**NRC INSPECTION MANUAL**	VPO

	INSPECTION PROCEDURE 70367

PART 52, INSPECTION OF PREOPERATIONAL TEST PROGRAM

PROGRAM APPLICABILITY:  IMC 2504 Appendix A

7036701	INSPECTION OBJECTIVES

This inspection guidance is to confirm that the licensee's administrative controls over preoperational testing have been developed in accordance with Final Safety Analysis Report (FSAR) commitments and regulatory requirements.

7036702	INSPECTION REQUIREMENTS

If this inspection has been completed for the first unit at a multi-unit construction site, then inspection of a subsequent unit may not require the same level of inspection as that conducted for the first unit.  Inspectors shall focus on program differences developed and employed since completion of the program inspection for the first unit.

02.01	Test Program

a.	Verify that the preoperational testing program (which is part of the overall testing and startup program) for the site is specified by a formally reviewed and approved administrative control manual containing administrative controls for the conduct of preoperational testing.  Such a manual may be referred to as the startup manual or equivalent title.

b.	Verify that the licensee has prepared a description of the preoperational test program.  General areas of testing should be identified and responsibilities should be assigned for the following:

1.	Flushing and cleaning of nuclear steam supply system (NSSS) and auxiliary systems, and components.

2.	Hydrostatic tests of piping, vessels, and systems designed to contain pressurized or radioactive fluids.

3.	Instrument calibration.

4.	System turnover from the constructor.

5.	Functional demonstration of equipment in all modes throughout its operating range, including applicable flow tests.

6.	Electrical, mechanical, and instrument and control testing.

c.	Verify that the licensee's test program includes requirements for testing consistent with FSAR commitments:

1.	Tests to be performed have been identified and sequenced.

2.	For each of the identified tests, the following information (test abstract) should have been identified:

(a) Scope of the test and test objectives.

(b) Necessary prerequisites.

(c) Test methods.

(d) Related significant parameters & plant performance characteristics.

(e) Acceptance criteria.

d.	Verify by review of the site administrative control manual for preoperational test program that the licensee has specified the format and content of preoperational test procedures sufficient to satisfy the procedure review guidance contained in IP 70702, “Part 52, Inspection of Preoperational Test Performance.”

02.02	Test Organization

a. Verify that the method and responsibility for appointing key personnel in the test program are formally specified in writing.

b. Verify that the lines of authority and responsibilities of test personnel are formally specified in writing.

c. Where interfaces exist between organizations involved in the test program, verify that organizational responsibilities are clearly established in writing.

d. Verify that the required responsibilities, qualifications, and training of management and staff (including the NSSS vendor, architect-engineer, and other major contractors, subcontractors, and vendors, as appropriate), who will develop preoperational test procedures (including operating, and other procedures used in the test program) and will conduct the preoperational tests are formally specified in writing.  

1. Ensure the following areas of the test program are included:

(a) Test procedure preparation.

(b) Test procedure approval.

(c) Test performance and documentation.

(d) Test results review and approval.

2. Verify that the required training includes the following:

(a) Administrative controls for testing.

(b) QA/QC for testing.

(c) Technical objectives.

02.03	Test Program Administration

a.	Verify that formal methods have been established for the test organization to receive (from construction or other organizations) the jurisdiction over systems, components, and instrumentation before beginning to test those items.

b.	Verify that formal administrative measures have been established for jurisdictional control of system, component, or instrumentation status before, during, and subsequent to testing.  Administrative measures should provide for:

1.	Control of system status before testing.

2.	Return of systems components or instrumentation to construction forces (if necessary to support modifications or repairs).

3.	Control of system status subsequent to testing, including measures necessary to prevent invalidation of test results.

c.	Verify that formal administrative measures have been established governing the conduct of testing including:

1. Method for verifying a test procedure is current before its use.

2. Consideration of the effect of testing on other nuclear facilities (units, spent fuel, new fuel, etc.) at the same site.

3. Requirements for conducting pretest briefings which should include discussion of the risk to personnel and equipment, possible malfunctions/failure modes including consequences and contingencies, Operating Experience applicable to the testing performed, and criteria to abort the test.

