IR 07100192/1989006
| ML19324C390 | |
| Person / Time | |
|---|---|
| Site: | 07100192 |
| Issue date: | 11/09/1989 |
| From: | Beth Brown, Jackie Cook, Catherine Haney, Jankovich J, Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML19324C389 | List: |
| References | |
| 71-0192-89-06, 71-192-89-6, NUDOCS 8911160216 | |
| Download: ML19324C390 (12) | |
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CONTAINER SUPPLIER INSPECTION PROGRAM l
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Inspection Report
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ORGANIZATION:
Pacific Nuclear Systems, Inc.
ADDRESS:
TRUPACT-II Assembly Facility 1010 South 336th Street Federal Way, WA 98003 CONTACT:
Dr. C. J. Temus TELEPHONE: 206-874-2235 TITLE:
Technical Director ACTIVITY:
Fabricate radioactive material packages.
L-QUALITY ASSURANCE PROGRAM APPROVAL NO.: 0192 i
Report Number:
Inspection Dates:
Inspection On-Site 710192/89-06 9/26-28/89 Person-Hrs: 87
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1NSPECTION BASES AND SCOPE:
A.
BASES:
Title 10 CFR Parts 21 and 71, and Certificate of i
Compliance No. 9218.
B.
SCOPE:
To determine whether the organization has established, i
documented and executed procedures which fulfill the comitments made in the organization's NRC-approved quality assurance program.
To determine whether fabricated packages were manu-
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i factured in accordance with the design approved by the Comission, i
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'8911160216 891109
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CONTAINER SUPPLIER INSPECTION PROGRAM
Inspection Report
FINDINGS:
Nonconformances with the requirements of 10 CFR Sections 71.111, 71.119, 71.123 and 71.135 were identified.
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INSPECTION TEAM LEADER:
A DATE:
qpnn aankovten, nnss
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DATE:
OTHER NRC INSPECTORS:
wt Jo n R. Cook, NMd5 O%
DATE:
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catnertne Mane, NM55 HM[d7
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DATE:
NRC CONTRACTOR:
Boyd W. Brown Idaho National Eng ering Laboratory, EG&G 1//9 I
REPORT APPROVED BY:
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DATE:
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charles E. MacDonald, chief l
Transportation Branch, NMSS
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INSPECTION SUMMARY
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An announced inspection by the U.S. Nuclear Regulatory Commission (NRC) of con-
'tainer fabrication activities at Pacific Nuclear Systems, Inc., TRUPACT-II Assem-bly facility (TAF) at Carlsbad, New Mexico was conducted on Septenter 26-28, 1989.
Inspection findings are based on data collected through observation of selected activities, review of implementation procedures and controls, review of selected documents and records, interviews with personnel, and exaniination of weld radio-graphs. The inspection team concluded that the implementation of the quality assurance (QA) program was satisfactory, in general. However, the team identi-fied specific items of nonconformance in some aspects of the fabrication process (10CFRSection71.119),recordcontrol(10CFRSection71.135),testcontrol (10 CFR Section 71.123), and QA management (10 CFR Section 71.111). The team discussed tentative findings with the organization's representatives, at the exit meeting.
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J 2.
CONTAINER SUPPLIER INSPECTION
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The team conducted the inspection to evaluate TAF's implementation of its NRC-approved QA program, and to ensure that products are fabricated in I
l compliance with'NRC requirements. 'The team evaluated TAF's QA activities from the perspective of three functional elements:
(NDE), personnel qualifications, and quality discrepancy reports (QDRs).
- 2.1 Persons Contacted The inspection team contacted the following persons.
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- R. H. Smith, Director, Corporate Quality Assurance
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- V. K. Cannon, Manager, Quality Assurance
- F. Humiston, Plant Superintendent
- W. B. Brown, Manufacturing Manager
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- A. W. Work, Inspection Supervisor
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- C. Carpenter Quality Assurance Inspector
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S. Garcia Busselman, Quality Assurance Inspector
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This individual attended the entrance and exit meetings only:
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C. R. McFarland, Senior Quality Assurance Engineer, Environmental Evaluation Group, State of New Mexico
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2.2 Nondestructive Exam nation Three certified Pacific Nuclear Systems Inc. NDE examiners are engaged in
radiographic (RT)and/orliquidpenetrant(PT)examinationsofTRUPACT-II containers. The Inspection Supervisor and a QA inspector are certified as
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- Attended Entrance and Exit Meeting
- Attended Entrance Meeting
- Attended Exit Meeting
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Level II PT inspectors, and a second QA inspector is certified in both PT and RT as a Level II inspector. A consultant from Boeing Aircraft is retained as
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the Pacific Nuclear Systems, Inc. Level III radiograph examiner.
