licensee uses AWS prequalified welding procedures, verify that those 

procedures meet all requirements stated in the Table E1 of the AWS D1.1 Code, or 

other licensing basis and/or QAP commitment.

c. For welding procedures other than those being prequalified in accordance with the 

requirements stated in Appendix E of the AWS D1.1 Code, verify that the procedure 

qualifications meet the requirements of Section 5, Part B of the AWS Code, or other 

licensing basis and/or QAP commitment.

d. Review two welding procedures (WPS) from each welding process used in production 

welding and verify conformance with items b or c as applicable.

e. Verify that the procedures mentioned in d above has been qualified in accordance with 

Section 5 of the AWS Code, or other licensing basis and/or QAP commitment, and that 

the supporting procedure qualification records (PQR) are on file.

f. Review PQRs for the above procedures and verify that each PQR lists the essential 

variables for the specific welding process or processes covered and that the values or 

ranges of these variables are consistent with those permitted by the WPS and within 
Issue Date: 12/14/15 K-3 69020

the limits of Section 5 of the AWS Code, or other licensing basis and/or QAP 

commitment.

g. Verify that all mechanical tests required by Section 5 of the AWS Code, or other 

licensing basis and/or QAP commitment, (including notch toughness when applicable) 

have been completed and are properly documented in the PQR.

h. Verify that the PQR has been certified by the contractor/ licensee and that the 

mechanical test results meet or exceed the minimum AWS Code requirement, or other 

licensing basis and/or QAP commitment.

i. Verify that any changes or revisions of the WPS essential variables are supported by 

requalification of the original WPS or a new WPS.

j. Verify that any changes in the WPS nonessential variables are properly identified and 

documented either as revisions to the original WPS or a new WPS.

02.04 Welder Qualifications

a. Verify that the manufacturer has established procedures for qualification of welders and 

welding operators in accordance with Section 5, Parts C and D of the AWS Code, or 

other licensing basis and/or QAP commitment. These procedures should include 

adequate provisions to preclude falsification of welders and welding operator's 

qualifications.

b. If practical, sample welders taking the qualification tests and confirm by positive 

identification that the person welding the test weldment is indeed the person being 

qualified.

c. Verify that the manufacturer has a workable system for maintaining a continuous record 

of the qualification status of all welders and welding operators and that this system is 

effectively utilized and accurate.

d. Verify by review of a sample of qualification status records that welders and welding 

operators performing production welding have been and are currently qualified to weld 

under the respective procedures. 

02.05 Production Welding. 

Survey a sample of ongoing welding activities and select typical in-process operations 

representing different welding process procedures and joint configurations for detailed 

review. Perform the following verifications:

a. Verify that welding procedures, detailed drawings and instructions, if applicable, and 

weld data sheets are at the work station or readily available.
Issue Date: 12/14/15 K-4 69020

b. Verify that the WPS assignment is in accordance with the applicable AWS Code 

requirements, or other licensing basis and/or QAP commitments. This is accomplished 

by comparing the essential variables of the WPS to the production weld.

c. Verify that the welding technique and sequence requirements are specified.

d. Verify that the base metals, welding filler materials, fluxes, gases and backing materials 

are of the specified type and grade, have been properly inspected, tested, and identified 

and are traceable to test reports or certifications.

e. Verify that weld joint geometry is as specified and that surfaces to be welded have been 

prepared, cleaned, and inspected in accordance with applicable procedures of 

instructions.

f. Verify that parts to be welded are assembled and held in place within specified gap and 

alignment tolerances and verify that the alignment is within limits allowed by the AWS 

Code, or other licensing basis and/or QAP commitments.

g. Verify that gas purging, if specified, is used in accordance with the applicable procedure 

and that protection is provided to shield the welding operation from adverse 

environmental conditions.

h. Verify that preheat, if specified, is in accordance with applicable procedures 

requirements.

i. Verify that the technique of each welder is in accordance with the welding procedure.

j. Verify that welding electrodes are used only in the positions and with the electrical 

characteristics specified in the welding procedure.

k. Verify that shielding gas flow and composition is as specified in the WPS.

l. Verify that shielding gas flowmeters indicate the gas type for which they are applicable 

and have appropriate conversion factors if a different gas or gas mixture is used for 

work under review.

m. Verify that welding equipment, including power cables and gas used for automatic 

welding have been calibrated in accordance with applicable procedure requirements. n. 

