IR 07100346/1993002

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Insp Rept 71-0346/93-02 on 921201-03.Nonconformance & Violation Noted.Major Areas Inspected:Exam of Procedures & Representative Records,Interviews W/Personnel & Observations of Activities at Fort St Vrain
ML20128E111
Person / Time
Site: 07100346
Issue date: 02/01/1993
From: Macdonald C, Oconnor S, Reid D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20128E067 List:
References
71-0346-93-02, 71-346-93-2, NUDOCS 9302100312
Preceding documents:
Download: ML20128E111 (10)


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CONTAINER SUPPLIER INSPECTION PROGRAM-

Inspection Report

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ORGANIZATION:

Public Service Company of Colorado ADDRESS:

P.O. Box 840 Denver,.CO 80201-0840

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CONTACT:

Mr. Michael Holmes TITLE:

Manager, Project Assurance TELEPHONE:

(,293)620-1701

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ACTIVITY:

Fabrication, use, and maintenance of radioactive material packaging.

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QUALITY-ASSURANCE. PROGRAM APPROVAL N0.:

0346-lNSPECTION REPORT-NO.:

710346/93-02

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Inspection Location:

Inspection Dates:

In..r.. tion On-site

Platteville, CO-12/01-03/92 Person-Hours:

57-INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 71, 10 CFR Part 21, and Certificate of Compliance No. 6346.

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B.

SCOPE: To determine whether procedures have-been; established,.

documented and-executed at. Fort St. Vrain,- that' meet the requirements of'10:CFR Part 21 and-10 CFR Part.71 To determine 'if the procedures fulfill commitments made in

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the NRC-approved Quality Assurance Program.

To determine whether packages were fabricated and i

maintained in accordance with the design approved by the i

Commission.

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3 CONTAINER SUPPLIER INSPECTION PROGRAM INSPECTION REPORT.NO.:. 710346/93-02 FINDINGS:

A violation with the requirements of 10 CFR S 21.51 was identified.

Nonconformances with the requirements of 10 CFR-Part 71, Sections-lll and-l 123 were identified, INSPECTION TEAM LEADER:

DATE:

'~ El~ D Stephin C. O'Connor

NM.

/SGTB INSPECTOR:

DATE:

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. Dennis JK Reid NMSS/SGTB INSPECTOR:

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DATE:

08-2' ~ 9 3 GarfD. Roberts REPORT APPROVED BY:

DATE: 3/(/9/

Charles E. MacDonald Chief, Transportation-Branch, NMSS i

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Inspection Report

Docket No. 71-0346 1.

SUMHARY A U.S. Nuclear Regulatory Commission inspection team conducted an announced inspection of Public Service Company of Colorado (PSC), Fort St. Vrain Facility (FSV), on December 1-3, 1992.

The inspection team reviewed FSV quality assurance (QA) activities to determine whether QA procedures have been established, documented, and executed in fulfillment of commitments made in the NRC-approved QA Program.

Inspection findings are based on data collected through review of procedures and controls, inspection of selected documents and records, and interviews with personnel.

The inspection team concluded that im)1ementation of the QA Program was satisfactory, in general. However, tie inspection team identified a violation to 10 CFR 5 21.51, and nonconformances with some aspects of the QA Program.

The items of nonconformance identified are summarized in Table 1.

Table 1 Items of Nonconformance

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10 CFR Part 71, No. of Section Subject Findings 111 Instructions, procedures, and drawings

123 Test Control

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The overall results of the inspection are summarized pictorially in Figure 1 (Ref. NUREG/CR-5717, " Packaging Supplier Inspection Guide").

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PACKAGE SUPPLIER INSPECTION TREE

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LEGEND QA PROGRAM HOLDER: Public Service Company of Colorado DOCKET NUMBER:

71-0346 PERFORMANCE ELEME*fF PROCEDURAL ADEOUACY c..

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Platteville, CO

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INSPECTION DATES:

December 1 - 3, 1992

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Inspection Report

Docket No.L71-0346

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DETAILS

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The NRC conducted an announced inspection of PSC, FSV, in Platteville, Colorado, on December 1-3,'1992.