4. Methods to ensure personnel involved in the conduct of the test are knowledgeable of the test procedure.

5. Requirements for procedure use (procedure in hand or other acceptable method, performance of steps out of sequence allowance, procedure compliance, etc.).

6. Methods to change (both major and minor) a test procedure during the conduct of testing.

7. Criteria for termination or interruption of a test and continuation of an interrupted test.

8. Methods to coordinate the conduct of testing including test (shift) turnover requirements for continuity, communication methods to be used, and clear identification of the test director.

9. Methods to document significant events, unusual conditions, or interruptions to testing.

10. Methods for identifying deficiencies, documenting their resolutions, and documenting retesting.

11. Method for providing the current test procedure and markedup drawings showing current modification status to the operators before test commencement.

d.	Verify that formal methods have been established to control scheduling of test activities.

e.	Verify that a formal program for evaluation of test results has been established.  The program should provide for the following:

1.	Test data is properly verified and compared to test results in a qualitative, quantitative, meaningful and understandable form.

2.	Test results are checked against design and compared with previously determined performance standards, limits or acceptance criteria.

3.	Deficiencies are clearly identified, documented, and appropriate corrective action has been proposed, reviewed, and completed.

4.	After corrective actions or modifications have been completed, tests or portions of a test have been rerun as necessary to ensure that tests on the asbuilt system are adequate and meet standards, limits or acceptance criteria.

5.	Test result evaluations were reviewed and formally approved by appropriate licensee personnel and/or contractor personnel, including the person(s) responsible for approving the original test procedures.

02.04	Document Control

a.	Test Procedures

1.	Verify that formal administrative measures have been established which control the test procedure processes for review, approval, and issuance. 

2.	Verify that formal administrative measures have been established which control revision of approved procedures.  The controls should specify:

70367	- 14 -	Issue Date:  08/??/13

Issue Date:  10/20/20	1	70367

(a)	Review by same persons and/or groups as the original procedure.

(b)	Approval by same persons and/or groups as the original procedure.

(c)	Issuance of revisions and control of obsolete procedures.

(d)	Screen changes to test procedures to determine if a change to FSAR Section 14.2 is needed.  For changes to tests in FSAR Section 14.2, verify that the inspection guidance in Section 02.05.a.3 of this procedure is followed.

3.	If operating procedures, surveillance procedures, etc., are to be used during preoperational testing, administrative controls for the preoperational test program procedures must ensure that they receive the same reviews and approvals required for preoperational test procedures.

4.	Verify that responsibilities have been assigned in writing to ensure that the procedure controls identified above will be implemented.

b.	Engineering Drawings and Vendors' Manuals

1. Verify that administrative controls have been established which require that current approved drawings (including P&IDs), and equipment vendor technical manuals will be provided to the plant site in a timely manner during this test program.

2.	Verify that master indexes are available for drawings and manuals which indicate their current revision numbers.

3.	Verify that a mechanism exists which ensures that affected test procedures will be updated when manual or drawing revisions occur.

02.05	Design Changes and Modifications

a.	Design Change Control

1.	Determine that a formal method has been established for initiating, reviewing, and approving requests for design changes and modifications to equipment that has been turned over to the test group for preoperational testing.

2.	Verify that the review process, including assignment of responsibility, provides for ensuring that all proposed plant changes are reviewed for potential FSAR impact.

3.	When the review process above identifies the need for a change to the FSAR and/or proposed technical specifications, verify that procedures and responsibilities are established to ensure that the changes will be made in accordance with the requirements in Title 10 of the *Code of Federal Regulations* (10 CFR) 52.98 and the applicable Part 52 Appendix for the certified design 

	being constructed for COLs.  See IP 35007, “Quality Assurance Program Implementation During Construction and Pre-Construction Activities,” for additional information on Tier 1, Tier 2* and Tier 2 changes requiring prior NRC approval for departures or changes to the FSAR. 

4.	Determine that controls have been established to ensure that design changes will be subjected to measures commensurate with those applied to the original design.

