ML19255E180

IP 73054 Part 52, Preservice and Inservice Inspection - Review of Program

ML19255E180
Person / Time
Issue date:	03/04/2020
From:	Michael Webb NRC/NRR/VPOB
To:
M. Webb
Shared Package
ML19255E120, ML20063E879	List:
References
CN 20-013
Download: ML19255E180 (14)

Text

NRC INSPECTION MANUAL NPHP INSPECTION PROCEDURE 73054 PART 52, PRESERVICE AND INSERVICE INSPECTION - REVIEW OF PROGRAM PROGRAM APPLICABILITY: IMC 2504 B 73054-01 INSPECTION OBJECTIVE 01.01 To verify whether the licensee's program pertaining to the Preservice Inspection (PSI) and In-service Inspection (ISI) is in conformance with regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a and the licensee's commitments and is ready to support the operation of the facility.

01.02 To verify that the PSI and ISI programs include: the proper scope of components, inspection requirements, and have been approved.

01.03 To verify that the Quality Assurance (QA) Program will support execution of the PSI/ISI programs.

01.04 To verify that the Repair/Replacement Program is established to allow repairs and replacements to be made in accordance with 10 CFR 50.55a and American Society of Mechanical Engineering (ASME) Boiler and Pressure Vessel Code requirements.

01.05 To verify that records maintenance and retention will support execution of the PSI/ISI program.

01.06 To verify that the licensee has established proper training requirements for personnel.

01.07 To verify that the licensee has established reporting requirements and methods.

01.08 To verify that the PSI/ISI program includes methods for requesting relief from or alternatives to the requirements.

73054-02 INSPECTION REQUIREMENTS AND GUIDANCE General Guidance: Inspectors performing this procedure should be familiar with the edition and addenda of Section XI being used for the PSI/ISI program. The inspectors should also be cognizant of the requirements of 10 CFR 50.55a and 10 CFR Part 50, Appendix B, as they relate to the implementation of preservice and ISI programs.

For the purpose of this inspection procedure, the term, "PSI/ISI program," includes the Repair/Replacement Program and the PSI/ISI plans and schedules for all components subject to examination per ASME Section XI and 10 CFR 50.55a. The term PSI/ISI program also includes all supporting administrative, technical, and QA documents, records, and Issue Date: 03/04/20 1 73054

procedures required to implement the PSI/ISI program in accordance with the regulatory requirements, license conditions, and the licensees commitments.

This procedure covers the review of the licensees PSI program for each unit and the licensees planned initial ISI program for each unit. This procedure also covers all ASME Section XI PSI/ISI activities except system pressure testing, which is covered in the Preoperational Test Program and inspected using other Inspection Procedures (IP) indexed in Appendix B of IMC 2504. The inspection percentages should be increased, as outlined in the following sections, if inspection results reveal issues in certain areas of program development.

Inspectors may use this IP to perform verification of the PSI program and ISI program together or separately. This will depend on the licensees implementation schedule and the Regions plan and schedule for the IMC 2504 inspections. If the PSI and ISI program inspections are performed separately using this IP, then the ISI program inspection should only focus on verifying the aspects of the ISI program that are different than the PSI program. Specifically, the ISI program inspection, at a minimum, should include the following procedure steps:

1. Verify that the appropriate percentages of components were selected for ISI (Sections 02.03.b.2, 02.03.c.2)

2. Verify that any proposed ASME Code Cases and alternatives have been approved by the NRC (Section 02.01.c-e)

3. Verify that the ISI program for steam generator tubing is in accordance with the Technical Specifications and Nuclear Energy Institute guidelines (Section 02.03.i)

4. Verify that augmented inspections described in the Final Safety Analysis Report or other licensee commitments have been included in the ISI program (Section 02.03.h)

5. Verify that Repair/Replacement Program activities meet the appropriate requirements (Section 02.05)

6. Verify that the ISI program has been filed with the NRC (Section 02.08)

For sites with multiple units under construction, it may be beneficial for the inspectors to take credit for performing portions of this procedure on one units program. However, some portions of the IP, such as Step 02.03, should include sampling from all units under construction.

