ML003753586

IP 60853 On-Site Fabrication of Components and Construction of an ISFSI

ML003753586
Person / Time
Issue date:	08/25/2000
From:	NRC/NRR/DIPM/IIPB
To:
Klingler, G R
References
CN 00-014
Download: ML003753586 (8)

Text

Issue Date: 09/07/00 60853 l

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NRC INSPECTION MANUAL SFPO/NMSS l

l INSPECTION PROCEDURE 60853 l

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ON-SITE FABRICATION OF COMPONENTS l

AND CONSTRUCTION OF AN ISFSI l

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PROGRAM APPLICABILITY:

2690 and 2515 l

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60853-01 INSPECTION OBJECTIVES l

l 01.01 To determine whether Independent Spent Fuel Storage Installation (ISFSI) dry cask storage l

system (DCSS) components are fabricated in accordance with:

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a.

the Safety Analysis Report (SAR);

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b.

the Quality Assurance (QA) program; l

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c.

the Safety Evaluation Report (SER);

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d.

the Certificate of Compliance (CoC), or the site-specific license and technical specifications; l

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e.

10 CFR Part 72.

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01.02 To determine whether ISFSI construction activities are conducted in accordance with the l

QA program.

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01.03 To determine whether the licensee has reviewed ISFSI activities for determination of no l

adverse impact on site operations or Technical Specifications.

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l 60853-02 INSPECTION REQUIREMENTS l

l 02.01 Determine whether:

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a.

materials, components, and other equipment received by the fabricator meet DCSS design l

procurement specifications; and l

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b.

the procurement specifications conform to the design commitments and requirements l contained in the SAR and, as applicable, the CoC or the site-specific license and technical l specifications.

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60853 Issue Date: 09/07/00 l

02.02 With regard to on-site DCSS fabrication activities, determine whether:

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a.

the fabrication specifications are consistent with the design commitments and requirements l

documented in the SAR, and, as applicable, the CoC or the site-specific license and l

technical specifications; l

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b.

the licensee, vendor, and fabricator personnel have established an effective method for l

tracking, evaluating, and dispositioning changes or modifications to the DCSS component l

design; l

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c.

for selected design changes, the applicable documentation is complete and accurate, l

including relevant 10 CFR 50.59 or 72.48 evaluations; l

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d.

individuals performing quality-related activities are trained and certified where required; and l

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e.

the on-site fabricators personnel are familiar with the specified design, designated l

fabrication techniques, testing requirements, and quality controls associated with the l

construction of the DCSS.

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02.03 With regard to on-site DCSS fabrication QA activities, determine whether:

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a.

they are conducted under an NRC-approved QA program (10 CFR 72.140);

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b.

DCSS components are being fabricated per approved QA and 10 CFR Part 21 l

implementing procedures and fabrication specifications.

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c.

the fabricators personnel are familiar with the reporting requirements of 10 CFR Part 21; l

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d.

the fabricator has complied with 10 CFR 21.6, Posting requirements; l

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e.

the fabricator has been audited by either the licensee or CoC holder; l

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f.

for selected audits and inspection findings from (as applicable) QA audit or surveillance l

and/or inspection reports issued in the previous 2 years, the findings were appropriately l

handled with corrective actions implemented in a time frame commensurate with their safety l

significance; l

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g.

supervision and quality control/assurance personnel perform appropriate oversight during l

fabrication activities; and l

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h.

nonconformance reports documenting the deficiencies have been initiated and resolved l

and corrective actions for identified fabrication deficiencies have been implemented in a l

time frame commensurate with their significance.

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02.04 With respect to ISFSI pad design:

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a.

for generally licensed ISFSIs, if not previously done, perform Sections 2.01b and 2.02a of l

IP 60856; or l

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b.

for specific licensed ISFSIs, verify that design requirements contained in the SAR, SER, l

and license or technical specifications have been properly incorporated into documents l

governing construction of the ISFSI storage pad.