Verify that interpass temperature is controlled in accordance with specified 

requirements.

o. Verify that interpass cleaning, grinding (especially starts and stops) and peening are 

conducted in accordance with applicable procedure.

p. Verify that backgouging, if applicable, is performed as specified.

q. Verify that temporary attachments, arc strikes and weld splatter are removed and 

inspected.
Issue Date: 12/14/15 K-5 69020

r. Verify by direct observation and/or record review that repairs are conducted in 

accordance with specified procedures.

s. Identify a sample of welders and welding operators involved in joint fit-up, welding and 

weld repair for qualification review per 02.03 above.

t. Verify that all production welding equipment is in such condition as to enable qualified 

welders to follow the production welding procedures and be able to duplicate the results 

obtained in the procedure qualification.

02.06 Preheat and Post Weld Heat Treatment

a. Verify that approved procedures are available for weld joint preheating when required 

by a welding procedure specification. These procedures should specify acceptable 

preheating methods and provide requirements for monitoring and recording preheat 

temperature before, during, and if specified, after welding until post weld stress relief.

b. Sample in-process preheating to verify that preheat control procedures are being 

following in production welding.

c. Verify that the preheat used in production welding is within the limits specified by the 

welding procedure, and in accordance with Table 4.2 of the AWS Code, or other 

licensing basis and/or QAP commitments.

d. Verify that approved procedures are available for the conduct of post weld heat 

treatment and that the fabricator has a system capable of meeting the heating and 

cooling rates, metal temperature, temperature uniformity and control limits specified in 

paragraph 4.4 of the AWS Code, or other licensing basis and/or QAP commitments.

e. If furnace heating is used, verify that furnace atmosphere is controlled as specified in 

approved procedure.

f. Review a sufficient sampling of PWHT operations (in-process and records) to assure 

that the stress relief heat treatment meets the requirements stated in Section 4 of the 

AWS Code, or other licensing basis and/or QAP commitments.

g. Verify that temperature control is exercised on in-process components which are 

required to be maintained at preheat or other specified temperature for extended time 

periods while waiting for further processing.

h. Examine cumulative stress-relief records for typical welds and verify that the total time 

and temperatures meet the AWS code requirements, or other licensing basis and/or 

QAP commitments.
Issue Date: 12/14/15 K-6 69020

02.07 Examination and Inspection of Welds

a. Select welds produced by different welding processes, procedures, and combination of 

procedures, and verify by visual examination that the following characteristics conform 

to the applicable AWS Code and fabricators welding procedure requirements:

1. Weld surface finish and appearance.

2. Transitions between welds of different diameters and wall thicknesses.

3. Weld reinforcement.

4. Shape and size of fillet and socket welds.

5. Joint configurations of structural supports.

6. Removal of temporary fabrication aids, arc strikes and weld spatter.

7. Finish-grinding or machining of weld surface.

8. Absence of surface defects including cracks, laps, lack of penetration, lack of fusion, 

porosity, slag, oxide film and under-cut exceeding prescribed limits.

b. Verify that approved procedures are available for the nondestructive examination of the 

weld when required by the AWS Code and/or contract requirements.

c. Verify that the fabricator's nondestructive procedures meet the AWS Code and/or 

contract requirements. 

d. Verify that the fabricator's welding inspectors are certified in accordance with the 

requirements of the AWS Code, or other licensing basis and/or QAP commitments.

e. Verify that the fabricator's inspection of welds meet the requirements stated in Section 6 

of the AWS Code, or other licensing basis and/or QAP commitments.

69020.A11-03 INSPECTION GUIDANCE

General Guidance. The IE inspector performing the inspection under this procedure should 

be thoroughly familiar with the requirements contained in AWS Structural Welding Code, or 

other licensing basis and/or QAP commitments The knowledge of welding, welding 

operations, their applications, limitations, and evaluations is essential for this inspection.

The intent of this procedure is to review of the overall welding activities taking place at the 

construction site on safety-related items. 

a. Preparation for Inspection. Prior to performing an inspection in accordance with the 

requirements of this procedure the IE inspector should review the following:

1. NRC requirements.

2. Licensees' commitments relative to Code editions; e.g., which Code edition applies 

to this site.