Some licensees may have implemented a risk-informed ISI program. Currently, implementation of a risk-informed ISI program requires NRC authorization in accordance with 10 CFR 50.55a(z) as an alternative to the ISI requirements of Section XI of the ASME Code. If the licensee has implemented a risk-informed ISI program, obtain the submittal and the NRCs safety evaluation before reviewing the program. Alternatively, inspectors may obtain support from the program office in conducting the risk-informed ISI inspection. The risk-informed approach is not applicable to the PSI requirements.

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

Guidance: This procedure step should be performed prior to performing any other sections of the IP.

Issue Date: 03/04/20 2 73054

a. Verify that the licensee has reviewed and approved PSI and ISI plans and that the licensee has documented the review and approval.

b. Verify that the licensee has procured the services of an Authorized Nuclear In-service Inspector (ANII) and that the ANII has reviewed the PSI and ISI plans.

c. Verify that any ASME Code Cases proposed for use as part of the PSI or ISI plans are approved by the NRC, per 10 CFR 50.55a and detailed in Regulatory Guide 1.147, or have been approved by NRC for use as an alternative to the ASME Code.

d. Verify that the NRC has authorized alternatives to the ASME Code requirements, if any, identified in the PSI/ISI program prior to use pursuant to 10 CFR 50.55a(z).

02.02 Program Organization. Verify the following items are included in the PSI/ISI program or in site procedures:

a. Identification of all licensee commitments and regulatory requirements pertinent to preservice and in-service examination.

Guidance: The inspector should develop a list of requirements and commitments, and determine if the licensee's program provides a means of tracking requirements and commitments.

If the licensee has adopted a risk-informed ISI program, the inspector should obtain the licensee submittal that requested use of this alternative method and the safety evaluation report issued by the NRC. Compare this material to the ISI program to ensure the requirements are met.

b. Means of preparing plans and schedules and filing them with enforcement and regulatory authorities having jurisdiction at the facility.

c. Site administrative procedures to define the authority and responsibilities of the persons or organizations involved with the final evaluation and acceptance of PSI/ISI results for the licensee.

d. Process for demonstrating alternative nondestructive examination methods to the ANII in accordance with the ASME Code,Section XI, IWA-2240.

Guidance: If there are no alternative nondestructive examination methods proposed in the PSI/ISI program, then this step may be skipped.

e. The ASME Code edition and addenda to be used for PSI/ISI is identified.

02.03 Program Scope. Verify the PSI/ISI program, including examinations and tests, is in conformance with relevant ASME Code,Section XI editions and addenda, and ASME Code cases proposed for use as part of the plan, as follows:

Guidance: Pursuant to 10 CFR 50.55a(g), ASME Section XI, IWA-2420, and ASME Section XI, IWA-6000, the licensee develops PSI and ISI plans and schedules.

Exceptions to or deviations from examination requirements shall be in accordance with those permitted by the PSI/ISI program as approved by the NRC.

Issue Date: 03/04/20 3 73054

It may be necessary to obtain support from the program office to support this phase of inspections. Contact NRO as needed to obtain the necessary support.

a. Obtain a listing of all ASME Code,Section XI Class 1, 2 and 3 components and welds in the PSI/ISI database.

Guidance: The inspector should verify that the PSI/ISI database is controlled as part of the QA program. If the licensee does not use a PSI/ISI database, then the inspector should perform the IP steps that refer to the database using whatever document the licensee uses to list the components that are part of the PSI/ISI program.

b. Obtain drawings of Class 1 systems, including all applicable components. Components (vessels, pumps, valves, piping, etc.) include all related items, such as welds, bolted connections, and integral attachments that are subject to examination in accordance with ASME Section XI, IWB-2500. Using these drawings, perform the following procedure steps:

Guidance: The review sample should include each of the Examination Categories in ASME Code,Section XI, Article IWB. The inspector can stop the review once 15% of the total components on the listing have been verified, and no Class 1 components were inappropriately omitted from the PSI/ISI database. If components were inappropriately omitted from the database, continue the review with an additional 15%

of the database. If no additional components were inappropriately omitted from the database then the inspector may conclude the review. However, if additional components are identified that were inappropriately omitted from the PSI/ISI database, the inspector should terminate this portion of the inspection, notify the licensee, and schedule a follow-up after the licensee corrects the deficiencies and reviews the database.