5.	Verify that a formal method has been established to bring proposed or implemented design changes to the attention of the test group for incorporation into the test program.

b.	Temporary Modifications, Jumpers, and Bypasses

1. Verify that written administrative controls have been established for controlling temporary modifications, jumpers, and bypasses.

2. Verify that the review process, including assignment of responsibility, provides for ensuring that all proposed temporary modifications, jumpers, and bypasses are reviewed for potential FSAR impact.

3. When the review process above identifies the need for a change to the FSAR, verify that procedures and responsibilities are established to ensure that the changes will be made in accordance with the requirements in 10 CFR 52.98 and the applicable Part 52 Appendix for the certified design being constructed for COLs.  See IP 35007 for additional information on Tier 1, Tier 2* and Tier 2 changes requiring prior NRC approval for departures or changes to the FSAR. 

4. Verify that the controls require that a formal log be maintained of the status of jumpers, lifted leads, control equipment, temporary trip points, etc.

5. Verify that responsibility is assigned for maintaining the log.

6. Verify that installed jumpers or lifted leads will be readily identifiable by their physical appearance.

7. Verify that controls are established to account for installation and removal of spool pieces, strainers, blank flanges, and valve internals where testing requires modification to fluid systems.

8. Verify that responsibility is assigned for determining when independent verification is required following installation or removal of temporary jumpers, lifted leads, temporary bypasses, or fluid system modifications.

9. Verify that responsibility is assigned for determining when functional testing of equipment is required following installation or removal of temporary jumpers, lifted leads, or fluid system modifications.

02.06	Plant Maintenance/Preventive Maintenance During Preoperational Testing

a. Plant Maintenance

Verify that the following items have been included in the administrative procedures in effect during preoperational testing:

1. Plant maintenance shall be performed in accordance with defined administrative controls.

2. Methods have been established for initiating, reviewing, approving, and scheduling maintenance.

3. Methods have been established for controlling replacement materials and parts that are designated for use in safetyrelated maintenance activities.

4. Controls have been established which require that only qualified personnel will perform maintenance activities.

5.	Maintenance administrative controls have been established which include the following:

(a)	Criteria for determining when maintenance procedures will be provided.

(b)	Method for preparing maintenance procedures.

(c)	Requirements for reviewing and approving maintenance procedures.

(d)	Methods of determining when training of personnel in the use of maintenance procedures is required.

(e)	A formal method to ensure that appropriate approvals will be obtained before performing any maintenance activity.

(f)	Inspection of maintenance work including final inspection of a completed task.

(g)	Testing of structures, systems, or components, following maintenance to reestablish the validity of preoperational tests.

(h)	Control of test and measurement equipment utilized in maintenance activities.

b. Preventive Maintenance Program

Verify that controls for preventive maintenance and equipment protection during and following preoperational testing have been established including:

1.	Periodic surveillance as required.

2.	Implementation of periodic maintenance and calibration programs.

3.	Protection from environmental extremes.

4.	Maintenance of cleanliness.

c. Maintenance Records

Verify that administrative controls have been established which require preparation and retention of maintenance records.

02.07	Equipment Protection and Cleanliness

a. Verify that a formal program for housekeeping activities during preoperational testing has been established.  The program should include provisions for:

1. Protection of equipment and control of personnel access to prevent damage from adjacent construction activities. 

2. Implementation of cleanliness zones, keyed to the progress of construction and testing.

3.	Control of facilities and equipment including cleanliness, environment, and fire protection/prevention.

4.	Periodic inspection to ensure the adequacy of housekeeping.

b.	Verify that responsibilities have been assigned in writing to ensure that the control methods identified above will be implemented.

c.	Verify that a program for maintaining the appropriate degree of cleanliness of nuclear plant components and piping during preoperational testing has been established.

d.	Verify that water chemistry controls have been established for fluid system undergoing preoperational testing, including:

1.	Water quality requirements.

2.	Layup of systems and components.

3.	Sampling requirements.

4.	Procedures to be followed for "out-of-specification" conditions.

02.08	Test and Measurement Equipment 

Verify by review of administrative procedures that controls have been established for special test equipment and all instrumentation used to provide data to show an acceptance criterion has been met or to ensure significant limitations are not exceeded that include:

a. A listing of controlled test equipment, the calibration requirements, and the calibration history.

b. Controls for storage and issuance to preclude use of test equipment which has not been calibrated within the specified interval.

c. Requirements for recording test equipment identity and calibration date in test procedures to permit retest if equipment is subsequently found out of calibration.

d. Controls for ensuring that installed instrumentation has been calibrated before being used to provide data to show an acceptance criterion has been met.

e. Requirements for actions to be taken when measuring and test equipment (M&TE) or reference standards are found out of calibration, lost, or stolen, including a documented evaluation of the validity of previous tests.