3. Applicable portions of the SAR.

4. Licensees' special requirements contained in their welding and purchasing 

specifications.
Issue Date: 12/14/15 K-7 69020

5. The number and scope of each welding contractor performing work at the site.

6. Licensees' programs and procedures pertaining to the subject.

7. Applicable portions of the QA Manual.

8. Licensees' commitments relative to welding and associated activities.

b. Review of Welding Specification and Procedures. The inspector may perform the 

following reviews:

1. Identify contractors or fabricators performing AWS welding at the site.

2 Identify which welding processes are used at the site and perform a review of all 

welding procedures used in production welding in accordance with the applicable 

paragraphs of section 02 of this procedure.

3. Determine whether the welding procedures being used meet all of the AWS Code 

and additional licensing basis requirements (if any). Establish whether the use of 

these procedures will result in the production of sound weld suitable for intended 

application.

c. Work Observations. The IE inspector may select for work observation a sample of 

welds comprising a combination of structures and AWS welding contractors associated 

with the work. The selected welds should also represent a cross section of the 

production activities in terms of welding processes used (SMA, TIG, etc.,) and materials 

to be welded (high strength steel, carbon steel, etc.). Considerations such as physical 

location, difficulties to weld and limited accessibility should be also incorporated in the 

sample selection. 

2. Record Review. The IE inspector may review relevant documentation related 

to randomly selected welds for each welding process used at the site (e.g., 

SMA, TIG, MIG, etc.). Same considerations as those stated in c above are 

applicable. It is preferable that the welds identified for record review are not the 

same welds identified for work observation. However, certain circumstances 

may necessitate the use of some of the welds sampled in c above (e.g., a 

contractor/licensee has completed only three welds to date and all three welds 

need to be included in the sample to provide meaningful statistical 

representation).

69020.A11-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 
Issue Date: 12/14/15 K-8 69020

69020.A11-05 REFERENCES

AWS Structural Welding Code.

Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam- and 

Radio-Waste Containing Components of Nuclear Power Plants

Regulatory Guide 1.29, Seismic Design Classification

Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, 

Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants

Regulatory Guide 1.50, Control of Pre-Heat Temperature for Welding of Low-Alloy Steel

Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination, and 

Testing Personnel

Regulatory Guide 1.71, Welder Qualification for Areas of Limited Accessibility Welding 

Handbook, Volume 1, Fundamentals of Welding, AWS Welding Inspection, AWS

END
Issue Date: 12/14/15 L-1 69020

APPENDIX L

INSPECTION OF NUCLEAR WELDING AT NON-POWER PRODUCTION AND UTILIZATION 

FACILITIES

69020.A12-01 INSPECTION OBJECTIVES

01.01 To determine whether the licensee's welding specification and procedures meet 

applicable ASME Code, regulatory, and contract requirements.

01.02 To determine through direct observation whether welding activities are performed in 

accordance with the ASME Code and safety analysis report (SAR) commitments.

01.03 To review a sample of records to determine whether they are prepared, evaluated and 

maintained in accordance with the ASME Code, applicable commitments and/or requirements.

01.04 To determine that welding specifications, procedures, production equipment and 

established licensee quality control systems are adequate for the production of sound welds.

69020.A12-02 INSPECTION REQUIREMENTS

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the safety-related nuclear welding being performed at the site. 

Inspectors should also be familiar with the licensee’s Quality Assurance Program (QAP) 

and the basis for the QAP (NPUF licensees are expected to commit to the QAP 

requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for related instrumentation and control 

system work on-site at the time of the inspection.

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the safety-related nuclear welding on the 

site, but may expand the inspection if time allows, or if significant concerns with the 

licensee’s control of safety-related nuclear welding arise. Inspectors should collect 

licensee procedures, construction specifications, and work completion records in 

advance, if possible. If unable to review these documents in advance of the on-site 

inspection, then the licensee should be notified that these documents, and any other 

relevant documents, should be available when the inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.7 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.
Issue Date: 12/14/15 L-2 69020

02.02 Base Material and Filler Metal Compatibility for Welding

a. Verify that base metal and welding filler material combinations are appropriate for the 

application.

b. Evaluate base material/filler metal combinations to determine the suitability of 

application.

c. Perform the following verifications related to control and handling of welding materials:

1. Verify that the contractor/licensee has established procedures and instructions for 

purchasing, receiving, storing, disbursing, and handling of welding materials 

including welding electrodes, filler material, consumable inserts, fluxes, and gases.

2. Review sufficient sampling of welding material purchasing and receiving records to 

verify that these operations are conducted in accordance with approved procedures 

or instructions.

3. Verify that welding material storage procedures, contain requirement for 

environmental (moisture) control, specify appropriate holding and baking 

temperatures and out-of-oven exposure time for each class of materials, and that 

actual practice follows these requirements.