1. Use Table IWB-2500 of the ASME Code,Section XI to verify all Class 1 components, subject to the guidance above, and ensure they are listed within the PSI/ISI database.

2. For each component selected, verify that the appropriate percentages of associated items were selected for PSI/ISI examination as required by ASME Code,Section XI IWB-2200 and the tables of IWB-2500, or the optional ASME Code Cases approved for use at the site, or the applicable risk-informed ISI requirements, excluding those exempted by IWB-1220.

GUIDANCE: For piping, it may be necessary to look at the entire piping system in order to verify that the appropriate percentages have been selected in accordance with the ASME Code.

3. Verify that the proper PSI/ISI examination for Class 1 components is identified in the database.

4. Identify any Class 1 weld/component not included in the database.

c. Obtain drawings showing the bolted connections, welds, and welded attachments for three Class 2 piping systems, including vessels. When selecting the sample, the Issue Date: 03/04/20 4 73054

inspectors should consider the size of the system as well as its risk significance. Using these drawings, perform the following procedure steps:

Guidance: If the licensee does not use a PSI/ISI database, then the IP steps that refer to the database should be performed using whatever document the licensee uses to list the components that are part of the PSI/ISI program.

1. Use Table IWC-2500 of the ASME Code,Section XI to verify all Class 2 components and ensure they are listed within the PSI/ISI database. If a risk-informed ISI has been approved verify the Class 2 components are listed within the ISI database.

2. Verify that the appropriate percentages of associated items were selected for PSI/ISI examination as required by the tables of ASME Code,Section XI, IWC-2500, or the appropriate risk-informed ISI requirements.

3. Verify that the proper PSI/ISI examination for Class 2 components is identified in the database.

4. If the inspector determines components were inappropriately omitted from the database, review the drawings for an additional three piping systems as outlined above. If no other components were inappropriately omitted, terminate the review.

5. If the inspector identifies additional components that were inappropriately omitted, terminate the review and notify the licensee and reschedule another review after the licensee corrects and reviews the database.

d. For a representative sample of Class 1 and Class 2 system piping, conduct a detailed review of the drawings and walkdown the system, ensure that all welds are depicted, and evaluate a selection of the components to ascertain accessibility and clearances for future ISIs. Determine if construction modifications have added welds, if so, have these welds been added to the PSI/ISI scope.

e. Obtain drawings for a minimum of ten ASME Code Class 3 components (preferably different types of components), showing the welded attachments. Using these drawings, perform the following procedure steps:

Guidance: If the licensee does not use a PSI/ISI database, then the inspectors should perform the IP steps that refer to the database using whatever document the licensee uses to list the components that are part of the PSI/ISI program.

1. If the components are present on site, then conduct a detailed review of the drawings and verify the accuracy of the welded attachment details for five of these components.

2. Identify all the attachment welds that are part of the ASME Code,Section XI PSI/ISI scope as identified in the tables of ASME,Section XI, IWD-2500 and ensure they are listed within the ISI database.

Issue Date: 03/04/20 5 73054

3. Verify that the appropriate number of attachment welds was selected for PSI/ISI examination as required by ASME Code,Section XI, IWD-2200 and are identified in the table of IWD-2500.

4. Verify that the database identifies the proper PSI/ISI examination for Class 3 components.

f. Obtain a listing of all ASME Class 1, 2, and 3 piping and component supports in the PSI/ISI database. Obtain a representative sample of isometric drawings from ASME Class 1, 2, and 3 systems that show pipe support designation and location. Using these drawings and the PSI/ISI database, perform the following procedure steps:

Guidance: If the licensee does not use a PSI/ISI database, then the inspectors should perform the IP steps that refer to the database using whatever document the licensee uses to list the components that are part of the PSI/ISI program.

