**NRC INSPECTION MANUAL** NMSS/RII

INSPECTION PROCEDURE 88136

MECHANICAL COMPONENTS

PROGRAM APPLICABILITY: 2630

88136‑01 INSPECTION OBJECTIVES

01.01 To determine whether the technical requirements detailed or
referenced in the facility Construction Authorization Request (CAR)
associated with mechanical components in Seismic Category I (SC-I) and
SC-II systems have been adequately addressed in the construction
specifications, drawings, and work procedures.

01.02 To determine whether requirements and commitments, in the approved
QA Quality Assurance (QA) Plan, have been addressed in QA plans,
instructions, and procedures, for mechanical components in SC-I and
SC-II systems, and have been established in the facility QA Manual.

01.03 To determine, through direct observation and independent
evaluation of work, whether the licensee=s work control system is
functioning properly and whether the installation of mechanical
components in SC-I and SC-II systems comply with U.S. Nuclear Regulatory
Commission (NRC) requirements, licensee commitments, and applicable
codes.

01.04 To determine whether the licensee is adequately implementing the
QA program associated with mechanical components, including: (1)
preparing, reviewing, and maintaining a system of quality records; (2)
records reflect work accomplishment consistent with NRC requirements,
CAR commitments, and the QA Plan; and (3) records indicate any
potentially generic problems, management control inadequacies, or other
weaknesses that could have safety significance.

88136‑02 INSPECTION REQUIREMENTS

02.01 Review construction documentation (specifications, drawings, and
work procedures) and QA procedures to determine whether they
appropriately and adequately

assure that specific activities associated with Quality Level 1 (QL-1)
and QL-2 mechanical components are controlled and performed according to
NRC requirements, CAR commitments, and the approved QA Plan. In
particular, ascertain whether provisions have been established to assure
that:

a.  Procurement documents incorporate the technical and quality
    requirements in the material requisition. This includes
    identification of material specifications and, if required,
    performance test requirements.

b.  Receipt inspections are adequate and capable of detecting damage or
    out‑of‑specification conditions, including adequacy of performance
    testing, etc. Also, provisions are in place to prevent nonconforming
    equipment and materials from being installed and used.

c.  Installation, testing, and inspection activities meet applicable
    specifications and established procedures.

d.  Specially trained personnel are used whenever complex or unusual
    activities are involved.

e.  Specifications and installation procedures for motor-operated valves
    provide detailed information relative to the setting of torque
    switches, limit switches, and limit-switch bypasses.

f.  Post‑inspection cleaning, preservation, and inspection requirements
    have been established before needed.

g.  Record-keeping requirements are established and clearly indicate
    those responsible for record generation; and provisions exist for
    their review by appropriate management personnel.

h.  Design changes, including field changes, are properly reviewed and
    coordinated among affected design and engineering organizations.

02.02 Select representative mechanical components for several QL-1 Items
Relied on for Safety (IROFS) and QL-2 Structures Systems and Components
(SSCs) (the approximate number of QL-1 and QL-2 items to inspect should
be specified in an approved inspection plan). The sample should contain
materials handling, fluid transport, and fluid systems components
(including, process vessels, tanks, and enclosures). Observe work
performance, partially completed work, and/or completed work on these
components, as appropriate. Review the pertinent quality-related \[work
and Quality Control (QC) inspection\] records relative to the components
selected, or a similar selection of components if more appropriate.
Determine whether the following activities, for each of the above
selected components, meet applicable requirements:

a.  [Receipt Inspection]{.underline}.

    1.  Adherence to receipt inspection procedures. Records confirm that
        required material characteristics, performance tests,
        nondestructive tests, environmental qualification tests, and
        other specification requirements are met.

    2.  Receipt inspection and storage records indicate that, where
        appropriate, defective or incorrect components, parts, and
        materials are controlled and prevented from installation and
        possible use.

    3.  Documentation has been prepared and maintained as required by
        receipt inspection and documentation storage instructions.

b.  [Storage, Handling, and Protection]{.underline}.

    1.  Storage environment and protection of components (protective
        covers, caps, preservatives, desiccants, heaters, inert gas
        blankets, etc.) are in accordance with manufacturer=s
        instructions and/or established procedures.

    2.  Implementation of special storage and maintenance requirements
        such as rotation of motors, pumps, lubrication, insulation
        testing (electrical), cleanliness, etc.