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02.05 If pad construction activities are observed, then verify:

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Issue Date: 09/07/00 60853

a.

through the review of records, that the pad's subsoil has been compacted or otherwise l

treated to meet the specifications defined in the SAR, SER, C of C, and, if applicable, the l

site-specific license and technical specifications; l

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b.

subsoil has been properly treated to meet the requirements specified for the ISFSI pad; l

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c.

the correct size, grade, and spacing of reinforcing steel are installed per the pad's l

specifications; l

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d.

restrictions on batch composition and time between mixing and pouring of concrete are met; l

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e.

concrete is properly placed in adequate forms, consolidated (vibrated), finished, and cured; l

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f.

slump and air entrainment tests fall within the specified values; l

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g.

the overall dimensions, orientation, and levelness of the pad meet the design specifications; l

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h.

compressive strength samples are collected, cured, and tested, per specifications, and tests l

indicate whether the concrete meets the specified minimum design strength; l

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i.

appropriate QA/QC involvement in and oversight of pad construction activities; and l

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through interviews with selected workers and supervisors, that individuals are familiar with l

the design and construction specifications for the ISFSI pad.

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02.06 For other ISFSI-related items and activities, such as construction or modification of l

roadways/railways, buildings, security systems, and other support systems, such as cranes, l

verify:

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a.

for specific licensed ISFSIs, that the design requirements contained in the SAR, SER, and l

license or technical specifications have been properly incorporated into documents l

governing construction or modification of these items; l

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b.

for generally licensed ISFSIs, that design requirements contained in the 10 CFR 72.212(b) l evaluations have been properly incorporated into documents governing construction or l

modification of these items; and l

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c.

if construction or modification activities are observed, then verify through interviews with l

selected workers and supervisors, that individuals are familiar with the design and l

construction specifications for the activity and that there is appropriate QA/QC involvement l

in and oversight of the activity.

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02.07 For generally licensed ISFSIs, if not previously done, perform Section 02.03 of IP 60856.

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l 60853-03 INSPECTION GUIDANCE l

l Definitions l

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Participants:

The terms licensee, vendor, CoC holder, fabricator, general licensee, and site-l specific licensee are terms you will commonly encounter while reviewing ISFSI activities. Refer l to Inspection Manual Chapter (IMC) 2690, Inspection Program for Dry Storage of Spent Reactor l Fuel at Independent Spent Fuel Storage Installations, Section 03, for definitions of these terms. l l

Safety Classification: ISFSI systems, structures, and components (SSCs) are classified as either l important to safety or not important to safety by the ISFSI designer.

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60853 Issue Date: 09/07/00 l

If important to safety, the SSC will typically either:

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1.

maintain the functions or conditions (i.e., confinement, criticality, shielding, and heat l

removal) necessary to store spent fuel safely; l

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prevent significant damage to the spent fuel container (DCSS) during handling and storage; l

or l

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3.

provide reasonable assurance that spent fuel can be received, handled, packaged, stored, l

and retrieved without undue risk to public health and safety.

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If an SSC does not perform any of the preceding functions, it may be classified as not important l

to safety.

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General Guidance l

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a.

Overall Focus: The inspection focus is to determine whether:

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1.

the fabricator is constructing on-site ISFSI components in accordance with an NRC l

approved QA program, and whether the DCSS component, as fabricated, will l

perform its intended function as stated in the SAR and, as applicable, the CoC or l

the site-specific license and technical specifications. DCSS components must be l

constructed under an NRC-approved QA program, which may be either the l

licensee's, CoC holders, or the fabricator's. Refer to IP 60851, Design Control of l

ISFSI Components, for guidance on inspecting design changes.

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2.

the ISFSI and its storage pad is designed and constructed in accordance with the l

site specific license and technical specifications or in accordance with the DCSS l

CoC, as applicable. Licensees for a generally licensed ISFSI will also need to review l

ISFSI activities for determination of no adverse impact on site operations or l

Technical Specifications.

Refer to IP 60856, Review of 10 CFR 72.212(b) l Evaluations for guidance on reviewing generally licensed ISFSIs.

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b.

Additional Assistance: You may obtain additional assistance for both technical and design l

questions from the cognizant Spent Fuel Project Office (SFPO) project manager (PM).

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c.

ISFSI SSCs Safety Classification: Before performing an inspection of ISFSI SSCs, the l

inspector should review the licensees design basis documents to determine whether the l

licensee has applied an appropriate safety classification to a particular SSC. Note that site-l specific variations in ISFSI designs may affect the safety classification of some SSCs.

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d.