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All welding procedures and personnel are to oe qualified in accordance with
ASMECodeSectionIX(TRUPACT-II,SafetyAnhlysisReport). Radiography of the Trupact-II containers is to be performed in accordance with ASME Code Section
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i III, Subsection NB.
10 CFR Section 71.119, " Control of special processes,"
specifies that special processes including welding must be accomplished using qualified procedures, in accordance with applicable codes, in this case, the aforementioned sections of the ASME Code.
The inspection team selected radiographs of TRUPACT-II Units 2, 3, and 5 for
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review. Each TRUPACT-II container requires approximately 310 radiographs, 80
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radiographs of the Inner Containment Vessel (ICV) and 230 radiographs of the Outer Cortainment Vessel (OCV). The team reviewed all radiographs for Unit 5, approximately 30 percent of the radiographs for Unit 2, and approximately 10 percent of the radiographs for Unit 3.
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A nonconformance was identified regarding 10 CFR Section 71.119 in that a weld on Unit 2 was found in nonconformance with the ASME Code. Drawing (Dwg.) 2077-042 Weld-10,(OCV)radiographview17-18,datedApril 10, 1989, shows a crack indi-cation and its attempted removal by grinding (a star-crack indication is noted adjacenttothegrindingexcavation). The repair radiograph (Weld-10RI), dated April 11, 1989, chows the same star-crack, yet was accepted by Pacific Nuclear Systems, Inc. This assessment was not acceptable to the NRC team.
A nonconformance was identified regarding 10 CFR Section 71.135, " Quality Assurance Records," which specifies that records must be maintained for three years after the QA holoer last engages in the activity for which the program was developed.
The initial radiograph of Weld-20 described above, which identi-fied the unacceptable condition before grinding, was not located in the radio-graph package and was not available to the inspection team. This radiograph should have been maintained on file at TAF.
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A nonconformance was identified regarding 10 CFR Section 71.119 because a weld
on Unit 5 was in nonconformance with the applicable ASME Code. Dwg. 2077-042,
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Weld-26 (OCV assembly lower body outer shell-to-bottom), radiograph views 10-11, l
11-12, and 16-17 show significant cracking. These crack indications were iden-tified and marked for repair.
The repair radiographs dated June 7,1989 show area 10-12 to be free from crack indications. However, repair area 16-17 still
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shows a crack indication that was accepted by Pacific Nuclear Systems, Inc.
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The following day, the NRC inspection team requested to re-review the final acceptanceradiographofWold-26(view 16-17). The team noted that the radiograph j
showed significant smudge!, and scratches in the area of interest, which the team had not observed previously, and which made the crack indication more difficult to interpret. The team was advised that Pacific Nuclear Systems, Inc. personnel
had reviewed the radiograph, using a contact magnifying glass, after the NRC inspection team had left the previous evening. As a general comment, the inspec-
tion team notes that Pacific Nuclear should consider using cotton gloves to han-
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die radiographs and prohibit placing anything on the radiographs which may damage the emulsion-in the area of interest on the radiographs, since these radiographs are permanent records. If the film had been permanently damaged, it would have
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been a nonconformance with 10 CFR Section 71.135, " Quality Assurance Records" which specifies that the records must be identifiable and retrievable, and must be retained for three yearc after the QA holder last engages in the activity for which the program was developed.
A nonconformance was identified regarding 10 CFR Section 71.119, because penetrameters were not used as required by ASME Code. On Unit 2, several DCV welds, having unacceptable indications and identified for repair by Pacific Nuclear, had their final acceptance radiographs taken after final assembly of the OCV and af ter the 10 inches of polyurethane foam had been installed (e.g., Weld 10 (Dwg. 2077-042), weldrepairradiograph). Code-required penetrameters were not used during the final radiography to confirm the sensitivity of the radio-graphs. Polyurethane foam can cause significant degradation of the radiographs due to gamma ray scatter. These radiographs should not have been accepted without confirmation of radiograph sensitivity.
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. A nonconformance was identified regarding 10 CFR Section 71.119, because I
incorrect penetrameters were used on the radiographs taken between January and l
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August 1989.
Radiography of the TRUPACT-II container should be performed per the requirements of ASME Code Section III, Subsection NB, Table NB-5111-1.