    3.  Performance of licensee/contractor surveillance activities and
        documentation thereof are being accomplished at required
        frequency.

c.  [Installation]{.underline}.

    1.  Installation requirements such as proper location, placement,
        orientation, alignment, mounting (torquing of bolts and
        expansion anchors), flow direction, tolerances, and expansion
        clearance are met.

    2.  Precautions to prevent damage during placement/mounting are
        adhered to, where appropriate.

    3.  Availability and usage of specially trained personnel and
        equipment where required to meet component manufacturer=s
        instructions.

    4.  Torque switches, limit switches, and bypass switches on valves
        have been properly installed, adjusted and checked out, in
        accordance with established instructions and procedures.
        Integrated system checks could be a potential focus of
        inspection.

    5.  Appropriate drawings and work procedures are available to
        installers. Installation requirements, construction drawings,
        specifications, and work procedures are technically adequate and
        of the latest approved issue.

    6.  Hold points are observed, when required.

    7.  Design changes relevant to the work being observed have been
        appropriately processed through required review and approval
        routes.

    8.  Preparation and maintenance of installation and inspection
        records are adequate.

d.  [Protection and Maintenance after Installation]{.underline}.

    1.  Inspection activities, including scope and frequency, are being
        performed according to instructions.

    2.  Protection provided as required, including protection against
        adverse temperature, humidity, flooding, and foreign materials,
        such as dirt, dust, bottles, cans, and general debris.

    3.  Lubrication, rotation, and electrical resistance checks are
        being performed, as required.

    4.  Records are being maintained on the status of installed
        components.

    5.  Appropriate stamps, tags, markings, etc., are in use to prevent
        oversight of required inspections, completion of tests,
        acceptance, and the prevention of inadvertent operation.

02.03 Select several as‑built/final design system drawings and compare
portions of these drawings with the actual installation. Discrepancies
observed may be caused by in‑process changes, such as those initiated by
the design organization, or those initiated in the field. If in‑process
changes are involved, determine whether the licensee has properly
controlled and documented these changes on a current base or engineering
review, approval, and subsequent incorporation in final as‑built
drawings.

02.04 Select various persons engaged in work activities, associated with
installation and inspection of mechanical components, and confirm or
discuss the following:

a.  Qualifications of those engaged in component installation and
    inspection work appear adequate and commensurate with the work in
    progress.

b.  Ability to perform their assigned duties and assume their assigned
    responsibilities.

c.  There is adequate time allocated to the QC function to study
    installation specifications and instructions and to perform the
    required component inspections.

d.  An appropriate level of independence exists between QA/QC and
    construction (i.e., organizational freedom to identify nonconforming
    conditions and document their existence).

e.  Adequate management support for QA/QC functions.

f.  Effectiveness of management=s control over component installation
    work as may be evidenced through the performance of audits (or their
    arrangements to have others conduct audits) including follow-up of
    audit findings.

02.05. Determine whether qualified licensee/contractor, engineering,
craft, and inspection personnel, associated with the installation of
QL-1 and QL-2 component-installation work are being used, by reviewing a
sampling (approximately five to 10 records total), covering several
different disciplines, of personnel-qualification records, as follows:

a.  Determine whether a system of personnel-qualification records
    meeting stated requirements exists and is being maintained in
    current status.

b.  Determine if the records are sufficient to reasonably support
    qualification in terms of certification, experience, proficiency,
    training, testing, etc., as applicable.

c.  Review the actions taken by responsible licensee/contractor
    organizations to independently authenticate the validity of critical
    qualification statements.

02.06 Review the licensee/contractor system for reporting and
dispositioning nonconformances associated with the procurement,
installation, and testing of QL-1 and QL-2 mechanical components, to
determine whether:

a.  Records adequately document current status of nonconformance and
    deviations. Review approximately 10 nonconformance/deviation
    reports, to sample system effectiveness.

b.  The sample of records is legible and complete, and indicates that
    reports are promptly reviewed by qualified personnel.

c.  Records are routinely being processed through established channels,
    for resolution of the immediate problem, as well as generic
    implications.

d.  Corrective actions are appropriate to the circumstances and are
    appropriately prioritized.

e.  Records are being properly identified and stored, and can be
    retrieved in a reasonable time.

f.  Nonconformance reports include the status of corrective actions or
    resolutions and actions to prevent recurrences.