1. Verify that piping/component supports on these drawings are contained within the PSI/ISI database.

2. Verify that the proper inspections are specified for piping/component supports in the PSI/ISI database in accordance with ASME Code,Section XI, IWF-2500.

3. During the construction phase, the inspector should field verify (i.e., walkdown) the piping isometric drawings and checking the accuracy of the pipe support information.

g. On a sampling basis, verify that the proper inspections are specified for the containment in the PSI/ISI database or other controlled document in accordance with ASME Code,Section XI, IWE/IWL-2500.

h. Verify that the augmented inspections described in the Final Safety Analysis Report (FSAR) or other licensee commitments have been included in the PSI/ISI program or some other program document.

Guidance: At the time of the inspection, the augmented inspections identified below may not be an all-inclusive list. Therefore, the inspector should review the FSAR to verify that the ISI program has been augmented as described.

1. All Licensees: The ISI program of all plants shall be augmented to include a 100% volumetric examination of the ASME Code required inspection volume of all pipe welds in high-energy piping in containment penetration areas (i.e., the break exclusion region/zone) during each inspection interval as defined in ASME Code,Section XI, IWA-2400. The break exclusion region/zone and affected piping subject to this augmented inservice examination is defined in FSAR Section 3.6.2. Select a representative sample of supports to verify that piping/component supports on these drawings are contained within the PSI/ISI database.

Class 2 piping welds in the area from the containment wall to and including the inboard or outboard isolation valves shall be defined in accordance with Issue Date: 03/04/20 6 73054

Examination Categories C-F and C-G, Table IWC-2520-1, Examination Categories,Section XI, ASME B&PV Code.

2. Pressurized Water Reactors: The ISI program for all pressurized water reactors shall be augmented with the inspections required by the following ASME Code Cases:

a. ASME Code Case N-729-1, entitled Alternative Examination Requirements for [pressurized-water reactor] PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration WeldsSection XI, Division 1, and subject to the conditions of 10 CFR 50.55a (g)(6)(ii)(D)(2) through (6).

ASME Code Case N-722-1, entitled Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated With Alloy 600/82/182 Materials, and subject to the conditions of 10 CFR 50.55a (g)(6)(ii)(E)(2) through (4). The inspection requirements of N-722-1 do not apply to components with pressure retaining welds fabricated with Alloy 600/82/182 materials that have been mitigated by weld overlay or stress improvement.

b. ABWR plants: The ISI program for licensees that reference the Advanced Boiling Water Reactor design certification shall be augmented to include the ISI of feedwater nozzles to address the issues identified in NUREG-0619, BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking. The ISI program should include the inspections described in FSAR Section 19B.2.6, A-10 BWR Feedwater Nozzle Cracking.

3. AP1000 Plants: The ISI program for licensees that reference the AP1000 design certification shall be augmented to include the performance of a 100% volumetric examination of the weld build-up on the reactor vessel head for the instrumentation nozzle penetrations (Quickloc) conducted once each inspection interval (reference: FSAR Section 5.2.4.1).

i. Verify that the PSI/ISI program for SG tubing complies with the Technical Specifications and is in accordance with the NEI 97-06 Steam Generator Program Guidelines. NEI 97-06 references the Electric Power Research Institute (EPRI) Pressurized Water Reactor Steam Generator Examination Guidelines and other guidelines that make up the EPRI Steam Generator Management Program.

Guidance: Using the plant Technical Specifications and EPRI guidance the inspectors should verify the following:

1. PSI of SG tubes and tube plugs is in accordance with Section 3.2 of the EPRI PWR Steam Generator Examination Guidelines report.

2. Planned ISI of SG tubes, tube sleeves, and tube plugs, and other tube repairs complies with the Technical Specifications and is in accordance with Sections 3.4 and 3.5 of the EPRI PWR Steam Generator Examination Guidelines report.

