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NRC INSPECTION MANUAL DI

INSPECTION PROCEDURE 73051

INSERVICE INSPECTION - REVIEW OF PROGRAM

PROGRAM APPLICABILITY: 2512, 2515 (BASIC)

73051-01 INSPECTION OBJECTIVE

Ascertain whether the licensee's program pertaining to the

Preservice Inspection (PSI) and Inservice Inspection (ISI) is

complete and in conformance with regulatory requirements and the

licensee's commitments.

73051-02 INSPECTION REQUIREMENTS

02.01 Program Approval. Ascertain that the following requirements are met:

a. ISI program, including examinations and tests, is in conformance with relevant ASME Code Section XI editions and addenda,

and Code cases proposed for use as part of the plan. Verify

that any relief from Code requirements has been approved by

NRR.

b. The services of an Authorized Nuclear Inservice Inspector

(ANII) have been procured and the ISI plan has been reviewed

by the ANII in accordance with Article IWA-2120 of the ASME

Code.

c. The ISI plan has been reviewed by the licensee's site nuclear

safety review committee, or equivalent licensee review and

approval has been documented.

02.02 Program Organization. Ascertain whether the following

items are included in the ISI program:

a. Identification of all licensee commitments and regulatory

requirements pertinent to ISI testing and monitoring.

b. Means of preparing plans and schedules and filing them with

enforcement and regulatory authorities having jurisdiction at

the facility.
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c. Sufficient organizational staff, both in number and training,

to ensure that acceptable ISI work is performed.

d. Site administrative procedures are in place to define the

authority and responsibilities of the persons or organizations

involved with the final evaluation and acceptance of ISI

results for the licensee.
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02.03 Quality Assurance Program. Review the licensee's and ISI

contractor's quality assurance programs to verify the following

items are included:

a. Procedures for the maintenance of required ISI records.

b. QA review includes assurance that plans and procedures have

been reviewed by appropriate personnel and meet regulatory

requirements.

c. Procedures are established for the corrective action of

conditions adverse to quality as detected during examination,

including provisions to preclude repetition of such adverse

conditions.

d. Audits or surveillances of ISI activities are conducted by

qualified QA personnel to verify compliance with the ISI

program.

e. Procedures are established to effectively oversee contractor

activities concerned with ISI/PSI.

02.04 Repair Program. Review the licensee's administrative and

maintenance procedures to verify that the requirements of Article

IWA-4000 of the ASME Code, and NRC supplementary requirements, are

included or referenced.

02.05 Replacement Program. Review the licensee's administrative

and maintenance procedures to verify that requirements of Article

IWA-7000 of the ASME Code, and NRC supplementary requirements, are

included or referenced.

02.06 Records. Ascertain that provisions for the maintenance

and retention of records, including inspection, examination, test

reports, repair and replacement, QA, and NDE records have been

established in the ISI program.

02.07 Qualification of Personnel. Ascertain whether the program

specifies personnel qualification requirements consistent with the

ASME Code, plant Technical Specifications (TS), and other applicable

documents.

02.08 Reporting Requirements. Verify that the licensee's

program includes the ASME Code and plant TS requirements for

submittal of written reports of ISI results, repairs, and replacements.

02.09 Relief Requests. Verify that the licensee's program

contains guidance regarding the identification and processing of

requests for relief from ASME Code requirements. Conduct a walkdown

inspection or an ISI data review, as appropriate, to verify that the

bases for the relief requested are valid and accurate.

73051-03 INSPECTION GUIDANCE
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General Guidance. The review of the licensee's program is to be

conducted for the PSI of each unit and for the first ISI of each

unit. Subsequent reviews shall be conducted every other outage and

should key only on program changes. The inspection frequency should

be increased if the licensee receives a Category 3 SALP rating in

the "outage" functional area. Additionally, a review of the

licensee's program shall be conducted upon submittal of the program

document to the NRC at the prescribed 10-year interval.

This procedure covers ASME Section XI with the exception of those

items in the PSI program that are covered in the Preoperational Test

Program, Chapter 7000 of the IE Manual.

For the purpose of this inspection procedure, the term, "ISI

program," includes the ISI plan and the administrative, technical,

and quality assurance programs required to implement the plan.