4. Verify that there are effective procedures for limiting electrode moisture pickup and 

maintaining identification after the welding materials are issued to the welder and 

that these procedures are strictly enforced.

5. If the contractor/licensee uses a single system for welding material control, verify that 

this system is conservative and meets the requirements for the most restrictive 

application and personnel involved are knowledgeable of the system, including 

material designations.

6. Verify that welding materials are clearly identified at all times in accordance with 

approved procedures and that identification of acceptable material is retained 

throughout storage handling and use until the material is actually consumed in the 

process.

7. Verify that the method for disbursement of welding materials is effective and 

controlled in accordance with approved procedures and the unused welding 

materials are scrapped or recycled in accordance with special provisions which 

include maintaining identification and rebaking of coated electrodes when applicable.

8. Verify by examination of representative records or direct observation that ASME 

Code required tests are performed on each lot of covered, flux cored or bare 

electrodes, rod, or wire, for each heat of consumable inserts and for each 

combination or bare electrodes and dry blend of flux mix to be used for welding.
Issue Date: 12/14/15 L-3 69020

02.03 Welding Procedures

a. Verify that the contractor/licensee has established adequate procedures or instructions 

for preparation, qualification approval/certification, distribution and revision of welding 

procedure specifications (WPS).

b. Select welding procedures (WPS) from each welding process or combination of 

processes used for ASME welding applications and verify conformance with procedures 

referenced in a, above.

c. Verify that the WPSs (b above) define all essential variables, supplementary essential 

variables and nonessential variables in accordance with the applicable editions of 

Section III and IX of the ASME Code.

d. Verify that each of the above procedures has been qualified in accordance with Section 

III and IX of the ASME Code and that the supporting procedure qualification records

(PQRs) are on file.

e. Review PQRs for the above procedures and verify that each PQR lists the essential 

variables for the specific welding process or processes covered and that the values or 

ranges of these variables are consistent with those permitted by the WPS and are 

within the limits of Section IX of the ASME Code.

f. Verify that all mechanical tests required by Section III and IX of the ASME Code 

(including notch toughness when applicable) have been completed and are properly 

documented in the PQR.

g. Verify that the PQR has been certified by the contractor/licensee and that the 

mechanical test results meet or exceed the minimum ASME Code requirements.

h. Verify that in making procedure test plates for butt welds of heavy section materials with 

80,000 psi or higher tensile strength, consideration has been given to the effect of 

angular, lateral and end restraints of the weldment (ASME Section III-NX-4320).

i. Verify that any changes or revisions of the WPS essential variables are supported by 

requalification of the original WPS or a new WPS.

j. Verify that any changes in the WPS nonessential variables are properly identified and 

documented either as revisions to the original or a new WPS.

k. Verify that, whenever applicable, the WPSs comply or meet the intent of Regulatory 

Guides referenced in Section 03 of this procedure.

02.04 Welder Performance Qualification

a. Verify that the contractor/licensee has established procedures for qualification of 

welders and welding operators in accordance with Section III and IX of the ASME Code. 
Issue Date: 12/14/15 L-4 69020

These procedures should include adequate provisions to preclude falsification of 

welders and welding operator’s qualifications.

b. If practical, sample adequate number of welders taking the qualification tests and 

confirm by positive identification that the person welding the test weldment is indeed the 

person being qualified.

c. Verify that the contractor/licensee has a workable system for maintaining a continuous 

record of the qualification status of all welders and welding operators and that this 

system is effectively utilized and accurate.

d. Verify by review of the qualification status records that welders and welding operators 

performing production welding have been and are currently qualified to weld under the 

respective procedures.

02.05 Production Welding

a. Survey ongoing welding activities and select typical in-process operations representing 

different welding processes, procedures, and joint configurations for detailed review. 

Perform the following verifications:

1. Verify that work is conducted in accordance with a "traveler" or similar document 

which coordinates and sequences all operations, references procedures or 

instructions, establishes hold points, and provides for production and QC signoffs. 

This document should be available at the work station.

2. Verify that welding procedures, detailed drawings and instructions if applicable, and 

weld data sheets are at the work station or readily available.

3. Verify that the WPS assignment is in accordance with the applicable ASME Code 

requirements. This is accomplished by comparing the essential variables of the WPS 

with the production weld.

4. Verify that welding technique and sequence requirements are specified.

5. Verify that the base metals, welding filler materials, fluxes, gases, and backing 

materials are of the specified type and grade, have been properly inspected, tested, 

and identified and are traceable to test reports or certifications.

