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NRC INSPECTION MANUAL LPEB

INSPECTION PROCEDURE 72701

MODIFICATION TESTING

PROGRAM APPLICABILITY: 2515

72701-01 INSPECTION OBJECTIVE

The objective of this procedure is to ascertain whether the

licensee's modification testing program for new or modified

structures, systems, and components involving a licensing amendment

is in conformance with the license amendment, detailed design

documentation, regulatory requirements, Technical Specifications

(TS), and industry-approved codes and standards.

72701-02 INSPECTION REQUIREMENTS

02.01 Construction Testing

a. Review the modification work package to determine whether the

new structures, systems, and components were properly prepared

for preoperational testing. These preparations should include

the following as appropriate:

1. Preservation (e.g., painting).

2. Wiring continuity and separation checks.

3. Cleaning and flushing.

4. Calibration of instrumentation and setpoints.

5. Hydrostatic pressure testing of fluid systems.

6. Component functional tests including:

(a) Trip testing of breakers.

(b) Freedom of movement checks for mechanical components.

(c) Rotational directional testing of prime movers.

7. Structural concrete and structural steel tests.
72701 - 2 - Issue Date: 04/14/92

8. Greasing and lubrication.
1 The steps of Section 02.02 are to be conducted twice, as appropriate (for both the

preoperational phase and startup phase of post-modification testing). The inspector may

additionally conduct the more extensive reviews of IP 70300 (Preoperational Test Procedure

Review) and IP 72300 (Startup Test Procedure Review) as determined necessary.

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9. Installation of packing and filtering materials.

10. Connection of support systems.

11. Reservoir priming, filling, and venting.

12. Adjustment of limit switches, interlocks, and stops.

13. Preventive maintenance (depending on the elapsed time

between construction and commencement of preoperational

testing).

b. Verify that the licensee's review and evaluation of completed

construction phase test procedures addressed whether test

results were within previously established acceptance

criteria, that test deviations were resolved, and that

retesting was accomplished as appropriate.

02.02 Preoperational and Startup Testing1

a. Verify that testing was conducted under procedures which

possessed the following appropriately detailed features:

1. Scope and objectives

2. Limitations

3. Precautions

4. Prerequisites

5. References

6. Acceptance criteria

7. System lineups and tag outs

8. Checkoff lists that include provisions for:

(a) Recording the completion of procedural steps,

observed of parameters, and observed deficiencies.

(b) Identifying the personnel conducting the test

procedure and performing the individual steps.

(c) Recording Quality Control (QC) verification of

critical step completion or important parameter

observation by independent QC inspectors.

(d) Recording the completion of system restoration.
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b. Verify that pre-test training was conducted to ensure proper

test conduct and proper operation of new or modified

equipment.

c. Verify that test procedures and changes thereto were reviewed

and approved in accordance with Technical Specifications and

the licensee's administrative procedures.

d. Verify that the licensee's review and evaluation of completed

test procedures addressed whether test results met previously

established acceptance criteria, and that test deviations were

resolved and required retesting accomplished prior to the next

testing phase or release for operation.

e. Review quality assurance records to verify that the test

performance records received an independent QA audit.

f. Verify that the testing criteria and results establish that

the levels of performance of new structures, systems, and

components were as described in the license amendment

application and detailed design documentation (normally

generated subsequent to the approval of the license amendment

application).

72701-03 INSPECTION GUIDANCE

General Guidance

a. Modification Categories. Modifications addressed in this

inspection procedure will fall into one of two categories (the

inspector should ensure that the prescribed testing is

consistent with the category of modification):

1. Small Modifications. Small modifications are those

changes made to existing structures, systems, and

components that are within the capability of the onsite

operating organization and that require only those

inspections and performance tests typically conducted

during routine maintenance and surveillance.

2. Major Modifications. Major modifications are major

structural, system, and component repairs or

replacements, or the installation of new systems. These

modifications in general will require the same type of

inspections and performance testing as is applied during

original plant construction.

b. Modification Phases. This inspection procedure addresses the

licensee's program for implementing three phases of plant

modification testing:

1. Construction Testing. Construction testing includes

preliminary tests, inspections, and preparation

activities.
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2. Preoperational Testing. Preoperational testing is

conducted to demonstrate the capability of structures,

systems, and components to meet performance requirements

of design criteria. Preoperational testing includes:

(a) Instrumentation, control system, flow rate,

interlock, alarm, equipment protection devices,

support system adequacy, structural support, and

vibration damping tests.

(b) Cold functional tests, such as heat runs or the

simultaneous operation of interfacing equipment.

(c) Hot functional tests at PWRs where pump flow heating

is used to simulate plant operating conditions at

elevated operating temperatures.

3. Startup Testing. Startup testing is conducted with the

reactor critical "behind the stops" or at appreciable

neutron power to confirm design bases and to demonstrate,

to the degree practical, that integrated systems will

operate in accordance with structure, system, and

component design criteria. Startup testing demonstrates

that the plant, as modified, is capable of responding to

anticipated transients and postulated accidents as

specified in the Safety Analysis Report.

Specific Guidance

03.01 No specific guidance.

03.02.a No specific guidance.

03.02.b No specific guidance.

03.02.c Test procedure descriptions for the specific phases of

modifications can be found in the ANSI standards referenced in

72701-04 (below). A well written modification testing procedure

would include:

1. A description of necessary communication equipment.

2. Reference to supporting documentation such as the license

amendment application, drawings, TS applicable

industry-approved codes and standards, and equipment

operating procedures necessary during the conduct of the

test.

3. The origin of acceptance criteria.

4. The means by which acceptable performance is to be

established.

5. The location, arrangement, restoration conditions, and

retest requirements for bypass lines, spool pieces, blank

flanges, disconnected or removed interlocks or stops, lifted
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leads, removed fuses, temporary strainers, and temporary

setpoints.

6. Hazards to personnel, equipment, and the plant.

03.02.d-f No specific guidance.

72701-04 REFERENCES

10 CFR 50, Appendix B, Criterion XI, "Test Control."

Regulatory Guide 1.68, Rev. 2, "Initial Test Programs for

Water-Cooled Nuclear Power Plants," August 1978.

ANSI N18.7-1976/ANS 3.2, "Administrative Controls and Quality

Assurance for the Operational Phase of Nuclear Power Plants."

ANSI N45.2.4-1972, "Installation, Inspection, and Testing

Requirements for Instrumentation and Electrical Equipment During

Construction of Nuclear Power Generating Stations."

ANSI N45.2.5-1974, "Supplementary Quality Assurance Requirements for

Installation, Inspection, and Testing of Structural Concrete and

Structural Steel During the Construction Phase of Nuclear Power

Plants."

ANSI N45.2.8-1975, "Supplementary Quality Assurance Requirements for

Installation, Inspection, and Testing of Mechanical Equipment and

Systems for the Construction Phase of Nuclear Power Plants."

END