7036703	INSPECTION GUIDANCE

03.01	Test Program

a. No additional guidance

b.	10 CFR 50.34 (b)(6)(iii) and 10 CFR 52.79 (a)(28) require a description of the preoperational test program in the FSAR.  10 CFR 50.34(h), 10 CFR 52.47 (a)(9) and 10 CFR 52.79 (a)(28) require the licensee to evaluate the facility against the requirements in NUREG-0800, “Standard Review Plan (SRP).”  SRP Section 14.2 addresses the preoperational test program in the FSAR and references Regulatory Guide (RG) 1.68, “Initial Test Programs for Water-Cooled Nuclear Power Plants.”  FSAR Section 14.2 should document facility commitments to the Initial Test Program. The guidance in RG 1.68 should be interpreted as one acceptable method of meeting the regulations in 10 CFR Part 50 and 10 CFR Part 52.

c.	The licensee should be able to demonstrate that the planned test program is consistent with FSAR commitments and RG 1.68.  If it does not conform to FSAR commitments the licensee must change the FSAR or bring the test program into conformance.  Omissions, exceptions, or proposed simulations in the test program that do not conform to RG 1.68 should be justified or brought to the attention of NRC for evaluation and resolution.  For each identified test, the objectives, major test steps, necessary prerequisites, and acceptance criteria should be identified so that the intent of the specified testing is clearly understood.  This information should be included in the FSAR and referenced in appropriate test program documents.

Issue Date:  10/20/20	1	70367

d.	RG 1.68, Appendix C provides guidance for the preparation of preoperational testing procedures.  Chapter 14 of the FSAR should also describe the preparation of these procedures.  Test program administrative procedures controlling preparation of test procedures should be consistent with this guidance and FSAR commitments.

03.02	Test Organization

Chapter 14 of the FSAR will normally specify the organizational requirements necessary to support the preoperational test program.  Qualifications and resumes of key personnel may be included.  The licensee's administrative documents should identify specific qualifications and responsibilities of key personnel in the test program.  Qualification requirements may be specified by reference to FSAR commitments.  Where contractor/vendor personnel are participating in the test program, their responsibilities, qualifications and training should be specified.  Interfaces and boundaries should be defined between the licensee's operations group, construction forces, AE and vendor personnel, and the startup organization.  Some facilities use the assistance of various outside organizations to support preoperational testing; these working relationships should be defined in administrative procedures.

a-c.	No additional guidance

d. Chapter 14 of the FSAR describes the Test Program and should state the required training or indoctrination of those persons involved in the test program.

03.03	Test Program Administration

a. No additional guidance.

b. Methods for turnover control should include measures for partial as well as complete turnover of a system or component.  Where the licensee's operations and test organizations are separate, jurisdictional control upon turnover should be specified.  Contents of the documented "turnover package" should be specified, and should include equipment deficiencies and remaining construction work items.

c. Criterion XIV of Appendix B to 10 CFR Part 50 requires the licensee to establish controls to indicate the status of tests performed and to identify items which have passed required tests.  Administrative procedures should require the use of logs, markedup drawings, and tags on systems or components to implement these controls.

1-2.	No additional guidance.

3-4.	Methods to ensure personnel are knowledgeable may include pretest briefings and signoff sheets.

5.	No additional guidance.

6.	Minor changes, which do not affect intent of the test procedure or acceptance criteria, may be made "on the spot" by obtaining the approval of the test director, and two members of the plant staff, at least one being a Shift Supervisor, subject 

Issue Date:  10/20/20	1	70367

	to subsequent review by the original approving body.  Minor changes, hence, will not require the interruption of testing and are used to resolve items such as typographical errors, minor changes to sequence of test steps, etc.  Major changes will require interruption of testing and the acceptance by the original approval body before testing continues.  The licensee should define major and minor changes in the administrative control manual.