6. Verify that weld joint geometry is as specified and that surfaces to be welded have 

been prepared, cleaned, and inspected in accordance with applicable procedures or 

instructions.

7. Verify that parts to be welded are assembled and held in place within specified gap 

and alignment tolerances and verify that the alignment is within limits allowed by the 

ASME Code.
Issue Date: 12/14/15 L-5 69020

8. Verify that temporary attachments such as bridging bars or fit-up clips have been 

attached by qualified welders, in accordance with qualified WPS.

9. Verify that gas purging, if specified, is used in accordance with the applicable 

procedure and that protection is provided to shield the welding operation from 

adverse environmental conditions.

10. Verify that preheat, if specified, is in accordance with applicable procedures

requirements.

11. Verify that the technique of each welder is in accordance with the welding procedure.

12. Verify that welding electrodes are used only in the positions and with the electrical 

characteristics specified in the welding procedure.

13. Verify that shielding gas flow and composition is as specified in the WPS.

14. Verify that shielding gas flowmeters indicate the gas type for which they are 

applicable and have appropriate conversion factors if a different gas or gas mixture is 

used for work under review.

15. Verify that welding equipment, including power cables and gas lines, is in good 

condition and that ammeters and voltmeters used for automatic welding have been 

calibrated in accordance with applicable procedure requirements.

16. Verify that interpass temperature is controlled in accordance with specified 

requirements. The interpass temperature for welding austenitic stainless steels and 

high nickel alloys should not exceed 350 _F.

17. Verify that interpass cleaning, grinding (especially starts and stops) and peening are 

conducted in accordance with applicable procedure.

18. Verify that backgouging, if applicable, is performed as specified.

19. Verify that temporary attachments, arc strikes and weld splatter are removed and 

inspected in accordance with specified procedures.

20. Verify that the process control system (travelers) have provisions for weld repairs 

and that approved procedures or instructions are available which describe or 

reference acceptable methods of defect removal and weld repair.

21. Verify by direct observation and/or record review that repairs are conducted in 

accordance with specified procedures.

This verification should include:
Issue Date: 12/14/15 L-6 69020

(a) Review of weld repair consistent of mechanical removal of surface defects with 

no rewelding.

(b) Review of repair involving metal removal by chipping, grinding or machining 

followed by rewelding.

(c) Review of a repair involving metal removal by thermal cutting or gouging followed 

by rewelding.

22. Verify that any repairs to the base metal are properly documented in a special report 

as required by Section III of the ASME Code (NB 4132). Verify that any repairs of 

modifications to ASME Code-stamped components are properly documented in a 

special report as required by ASME Sections III and XI.

23. Identify all welders and welding operators observed during inspection of joint fit-up, 

welding and weld repair for qualification review per 02.03 above.

24. Verify, if applicable, that no peening has been done on the root and surface layer of 

the weld or base metal at the edges of the weld.

25. Verify that the contractor/licensee has a periodic preventive maintenance program 

for welding equipment used for welding safety-related materials.

02.06 Preheat and Post Weld Heat Treatment

a. Verify that approved procedures are available for weld joint preheating when required 

by a welding procedure specification. These procedures should specify acceptable 

preheating methods and provide requirements for monitoring and recording preheat 

temperature before, during and, if specified, after welding until post weld stress relief.

b. Sample sufficient number of in-process components to verify that preheat control 

procedures are being followed in production welding.

c. Verify that the preheat used in production welding is within the limits specified by the 

welding procedure.

d. Verify that approved procedures are available for the conduct of post weld heat 

treatment and that the fabricator has a system capable of meeting the heating and 

cooling rates, metal temperature, temperature uniformity and control limits specified in 

Section III of the ASME Code. The procedures should cover furnace as well as local 

heating if both methods are used in production.

e. If furnace heating is used, verify that furnace atmosphere is controlled as specified in 

approved procedure.

f. Review a sufficient sampling of PWHT operations (in-process and records) to assure 

that the following items are satisfied.
Issue Date: 12/14/15 L-7 69020

1. Verify that components are instrumented to provide time-temperature recordings for 

the duration of the entire heat treatment cycle (both furnace and local HT).

2. Verify that sufficient thermocouples are used to measure the anticipated hottest and 

coldest temperatures of the weld during holding at temperature and to measure 

temperature variation within any 15-foot interval of weld length during heating or 

cooling. This variation must not exceed 250 oF.