Instead,PacificNuclearSystems,Inc.,RadiographicProcedure(RT-G1)incor-
rectly specified ASME Code Section V, Article 2, Table T-276 for penetrameter selection. Using the incorrect Section/ Table resulted in the use of the incor-
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rect penetrameter, i.e., a 15 penetrameter with the 2T hole imaged on the radio-
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graph was used, rather than a 7 penetrameter with the 4T hole imaged on the-radiograph; the latter ensures a more sensitive radiograph. When questioned about the discrepancy, the TAF level II Radiographer provided QDR No.1254, dated
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July 31,1989, identifying misidentification of.the reference table. The dispo-sition on the QDR states:
" Accept as is: Sensitivity achieved for the 2T hole l
in a 15 penetrameter is greater than that required for a 4T hole in a 7 penetra-
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meter." This QDR also stated that, as of August 23, 1989, Table NB-5111-1 will be used for penetrameter selection. Although the disposition statement in the
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QDR is incorrect, the QDR specifies the appropriate corrective action and, there-fore, the inspection team accepted the correction as proposed by Pacific Nuclear Systems Inc.
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Nonconformances were identified regarding 10 CFR Section 71.123, " Test Control,"
which requires that a test program, e.g., inspection program, be established, l
demonstrating that the package components will perform satisfactoriiy in service.
l (a)
In nonconformance with 10 CFR Section 71.123, the team found discrepancies l
for Unit 2 between the date showing on the radiographs of Weld-2 (Dwg.
2077-054) and the date on the radiograph reader sheets. The acceptance date on the radiograph reader sheet for Weld-2 is January 23, 1989. The date on the radiographs of Weld-2 is January 26,1989(3 days af ter final
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acceptance).
(b)
In nonconformance with 10 CFR Section 71.123, radiographs were found for Unit 5, Dwg. 2077-042, Welds-43 and -44; however, these welds could not be located on Dwg. 2077-042. Discussions with TAF personnel confirmed that these welds are not on the fabrication drawings because they were additional
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. welds, added to extend the overall length of the OCV. The radiograph pack-
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age did not contain any documentation about the acceptability of W1d-44.
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2.3 Personnel Qualifications t
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The inspection team reviewed the " Certificates of Personnel Qualification" on file for~the TAF inspectors. The education, training, and testing records for
these individuals were on file at Pacific Nuclear Systems, Inc., Federal Way,
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Washington and were prceptly telecopied for the inspection team. The records L
'were found satisfactory.
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Midland Inspection, Inc. of Midland, Texas, is contracted to perform radiographic examination of the TRUPACT-II containers at TAF. Certification documentation
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for three Midland Inspection Level II and one Level III examination personnel was on file at TAF. Education, training, and testing records for these person-
nel were reported to be on file at Midland Inspection and, therefore, were un-available for review. From the information that was available at the site the team found no nonconformances.
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l A nonconformance was identified regarding 10 CFR Section 71.111. "Instruc-
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tions, Procedures, and Drawings," which specifies that instructions, procedures, and drawings affecting quality must be prescribed and must be followed. The team noted a nonconformance with regard to Quality Assurance Instruction Q1-16.4, Rev. O, " Certification of NDE Personnel." The procedure requires annual eye L
examinations of NDE personnel. During review of the NDE certification records, the team noted that the required annual visual acuity examination for a QA inspector, certified as Level II inspector, had expired on September 6, 1989.
The team subsequently noted that the inspector had performed PT examinations after the September 6, 1989 expiration date.
2.4 Quality Discrepancy Report
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A system of QDRs is used for disposition of discrepancies pertaining to material, components, hardware and products.
The inspection team reviewed a large number of QDRs and found them in conformance with regulatory requirements.
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DOCUMENTS REVIEWED
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Yraveler 2077-248-1 0CV Upper Body Inner Traveler 2077-245-1 OCV Upper Body Outer Welder or Welding Operatot Qualification Tests (WPQ) For Woldre A 5/5/89 Procedure W-0003-WP
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Welcer B 5/10/89' Procedure W-0007-NP
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QA Data' Package Unit S/N 102 QA Data Package Unit S/N 101 (Section A only)
P.O. 6832-2077, 5/27/88, Pacific Nuclear Systems, Inc to Inc.