03.01 Specific Guidance.

a. Inspection Requirement 02.01. Pursuant to 10 CFR 50.55a(g),

the licensee periodically submits an updated ISI program to

the NRC for review and approval. Requirements delineated in

this program are regulatory requirements as are the TS. In

the event of conflict between the TS and 10 CFR 50.55a(g), the

regulatory position is that of the more stringent requirement.

Exceptions to or deviations from testing requirements shall

be consistent with those permitted by the ISI program approved

by the NRC.

b. Inspection Requirement 02.02. The PSI/ISI program requirements differ for each facility. Each facility will have

submitted an ISI plan to the NRC and often have been granted

relief from certain requirements. The inspector should

contact the licensing project manager for the site to

determine the status of any relief requests for TS changes

involving PSI/ISI activities. The inspector should develop

a list of requirements and commitments involving ISI and

determine if the licensee's program provides a means of

tracking requirements and commitments. ANSI N45.2.6,

"Qualification of Inspection, Examination, and Testing

Personnel" and RG 1.58, "Qualification of Nuclear Power Plant

Inspection, Examination, and Testing Personnel" provide

guidance to ensure that commitments to qualifications of

organizational staff are met.

The inspector should also be aware of NRC/industry initiatives

in the area of qualification of procedures and personnel for

ISI.

c. Inspection Requirement 02.03. PSI and ISI activities are

subject to QA audit, monitor, surveillance, and QC inspection.

The licensee's QA Manual and (if applicable) contractor's QA

Manual should cover all PSI and ISI activities.

The QA program must be documented in accordance with 10 CFR

50 or ANSI/ASME NQA-1-1979, "Quality Assurance Program

Requirements for Nuclear Facilities, Parts II and III."
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d. Inspection Requirement 02.04. Detailed requirements for

repair programs are specified in Article IWA-4000 of the ASME

Code. Repairs should be performed in accordance with the

licensee's design specifications and the Construction Code of

the component or systems to be repaired. Later editions of

the Construction Code or Section III may be used. If repair

welding cannot be performed in accordance with these requirements, the following may be used:

1. IWB - 4000 for class 1 components

2. IWC - 4000 for class 2 components

3. IWD - 4000 for class 3 components

4. IWE - 4000 for class MC components

Proper justification is essential for deviations from, or

exceptions to, codes and standards.

Individual repair projects differ widely, so the licensee's

pre-established program must recognize this. The program

should address the various aspects of repair work and require

that explicit procedures be developed, reviewed, approved, and

implemented to accomplish the specific project.

e. Inspection Requirement 02.06. As required by Section XI, the

licensee prepares records of inservice inspection. The

standard FSAR and standard TS specify record retention

periods, and ANSI N45.2.9 provides specific guidance on

retention periods and design features for a permanent record

storage facility. It is not necessary that all PSI and ISI

records be stored onsite. Special concern should be given to

the acquisition and proper storage of PSI records for the PSI

performed by the manufacturer. The licensee's program for the

evaluation of indications found during ISI should include the

requirement that the inspection results be compared to the

last ISI or the PSI results.

f. Inspection Requirement 02.09. Requests for relief based on

component inaccessibility should be verified by performing a

walkdown inspection of the item for which relief was requested. For requests based on other limitations to inspection, a review of existing NDE data should be performed.

Also, during PSI program reviews, the inspector should verify

that the relief requests do not involve matters that are

rejectable under the original system building code (i.e., ASME

Code Section III).

73051-04 REFERENCES

ASME Code Section XI, "Rules for Inservice Inspection of Nuclear

Power Plant Components."

ANSI N45.2.6, "Qualification of Inspection, Examination, and Test

Personnel."
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Society for Nondestructive Testing, "Recommended Practice No.

SNT-TC-1A."

ANSI N45.2.9., "Requirements for Collection, Storage, and Maintenance of QA Records."

Regulatory Guide 1.58, "Qualification of Nuclear Power Plant

Inspection, Examination, and Testing Personnel."

ANSI NQA-1-1979, "Quality Assurance Program Requirements for Nuclear

Facilities, Parts II and III."

Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability - ASME Section XI Division 1."

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