Issue Date: 03/04/20 7 73054

3. The licensee has documented the basis for any deviations from the EPRI guidelines.

4. If the licensees program refers to the use of tube repair methods (e.g., sleeves) or alternate plugging or repair criteria, verify that the NRC staff has approved a corresponding license amendment.

02.04 Quality Assurance Program. Verify the following items are included in the licensee's and PSI/ISI contractor's QA programs:

a. Procedures for the maintenance of required PSI/ISI records.

b. QA review includes assurance that plans and procedures have been reviewed 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 surveillance of PSI/ISI activities are conducted by qualified QA personnel to verify compliance with the PSI/ISI program.

e. Procedures are established to effectively oversee contractor activities concerned with PSI/ISI.

Guidance: PSI and ISI activities are subject to QA audit, monitor, surveillance, and Quality Control 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 Part 50, Appendix B, or ASME NQA-1. The edition and addenda of ASME NQA-1 endorsed by the staff will be identified in Regulatory Guide (RG) 1.28, Quality Assurance Program Criteria (Design and Construction).

f. Verify that measures are in place to ensure that changes to the design are translated into the PSI/ISI program.

Guidance: PSI/ISI programs are developed and updated using a plant design that has been frozen to a certain date. As design changes and construction modifications occur, the licensee must have design control measures (per 10 CFR Part 50, Appendix B) in place to ensure that these changes are included in the design documents used to update the PSI/ISI program. These measures will ensure that ASME Code,Section XI requirements are met even as the design changes over time.

02.05 Code Repair/Replacement Program Review. Verify that the Repair/Replacement Program meets the requirements of the ASME Code,Section XI.

Guidance: Prior to the Commission making its finding under 10 CFR 52.103(g), repairs to ASME Code components shall be made to the Construction Code (Section III).

Issue Date: 03/04/20 8 73054

ASME Code,Section XI rules for Repair/Replacement may be used prior to the 52.103(g) finding, provided they do not conflict with Section III requirements. If they do conflict, then the inspector should verify that licensee has submitted its proposed use of Section XI rules to the NRC for authorization as an alternative to the regulations pursuant to 10 CFR 50.55a(z). Per 10 CFR 50.55a(z), the alternative must be approved prior to its use.

Given the requirement that repairs be performed to ASME Section III prior to the 52.103(g) finding, the licensee may not have a traditional Section XI IWA-4000 Repair/Replacement Program in place until the ISI program is developed.

a. Verify the following:

1. For PSI, verify the licensees program, and site procedures, ensure that repair/replacement is performed in accordance with ASME Section III requirements.

2. For ISI, verify that the R/R Program is in accordance with the requirements of ASME code,Section XI, IWA-4000 and 10 CFR 50.55a.

Guidance: The inspector performing this IP step should be familiar with the edition and addenda of Section XI being used for the R/R program. The inspector should also be cognizant of the requirements related to Repair/Replacement plans, acceptability/suitability reviews, Inspection (Authorized Inspection Agency), the application of Section XI Code Cases, and reconciliation.

b. If repair/replacement activities have occurred at the time of inspection, then verify the following:

1. Verify, by sampling, that repairs were performed to ASME Code Section III requirements.

2. Verify, by sampling, that the licensee has evaluated all repair and replacement actions in accordance with 10 CFR 50.59 to ensure that a license amendment is not required.

02.06 Records. Verify that provisions for the maintenance and retention of records, including inspection, examination, test reports, repair and replacement, QA, and nondestructive examination (NDE) records have been established in the PSI/ISI program.

Guidance: As required by ASME Code,Section III or XI, the licensee prepares records of ISI. The FSAR, the PSI/ISI program, or site procedures should specify record retention periods, and ASME NQA-1 and RG 1.28 provide 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 component manufacturer.

Issue Date: 03/04/20 9 73054

02.07 Qualification of Personnel. Verify that the PSI/ISI program, and applicable site procedures, specify personnel qualification requirements that are consistent with the ASME Code, and other applicable documents.

