**NRC INSPECTION MANUAL** NMSS/RII

INSPECTION PROCEDURE 88133

STRUCTURAL STEEL AND SUPPORTS ACTIVITIES

PROGRAM APPLICABILITY: 2630

88133-01 INSPECTION OBJECTIVES

01.01 To determine whether the technical requirements detailed or
referenced in the Construction Authorization Request (CAR), the U.S.
Nuclear Regulatory Commission (NRC) Safety Evaluation Report (SER), and
the approved Mixed-Oxide (MOX) Project Quality Assurance (QA) Plan
(MPQAP), associated with structural steel and supports activities and
quality control (QC) for Seismic Category I (SC-I) and SC-II structures,
have been adequately addressed in the licensee and/or contractor
construction specifications, drawings, and work procedures, and whether
the established system of management controls is adequate.

01.02 To determine whether QA plans, instructions, and procedures for
structural steel and supports activities have been established in the
facility QA manual.

01.03 To determine, by direct observation and independent evaluation,
whether work and inspection performance relative to structural steel and
supports activities are being accomplished in accordance with design
specifications, drawings, and procedures.

01.04 To determine whether the licensee=s system for preparing,
reviewing, and maintaining records, is functioning properly, and to
determine whether the records reflect work accomplishment consistent
with specifications and procedures.

01.05 To determine by direct observation of work activities and review
of records whether inadequacies in work activities associated with
structural steel and supports activities indicate any potentially
generic problems, management control inadequacies, or other weaknesses
that could have safety significance.

88133-02 INSPECTION REQUIREMENTS

02.01 For each onsite organization with QA/QC responsibilities relative
to structural steel

and supports activities, the inspectors should refer to the appropriate
MOX Fuel Fabrication Facility QA inspection procedures (IPs). If there
are multiple contractors with

QA/QC responsibilities in this area, inspect a sample, using engineering
judgment,

concerning the safety significance and the complexity of each work
activity.

02.02 Review the construction specifications related to structural steel
and supports activities and ascertain whether the specified technical
requirements conform to the commitments contained in the CAR. Determine
whether appropriate and adequate procedures in the following areas are
compatible with the QA program and prescribe adequate methods to meet
the construction specifications, where applicable:

a.  [Receipt inspection and storage]{.underline}.

> Use of specified materials and components;

1.  Installation and erection; and

2.  Inspection, testing, (non destructive examination (NDE), and
    records.

02.03 Determine whether the licensee has an established audit program
(including plans, procedures, and schedule) covering the SC-I and SC-II
work and control functions in the area of structural steel and supports
activities and for ensuring that examination and inspection personnel
associated with structural steel and supports activities are qualified
to perform their assigned work.

02.04 By direct observation of work in progress on the material
supporting SC-I and SC-II structures, ascertain whether the following
applicable structural steel and supports activities are being controlled
and accomplished in accordance with the requirements of the documents
reviewed in Section 02.02, above:

a.  [Receipt Inspection and Storage]{.underline}. Verify that the
    following items have been implemented:

    1.  Receipt inspections: Verify the acceptability of specification
        requirements.

    2.  Storage: Verify that controls, markings, protection, and
        segregation are maintained.

b.  [Use of Specified Materials and Components]{.underline}. On a
    sampling basis verify the following:

    1.  Type and grade of materials are as indicated in specifications
        and drawings.

    2.  Certificates of conformance or mill test reports meet the proper
        specifications or physical and chemical requirements, including
        impact tests, if required.

c.  [Installation and Erection]{.underline}. Verify that the following
    items are implemented in the installation or erection process:

    1.  The component or support is being erected in accordance with the
        most current specifications and drawings.

    2.  The layout crew=s instruments and tapes are calibrated.

    3.  Fit‑up and alignment meet the tolerances in the specifications
        and drawings.

    4.  Components are being properly handled (including bending or
        straightening).

    5.  Specified clearances are being maintained.

    6.  Edge finishes and hole sizes are within tolerances.

    7.  Anchor bolts, embedded weldments, liner plate anchors, concrete
        anchors, and studs are of the proper material and grade and have
        been properly located, and tested and examined.

    8.  For bolted connections: bolts, nuts, and washers are of the
        specified type and grade; torque wrenches are calibrated in
        accordance with approved procedures; other test and measuring
        equipment used in the bolting process are calibrated; and thread
        engagement is as specified.

