Issue Date: 03/29/85 - 1 - 2920

NRC INSPECTION MANUAL DI

MANUAL CHAPTER 2920

CONSTRUCTION APPRAISAL TEAM INSPECTION PROGRAM

2920-01 PURPOSE

The purpose of this chapter is to describe the methodology for

performing the multidisciplined construction appraisal team (CAT)

inspections at nuclear power plants under construction.

2920-02 OBJECTIVE

The objective of the CAT inspection program is to determine through

an integrated multidisciplined approach that (1) the facility is

being constructed and the hardware is being installed in accordance

with regulatory requirements and appropriate industry practices, and

(2) the applicant's management and quality control programs are

effective. The team inspections focus primarily on hardware

installation and construction quality. Documentation is reviewed

to the extent necessary to understand the applicant's programs to

provide for final hardware installations of appropriate quality.

Guidance for the development of facility-specific inspection plans

is included. The results of the CAT inspection and evaluation

provide an input for the assessment of the effectiveness of the

regional implementation of the NRC construction inspection programs,

and an input for the overview of INPO construction facility audits.

2920-03 DEFINITIONS

03.01 Hardware: Foundations, structures, systems, equipment,

and components.

03.02 Potential Enforcement Finding: An apparent noncompliance

with specific regulatory requirements or deviation from specific

commitments made by the applicant that are identified during the CAT

inspection. Regional management of the applicable regional office

is responsible for deciding the appropriate enforcement action to

be taken in accordance with 10 CFR 2, Appendix C.

03.03 Inspector Observations: An item of concern identified

during the CAT inspection that, while not related to specific

regulatory requirements or applicant commitments, is a departure

from appropriate engineering/construction practice and is significant enough that applicant management should take corrective action.
2920 - 2 - Issue Date: 03/29/85

03.04 Applicant or Licensee: Utility that holds the construction permit.
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03.05 Integrated Design Inspection (IDI): Multidiscipline

inspection performed to assess the quality of design activities on

a nuclear power plant project. The inspection provides a comprehensive examination of the design development and implementation for

a selected plant system. An IDI may precede or follow a CAT

inspection for a specific or replicate plant.

2920-04 RESPONSIBILITIES AND AUTHORITIES

04.01 Director, Office of Inspection and Enforcement. Selects

facilities to be inspected based on input from the NRC offices and

the regions, and issues the results of inspections.

04.02 Director, Division of Inspection Programs, IE. Administers the CAT program.

04.03 Chief, Reactor Construction Programs Branch, IE. Implements the CAT program.

04.04 Regional Administrator. Determines the scope and schedule

for applicant responses to the inspection report and determines

final action on potential enforcement findings.

2920-05 INSPECTION CONCEPT

05.01 The concept of CAT inspections at nuclear facilities under

construction is based on concurrent inspections and subsequent

evaluation of the installed hardware quality by a multidisciplinary

team. The primary focus of the effort is on actual quality of in

situ hardware with review of documentation to the extent necessary

to identify the strengths and weaknesses of the applicant's

programs. The functional areas that should be considered in the

performance of this inspection are listed in 06.05c below.

05.02 The determination of the facility hardware quality and the

effectiveness of the applicant's programs to provide for appropriate

hardware quality is made generally by the following process:

a. Define the scope and depth of the CAT inspections for a

particular facility using criteria selected from the guidelines provided in Appendix 1 of this manual chapter. This

definition should be based upon consideration of the facility's past inspection history and salient features. The scope

of the inspection is defined during the planning and preparation phase, and appropriate revisions are made as the

inspection progresses.

b. Determine the quality of hardware as compared with that

dictated by appropriate application of design, construction,

and maintenance specifications. In addition, the adequacy of

the specifications, on the basis of inspector observations,

should be judged considering appropriate

engineering/construction practices which may or may not be

incorporated into the governing specifications such as

regulatory guides, NRC staff positions, consensus standards
2920 - 4 - Issue Date: 03/29/85

(e.g., ANSI, IEEE, ASME, ACI, and AISC), and NRC

interpretations.

c. The applicant's programs to provide for hardware quality

should be compared with the criteria for effective programs

to the extent necessary to understand the strengths and

weaknesses of the applicant's programs. The criteria to be

utilized are regulatory requirements, applicant commitments,

and/or appropriate practices as discussed in 05.02b above.