- Joseph T. Ryerson & Sons,ific Nuclear Systems, Inc. to Great Western P.O. CB092,-10/10/88, Pac P.O.'CB260,'2/13/89'-
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Calibration' certificates:
Varian leak standard SN 71J-132, 71J-328
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'Starrett dial caliper SN QA-CB-88-25
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. Certificate of Personnel Qualifications:
h Inspection' Supervisor Level 2, Helium Mass Spectrometer Leak Test l'
Liquid Penetrant Testing i
L QA Inspector 10, Liquid Penetrant Testing L
QA Inspector 11 Radiographic Testing, Gamma Ray Tech'nical Examination:
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Inspection Supervisor 9, Liquid Penetrant Testing p
l QA Inspector 10, Liquid Penetrant Testing L-QA Inspector 11, Radiographic Testing-Gama Ray L
L Technical Procedures:
L Procedure Revision No. Date T1tle L
QI-5.1
7/18/89 Manufacturing / Inspection Plan-NbPAC l
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8/21/89 Material / Components Traceability Plan - NUPAC TAF c
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8/22/89 Material Overcheck/ Verification
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Plan - NUPAC TAF
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QI-16.4
1/17/89 Certification of NDE Personnel
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QI-16.5
7/17/89 Welder / Welding Operator Qualifications Continuations
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- Technical Procedures (continued):
v Procedure '
Revision No. Date Title
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NDE-001 Certification of Nondestructive.
I Testing Personnel
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NDE-003 0.
3/1/88 Nondestructive Test Procedure, Liquid Penetrant Testing
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(SolventRemovable),
RT-G1 4-8/29/88 Midland Inspection " Radiographic Procedure," approved by NUPAC 9/12/88 o
Quality Discrepancy Reports:
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No. 1213 dated 6/27/89 through 1255, dated 9/25/89 Travelers:
Travelers for Unit'7, Nos. 2077-205, 248, 261, 269, 320 Travelers for Unit 9. Nos. 2077-204, 205, 243, 253, 259, 261, 262, 264.
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NONCONFORMANCES
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The following nonconformances were identified:
Nonconformances 1, 2, 3 a,nd 4 10 CFR Section 71.119, requires special processes, including welding, to be.
accomplished using qualified procedures in accordance with applicable codes, j
In nonconformance with 10 CFR Section 71.119:
1. Welds on Unit 2 were found to be in nonconformance with ASME Code.
(ReferenceSec.2.2,Page5).
2. Welds on-Unit 5 were found to be in nonconformance with ASME Code.
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(Reference'Sec.2.2,Page6).
3. Penetrameters were not used on radiographs taken after the repair of welds on Unit 2.
(ReferenceSec.2.2,Page6).
4. The incorrect penetrameter was used on radiographs taken prior to August 23, 1989(ReferenceSec.2.2,Page7).
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Nonconfermance 5
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10 CFR Section 71.135, requires that records must be maintained for three years after the QA holder last engages in the activity for which the program was r
developed.
In nonconformance with 10 CFR Section 71.135:
5. The original radiograph for Dwg. 2077-042 Weld-10, radiograph view 17-18, was not available.
(Reference Sec. 2.2, Page 5)
l Nonconformances 6, 7 10 CFR Section 71.123, requires that a test program be established that demonstrates that the package components will perform satisfactorily in l:.
service..
L In nonconformance with 10 CFR Section 71.123:
E. The date indicated on one reader sheet for Unit 2 was three days before the date on the radiograph.
(Reference Sec. 2.2, Page 7)
7. Welds-43 and -44, on Unit 5, could not be located on Dwg. 2077-042, and there was no documentation of the acceptability of Weld-44.
(Reference
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Sec.2.2,Page7).
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j Nonconformance 8
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10 CFR Section 71.111, requires that instructions procedures, and drawings affecting quality must be prescribed and must be followed. The instructions, procedures and drawings must include quantitative or qualitative acceptance criteria.
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In nonconformance with 10 CFR Section 71.111:
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8. The annual visual acuity examination, required by Procedure QI-16.4, for
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a QA Inspector certified as Level II PT inspector, expired on September 6, 1989. This inspector had performed PT examinations after the September 6, 1989 expiration date.
(ReferenceSection2.3,Page8).
5.
EXIT MEETING In the exit meeting, held on September 28, 1989, the team members stesterized the preliminary results of. the inspection.
The following personnel attended the meeting:
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R. H. Smith, Director, Corporate Quality Assurance V. K. Cannon, Manager, Quality Assurance F. Humiston, Plant Superintendent A. Work, Inspection Supervisor C. R. McFarland, Senior Quality Assurance Engineer, Environmental Evaluation Group, State of New Mexico C. Car > enter, Quality Assurance Inspector A. Atc1enson, Quality Assurance Manager, Westinghouse L
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