02.07 Determine whether the licensee has an established audit program
(including audit plans, procedures, and schedules) covering work and
control functions in the area of QL-1 and QL-2 component installation.
Sample the audit output for the components, processes, and work being
followed in the inspection effort.

88136‑03 INSPECTION GUIDANCE

03.01 [General Guidance]{.underline}.

a.  Applicable portions of the CAR (and Integrated Safety Analysis (ISA)
    Summary, if available) should be reviewed, to determine licensee
    commitments relative to mechanical components (including, process
    vessels, tanks, and enclosures), before performing this inspection.
    The inspectors should then use the CAR and Safety Evaluation Report
    (SER) commitments during the review of the licensee=s implementing
    construction specifications, drawings, work procedures, and QA
    implementing procedures. Some of this review can be completed in the
    office, during inspection preparation, if previous arrangements have
    been made with the licensee to provide selected documents.

b.  Particular attention should be given to the traceability of material
    and equipment, to prevent the use of incorrect or defective
    materials, parts, and components. The inspectors may review 10 CFR
    Part 50, Appendix B, Criterion VIII, AIdentification and Control of
    Materials, Parts, and Components,@ and applicable codes and
    specifications, for additional guidance. The inspectors should
    verify that the licensee has established measures for identification
    and control of materials, parts, and components, and for
    traceability, to the approved design basis and to the source. The
    inspectors should ensure that required identification of the item is
    maintained by heat number, part number, serial number or other
    appropriate means, either on the item or on records traceable to the
    item, as required, and that required markings are on the item.

> The inspectors should note markings on material and equipment and
> verify that the markings represent material and equipment as specified
> by the design drawings and specifications. In the case of fasteners,
> compliance with the applicable material specification \[e.g.,
> (American Society for Testing and Materials) or (American Society for
> Mechanical Engineers) material and grade\] should be verified by
> required markings on bolts and nuts and certified material test
> reports or certificates of conformance, as required by the applicable
> procurement drawings and specifications, and/or by the applicable
> codes and specifications. In the case of vendor‑supplied equipment
> assemblies containing fasteners, samples should be inspected to verify
> compliance with approved vendor drawings and specifications and other
> information, such as materials used for equipment-qualification tests
> and/or analyses. Caution should be exercised to ensure that the
> required markings on material and equipment, including fasteners, not
> only exist, but that the markings indicate the correct material and
> grade, as specified.

c.  Findings from this inspection activity should address each element
    covered during the inspection as being satisfactory, being
    unresolved and requiring resolution, or being in violation and
    requiring correction. If significant inadequacies or weaknesses are
    identified in the implementation of established management-control
    systems, the inspectors should so inform cognizant Regional
    supervision. The issue should be promptly addressed and resolved at
    the appropriate level of licensee management.

d.  The inspectors may not be able to observe all facets of all
    activities identified in Section 02, of this procedure, during a
    particular inspection. However, direct observation of important
    activities should be made on a sampling basis. In some cases it will
    be necessary to observe a completed activity rather than work in
    progress. The inspectors= judgment in sample selection should
    consider both the importance of the component to overall plant
    safety and the opportunity to inspect during the most advantageous
    part of the installation effort.

03.02 [Specific Guidance]{.underline}.

Note: The numbering of the guidance below refers to specific subsections
of 02, above.

> 02.01 If any of the inspection requirements pertaining to mechanical
> components have been previously completed, because the same
> organization and procedures were recently or are presently used at the
> site for similar work, the inspection requirements need not be
> repeated (unless problems were found in the previous inspection of
> those requirements).
>
> 02.02b Material-storage procedures should include the requirements
> that components be identified; properly segregated by type; provided
> protection from physical or contamination damage, during handling and
> storage; and that controls for component withdrawal are provided, to
> ensure proper issuance.
>
> 02.03 Components selected should be representative of the type of
> plant components involved in materials-handling, fluid transport, and
> fluid systems, as described in Section 11 of the CAR.
>
> 02.05 The Mixed-Oxide Project QA Plan addresses specific training of
> individuals. The licensee=s site programs are outlined in the
> upper-tier documents. Other trade or operations personnel
> qualifications should be detailed in site=s or contractors=
> procedures.
>
> 02.06 Review selected nonconformance and deviation reports in detail.
> Specifically, determine whether the corrective action initiated
> appears likely to preclude repetition. The reviewer should be
> particularly watchful for nonconformance reports signed off without
> adequate explanation, or reports that have been closed before being
> fully processed in accordance with procedures. Also, if components
> with reported nonconforming conditions are permitted to be installed,
> NRC inspectors should confirm that the licensee=s control system
> effectively tracks the condition until resolved.
>
> 02.07 Inspectors should determine if audits have been planned and
> carried out in accordance with an announced schedule. Qualification of
> auditors should be verified to ensure that they are fully qualified
> for the assigned areas.