If the applicant is not committed to the appropriate

engineering/construction practices and the applicant's

program(s) is (are) inferior to the appropriate practice(s),

this is identified as an observation of applicant program

weakness.

d. Verify that the construction programs including quality

programs are implemented. This verification is performed

during the site inspection by observations of installed

hardware, work in progress, discussions with site personnel

during the conduct of the inspection, and quality program

reviews.

e. Evaluate management involvement by discussions with management

personnel and limited reviews of documentation, augmented by

information obtained as a result of the efforts described in

05.02d above.

f. Evaluate any program weaknesses identified by a preceding IDI

which could be expected to affect installed and inspected

hardware so as to be apparent in an inspection of hardware

quality. Identify for any following IDI design-related

construction problems which should be considered for followup

during IDI.

2920-06 PROGRAM GUIDANCE

06.01 Program Timetable and Scope. IE management will determine

the frequency of the implementation of the CAT inspections and

evaluations. The scope of the program at a particular facility is

to accomplish a multidisciplined inspection of the overall quality

of the facility's hardware and within a given discipline to focus

primarily on potential areas of concern. The factors to be

considered in the inspection plan development and implementation are

delineated in enclosed Appendix 1 of this manual chapter. The

planning, inspection, and reporting for each facility should be

completed within an approximate 3-month period. This schedule

provides about 2 weeks for team planning, two 2-week onsite

inspection periods separated by a 1- or 2-week preliminary

evaluation and plan reassessment period, and a 1-month period for

documentation of inspection results.

06.02 Team Member Assignments. Inspector assignments to the CAT

shall be based on the expertise needed to implement the scope of the

inspection planned for a particular facility. Consideration will

be given to assignments of IDI team members to the CAT, particularly
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those who have or are expected to participate in an IDI on the same

or a replicate plant.

06.03 Regional Participation

a. The applicable regional office will be given an opportunity

to assign regional inspectors to the construction appraisal

team. Regional personnel that are assigned to CAT will report

to the Team Leader for direction during the conduct of the

inspection. Input for the CAT inspection report from assigned

regional personnel shall be provided directly to the Team

Leader.

b. The evening before the exit briefing the team will meet to

review their findings. The regional office is encouraged to

be represented at this meeting.

c. The regional office is encouraged to be represented at the

entrance and exit briefings with the applicant.

06.04 Information Acquisition. Before initiating the team

planning phase for a facility inspection, the Team Leader, or his

representative, will contact and/or meet with regional

representatives and applicant representatives, as necessary, to

identify and obtain information related to the factors identified

in 06.05b below. The CAT inspectors should review the report from

any preceding IDI, discuss relevant findings with the IDI Team

Leader and members, and obtain specific information on any problems

requiring further investigation during the CAT inspection.

In addition, the team should obtain information about the

applicant's document control and filing system; design,

construction, and maintenance criteria; and governing construction

drawing and specification definition summaries for the various

disciplines. This information must be available to the team for the

efficient development of a meaningful facility-specific inspection

plan. During this time, NRC inspection specialists and contractor

personnel should participate in the preparation of the inspection

plan.

06.05 Inspection Planning and Preparation

a. A key element for a successful team inspection is detailed

planning and preparation. The objectives of planning and

preparation are

1. To identify those elements that are applicable to the

specific facility inspection.

2. To formulate a detailed inspection plan appropriate for

the particular facility. The inspection plan should be

a guide for performing inspections and should be revised

based on the results of ongoing inspection activities.

3. To make specific functional assignments to each team

member.
2920 - 6 - Issue Date: 03/29/85

4. To define inspection schedules.

5. To familiarize the team members with the facility

organization, procedures, specifications, and drawings

that define construction and program requirements.