7.	Criteria for stopping a test should be provided.  A test should not be allowed to continue until prerequisites have been reestablished and documented in test notes, data sheets, or logs.

8-10.	Logs should be maintained and retained as part of each test.  They should contain historical information relevant to the conduct of the test and document interruptions; equipment deficiencies should be identified; and prerequisites, valve lineups, etc., should be reestablished.

d. Test schedules should exist that support the schedule given in the FSAR Chapter 14.  Responsible individuals should be charged with maintaining and implementing the test program schedule.

03.04	Document Control

a. Chapter 14 of the FSAR will normally describe the review, change, and approval procedures for test procedures.  The implementing instructions must provide the specific review and approval requirements for test procedures and test results.  A procedure for issuance of revised procedures and disposal of obsolete procedures must be sufficient to ensure that all testing will be accomplished in accordance with the most recently approved revision of the procedure.  If page changes to a procedure are issued, the licensee must have a cover sheet list of effective pages, etc., to enable the user of the procedure to account for the pages of the procedure.  Some mechanism must be provided to ensure that all affected test procedures are updated as necessary to reflect any design changes.  There may be a requirement that the responsible test engineer check all referenced drawings or vendor manuals for the latest revisions before testing, or there may be a crossreference file which lists all procedures that reference a particular drawing so that each affected procedure would be updated when drawing changes come in.

b. Some mechanism must be provided to ensure that all affected drawings and vendor manuals are updated as necessary to reflect any design changes.  There may be a requirement that the responsible test engineer check a master list to ensure they have the latest revisions, or to check design changes to ensure they do not affect the testing.

03.05	Design Changes and Modifications

a. Design Change Control

Chapter 14 of the FSAR normally should describe the measures for incorporating any needed system modifications or procedure changes, based on the results of the tests (e.g., failure of equipment to meet performance specifications or finding that system operation differs from FSAR description).  RG 1.28 endorses industry guidance that identifies many of the actions that should be covered by the design control program.

1.	After responsibility for components, systems, or structures has been turned over to the test group, a formal system is necessary to handle the design change and modification requests which will result from such things as:  (1) unsatisfactory qualification or preoperational test results, and (2) failure of structures, systems or components to meet functional requirements.  Each change request should be documented in such a manner that the licensee can ensure that appropriate reviews will be conducted and approvals obtained before effecting the change.  The licensee should have a formal system for reviewing all routine work requests to ensure that they do not involve an unreviewed design change.

2-3.	The licensee is responsible for constructing the plant as described in the FSAR and subsequently operating it in accordance with the technical specifications.  Design changes and modifications must be reviewed to ensure that the plant is being built as described in the FSAR, that safety questions have been reviewed, and that the technical specifications reflect the asbuilt plant.

4.	Normally during preoperational testing the same design organization(s) responsible for construction will process design changes and modifications that are generated as a result of preoperational testing.  For this case, design control measures should have been previously inspected.

5.	Preoperational test procedures are frequently written well in advance of actual testing and could be written before the actual turnover of equipment to the test group.  It is essential that measures are established to ensure that design changes and modifications will be incorporated into the test program.

b.	Temporary Modifications, Jumpers, and Bypasses

1-3.	Control of temporary modifications, jumpers, and bypasses becomes important at the time formal preoperational testing (verification of conformance to design criteria) begins. Otherwise, the performance of components, structures, or systems cannot be ensured subsequent to testing.

4-5.	No additional guidance.

6.	Installed jumpers should be easily identified when electrical equipment is inspected (e.g., made of long brightly colored strands of wire).  Lifted leads should be uniquely tagged for ease of identification.  Industry standards endorsed by RG 1.33, Quality Assurance Program Criteria (Operation), provide additional guidance.

7.	Installation of temporary strainers or removal of check valve internals is not evident to a casual observer.  Controls such as logs, physical tags, etc., should be used.  Industry standards endorsed by RG 1.33 provide additional guidance.