> The inspectors should independently sample installed and QC‑accepted
> bolts and bolted connections of various bolt diameters by use of a
> calibrated torque wrench, to ensure that proper tension is being
> developed in the bolt. Proper torque values may be obtained through
> the use of site‑generated data.
>
> For friction type connections, ensure that the craft personnel follow
> the procedures properly, so that the bolts will have the required bolt
> tension. For instance when the turn‑of‑nut method is used, make sure
> enough bolts are brought to a Asnug tight@ condition, to ensure that
> the parts of the joint are brought into good contact with each other.
>
> For sliding-type connections, ensure the craft personnel follow the
> procedures properly so that the bolts are not over-tightened and so
> that bolts are not at the end of slots, preventing movement of the
> connection.

d.  [Inspection, Testing, NDE, and Records]{.underline}. For inspection,
    testing, NDE, and records, verify the following items:

    1.  Inspections are performed at the specified frequency, in
        accordance with appropriate codes, specifications, and
        procedures, and adequate acceptance criteria are specified.

    2.  Accurate records are developed in accordance with procedures.

    3.  .Proper and calibrated equipment is used as required.

    4.  Personnel conducting testing and NDE are qualified as required
        (i.e., in accordance with SNT‑TC‑1A).

02.05 Review the documentation generated for the structural steel and
supports activities. Determine whether the licensee/contractor system
for documenting safety‑related work is functioning properly. Records
should be legible, complete, reviewed by QC and/or engineering
personnel, and readily retrievable. Review a sample of the following
records:

a.  [Receipt Inspection and Material Certification (if
    applicable)]{.underline}. Applicable for materials purchased from
    offsite suppliers. Records confirm that required material
    characteristics, performance tests, nondestructive test, and other
    specification requirements were met.

b.  [Installation Inspection]{.underline}. Records confirm that
    specified materials and components were installed as specified and
    that the required inspections were performed and acceptance criteria
    are defined.

c.  [Nonconformance/Deviation Record]{.underline}. Records include
    current status of these items. Nonconformance reports include the
    status of corrective action or resolution.

d.  [Training/Qualification Records of Craft, QA, and Inspection (QC)
    Personnel]{.underline}. Records establish that QA/QC personnel are
    adequately qualified for their assigned duties and responsibilities
    and that craft personnel have been trained in their assigned tasks.

e.  [QA Audits]{.underline}. Records establish that the required audits
    were performed and that deficiencies identified during audits were
    corrected, and that corrective action was such that repetition of
    the deficiency, or similar deficiencies, would be precluded.

02.06 Review the construction and QC procedures generated from the
specifications and determine their adequacy with respect to prescribing
adequate methods for achieving the construction specification
requirements, including handling and storage of materials.

88133-03 INSPECTION GUIDANCE

[General Guidance]{.underline}. Applicable portions of the CAR, the SER,
and approved MPQAP should be reviewed to determine licensee commitments
relative to construction and inspection requirements, before performing
this inspection. The inspectors should then use these documents during
the review of the construction specifications, drawings, work
procedures, and QA implementing procedures. Structural steel and
supports activities should also be reviewed in the light of being
consistent with standard industry practice for the successful completion
of that activity.

Because structural steel and supports involve unique construction
processes for each project, the number of structural steel and supports
activities, listed above, which should be reviewed, depends on the
significance and applicability of that activity with respect to site
conditions and the need for establishing a close relationship between
the structural design and the construction techniques. It is for this
reason that this inspection module should be performed by someone who is
able to discriminate between, and weigh, those activities which will
require the most attention and that will have the most impact on safety.
The inspectors should use judgment in determining sample selection
during inspection activities. Sample selection should reflect the
importance of the activity to safety. Observations of work and
independent verification of critical dimensions, locations, etc. should
be performed at various stages of completion.

The licensee is responsible for implementing or having implemented, the
approved QA program and the commitments described in the CAR. The
inspectors must determine if this program is implemented in an adequate
and timely manner for the important-to-safety work in progress.

QA/QC procedures must provide for effective inspections that will ensure
that work is performed in accordance with specification requirements. QA
audits should identify procedural inadequacies and the root cause of
repetitive nonconforming conditions. Inspections should require
verification of specified controls and should not be accomplished merely
by surveillance. Laboratory and field testing procedures must provide
for verification of correct material usage, correct selection of
reference standards, and should prohibit contractor or QC personnel from
discretionary selection of inspection and testing parameters. Qualified
personnel should review and determine if the results of testing are
acceptable. Construction procedures must reference the required
inspection hold points and must also address the QA/QC department
stop-work authority.