6. To indoctrinate team members to the team concept. Before

the start of the onsite inspection the Team Leader should

conduct an indoctrination session for the team members on

the concept of team inspections and discuss the broad

schedule, inspection ground rules, and areas of

assignment. As the team refines the elements of the

inspection by defining priorities, inspector

capabilities, and site status, detailed inspection

assignments are made and parallel activities are

identified. The inspection plan scope should be based on

two 2-week periods on-site with a 1- or 2-week period

separating the two for reassessing and revising the plan.

b. The team member(s) assigned a functional area should develop

an inspection plan for that area using Appendix 1 of this

chapter as guidance. Appendix 1 may be supplemented as

required by using applicable inspection procedures contained

in the IE Manual. The team members will use the following

materials in planning the details of and preparing for the

onsite inspection:

1. Safety Analysis Report and facility design/construction

specifications and drawings that define requirements and

commitments.

2. Inspection history - inspection reports and docket files

provide an overview of regional activity and applicant

performance and aid in developing priorities.

3. Licensee reports - reports submitted by the applicant

(such as 10 CFR 21 and 50.55(e) reports) provide

indications of the effectiveness of the applicant's

program.

4. Applicant manuals - arrangements should be made to obtain

the project manual, quality assurance manual, topical

reports, and administrative control manuals, as required.

These documents provide the basis of management controls

at the site and define responsibilities, authorities,

interfaces, and procedural aspects of project control.

5. Contractual arrangements - the degree to which the

applicant acts as his own A/E, use of separate A/E and

multiple consultants, and constructor use of multiple

contractors are primary inputs into the sample definition

required to provide for evaluation of interface

effectiveness and an adequate cross-section of the work

of various contractors.
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6. Construction status - stage of completion will dictate

the scope and types of inspections and evaluations

appropriate for a particular discipline.

7. Organization charts - provide the inspectors with an

overview of the management interfaces, communication

channels, and the identification of management personnel.

Each inspector must develop an understanding of the

organization and identify those managers and supervisors

to be contacted.

8. NRC staff positions/interpretations/regulatory guides

(RGs) - current NRC (NRR or IE) staff

positions/interpretations/RGs define the most recent NRC

positions and should be considered in the detailed

planning and the determination of acceptability of the

applicant's program.

9. Consensus standards - ANSI/ASME/IEEE/ACI/AISC standards

shall be used as applicable.

10. Regional management and inspector impressions of

construction adequacy in the various disciplines.

11. IDI reports that are specific to, or a replicate of, the

plant where the CAT inspection will be conducted. In

particular, the system(s) inspected by any preceding IDI

should be considered in the CAT hardware sample selected

for each functional area. The intent is for the CAT and

any related IDI to provide for an in-depth vertical

sample examination of a particular system from design

through construction. Duplication of effort should be

avoided.

c. The planning and preparation stage should result in an initial

inspection plan which will ensure that the objectives of this

chapter are met. It is the responsibility of the Team Leader

to integrate each team member's proposed plan/schedule/

activities into an overall plan and to coordinate the

inspection activities.

The inspection plan should be formulated to address the

following functional areas as a minimum:

1. Civil/structural construction, including design change

control

2. Mechanical construction, including design change control

3. Electrical: power, instrumentation, and controls,

including design change controls

4. Welding and nondestructive examination (NDE), including

design change controls
1 These areas overlap with areas 1, 2, 3, and 4. The inspectors assigned areas 5, 6, and 7

and the inspectors assigned areas 1, 2, 3, and 4 will decide "who inspects what" during the

preparation phase.

2 Only requests for information may be given the applicant's representative in writing without

the approval of the Team Leader. All other information given the applicant in writing must be

approved by the Team Leader. It is important to ensure that information requests do not

include any information about inspection results or findings.

2920 - 8 - Issue Date: 03/29/85

5. Traceability and maintenance and storage (both in-place

and preinstallation)1

6. QA/QC inspector effectiveness and corrective action

systems1

7. System turnover from construction to operation (only at

sites that have established the turnover mechanism) 1

d. The depth of NDE performed by or under the direction of the

CAT will be dictated by the particular circumstances at a

facility. In special situations and as dictated by relative

importance to completion of the overall inspection scope,

limited destructive or semidestructive examinations may be

conducted under the direction of the CAT, as approved by the

Chief, Reactor Construction Programs Branch. Such needs must

be presented to the applicant as soon as they are identified

to provide for their timely completion. Also, such

examinations may require additional contractor assistance,

which requires as much advance notice as possible.

e. The initial inspection plan may be revised as the inspection

progresses to focus on more meaningful areas. The Team Leader

is responsible for arranging/directing changes to the initial

inspection plan.

