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NRC INSPECTION MANUAL RVIB

INSPECTION PROCEDURE 93807

SYSTEMS BASED INSTRUMENTATION AND CONTROL INSPECTION

PROGRAM APPLICABILITY: 2515

SALP FUNCTIONAL AREA: ENGINEERING/TECHNICAL SUPPORT (SOETS-O)

93807 INSPECTION OBJECTIVES

The objective of the System Based Instrumentation and Control

Inspection (SBICI) is to verify the functionality of safety systems

by inspecting performance related attributes of the safety system

with a focus on its associated instrumentation and control.

93807-02 INSPECTION REQUIREMENTS

02.01 Inspection Planning. The team leader shall develop an

inspection plan to address the background information on the plant

relative to this inspection, the basis for selecting the system(s)

for inspection, the selected instrumentation, the assignment of

individual team members to specific areas, and the schedule.

02.02 Selection of Instrumentation. The team leader, assisted

by the mechanical system design engineer, and one I&C design

engineer, should review a current plant specific probabilistic risk

assessment (PRA) and plant experience to identify the dominant

accident sequences that contribute significantly to core damage.

Two or three systems whose failure could affect these accident

sequences should be selected, and about 10 to 12 instrument loops

in these systems that initiate and control protective actions for

accident mitigation should then be identified for inspection. A

review of applicable experience reports may be helpful in

identifying specific instrument loops within the selected systems.

02.03 Conduct of the Inspection. This inspection has two

components, a design inspection typically conducted in the

engineering offices of the licensee and a concurrently conducted

site inspection.

a. Design Inspection

1. Verify that the thermal/hydraulic performance of the

mechanical system is consistent with the limits specified
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in technical specifications (TS), accident analyses,

emergency operating procedures, and design bases

documents (DBD).

2. Verify that the process parameters used as controlling

variables and their specified control values have been

selected with adequate 
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margins to assure system functionality.

3. Verify that the device range for each selected parameter

is adequate, taking into consideration the device

accuracy, calibration tolerances, drift, etc. Also

verify that the licensee's loop calibration methodology

ensures that the device is calibrated over its entire

range.

4. Verify that the calculated system process response times

are consistent with required system performance.

5. Verify that setpoints are calculated consistent with the

methodologies defined in NRC approved topical reports,

Regulatory Guides, or equivalent guidelines in industry

standards as applicable, and utilize correct inputs from

technical specifications, accident analyses or DBD. Also

verify that effects of physical elevations, density

ranges and temperatures ranges are appropriately

considered.

6. Verify that devices have been qualified for the

anticipated normal and accident environmental conditions

applicable to their physical location (e.g., temperature,

humidity, radiation, seismic loading) and that

inaccuracies associated with environmental conditions

have been appropriately factored into loop accuracy

calculations and considered in appropriate abnormal and

emergency operating procedures. Also verify that all

inaccuracies due to environmental effects of the loop

elements (i.e., cables, transmitters, terminal blocks,

penetrations, etc.) have been appropriately considered.

7. Verify that proper logic has been incorporated for system

actuation, annunciation and control.

8. Verify that system modifications, including revisions to

setpoints, have been appropriately evaluated per 10 CFR

50.59, and that in-kind replacements were truly in-kind.

9. Verify that all pertinent functions of the equipment are

checked during surveillance testing.

10. Verify that equipment responses to a loss of power are

adequate. Also, verify that procedures for handling loss

of power incidents are adequate for the instruments

selected.

11. Verify that the required isolation devices are qualified

and that the system maximum credible fault/surge

withstand capability is bounded by the installed

isolation devices.

12. Verify that protection system/control system failure will

not adversely challenge plant safety systems (control

system interaction).
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13. Verify grounding of equipment and cabling have been

evaluated for the effects of noise interference,

lightning induced surges, or ground loops.

14. Review maintenance, calibration, and surveillance

procedures, and verify conformance to TS, FSAR and

calculation requirements. Confirm that calibration,

annunciator, abnormal response and maintenance procedures

have been updated to reflect any revised equipment

requirements due to system modifications.

15. Verify that the installed equipment configuration and

rack arrangement allow adequate equipment cooling.

16. Verify that equipment susceptibility to Electromagnetic

Interference/Radio Frequency Interference (EMI/RFI)

sources has been evaluated.

17. Verify that appropriate electrostatic discharge

procedural precautions are in place.

b. Site Inspection

1. Verify that physical locations of instrument taps and

device elevations are consistent with calculations.

2. Verify that sensing lines are arranged with appropriate

consideration of slope, venting, draining, equalizing,

process isolation and hydraulic requirements.