3. Verify that the PWHT temperature and holding time is specified, is adhered to and is 

consistent with ASME Code (NX-4600) requirements based on the material type and 

wall thickness.

4. Verify that the maximum initial furnace temperature, heat up and cool-down rates are 

specified, are adhered to and are consistent with the ASME Code (NX-4600) 

requirements.

g. Verify that procedures are available for conduct of intermediate or "non-code" stress 

relief of in-process components if such treatments are used in component fabrication.

h. Verify that temperature control is exercised on in-process components which are 

required to be maintained at pre-heat or other specified temperature for extended time 

periods while awaiting further processing.

i. Verify that measures are taken to avoid sensitization of austenitic stainless steel and 

high-nickel alloys during stress relief treatments. This generally involves provisions 

which preclude furnace stress-relieving of austenitic stainless steel components or parts 

and limit their exposure to sensitization temperature range (800-1500 oF).

j. Examine cumulative stress-relief records for typical component welds and verify that the 

total time at temperature does not exceed that permitted by Section III of the ASME 

Code based on the welding procedure qualification records.

02.07 Examination of Welds

a. Select welds produced by different welding processes, procedures, and combination of 

procedures, and verify by visual examination that the following characteristics conform 

to the applicable ASME Code and fabricators welding procedure requirements:

1. Weld surface finish and appearance. Include inside diameter of pipe welds when 

accessible.

2. Transitions between components of different diameters and wall thickness.

3. Weld reinforcement.

4. Shape and size of fillet and socket welds.
Issue Date: 12/14/15 L-8 69020

5. Joint configurations of permanent attachments and structural supports to clad 

components.

6. Removal of temporary attachments, arc strikes and weld spatter.

7. Finish-grinding or machining of weld surface – verify absence of wall thinning.

8. Absence of surface defects including cracks, laps, lack of penetration, lack of fusion, 

porosity, slag, oxide film and undercut exceeding prescribed limits.

b. Verify that approved procedures are available for the nondestructive examination of the 

weld when required by the ASME Code and/or contact requirements.

69020.A12-03 INSPECTION GUIDANCE

General Guidance. The inspector performing the inspection under this procedure should be 

thoroughly familiar with the requirements contained in Sections III and IX of the ASME 

Code. The knowledge of welding and techniques, their applications, limitations and 

evaluations, is essential for this inspection. The intent of this procedure is to achieve an indepth review of the overall welding activities taking place at the construction site.

a. Preparation for Inspection. Prior to performing an inspection in accordance with the 

requirements of this procedure, the inspector should review the following:

1. NRC requirements.

2. Licensees' commitments relative to applicable Codes and standards; e.g., which 

Addenda of the ASME Code applies to this site.

3. Applicable portions of the SAR.

4. Licensees' programs and procedures pertaining to the subject.

5. Applicable portions of the QA Manual.

6. Licensees' commitments relative to welding and associated activities.

b. Review of Welding Specification and Procedures. The inspector may perform the 

following reviews:

1. Identify contractors or fabricators performing welding at the site.

2. Identify which welding processes are used at the site and perform a review of all 

welding procedures used in production welding in accordance with the applicable 

paragraphs of Section 02 of this procedure.

3. Determine whether the welding procedures being used meet all of the ASME Code 

and additional contract requirements (if any). Establish whether the use of these 

procedures will result in the production of sound welds suitable for the intended 

application.
Issue Date: 12/14/15 L-9 69020

c. Work Observations. The inspector may select for work observation a sample of welds 

composed of a combination of systems and welding contractors associated with the 

work. The selected welds should also represent a good cross section of the production 

activities in terms of welding processes used (SMA, TIG, etc.) and materials to be 

welded (stainless steel, carbon steel, etc.). Considerations such as physical location, 

difficulties to weld and limited accessibility should be also incorporated in the sample 

selection. 

d. Record Review. The inspector may review relevant documentation related to a sample 

of randomly selected welds for each ASME subsection (e.g., NB, NC, ND, etc. For 

subsection NG, "core support structures", the sample size can be reduced at the 

discretion of the inspector). Same considerations as those stated in c above are 

applicable. It is preferable that the welds identified for record review are not the same 

welds identified for work observation.

69020.A12-04 RESOURCE ESTIMATE

This inspection procedure is expected to take 32 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A12-05 REFERENCES

ASME Boiler and Pressure Vessel Code Section III and IX

Regulatory Guide 1.31, Control of Ferrite Content in Stainless Steel Weld Metal.