2920-07 INSPECTION CONDUCT AND DOCUMENTATION

07.01 General. All team members should be dedicated for the

duration of the inspection. Each day, the Team Leader should

conduct a coordination meeting of all team members to discuss the

day's activities and findings. As a result of such meetings, team

members may be given additional assignments or their effort may be

redirected.

At the beginning of the inspection the applicant should be asked to

appoint representatives as points of contact for each of the

functional areas, as appropriate. It is the responsibility of the

inspector assigned to each of the functional areas to apprise the

applicant's representatives of the progress of the inspection on a

daily basis through informal2

 contact. This will expedite the exit

meeting conducted by the Team Leader at the end of each onsite

period.

07.02 Entrance and Exit Interviews
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a. An entrance interview between senior applicant management and

all CAT members shall be held before starting the onsite

inspection. The regional office is encouraged to be

represented at this meeting. IP 30703, "Management Meeting

- Entrance and Exit Interviews," should be used as guidance

when conducting the entrance interview.

b. An exit interview shall be held between senior applicant

management and the CAT Team Leader at the conclusion of each

of the 2-week inspection periods. Individual CAT members will

participate at the discretion of the Team Leader. IE

management also may attend the exit interviews. The regional

office is encouraged to be represented at these meetings. The

designated Team Leader for any IDI scheduled to follow the CAT

inspection should be invited to attend the final exit

interview. For a plant where an IDI is not scheduled to

follow a CAT and CAT findings indicate that a limited IDI for

the on-site design function may be warranted, the IDI Team

Leader also should be invited to attend the final exit. IP

30703 should be used as guidance when conducting the exit

interviews.

The exit interview will be used to summarize the findings and

to convey the significance thereof to senior applicant

management. The results of the inspection shall be openly and

freely discussed, but the results or findings shall not be

given the applicant in writing. This will ensure that

preliminary information is not provided "via draft reports"

before the final report is issued.2

07.03 Inspection Documentation

The team will prepare an inspection report for issuance by the

Director, IE, or his representative, that documents inspection

activities and findings identified during the inspection. The

inspection report and related transmittal correspondence should be

transmitted within about 1 month after completion of the onsite

inspections.

The CAT inspection concept employed in this procedure includes an

evaluation of overall hardware and construction quality and a

determination of applicant program effectiveness. Therefore, in

addition to using specific requirements and commitments as a basis

of evaluation, the inspector may be using other criteria for which

explicit regulatory requirements may not exist, such as regulatory

guides, staff positions and interpretations. Consequently, in

addition to inspection findings, which are potential enforcement

findings, the report may contain other observations which of and by

themselves, add up to perceived strengths or weaknesses. If it is

found that the hardware quality or the applicant's program does not

meet these criteria, the finding is considered as an observation of

weakness or inadequacy. The hardware quality or the applicant's

program could exceed requirements, commitments, and these other

criteria, so that this program element is superior. In this

situation, it would be considered as an observation of strength.
3 Specific detailed examples of these items are obtained by referring to previous CAT

inspection/evaluation reports.

2920 - 10 - Issue Date: 03/29/85

a. Inspection Report. The cover page to the report will conform

to IE MC 0610. The body of the report will identify the scope

and results of the inspection. In addition, to identifying

potential enforcement findings, each major inspection topic

area discussed will include the other observations of

perceived strengths and weaknesses discussed above. The topic

areas addressed should include as a minimum the functional

areas listed in 06.05c above.