The inspection team reviewed documentation representing implementation of the QA functions- : The inspection team focused

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on design, fabrication, use, and maintenance activities concerning transportation packagings with NRC Certificates of Compliance -(C0Cs).

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The objectives of the NRC inspection were to verify that the QA fuactions were accomplished in compliance with regulatory requirements; to determine if FSV's QA Program complied with-commitments made to.NRC; and_ to_ verify-that the packagings were maintained in 3ccordance with COC requirements.-

The inspection team evaluated-the: performance-of-QA activities from the perspective of three functional control. elements: management, fabrication,.

and maintenance. The inspection team focused on the QA activities regarding the Model No. FSV-1 packaging (C0C No. 6346).-

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- 2.1 Persons Contacted An entrance meeting was held on December.1,1992, to present;the objectives of the NRC inspection. An exit meetingLwas held on December 3,n1992,_to present the preliminary findings of the inspection. The-individuals present at _tho-entrance and exit meetings =are listed in Table 2.

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Inspection Report

Docket No. 71-0346

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Table 2 Entrance / Exit Meeting Attendees T. Borst Radiation Protection Manager

P. Burck Quality Assurance Engineering Supervisor

C. Cummin Rad Waste Supervisor Scientific Ecology Group M. Holmes Project Assurance Manager

W. Hug Operation Manager, MK Ferguson

J. Krauss Project Director, Westinghouse

L. McBride Project Controls Manager

G. Redmond Project Assurance G. Reigel Operations Manager

R. Sexton Acting Radiation Protection Manager, Scientific Ecology Group D. Warembourg Nuclear Operations Manager

W. Woodyard Environmental Analyst

P. Michaud Project Manager, NRC Region IV

      • J. Johns Nuclear Licensing Engineer
      • S. Ruffin Project Manager, NRC Present at entrance and exit meetings.
  • Present at entrance meeting only.
      • Present at exit meeting only.

2.2 Management Controls The inspection of management controls focused primarily on the extent to which FSV has implemented the QA Program, and the independence and proficiency of QA y

personnel responsible for fulfilling QA commitments. The inspection team

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determined QA program effectiveness by reviewing administrative procedures, inspecting fabrication and maintenance documents, and interviewing staff members.

A violation was identified regarding 10 CFR S 21.51, " Maintenance and inspection of records." This section requires the licensee to assure that records are prepared and maintained to accomplish the purpose of 10 CFR Part 2)

Evaluations of-all deviations and failures to comply should be retained for a minimum of 5 years after the date of evaluation.

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Contrary to the above, certain 10 CFR Part 21 report information could not be located to establish disposition of a possible failure to comply.

Specifically, the 0-rings purchased for use in sealing the Model No. FSV-1 packaging were purchased from Parker Seals; FSV Part 21 Report No. P21-0030,

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Inspection Report

Docket No. 71-0346 i

recorded as being received on 06/21/88 and reviewed on 06/23/88, had the following description:

Certificate of Confirmation for specific Parker Seal shipment potentially falsified.

No documentation could be located by the FSV staff to establish disposition of this issue.

2.3 Fabrication Controls

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The inspection of fabrication controls focused on the implementation of control measures regarding material procurement, fabrication processes, test

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and inspection, and tools and equipment. The inspection. team evaluated program effectiveness by interviewing staff members and examining fab-fcation records. Staff members were interviewed for knowledge.of applicable policy and procedures. The documents were reviewed for completeness, adequacy, and

. appropriate approvals.

I There were-no findings in this area.

2.4 M intenance Controls The inspection team reviewed the implementation of the_QA Program in the performance of packaging maintenance. ' Maintenance documents were inspected for completeness and adequacy of scheduled maintenance, actual maintenance performed, and QA Program controls. Compliance with packaging maintenance,.

testing, and inspection requirements was verified.- Documents were reviewed for completeness, adequacy, and appropriate approvals.

Nonconformances-were identified regarding 10 CFR-9 71.111,:" Instructions, procedures, and drawings." This._section requires the licensee _to establish procedures that Linclude appropriate quantitative or-qualitative acceptance

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criteria for determining that important activities have been satisfactorily accomplished. The licensee shall-require that these procedures are followed.

Contrary to the above, the following activities were not conducted in-accordance with established procedures.

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1.