03.03 [Prevalent Errors/Concerns]{.underline}.

This section is included to provide background for inspectors on past
problems of a generic nature.

a.  Documentation not kept current, causing speculation and concern that
    uncurrent records in an attempt to catch-up may be incorrect or
    invalid.

b.  Inspection documentation signed off by persons other than the
    inspectors actually responsible for the recorded information.

c.  Nonconformance report system deficient in that reports could be
    destroyed, filed away, or otherwise signed off, without proper
    resolution or accountability of action taken.

d.  Weather protection allowed to degrade because of to inattention to
    damage, and normal Awear and tear,@ leading to substandard or
    unacceptable protection provisions.

e.  Improper installation and adjustment of motor-operated valve torque
    switches, limit switches, and bypass switches. Applicable
    specifications and instructions have not been adequate to ensure
    proper installation, adjustment, and check-out.

f.  Inspection procedures, instructions, and acceptance criteria lack
    clarity, and in some cases are difficult to find and use.

g.  Licensee audit reports containing adverse findings and
    recommendations were filed away without appropriate follow-up and
    resolution.

88136‑04 RESOURCE ESTIMATE

Because of the importance and extent of IROFS and SSC installation,
observation of work activities in this area is scheduled to be conducted
in stages. The intent of this procedure is to accomplish the inspection
requirements of Section 02.04 when component installation activities are
about one‑third complete, and with Section 02.05, when activities are
about two‑thirds complete.

This inspection procedure is expected to take, on the average, 32 to 64
hours for each review of licensee/contractor activities. The procedure
should be conducted early in the installation of components relied on
for safety, with primary focus on procedures, personnel qualifications,
and handling of individual components. Subsequent inspections should be
conducted of the components relied on for safety, installed, with the
primary focus on inspection of as-built configurations and review of
installation records.

88136‑05 REFERENCES

Duke, Cogema, Stone and Webster, AMixed-Oxide Fuel Fabrication Facility
Construction Authorization Request,@ Docket Number 070-03098, latest
revision accepted by NRC.

Duke, Cogema, Stone and Webster, AMixed-Oxide Fuel Fabrication Facility,
MOX Project Quality Assurance Plan (MPQAP),@ Docket Number 070-03098,
under U.S. Department of Energy Contract DE-AC02-99-CH10888, latest
revision accepted by NRC.

American Society for Mechanical Engineers, ASME NQA-1-1994 Edition with

NQA-1a-1995 Addenda.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.28, AQuality
Assurance Program Requirement (Design and Construction).@

END

ATTACHMENT 1

Revision History for IP 88136

+--------+--------+------------------------+-----+-------+-------------+
| Comm   | Issue  | Description of Change  | Tr  | Tra   | Comment     |
| itment | Date   |                        | ain | ining | Resolution  |
| Tr     |        |                        | ing | Compl | Accession   |
| acking |        |                        | Nee | etion | Number      |
| Number |        |                        | ded | Date  |             |
+--------+--------+------------------------+-----+-------+-------------+
| N/A    | 07     | IP 88136 is a newly    | N   | N/A   | ML071730462 |
|        | /25/07 | issued procedure.      | one |       |             |
|        |        | Issued for MOX         |     |       |             |
|        | CN     | inspection program to  |     |       |             |
|        | 07-023 | improve effectiveness  |     |       |             |
|        |        | and efficiency by      |     |       |             |
|        |        | incorporating and      |     |       |             |
|        |        | consolidating          |     |       |             |
|        |        | mechanical components  |     |       |             |
|        |        | inspection             |     |       |             |
|        |        | requirements.          |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+