The potential enforcement findings together with the other

appropriate observations, provide the basis for evaluation of

facility hardware quality and the effectiveness of the

applicant's system of controls. The report should identify

as clearly as possible the perceived reasons that caused the

weakness or strength to exist and should not just repeat the

weakness or strength.

b. Transmittal Letter.3

 The transmittal letter will generally

conform to the example contained in Appendix 2 of this manual

chapter.

c. Appendix A - Executive Summary.3

 The Executive Summary should

summarize the significant overall conclusions and the scope

and results of the CAT inspections and evaluations.

d. Appendix B - Potential Enforcement Findings.3

 This appendix

summarizes any apparent noncompliances with specific

regulatory requirements or deviation from specific commitments

made by the applicant that are identified during the CAT

inspections. Explicit references to the detailed section of

the inspection report are made for complete descriptions of

the bases for the potential findings. These are referred to

the appropriate regional office for review and necessary

action.

e. Appendix C - Inspector Observations.3

 This appendix

summarizes items of concern identified during the CAT

inspections. These items, while not related to specific

regulatory requirements or applicant commitments, are

departures from appropriate engineering/construction practices

and are significant enough that applicant management should

take corrective action. Explicit references are made to the

detailed section of the inspection report for complete

descriptions of the bases for these items. This appendix may

not be required for all CAT inspection reports.

f. Distribution. The CAT report will be sent to the appropriate

Regional Administrator at the same time it is sent to the

applicant. After proprietary clearance the report will be

distributed using the region's standard distribution for the

inspected facility. In addition, the report will be sent to

all utility executives using distribution list 1S, and to
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other interested NRC organizations using distribution list

IE01.

g. Input to Regional Assessments. The Team Leader shall be

responsible for the preparation of the assessment

documentation as required by IE Office Procedure 0200.

h. Construction Inspection Program (MC-2512) Credit. Each

inspector who was assigned inspection responsibility in a

functional area shall provide the Team Leader a listing of the

extent to which the CAT effort has served to satisfy the

MC-2512 program requirements. This information will be sent

to the appropriate regional management by the Director,

Division of Inspection Programs.

i. INPO Overview. The overview of the INPO activities related

to facility construction will be conducted in accordance with

the NRC/INPO Coordination Plan attached to the April 1983

letter from W. Dircks (NRC) to E. Wilkinson (INPO).

j. Program Changes. Each team member shall provide

recommendations (if any) to the Team Leader for construction

inspection program changes. The Team Leader shall provide the

recommendations (as appropriate) to the Chief, Reactor

Construction Programs Branch.

2920-08 LIST OF APPENDICES

1. Guidance for Inspection Plan Development.

2. Sample CAT Inspection Report Transmittal Letter.

END

Appendix 1

Appendix 2
1 These areas overlap with areas 1, 2, 3, and 4. The inspectors assigned areas 5, 6, and 7

and the inspectors assigned areas 1, 2, 3, and 4 will decide "who inspects what" during the

preparation phase.

Issue Date: 03/29/85 A-1 2920 Appendix 1

APPENDIX 1

GUIDANCE FOR INSPECTION PLAN DEVELOPMENT

A. PURPOSE

To provide guidance in developing an inspection plan for

conducting a CAT inspection.

B. SCOPE

This planning guidance is intended for all areas covered by

the CAT inspection:

1. Civil/structural construction, including design change

control

2. Mechanical construction, including design change control

3. Electrical: power, control and instrumentation

construction, including design change control

4. Welding and NDE, including design change control

5. Material traceability, maintenance, and storage (both

in-place and preinstallation)1

6. QA/QC inspector effectiveness and corrective action

systems1

7. System turnover from construction to operation (only at

sites that have established the turnover mechanism) 1

This inspection will focus on components, systems, and

hardware important to safety to determine conformance to

engineering design, regulatory requirements, and applicant

commitments. The CAT inspectors will concentrate on "hands

on" inspections of selected components, systems, and hardware

to evaluate quality and conformance to specifications. To the

extent necessary to evaluate deficiencies observed in the

hardware, the applicant's construction, inspection and QA

procedures, and documentation controlling on-going and

completed work will be reviewed.
2920 Appendix 1 A-2 Issue Date: 03/29/85

C. PLAN PREPARATION

1. Background Review

In preparing the plan for these inspections the following

information should be reviewed:

a. Recent inspection reports (last 6 months)

b. 10 CFR 50.55(e) reports

c. Allegations/investigations

d. FSAR requirements and commitments

e. National standards (ASME, AWS, ANSI, IEEE, etc.)

committed to by the licensee

f. Construction, inspection, and QA procedures

g. Drawings

h. The IDI report for the same plant or one of similar

design.