Regulatory Guide 1.44, Control of the Use of Sensitized Stainless Steel

Regulatory Guide 1.50, Control of Preheat Temperature for Welding of Low-Alloy Steel

Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination, and 

Testing Personnel

Regulatory Guide 1.71, Welder Qualification for Areas of Limited Accessibility

Regulatory Guide 1.85, Materials Code Case Acceptability ASME Section III Division 1

Regulatory Guide 1.88, Collection, Storage and Maintenance of Nuclear Power Plant Quality 

Assurance Records

END
Issue Date: 12/14/15 M-1 69020

APPENDIX M

INSPECTION OF FIRE PROTECTION SYSTEMS UNDER CONSTRUCTION AT 

RADIOISOTOPE PRODUCTION FACILITIES

69020.A13-01 INSPECTION OBJECTIVES

01.01 To verify that the installation or modification of fire protection systems are being 

accomplished in accordance with applicable codes, standards, and licensee 

commitments.

69020.A13-02 INSPECTION REQUIREMENTS

02.01 Preparation: Inspectors should review the facility description in the safety analysis report

(SAR) and be familiar with the fire protection system work being performed at the site. 

Inspectors should also be familiar with the licensee’s Quality Assurance Program (QAP) 

and the basis for the QAP (NPUF licensees are expected to commit to the QAP 

requirements of ANS/ANSI 15.8, “Quality Assurance Program Requirements for 

Research Reactors”). It is not the objective of this IP to verify the adequacy of the 

licensee’s QAP, but inspectors should be prepared to identify potential weaknesses in the 

licensee’s QAP for future inspections. Inspectors should complete this appendix by 

inspecting the attributes listed in this appendix for related instrumentation and control 

system work on-site at the time of the inspection.

Inspectors should contact the licensee prior to the on-site inspection to determine which 

work activities are to be inspected. Observation of in-progress work is desirable but not 

required. If necessary, inspectors may select completed work activities for inspection. 

Inspectors should not attempt to inspect all of the fire protection system work on the site, 

but may expand the inspection if time allows, or if significant concerns with the licensee’s 

control of fire protection system arise. Inspectors should collect licensee procedures, 

construction specifications, and work completion records in advance, if possible. If 

unable to review these documents in advance of the on-site inspection, then the licensee 

should be notified that these documents, and any other relevant documents, should be 

available when the inspector(s) arrives at the site.

Inspectors should review the areas listed in 02.02 through 02.4 to the extent practical, 

and may use their judgment in determining which areas to concentrate on, if time is 

limited. However, inspectors should gain an understanding of the licensee’s program to 

the extent necessary to determine if the licensee conforms to regulatory requirements.

02.02 Review of Procedures. Verify that specifications, drawings, work instructions and IPs 

have been established that will assure the technical adequacy of the following activities 

pertaining to fire protection systems. Verify that these documents comply with licensee 

commitments.
Issue Date: 12/14/15 M-2 69020

a. Procurement. Review the design and purchase specifications and drawings to assure 

that specific technical requirements and commitments contained in the safety analysis 

report (SAR) have been translated into vendor purchase documents. Verify the 

following:

1. Fire protection equipment associated with the fire-suppression systems specified in 

the SAR (as noted below) have been identified and specified in procurement 

documents:

(a) Water-based suppression systems (pre-action, wet-pipe, dry-pipe, waterspray, and deluge systems);

(b) Carbon-dioxide systems;

(c) Standpipe systems; and/or

(d) Portable fire extinguishers.

2. Materials, such as pipes, pipe joints, mains, anchors, valves, and clamps meet 

specifications.

3. Fire pump(s) and associated controls and wiring conform to National Fire Protection 

Association (NFPA) 20 standards, and/or other licensing basis commitments.

4. Appropriate design and fabrication codes and standards [NFPA; American Water 

Works Association (AWWA); American National Standards Institute; American 

Society for Mechanical Engineers] requirements have been identified or specified in 

procurement documents.

5. Critical dimensions are specified. (Size and location of water supplies, size and 

location of all piping, and the depth to which they are to be buried, etc.)