Findings from this inspection activity should address each element as
being satisfactory, being unresolved and requiring resolution, or being
in violation and requiring correction. When significant inadequacies are
identified in the specifications or procedures, indicating weakness
within the preparing organization, the inspectors should inform
cognizant regional management. The issue should be addressed at the
appropriate level of licensee management.

03.01 [Specific Guidance]{.underline}.

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

> 02.04a The licensee may perform varying degrees of acceptance
> inspection, as part of its vendor shop-surveillance program. Results
> of these inspections should be reviewed.
>
> 02.04c Connection joints in structures are usually the area of
> installation problems and also are generally not given the same
> engineering attention as other structural steel items. Therefore, it
> is important to select, for review, a few connections in each
> structure or support reviewed in Section 02.04, above.
>
> 02.06 QA/QC procedures must provide for effective inspections that
> will ensure that work is performed in accordance with specification
> requirements. Inspection should require verification of specified
> controls and should not be accomplished merely by surveillance.
> Construction procedures must reference the required inspection hold
> points and also must address the QA Department=s authority to stop
> work.
>
> The items selected for review during this inspection should include
> the following, as appropriate for the specific site design:

1.  [Control of Specific Materials]{.underline}.

    a.  Steel plates and shapes;

    b.  Pipes and tubes;

    c.  Forgings and castings;

    d.  Bolts and studs;

    e.  Weld filler-metal

    f.  Coatings; and

    g.  Other related materials.

2.  [Control of Specific Processes or Activities]{.underline}.

    a.  Heat treatment;

    b.  Impact testing;

    c.  Examination;

    d.  Repair;

    e.  Cutting, forming, bending, and aligning;

    f.  Erection and bracing;

    g.  Welding (for cross flange welding on loaded members, be sure
        that the procedures or engineering evaluations ensure that the
        structural integrity of the loaded beams or columns affected
        will not be compromised.);

    h.  Radiography;

    i.  Other NDE methods;

    j.  Bolting (ensure that the procedures will provide the required
        bolt tension. For instance, when the turn‑of‑nut method is used,
        the procedures should make sure enough bolts are brought to a
        Asnug tight@ condition so that the parts of the joint are
        brought into good contact with each other.);

    k.  Postweld heat treatment;

    l.  Local leakage testing;

    m.  Inspection; and

    n.  Documentation of inspection and testing.

03.02 [Prevalent Errors and Concerns]{.underline}. Prevalent errors and
recent concerns are areas in where the inspectors should be alert to
potential generic issues. These areas include:

a.  Storage of structures and support components should ensure that
    contact with ground surfaces is avoided.

b.  Inattention to damage and normal wear and tear of protective
    coverings may lead to substandard or unacceptable weather
    protection. The licensee=s maintenance of protection (canvas or
    plastic covering) should be reviewed.

c.  In the area of maintenance of material identification, damage by
    handling or weather frequently makes paper tags illegible. Paper
    tags are usually considered to be inadequate.

d.  The use of galvanized bolts and nuts in bolted connections may
    require thread lubricant, to ensure that minimum torque or
    pretension requirements are met. There may be frequent adjustments
    of the minimum torque value.

e.  Piece-work traceability of structural steel and American Society of
    Testing and Materials (ASTM) A325/A490 bolting material has been a
    problem in the recent past.

f.  Deficient alignment or fit‑up for welded connections has caused
    improper welding practices.

g.  There have been instances of cutting or edge finishes not being in
    accordance with specifications or drawings.

h.  Instances of weld undercut have gone undetected by QC inspections.

i.  Uncalibrated torque wrenches have been used. There should be
    provisions for the evaluation or reverification of the activities
    performed by the uncalibrated torque wrench since the last
    calibration.

j.  Difficulties in using the turn‑of‑nut method, for bolted
    connections, in defining the initial Asnug‑tight@ condition, and
    inadequate gauge marks to determine amount of additional turns after
    Asnug‑tight.@ Actual observation may be the only means of verifying
    the proper implementation the turn‑of‑nut method.

k.  NRC personnel, through independent sampling of bolted connections
    using calibrated torque wrenches, found that high strength bolted
    connections do not meet project requirements for proper bolt
    tension.

l.  Welding across the flange of loaded members without engineering
    evaluation is only to be done under controlled conditions.