ISFSI SSCs Not Important to Safety: For this class of SSCs, the licensees use of generally l

accepted commercial-grade standards, practices, and materials in design, fabrication, and l

construction activities is acceptable. However, these SSCs must still conform to the design l

requirements described in the safety analysis report (SAR) and supporting engineering l

documents.

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e.

Design Changes: Each DCSS design has been approved by the NRC through the licensing l

process, for a site-specific license, or the 10 CFR Part 72, Subpart L, process for a general l

license. All changes to the design described in the SAR must be approved by the licensee l

or CoC holder. Approval authority for changes can be difficult for the inspector to l

determine. In such cases, you can find additional guidance in IMC 2690, Section 05.10.

l (NOTE: Recent changes to Part 72 have extended the provisions of 72.48 to CoC holders, l

not just licensees.)

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f.

Component Functionality: Functionality is the ability of a component to meet its design l

requirements. Some components may have multiple design requirements and several

Issue Date: 09/07/00 60853 functions. These requirements and functions are defined in the SAR, SER, and, as l applicable, the CoC or the site-specific license and technical specifications for the DCSS l

. For example, the cask support basket that separates the individual fuel bundles serves l several functions: structural integrity, criticality control, heat transfer, and radiation shielding. l Assistance in identifying the function(s) of a given component may be obtained from SFPO. l l

g.

Document Review: Before any onsite inspection activity, for each DCSS in use, review l

(as applicable) the:

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safety analysis report and corresponding NRC safety evaluation report; l

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certificate of compliance; l

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site-specific license and technical specifications; l

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10 CFR 72.212(b) evaluations for generally license ISFSIs; and l

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5.

72.48 evaluations performed since the last update to the DCSS SAR.

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SARs and SERs describing DCSS components have been written for each type of l approved DCSS. Information on operational commitments for a particular DCSS may also l be found in the CoC or the site-specific license and technical specifications. As DCSS l designs vary, be careful to review the appropriate documentation. You can obtain copies l of these documents from the appropriate regional division or cognizant SFPO PM.

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60853 Issue Date: 09/07/00 l

Specific Guidance l

l 03.01 Verify that the procurement specifications conform to the design requirements contained in l

the SAR, CoC, and other applicable engineering documents. Place emphasis on instances in which l

components or raw materials do not meet the procurement specifications thus representing a l

nonconforming condition. Verify that the licensees or CoC holders design change process has l

evaluated and handled these nonconformances. Reference Section 03.03(h) of this procedure for l

guidance on the evaluation of nonconformances.

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You can find supplemental guidance on the quality classification levels of ISFSI components from l

references found in Section 05 of this inspection procedure.

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03.02 Guidance for on-site DCSS fabrication activities.

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a.

Fabrication specifications include, but are not limited to, component material specifications, l

fabrication techniques, examination techniques, and required dimensions and tolerances.

l Previously identified problems related to DCSS component fabrication include l

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incomplete documentation of actual fabrication activities in fabrication traveler l

documents; l

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failure to explicitly state required critical component dimensions, such as minimum l

allowable wall thickness, on fabrication traveler documents; l

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3.

failure to require verification of critical component dimensions using a specified non-l destructive examination (NDE) technique (i.e.- ultrasonic testing) as required in the l

DCSS design documentation; l

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4.

design changes made outside of the approved design change process (e.g., by letter l

or memorandum);

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5.

inadequate oversight of fabrication activities by the licensee or CoC holder; and l

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fabrication of a component to a different safety classification than that shown in the l

design specifications.

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b.

Determine, through review of records, inspection of equipment and components, and/or l

interviews with selected personnel, whether the licensee or CoC holder has performed l

design changes and modifications.

Evaluate the quality and timeliness of such l

documentation. Assess the thoroughness of documentation and the independence of l

reviews, particularly for those design changes that resolve nonconformances and field l

change requests. Check that evaluations contain a discussion of the effect on component l

functionality. You can find information on component functionality in the SAR, SER, CoC, l

or, as applicable, the site-specific license and technical specifications.

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Determine the adequacy of the timing of design change reviews. Ideally the licensee or l

CoC holder should complete the reviews before the component is fabricated. However, l

if the licensee elects to proceed with fabrication at risk, verify that the licensee does not l

use the DCSS until all design changes have been evaluated and appropriately l

dispositioned.