8.	Installation of electrical jumpers in crowded panels, the lifting of leads in congested areas, removal of check valve internals, etc., may warrant independent verification by a knowledgeable person to ensure that some safety function was not inadvertently negated through error.  Industry standards endorsed by RG 1.33 provide additional guidance.

9.	The nature of a bypass mechanism may be such that a functional test of the system(s) will be required after installation or removal, to ensure that a function was not inadvertently negated.

03.06	Plant Maintenance/Preventive Maintenance During Preoperational Testing

a. Plant Maintenance

The FSAR may be silent on maintenance controls during preoperational testing; however, it is important that administrative controls be established for all plant maintenance.  Maintenance performed during preoperational testing affects equipment reliability and performance during operations and therefore must be controlled.  Industry standards endorsed by RG 1.33 provide additional guidance for establishing administrative control requirements for maintenance during plant operations are equally applicable to the preoperational testing phase.

1. Plant maintenance must be performed in accordance with defined administrative controls in order to ensure that a planned maintenance activity can be performed safely without invalidating preoperational testing that is in progress or that has been completed.

2. To initiate requests for maintenance the licensee may, for example, use some sort of consecutively numbered work request forms or computer based database.  The methods for reviewing, approving, and scheduling maintenance should ensure that responsible plant supervision determines that:

(a).	Appropriate work procedures (technical manuals or locally prepared procedures) are available.

(b).	Appropriate inspection hold points have been identified.

(c).	Required testing of equipment subsequent to maintenance is specified.

(d).	Maintenance is scheduled so as not to impact on the validity of preoperational testing.

3. The inspector should look for controls that ensure that the quality of materials and spare parts issued to the maintenance personnel and used in performing safetyrelated maintenance activities will be at least equivalent to those specified in applicable codes, standards, design requirements, material specifications, etc., committed to in the FSAR as applicable during construction.  Requirements for the handling, storage, and shipping of replacement parts are contained in Criterion XIII of Appendix B to 10 CFR Part 50.

4. Controls are required to ensure that workers performing special processes are qualified in accordance with applicable codes and standards.  Personnel performing other maintenance on safetyrelated equipment should be trained or qualified according to the facility training program.

5. Nuclear safety should not be of immediate concern for maintenance performed during preoperational testing since Technical Specification and limiting conditions for operation do not apply (unless multiple unit site).  There is a concern that appropriate procedures (i.e., technical manuals or locally prepared procedures) are available to ensure that the performance of safetyrelated equipment will not be impaired by improper maintenance.  Another concern is that when maintenance is performed, subsequent to or during preoperational testing, test results could be invalidated unless retesting is performed.  For certain critical or complicated maintenance, it might be appropriate for the Plant Safety Committee to review the maintenance procedures.

(a-d)	Formal controls must be established to ensure that appropriate plant supervision determines the adequacy of detailed work procedures and the need for special work procedures.  Guidance and responsibilities for preparation, review, and approval of maintenance procedures should be provided.

e. The inspector should look for provisions to ensure that a supervisory representative from the operations and the testing group grant approval immediately before performing a plant maintenance activity so as not to jeopardize the validity of preoperational testing.

f. Provisions should be available to ensure that appropriate inspections by means of examination, observation, or measurement will be conducted of maintenance work in progress.  Individuals other than those actually performing the work should perform the inspections.  Hold points (beyond which work will not progress until appropriate inspections are performed) should be incorporated into inspection plans and maintenance procedures where applicable.

g. When maintenance is performed that could invalidate previously obtained preoperational test results, provisions should ensure that appropriate retesting will be conducted.  Procedures for controlling and performing the retest should be specified.

h. No additional guidance.

b.	Preventive Maintenance

1. No additional guidance.

2. Verify that measures have been established to ensure that preventive maintenance requirements and schedules will be developed and implemented on equipment transferred from the construction to the test or operations groups.  These schedules and responsibilities should be developed at the time construction relinquishes responsibility for equipment.  The schedules and requirements should be refined and changed as experience is gained with the equipment.

