Issue Date: 07/25/07 88136 1

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.
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b. Receipt inspections are adequate and capable of detecting damage or outof-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.

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.
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b. Storage, Handling, and Protection.

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.

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.

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,
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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.
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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.

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, “Identification
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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 equipmentqualification 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 managementcontrol 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.

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
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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.

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 “wear and tear,” leading to substandard or unacceptable protection

provisions.
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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, “Mixed-Oxide Fuel Fabrication Facility Construction

Authorization Request,” Docket Number 070-03098, latest revision accepted by NRC.

Duke, Cogema, Stone and Webster, “Mixed-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, “Quality Assurance Program

Requirement (Design and Construction).”

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

ATTACHMENT 1

Revision History for IP 88136

CommitmentTrackingNumber

Issue Date Description of Change Training

Needed

TrainingCompletionDate

CoAc

N/A 07/25/07 

CN 07-023

IP 88136 is a newly issued procedure. Issued for MOX inspection program toimprove effectiveness and efficiency byincorporating and consolidatingmechanical components inspectionrequirements.

None N/A ML