IR 05000247/2010010

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lnspection No.Docket No.License No.Licensee:Facility:Location:Inspection Dates:Inspector:Approved By:U.S. NUCLEAR REGULATORY COMMISSIONREGION IINSPECTION REPORT05000286/201 001 005000286DPR-64Entergy Nuclear Operations Inc.Holtec Manufacturing DivisionTurtle Creek, PANovember 29 - December 2,2010,FebruaryT -10,17,2011John NicholsonHealth PhysicistDecommissioning BranchDivision of Nuclear Materials SafetyRob TempsSenior Safety InspectorRules, Inspections, & Operations BranchDivision of Spent Fuel Storage and TransportationJudith A. Joustra, ChiefDecommissioning BranchDivision of Nuclear Materials SafetyDocument Name: TIDNMS\WordDocs\Current\lnsp Report\RO50002B6.2010010.doc EXECUTIVE

SUMMARY

lR 050002861201001Q; 1112912010 - 1 21212010, 02107 - 1 0, and 17 , 2011 ; Indian Point EnergyCenter (IPEC); Oversight of factory testing and inspection of IPEC Unit 3 shielded transfer cask(STC) at the Holtec Manufacturing Division (HMD) facility in Turtle Creek, Pennsylvania.This report covers an announced on-site inspection conducted by an NRC Region I inspectorand an inspector from the NRC Nuclear Materials Safety and Safeguards Division, Spent FuelStorage and Transportation Branch, of IPEC's oversight of the factory testing of the Unit 3 STCat HMD. A license amendment request (M1091940177) for the STC under 10 CFR Part 50 wassubmitted by Entergy Nuclear Operatons, Inc. (the licensee) to the NRC on July 8, 2009. At thetime of this inspection, the NRC was in the process of drafting a second request for additionalinformation (RAl) to the licensee regarding the amendment request for the STC. The review ofthat request is ongoing. This STC will be used for the wet transfer of spent fuel assemblies fromthe IPEC Unit 3 spent fuel pool (SFP) to the IPEC Unit 2 SFP.The inspector reviewed equipment performance, program controls, and documentation. Specificinspection areas included the testing of STC components, observing STC component inspectionon the floor of the manufacturing facility, a review of the non-conformance reports to date, areview of the licensee's quality assurance program, and interviews with both the licensee andHoltec personnel performing the testing and inspection of the components.Within the scope of this inspection, no violations of NRC requirements were identified.ii Inspection Report No. 05000286/2010010T:\DN MS\WordDocs\Current\lnsp Report\RO5000286.20 1 00 1 0,doc

REPORT DETAILS

1.0 Review of Fabrication Documentationa. Inspection Scope (1P60852)The inspection included a limited review of the licensee's oversight of the HMDfabrication of the IPEC STC since the previous inspection at HMD conducted in April2Q10. The inspector performed an onsite review of the HMD's Technical Specificationrequirements for implementing procedures controlling fabrication to assure that HMD'sTechnical Specification requirements were incorporated.b. Observations and FindinqsIPEC has a written contract with URS Washington Division (URS), an engineering andtechnical services provider company, to provide oversight of onsite quality assurance forthe fabrication of the STC at HMD. The URS contractor is required to witness holdpoints during the fabrication process. The inspector reviewed several hold points andnoted that URS staff signed off on the component documentation to confirm that holdpoints had been inspected as required. Weekly verbal communication occurs betweenURS and the IPEC Project Manager. The inspector reviewed the purchase agreementspecifications developed by the licensee and provided to HMD. The purchaseagreement states that all drawings for fabrication must be approved by the licensee priorto the start of fabrication. lt also states that non-conformance reports (NCRs) consideredas design changes require the licensee's approval, although the contractor may proceedat its own risk prior to IPEC's acceptance. The contractor must request and obtainwritten approval of the licensee prior to shipment of the component.While reviewing NCRs associated with the STC, the inspector noticed that NCR 09121-1,Rev. 3, involved a design change to the STC shellthickness lrom718" to 3/4". Thisdesign change was dispositioned without the licensee's approval or review of theanalysis performed by Holtec. Licensee personnel stated that they were not notified ofthe significance of this NCR by Holtec and at the time of the inspection had not yetperformed the proper analysis of the design change as required by the Entergy QualityAssurance Manual. The NCR form used by Holtec did not differentiate between reworkand repair. In general, rework is the act of reprocessing non-complying components,through the use of original or equivalent processing, in a manner that assures fullcompliance of the component with applicable drawings or specifications. In contrast,repair is generally the act of restoring the functional capability of a defective componentin a manner that precludes compliance of the component with applicable drawings orspecifications. Usually rework does not require customer approval, while most repairwork does.The IPEC Assistant Project Manager stated to the inspector that an Entergy CorrectiveAction Request (CAR) LO-CAR-2010-00098 was sent to Holtec on December 2Q,2010for their follow up. The follow-up response to the CAR from Holtec had not beenreceived by the licensee prior to the end of this inspection.1 Inspection Report No. 05000286/2010010TIDNMS\WordDocs\Cunent\lnsp Report\R05000286.201 001 0.doc

c. Conclusions

The inspectors determined that the licensee representatives on site at HMD including theURS Washington Division personnel, and IPEC project management personnel, did notappear to be as familiar as they should have been with how design changes should behandled per the contractural agreement between the licensee and HMD and the EntergyQuality Assurance Manual. As of February 7,2011, the licensee drafted new languagefor the contract with Holtec, and Holtec modified the NCR form they use to include adesignation for repair. The Entergy Quality Assurance Program Manual requires thatsupplier evaluations be performed any time prior to placing the component in service. Atthe conclusion of this inspection, the STC was still being fabricated by Holtec, had notbeen licensed by the NRC, and had not been shipped to or used by the licensee. Atimely review of the design change was not performed by the licensee. However sincethe STC had not been placed into service, no findings of significance were identified.2.0 Factory testing and Fit up of STC Componentsa. lnspection ScopeThe testing and inspection of the various STC components on the HMD factory floor wasobserved. The inspector also reviewed documentation of factory testing of variouscomponents that had occurred prior to the inspection.b. Observations and FindinqsIPEC personnel prepared a spreadsheet that included each component of the STC andwhat actions where to be performed for that component. Actions included visualinspection for component integrity, testing of the selected component with othercomponents, and functionality of the component. IPEC personnel performed anextensive review of the various components and identified numerous action items forfollow up by HMD. In addition load test results of the STC lifting trunnions and the lidlifting devices were reviewed. Open items were noted by the IPEC project managers aswell as spare parts to be provided with the STC. Additional visits to Holtec by thelicensee will be necessary to resolve the remaining open items.c. ConclusionsThe licensee demonstrated adequate oversight of HMD during the testing and inspectionof STC components. A detailed spreadsheet of components, test results, and follow upitems was developed. No findings of significance were identified.Exit Meeting SummaryWithin the scope of this inspection, no violations of NRC requirements were identified. Theinspector presented the inspection results in a conference call with Joe DeFrancesco, ProjectManager for IPEC, and other licensee personnel at the conclusion of this inspection onFebruary 17,2011.ATTACHMENT:

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