Guidance: Per ASME Section XI, personnel performing NDE shall be qualified and certified using a written practice in accordance with ANSI/ASNT CP-189, as amended by the requirements of IWA-2300. Other certifications (i.e., SNT-TC-1a, ANS45.2.6, etc.) are valid until recertification is required. Outside agencies, as defined in ASME Section XI, Appendix VII, may be used to qualify NDE personnel; however, the certification of Levels I, II, and III personnel is the sole responsibility of their employer.

The inspector should review the written practice of each organization (i.e. licensee, vendor, and/or subcontractors) that certifies personnel performing NDE as part of the PSI/ISI program. When more than one organization is involved, the inspectors should verify the responsibilities, interfaces, and authority of each organization to ensure that the appropriate documents are reviewed.

The inspector should also be aware of NRC and industry initiatives in the area of qualification of procedures and personnel for PSI/ISI, such as the EPRI Performance Demonstration Initiative for the qualification of procedures and personnel for ultrasonic testing.

02.08 Reporting Requirements. Verify that the licensee's program includes the ASME Code and plant Technical Specification requirements, as applicable, for submittal of written reports of PSI/ISI results and repairs/replacements.

Guidance: The intent of the review is to ensure the licensees program has provisions for submitting the reports required by ASME Section XI, IWA-6000, or any other applicable governing document or site procedure.

For reviews during construction, just prior to commercial service, the inspector should review the PSI summary report and initial ISI program, if available and ensure they have been filed with the NRC for review, or that the program has proper instruction to send the PSI summary report and ISI program to the NRC.

02.09 Relief Requests. Verify that the licensee's program contains appropriate guidance regarding the identification and processing of requests for relief from ASME Code requirements that are impractical pursuant to 10 CFR 50.55a(g)(5)(iii).

Guidance: Relief requests per 10 CFR 50.55a(g)(5) are only applicable to the initial and subsequent 120-month inspection intervals and therefore do not apply to PSI. As such, the licensees PSI program, or site procedures, should not allow the submittal of relief requests prior to commercial operation.

73054-03 RESOURCE ESTIMATE Total resource estimate is between 456 and 556 hours0.00644 days <br />0.154 hours <br />9.193122e-4 weeks <br />2.11558e-4 months <br />, depending on what is identified during the inspection. The inspection hours are broken out by sections as identified below.

Issue Date: 03/04/20 10 73054

03.01 Review of Program Approval. Performed in accordance with Section 02.01. This estimate is included in the estimate for the review of the program scope.

03.02 Review of the Program Organization. Performed in accordance with Section 02.02, which involves a review of programmatic procedures, and should take 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />.

03.03 Review of the Program Scope. Performed in accordance with Section 02.03, which includes review of drawings, databases, and walk downs, and should take on the order of 300-400 hours, depending on issues that arise.

03.04 Review of the QA Program. Performed in accordance with Section 02.04 and should take on the order of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

03.05 Review of the Repair/Replacement Program. Performed in accordance with Section 02.05 and should take on the order of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

03.06 Review of Records. Performed in accordance with Section 02.06 and is included within the estimate for the review of the program organization.

03.07 Review of Qualification of Personnel. Performed in accordance with Section 02.07 and should take on the order of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

03.08 Review of Reporting Requirements. Performed in accordance with Section 02.08 and is included within the estimate for the review of the program organization.

03.09 Review of Relief Requests. Performed in accordance with Section 02.09 and is included in the estimate for the review of the program organization.

Guidance: If this IP is used to inspect the PSI program and planned ISI program separately, then the resource estimates provided are only valid for the inspection of the PSI program.

Given that the PSI and ISI program requirements are identical for several inspection areas, the inspectors may take credit for performing portions of the IP once to cover both programs. This will result in a decrease in the resources needed to perform the ISI program inspection.

73054-04 PROCEDURE COMPLETION This procedure is complete when the programmatic portions of each section of the IP have been inspected and verified to meet the intent of that described in the FSAR and the inspectors can make a determination that the program has been adequately implemented.