6. Fire hydrants comply with NFPA or AWWA criteria, and/or other licensing basis 

commitments.

b. Receipt Inspection. Verify that receipt inspection instructions require: (a) inspections 

for damage; (b) conformance to purchase specifications (including any special 

requirements); (c) proper identification and tagging; and (d) receipt of proper 

supplier/vendor documentation.

c. Storage. Verify that site storage procedures provide for proper identification, handling, 

cleanliness preservation, protection from adverse weather, and other physical damage 

and QC.

d. Installation. Verify that the fire suppression systems, as specified in the licensing basis,

have been properly installed and that installation work procedures provide adequate 

instructions for the following (if applicable):
Issue Date: 12/14/15 M-3 69020

1. Installation work is to be done by fully experienced responsible persons.

2. There are procedural controls of rigging and handling activities, to prevent damage to 

pipes, fittings, valves, and other equipment.

3. Proper locations of valves, hydrants, mains, etc., are clearly identified.

4. Fire-pump installation complies with NFPA-20. Separation and protection are in 

accordance with SAR commitments and Regulatory Guide 3.16, and/or other 

licensing basis commitments.

5. Dimensional checks are specified for levelness, alignment, clearances, etc.

6. Proper restraints are provided for all tees, plugs, caps, bends, and hydrant branches.

7. Installation of hydrants is in compliance with NFPA 24, and/or other licensing basis 

commitments.

8. Proper backfill methods are specified.

9. Water-tank installation is in accordance with NFPA 22 standards, and/or other 

licensing basis commitments.

10. Proper flushing and hydrostatic testing of the fire-loop water piping are specified.

02.03 Observation of Work and Work Activities.

a. Visually examine a sample of pipes, fittings, valves, and hydrants before installation. 

Plain ends shall be inspected with special attention, since these ends are most 

susceptible to damage. Verify that commitments in the licensing basis are being met in 

the following areas:

1. Cleanliness;

2. Configuration of loop and appurtenances, relative to drawings;

3. Obvious defects, such as cracks and dents, are identified and evaluated for 

suitability for use; and

4. There are provisions for proper identification of components.

b. Observe work activities or completed work during the installation of the fire loop (if 

applicable). Verify the following items:

1. Components are installed with proper location and orientation.

2. All specified anchors are in proper places.
Issue Date: 12/14/15 M-4 69020

3. No apparent damage was done to fire-loop components during installation.

4. Ongoing work is being performed in accordance with approved procedures.

5. There is adequate QC inspection coverage.

c. If possible, observe portions of construction-completion testing (hydrostatic testing and 

fire-pump performance testing). If testing cannot be observed, examine records of 

completed tests.

02.04 Review of Records. Verify that a sampling of the following QA records indicate that 

applicable commitments have been met:

a. Receiving inspection records. 

b. Shop fabrication records.

c. Installation records. 

1. Leveling, alignment, clearances;

2. Anchoring installation;

3. Backfill and soil composition;

4. Cleanliness;

5. Flushing;

6. Hydrostatic test; and

7. Fire pump full load operational and automatic starting tests.

d. Nonconformance Reports, if any; and

e. QA Audits.

69020.A13-03 INSPECTION GUIDANCE

03.01 Definition. A “Fire Loop” is a main water-piping loop for fire protection, usually feeding 

hydrants, standpipes, and other fire-protection systems and components. Fire loops are 

provided to permit feeding hydrants and other components and systems, from at least 

two directions, for redundancy.
Issue Date: 12/14/15 M-5 69020

03.02 Applicable portions of the SAR should be reviewed to determine licensee commitments 

relative to construction and inspection requirements, before review in this area. 

Inspectors should determine which versions of the industry codes and standards the 

licensee has committed to in the SAR or other docketed correspondence. They should 

obtain copies of those documents and become familiar with those industry codes and 

standards during inspection preparation. 

69020.A13-04 RESOURCE ESTIMATES

This inspection procedure is expected to take 24 hours of on-site inspection. Inspection 

preparation, including SAR review, review of applicable codes and standards, and licensee 

quality assurance procedure review, is not included in this estimate. 

69020.A13-05 REFERENCES

National Fire Protection Association, (NFPA), NFPA 13, 14, 22, and 25, and/or other 

applicable referenced NFPA standards, American Water Works Association, American 

National Standards Institute and American Society for Testing and Materials codes.

END
Issue Date: 12/14/15 Att1-1 69020

Attachment 1 – Revision History for IP 69020

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

(Pre-Decisional, NonPublic)

N/A ML15083A168

12/14/15

CN 15-029

Initial issuance to provide guidance for the 

safety-related items and services during 

construction of non-power and utilization 

facilities.

Briefing for 

inspectors, prior to 

performing inspection 

covered by this IP. 

ML15189A134