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Review IP 37700 for additional guidance and a listing of potentially related procedures.

l Note that although IP 37700 contains guidance on reactor design changes, ISFSI SSCs l

are only classified as important to safety or not important to safety, and a safety-related l

classification is not considered. Consequently, exercise caution in assessing the scope l

and thoroughness of the evaluations if you use IP 37700. Contact the cognizant SFPO l

PM for assistance on acceptable calculational methods or code applicability. You can

Issue Date: 09/07/00 60853 obtain supplemental information on the quality classification of components from references l

found in Section 05 of this inspection procedure.

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c.

Design-basis accidents, such as a DCSS tipover or a drop from a maximum specified l height, are addressed in the SAR; however, you may obtain assistance from the cognizant l SFPO PM in determining whether a change requires NRC approval for a particular DCSS l design.

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d.

Fabricator personnel performing quality functions may be welders, NDE inspectors, quality l control (QC) staff, and QA auditors. A program for certification of each of these personnel l should have been defined and implemented by the fabricator and approved by the licensee l prior to performance of quality activities by these individuals.

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e.

No specific guidance.

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03.03 Guidance for on-site DCSS fabrication QA activities.

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a-d. No specific guidance.

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e-g. Determine if and when the licensee's QA staff or other licensees' QA staffs have audited l fabricator activities. You can obtain information about audits of specific fabricators from l

the owners' groups for specific DCSS designs, the licensee's QA staff, or NMSS/SFPO.

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You should obtain and review copies of audits and surveillances performed by onsite QA l personnel (the fabricators or other oversight groups such as the CoC holders or l licensees). Assess the quality and depth of the audits and surveillances and determine l if appropriate corrective actions were implemented for negative findings. You should also l review fabrication documents, such as travelers, to ensure that hold points are identified l and QA signatures made where required.

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h.

For nonconformance reports in which the adverse condition is determined to be acceptable l "as is," the report should contain sufficient information to justify why the nonconforming l condition does not compromise the ability of the component to perform its intended l function(s). Nonconformances should be dispositioned before the DCSS is released to the l licensee, unless otherwise authorized by the licensee. Review nonconforming conditions l that are resolved by design changes to ensure that component function is not l compromised. You may obtain assistance in determining component function from l NMSS/SFPO. Also, you can find supplemental information on inspecting design changes l in IP 60851.

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03.04 Guidance on ISFSI pad design.

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a.

Reference Sections 03.01b and 03.02a of IP 60856.

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b.

No specific guidance.

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c.

No specific guidance.

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03.05 IPs 46053 and 46051 may be used for supplemental guidance.

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03.06 No specific guidance.

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03.07 Reference Section 3.03 of IP 60856.

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l 60853-04 INSPECTION RESOURCES l

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60853 Issue Date: 09/07/00 l

To prepare for these inspections, each inspector should spend approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on in-office l

review. Inspection activities will require approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, each, by three inspectors at the l

ISFSI site. Documentation is estimated to require 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for each inspector. Inspection hours l

may vary, depending on the amount of activity occurring at the site.

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l 60853-05 REFERENCES l

l NRC Information Notice 95-28, Emplacement of Support Pads for Independent Spent Fuel Dry l

Storage Installations at Reactor Sites, June 5, 1995.

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NRC Information Notice 95-29, "Oversight of Design and Fabrication Activities for Metal l

Components Used in Spent Fuel Dry Storage Systems," June 7, 1995.

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NRC Inspection Manual Chapter 2690, Inspection Program for Dry Storage of Spent Reactor Fuel l

at Independent Spent Fuel Storage Installations, February, 1997 l

NRC IP 37700, Design Changes and Modifications, September,1990.

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NRC IP 60851, Design Control of ISFSI Components. May, 2000 l

l NRC IP 60852, ISFSI Component Fabrication by Outside Fabricators. August, 2000 l

l NRC IP 60856, Review of 10 CFR 72.212(b) Evaluations, November, 1999.

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NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System l

Components According to Importance to Safety," February 1996.

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10 CFR Part 21, Reporting of Defects and Noncompliance.

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10 CFR 72, Subpart L, Approval of Spent Fuel Storage Casks.

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10 CFR § 50.59, Changes, tests, and experiments.

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10 CFR § 72.48, Changes, tests, and experiments.

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END l