73054-05 REFERENCES ASME Code,Section XI, "Rules for In-service Inspection of Nuclear Power Plant Components" ANSI/ASNT CP-189 ASNT Standard for Qualification and Certification of Nondestructive Personnel Issue Date: 03/04/20 11 73054

ASME NQA-1-2008, "Quality Assurance Program Requirements for Nuclear Facility Applications" ASME NQA-1a-2009 Addenda to ASME NQA-a-2008, "Quality Assurance Program Requirements for Nuclear Facility Applications" EPRI Primary-to-Secondary Leak Guidelines (ADAMS Accession No. ML050840522)

EPRI Primary Water Chemistry Guidelines (ADAMS Accession No. ML081140284)

EPRI PWR Steam Generator Examination Guidelines (ADAMS Accession No. ML062360553)

EPRI Secondary Water Chemistry Guidelines (ADAMS Accession No. ML050840514)

EPRI Steam Generator Integrity Assessment Guidelines (ADAMS Accession No. ML100480264)

EPRI Steam Generator in Situ Pressure Test Guidelines (ADAMS Accession No. ML072970252)

NEI 97-06, Steam Generator Program Guidelines (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML052710007)

NRC RIS 2007-20, Implementation of Primary-To- Secondary Leakage Performance Criteria NRC RIS 2009-04, Steam Generator Tube Inspection Requirements NRC Information Notice 2010-05, Management of Steam Generator Loose Parts and Automated Eddy Current Data Analysis Regulatory Guide 1.28, Quality Assurance Program Criteria (Design and Construction)

Regulatory Guide 1.147, "In-service Inspection Code Case Acceptability - ASME Section XI Division 1" 10 CFR 50.55a, Codes and Standards 10 CFR 52.99, Inspection during Construction END : Revision History for IP 73054 Issue Date: 03/04/20 12 73054

Attachment 1 - Revision History for IP 73054 Comment Resolution and Closed Feedback Commitment Accession Number Description of Form Accession Tracking Issue Date Description of Change Training Required Number (Pre-Number Change Notice and Completion Date Decisional, Non-Public Information)

N/A 07/01/08 Initial issue to support inspections of operational N/A ML070920379 CN 08-019 programs described in IMC 2504, Non-ITAAC Inspections.

Completed 4-year search of historical CNs and found no commitments.

N/A ML13231A038 Revised to update ASME and other references and to N/A ML13231A039 09/25/13 make editorial changes.

CN 13-023 N/A ML14302A552 Periodic update based on in-depth discussions N/A ML14302A553 12/22/2014 between Headquarters staff and Region II inspectors to CN 14-031 address usability issues. Includes guidance on inspecting the planned ISI program separate from the PSI program; a new section on PSI/ISI program approval; guidance on the sample size of Class 1 components; additional procedure steps for inspection of the PSI/ISI program for SG tubing; a procedure step and guidance for verifying augmented inspections are included in the PSI/ISI program; separate procedure step to verify that procedural controls are in place to prevent omissions from the PSI/ISI program; revised procedure step and guidance regarding Code Repair/Replacement Program review; revised procedure step and guidance regarding relief requests per 10 CFR 50.55a(g)(5)(iii).

Issue Date: 03/04/20 Att1-1 73054

Comment Resolution Description of and Closed Feedback Commitment Accession Number Training Form Accession Tracking Issue Date Description of Change Required and Number (Pre-Number Change Notice Completion Date Decisional, Non-Public Information)

N/A ML17033B611 Periodic update based on in-depth discussions between N/A ML17033B609 05/03/17 HQ staff and Region II inspectors as well as lessons CN 17-009 learned from the first round of PSI program inspections.

Includes revised general guidance; new guidance on alternative examinations; revised guidance and procedure step for repair/replacement; revised guidance on qualification of personnel; revised guidance on reporting requirements; new guidance on relief requests during PSI, revised ASME references and editorial changes.

ML19255E180 N/A None Revised to make changes to the sample selection as well 03/04/20 as additional minor editorial changes.

CN 20-013 Issue Date: 03/04/20 Att1-2 73054