Each inspector should review these documents or portions

of documents applicable to his assigned technical area.

Items a through c should be reviewed for the purpose of

guiding or focusing the inspections. The inspectors

should not spend excessive amounts of time in areas that

the region has recently identified as a problem area in

the inspection reports. Inspection efforts in these

areas should be limited to seeing if the problems

continue in present work and that corrective action is

being taken on previously identified defective work.

Areas identified in 10 CFR 50.55(e) reports should be

treated in the same manner.

Allegations should not be pursued. These are the

responsibility of the Regional Office and/or Office of

Investigations.

Items d through g should be reviewed principally to

identify licensee commitments and physical

characteristics to be used during the hands on

inspections (dimensions, tolerances, accept/reject

criteria materials heat treatment, etc.)

2. Sample Selection

The following guidance on selecting samples for

inspection is prioritized in descending order of

importance:

a. The sample size selected in each area inspected

should be representative of the installed and

inspected hardware.
Issue Date: 03/29/85 A-3 2920 Appendix 1

b. The samples selected should be representative of the

different contractors and vendors, shop, field, and

site work.

c. Sample should be selected from different buildings

on the site and if it is a multiunit site, from those

units still under construction.

d. A sample should be selected, in all disciplines, of

hardware associated with the system(s) inspected by

any preceding IDI.

D. IMPLEMENTATION

1. Inspect samples of completed installation, after licensee

QC inspections, to determine work conformance to design

drawings, specifications, site procedures, and FSAR

requirements.

2. Observe ongoing work and interview crafts and QC

personnel as to work skills, knowledge of procedures and

requirements, and compliance with design and procedural

requirements.

3. Review procedures and QA/QC documentation to the extent

necessary to evaluate causes of deficiencies observed in

hardware or documentation.

END
Issue Date: 03/29/85 B-1 2920 Appendix 2

APPENDIX 2

SAMPLE CAT INSPECTION REPORT TRANSMITTAL LETTER

Docket Nos. 50-(number)

ATTN: (Utility Executive)

Gentlemen:

SUBJECT: Construction Appraisal Inspection 50- (Report No.)

This refers to the construction appraisal inspection conducted by

the Office of Inspection and Enforcement (IE) on (dates) at

(location). The construction appraisal team (CAT) was composed of

members of IE. The team was provided technical assistance by a

number of highly qualified contractor personnel. This inspection

covered construction activities authorized by NRC Construction

Permit CPPR-(no.).

The enclosed report identifies the areas examined during the

inspection. Within these areas, the effort consisted of detailed

inspection of selected hardware after quality control inspections,

a comprehensive review of your quality assurance program,

examination of procedures and records, observation of work

activities, and interviews with management and other personnel.

Appendix A to this letter is an Executive Summary of the results of

the inspection and of the conclusions reached by this office.

(Short statement of key conclusions)

Appendix B to this letter contains a list of potential enforcement

actions based on CAT inspector observations. These have been

referred to the Region (no.) Office for review and necessary action.

Appendix C to this letter contains a list of CAT inspector

observations relating to matters which, while not specific

regulatory requirements, are considered to be of sufficient

importance to quality construction to warrant (utility name)

management attention and appropriate action.

In accordance with 10 CFR 2.790(a), a copy of this letter and the

enclosures will be placed in the NRC Public Document Room. No reply

to this letter is required at this time. You will be required to

respond to these findings after a decision is made regarding

appropriate enforcement action.
2920 Appendix 2 B-2 Issue Date: 03/29/85

Should you have any questions about this inspection, please contact

us or the Region (no.) Office.

Sincerely,

, Director

Office of Inspection and

Enforcement

Enclosures:

1. Appendix A - Executive Summary

2. Appendix B - Potential Enforcement Findings

3. Appendix C - Inspector Observations

4. Inspection Report 50- (Report No.)

END