3. Equipment should be protected from extreme temperatures, dust, or moisture.  The inspector should look for items such as use of motor heaters, requirements for periodic rotation of motors, lubrication schedules, recalibration of process instrumentation, freeze protection, etc.  The duration of a preoperational test program may require extensive implementation of a facility's periodic maintenance and recalibration program well in advance of plant operation

4. No additional guidance.

b. Maintenance Records

Section 13.6 of the FSAR establishes record retention requirements.  Criterion XVII of Appendix B to 10 CFR Part 50 establishes requirements with regard to required records and record retention. Industry standards endorsed by RG 1.33 provide additional guidance for records requirements and retention periods.

03.07	Equipment Protection and Cleanliness

a-c.	Industry standards endorsed by RG 1.28 provide additional guidance on cleanliness requirements during construction and operational phases.

Endorsed industry guidance defines cleanliness zones which may require different levels of cleanliness.  The endorsed industry guidance gives additional criteria for storage of equipment, and more importantly, makes all the storage requirements applicable to items which have been installed.

Identification methods may include tagging, markedup drawings, ribbons, etc.  "Reentry" controls for any activity that would open the boundaries of a cleaned system to foreign material should be defined.

d.	The licensee should have commitments in their licensing basis on cleaning of fluid systems and water quality requirements.  The water chemistry specifications should be included in Chapter 5 of the FSAR.  The water chemistry specifications for reactor coolant system components are included under NUREG-0800, SRP Section 5.4, “Reactor Coolant System Components and Subsystem Design.”  The steam generator program chemistry is included under NUREG-0800, SRP Section 5.4.2.2, “Steam Generator Program,” and Branch Technical Position (BTP) 5-1, “Monitoring of Secondary Side Water Chemistry in PWR Steam Generators.” 

1. This includes chemistry control of chloride, fluoride, other elements and chemicals within specified limits while in wet layup before, during and after completion of preoperational tests.  Water quality requirements for various conditions (i.e., temperatures) of preoperational testing should be specified.  Makeup water, storage tank water, and process water quality should be specified.  Water chemistry controls may be applicable to carbon steel and stainless steel components.

2. Procedures for system layup should include water treatment, use of nitrogen blankets, recirculation requirements, and fill/drain requirements, where applicable.

3-4.	No additional guidance.

03.08	Test and Maintenance Equipment

Control of Test and Measurement Equipment

Section 17.5 of the FSAR speaks to measures appropriate for the control of test and measuring equipment.  Industry standards endorsed by RG 1.28 provide guidance appropriate for control of test and measurement equipment.  Control of test and measurement equipment during preoperational testing should be consistent with the commitments and guidance contained in these documents.

It is not intended that special calibration and control measures are needed for rulers, tape measures, levels, and other similartype devices where normal commercial practices provided adequate accuracy.

If test equipment or installed equipment that requires no calibration is in use, the licensee may identify it with a "No Calibration Required" sticker and establish appropriate administrative controls.

70367-04 	RESOURCE ESTIMATE

This procedure supports a program review as specified under Inspection Manual Chapter (IMC) 2504.  Resources for implementation of all the programs under IMC 2504 are as specified in IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document.  The resource estimate for this procedure is approximately 200 hours of direct inspection.  The resource estimate for this procedure for an inspection of a subsequent unit focused on program differences is approximately 8 to 40 hours of direct inspection.

70367-05 	REFERENCES

Branch Technical Position (BTP) 5-1, “Monitoring of Secondary Side Water Chemistry in PWR Steam Generators,” (NUREG-0800, Chapter 5)

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

IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document

IP 35007, “Quality Assurance Program Implementation during Construction and Pre-Construction Activities” 

IP 70702, Part 52, “Inspection of Preoperational Test Performance”

NUREG-0800, “Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition” 

RG 1.28, “Quality Assurance Program Criteria (Design and Construction)”

RG 1.33, “Quality Assurance Program Criteria (Operation)”

RG 1.68, “Initial Test Programs for Water-Cooled Nuclear Power Plants”

	END

Attachment:

Revision History for IP 70367

Attachment 1 - Revision History for IP 70367

Issue Date:  10/20/20	Att1-1	70367