3. Verify that device make and model number and actual

setpoint are consistent with the calculation and

instrument list.

4. Verify that the physical location of the instrumentation

loop is such that there are no unresolved concerns due to

high-energy or moderate-energy line breaks, jet

impingement, seismic II/I, flooding, missiles, or

vibration.

5. Verify that plant specific historical data on instrument

drift between calibrations is consistent with the

calculation assumptions.

6. Verify that calibration procedures are consistent with

the calculation requirements.

7. Verify that preventive maintenance, including vendor

recommended periodic replacements of aging parts, is

satisfactory.

8. Verify that test equipment accuracies are consistent with

those assumed in setpoint calculations.

9. Verify that instrumentation that is bypassed is properly

indicated or annunciated.
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10. Verify that adequate corrective action has been taken to

identify and correct I&C related maintenance concerns

identified in information notices, IE Bulletins, generic

letters and vendor recommendations.

11. Verify that appropriate documented

operability/reportability evaluations have been performed

for dispositioning identified problems and maloperation

or failure of instrumentation.

12. Verify that adequate physical separation/independence is

maintained between channels/divisions.

93807-03 INSPECTION GUIDANCE

General Guidance

The inspection will review the licensee's evaluation of the

thermal/hydraulic performance of the safety system and the process

parameters used to control the operation of the safety system to

assure that it will perform as described in the FSAR and as assumed

in the accident analysis. The inspection will also review the

design and field aspects of the associated instrumentation and

control systems, including setpoint calculations, mechanical

systems interfaces, testability, calibration procedures, isolation

and bypass status indication, maintenance, and equipment

installation.

Specific Guidance

03.01 No specific guidance.

03.02 Selection of Instrumentation. The selection of

instruments for inspection should be done during the pre-inspection

visit to the licensee's facilities. The inspection sample should

include those instruments that are typically engineered by the NSSS

vendor, e.g., ECCS and other accident mitigating systems, and those

engineered by the architect-engineer, e.g., balance of plant

systems. Technical specifications and FSAR system descriptions

should be used in the selection process. The size and scope of the

inspection sample may be adjusted for each facility as determined

necessary.

03.03a Design Inspection. The inspectors assigned to perform

system based I&C design inspections should have experience in

designing the systems being inspected or, as a minimum, with the

NSSS design to be inspected. Preferably this experience should

have been gained while working at the design offices of an NSSS

supplier or an architect-engineer. 

The inspectors should evaluate the I&C systems relative to their

design bases, technical specifications and accident analyses (as

appropriate), process limits calculations, setpoint calculations,

and control loop logic for actuation/alarm functions. For

verifying instrument setpoints the guidance in Regulatory Guide
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1.105, "Instrument Setpoints for Safety Related Systems" should be

used. Specific design attributes to be considered are listed in

Section 02.03a of this procedure. 

03.03b Site Inspection. Field engineers performing the site

inspection should be experienced in I&C component installation,

maintenance, surveillance, calibration, testing and operations.

Site inspectors should closely coordinate their activities with the

design inspectors to ensure that the physical installation,

procedure requirements, test results, drift data, etc., are

consistent with the design documents and calculations. Specific

site attributes to be considered are listed in Section 02.03b of

this procedure.

93807-04 INSPECTION RESOURCES

04.01 Team Composition. The SBICI team includes 5 or 6 inspectors

with the following assignments:

Team leader

Assistant team leader (optional depending on the need to split

the team for concurrent inspections at the site and the

engineering office remote from the site)

Two I&C design engineers

One mechanical system design engineer.

One I&C field engineer

04.02 Inspection Duration. The following guidance is provided for

planning the inspection:

Week 1 - Three days of pre-inspection visit by the team leader,

the mechanical system design engineer and one I&C design

engineer, for selection of instruments for inspection and

acquisition of inspection documents.

Week 2 - In office inspection preparation and review of

documents.

Week 3 - Inspection at the site and licensee engineering offices.

Week 4 - In office review of information collected during week 3

and continuation of review of documentation.

Week 5 - Completion of site and engineering office inspection.

Pre-exit meeting with the NRC management and exit meeting with

the licensee.

Week 6 - Preparation of report inputs by the team members and

transmittal to the team leader.

Weeks 7 through 11 - Team leader compile and finalize team member

inputs and issue inspection report.
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93807-05 REPORTING REQUIREMENTS 

The team leader shall develop input for the facility Systematic

Assessment of Licensee Performance (SALP) report, based upon the

inspection observations. This input should generally address

functional areas such as Engineering and Technical Support,

Maintenance/Surveillance, and Safety Assessment/Quality

Verification.

END