Issue Date: 07/25/07 88133 1

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
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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.

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. 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. 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. 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).
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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 “snug 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. 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:
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a. Receipt Inspection and Material Certification (if applicable). 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. 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. 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.

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. 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. 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
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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.

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.

(a) Steel plates and shapes;
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(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.

(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

“snug 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.
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03.02 Prevalent Errors and Concerns. 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 “snug-tight” condition, and inadequate gauge marks to determine amount of

additional turns after “snug-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
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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, “Reinforced Concrete Design for

Thermal Effects on Nuclear Power Plant Structures.”

ACI 349-97, “Code Requirements for Nuclear Safety-Related Concrete Structures.”

ACI 349.2R-97, “Embedment Design Examples.”

American National Standards Institute/American Institute of Steel Construction

(ANSI/AISC), ANSI/AISC N690-1994, “Specifications for the Design, Fabrication, and

Erection of Steel Safety-Related Structures for Nuclear Facilities.”

ANSI/ANS-2.8-1992, “Determining Design Basis Flooding at Power Reactor Sites.”

American Society of Civil Engineers (ASCE), ASCE 4-98, “Seismic Analysis of SafetyRelated Nuclear Structures and Commentary.”

ASCE 7-98, “Minimum Design Loads for Buildings and Other Structures.”

American Welding Society (AWS) D1.1, “Structural 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, “Requests 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, “Mixed-Oxide Fuel Fabrication Facility, MOX Project
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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, “Mixed-Oxide Fuel Fabrication Facility Construction

Authorization Request,” latest revision accepted by NRC.

U.S. Nuclear Regulatory Commission, NUREG-0800, “Standard Review Plan for the

Review of Safety Analysis Reports for Nuclear Power Plants.”

U.S. Nuclear Regulatory Commission, NUREG-1718, “Standard 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, “Development of Floor

Design Response Spectra for Seismic Design of Floor- Supported Equipment or

Components.”

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.60, “Design Response Spectra

for Seismic Design of Nuclear Power Plants.”

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.61, “Damping Values for

Seismic Design of Nuclear Power Plants.”

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.92, “Combining Modal

Responses and Spatial Components in Seismic Response Analysis.”

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.40, “Design Basis Floods for

Fuel Reprocessing Plants and for Plutonium Processing and Fuel Fabrication Plants.”

END

ATTACHMENT 1

Revision History for IP 88133

Commitment

Tracking

Number

Issue Date Description of Change Training

Needed

Training

Completion

Date

C

A
Issue Date: 07/25/07 Att 1-1 

N/A 07/25/07

CN 07-023

IP 88133 is a newly issued procedure. Issued for MOX inspection program toimprove effectiveness and efficiency byincorporating and consolidatinginspection requirements involvingstructural steel inspection activities.

None N/A ML