88133-04 RESOURCE ESTIMATE

This IP is expected to take, on the average, 24 to 32 hours for each
review of licensee/contractor activities. This procedure should be
performed every 3 months, during the first year of placement of SC-I and
SC-II structures. Thereafter, select at least two placements per year
(as applicable). Regional Management should use the inspectors
observations of the relative complexity of required SC-I structural
steel work activities, and of the observed competency of licensee and
contractor personnel, to schedule additional inspections, as required.

88133-05 REFERENCES

American Concrete Institute (ACI), ACI 349.1R-91, AReinforced Concrete
Design for Thermal Effects on Nuclear Power Plant Structures.@

ACI 349-97, ACode Requirements for Nuclear Safety‑Related Concrete
Structures.@

ACI 349.2R-97, AEmbedment Design Examples.@

American National Standards Institute/American Institute of Steel
Construction (ANSI/AISC), ANSI/AISC N690-1994, ASpecifications for the
Design, Fabrication, and Erection of Steel Safety‑Related Structures for
Nuclear Facilities.@

ANSI/ANS-2.8‑1992, ADetermining Design Basis Flooding at Power Reactor
Sites.@

American Society of Civil Engineers (ASCE), ASCE 4-98, ASeismic Analysis
of Safety‑ Related Nuclear Structures and Commentary.@

ASCE 7‑98, AMinimum Design Loads for Buildings and Other Structures.@

American Welding Society (AWS) D1.1, AStructural Welding Code.@

U.S. Nuclear Regulatory Commission, Draft Safety Evaluation Report,
Revision 1.

U.S. Nuclear Regulatory Commission, Letter to P. Hastings, Duke Cogema
Stone & Webster, RE Mixed Oxide Fuel Fabrication Facility Construction
Authorization - Request for Additional Information, June 21, 2001.

Duke Cogema Stone & Webster, letter to U.S. NRC, ARequests for
Additional Information,@ Clarification, and Open Item Mapping into the
Construction Authorization Request Revision (DCS01-NRC-000120), November
22, 2002.

Duke Cogema Stone & Webster, letter to U.S. NRC, RE MOX Fuel Fabrication
Facility Site Geotechnical Report (DCS01-WRS-DS-NTE-G-0005-C), August
10, 2001.

Duke Cogema Stone & Webster, letter to U.S. Nuclear Regulatory
Commission, RE Clarification of Responses to NRC Request for Additional
Information (DCS-NRC-000085), March 8, 2002.

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.

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

U.S. Nuclear Regulatory Commission, NUREG-0800, AStandard Review Plan
for the Review of Safety Analysis Reports for Nuclear Power Plants.@

U.S. Nuclear Regulatory Commission, NUREG-1718, AStandard Review Plan
for the Review of an Application for a Mixed Oxide (MOX) Fuel
Fabrication Facility.@

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.122, ADevelopment
of Floor Design Response Spectra for Seismic Design of Floor‑ Supported
Equipment or Components.@

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.60, ADesign
Response Spectra for Seismic Design of Nuclear Power Plants.@

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.61, ADamping
Values for Seismic Design of Nuclear Power Plants.@

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.92, ACombining
Modal Responses and Spatial Components in Seismic Response Analysis.@

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.40, ADesign Basis
Floods for Fuel Reprocessing Plants and for Plutonium Processing and
Fuel Fabrication Plants.@

END

ATTACHMENT 1

Revision History for IP 88133

+--------+--------+------------------------+-----+-------+-------------+
| 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 88133 is a newly    | N   | N/A   | ML071720022 |
|        | /25/07 | issued procedure.      | one |       |             |
|        |        | Issued for MOX         |     |       |             |
|        | CN     | inspection program to  |     |       |             |
|        | 07-023 | improve effectiveness  |     |       |             |
|        |        | and efficiency by      |     |       |             |
|        |        | incorporating and      |     |       |             |
|        |        | consolidating          |     |       |             |
|        |        | inspection             |     |       |             |
|        |        | requirements involving |     |       |             |
|        |        | structural steel       |     |       |             |
|        |        | inspection activities. |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+