Procedure FHPWP-300-123,-" Spent Fuel Shipping. Transaction," Task 30,

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Step 30.8, a Quality Control _ (QC) witness point, requires that a QC person' initial and date the acceptance or replacement of a set of _" Heli-Coils" on.the Model No. FSV-1 packaging. During activities' performed on-

- 10/06/91,..neither initials nor. a date were documented to certify that

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this step had been completed. The procedure step was left blank;-

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therefore, there is no way to verify-that the QC reouirement had been implemented.

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Procedure FHPWP-300-124, " Spent Fuel Shipping Transactions," Task 14, Step 14.2, a QC witness point, requires that the torquing value for the

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Inspection Report

Docket No. 71-0346 leveling studs on the Model No. FSV-1 packaging be verified and documented in the procedure. On approximately 50 percent of the records reviewed, the torque value was not documented as required by the procedure.

A nonconformance was identified regarding 10 CFR S 71.123, " Test Control."

This section requfrr3 the licensee to establish procedures that include provisions to assure adequate test instrumentation is available and used. The licensee is required to assure that test requirements have been met.

Contrary to the above, a gauge used to perform leak testing was not documented for future verification.

Specifically, Procedure MPF-1001, " Maintenance Procedure fuel Deck," Section 5, Step 5.9.12, provides guidance for performing the annual preventative maintenance leak test on the Model No FSV-1. A pressure gauge with a tolerance value of i 0.5 psi is required for the leak test. No gauge serial number was documented in the procedure nor in the associated QC Inspection Report (SSR No. 91501306, dated 10/17/91),

The pressure achieved during this test could not be verified by the inspection team for the accuracy that was required in the procedure.

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Inspection Report

Docket No. 71-0346

3.

DOCUMENTS REVIEWED

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3.1 Procedures and Specifications Quality Assurance Program dated 01/29/92.

Procedure G-8, Compliance with 10 CFR 21 Requirements, Revision 10 dated 07/01/92.

MPRM-ll, Modification and Procurement Review Manual, Revision 11, dated

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03/22/91.

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Procedure EE-GA-QAL-0002, Determination of Quality Assurance Levels for Parts Supplied by GA Technologies, Revision E, dated 07/27/92.

rocedure GADR-55, Section 7.0 Operating Procedures, Revision 22, dated 01/14/92.

FSAR B.5-15, Revision 9, QA Program for Plant Operation.

FHPWP-300-122, Spent Fuel Shipping Transaction, Issue 1.

FHPWP-300-123, Spent Fuel Shipping Transaction, Issue 2.

FHPWP-300-124, Spent Fuel Thipping Transaction, Issue 1.

SSR 91501305, Maintenance Procedure Fuel Deck, MPF-1001, Issue 6, Component ID

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H1501-1, dated 09/26/91.

SSR 91501306, Maintenance Procedure fuel Deck, MPF-1001, Issue 5, Component ID Hl501-1, dated 01/04/91.

3.2 Purchase Orders, Change Notices and Deviations Nonconformance Re90rt Action Request Log.

Part 21 Report Log.

- Purchase Order No. N4942, to Rocket Seals Corp. for Gaskets.

Purchase Order No. N6977, to Fluorocarbon Corp. for Gaskets.

Purchase Order No. N9929 to Parker Seal for Buna-N 0' rings.

f Nonconformance Report 91-033, identified 10/04/92.

3.3 Logs, Files and Reports Approved Vendor Lis.

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Inspection Report

Docket No. 71-0346

Fabrication File for Model No. FSV-1, P.O. 915-HOL.

Audit Report 92-002, dated 05/06/92.

Audit Report ERCN-91-01, dated 07/26/91.

Helicoflex Vendor Qualification Evaluation, dated 02/28-31/91.

Parkers Seals Vendor Qualification Evaluation, dated 08/27-28/91.

General Atomics Vendor Qualification Evaluation, dated 03/27-30/90.

Consolidated Design Report for the Model No. FSV-1 Shipping Cask, No. 910013, Revision N/C, Volume 2, dated 01/14/92.

QC Inspection Report for SSR No. 91501306, dated 10/17/91.

Qualification Records for Quality Assurance Personnel performing on-site inspections.

Calibration records for selected gauges and torque wrenches.

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