ML033100169
| ML033100169 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/03/2002 |
| From: | Narbut P NRC/NMSS/SFPO |
| To: | |
| References | |
| FOIA/PA-2003-0395, NMSS-02-A-0002 | |
| Download: ML033100169 (6) | |
Text
SENSITI D
SQAIF MlRE NMSS-2002-A- 0002 ALLEGATION BRIEFING SHEET Prepared by: Paul P. Narbut 4/3/02 FACILITIES/ORGANIZATIONS: Holtec International, Mariton NJ US Tool and Die, Pittsburgh PA Exelon (ComEd) Corp.,
STATEMENT OF ALLEGATION(S)/CONCERN(S):
Region III letter to NMSS characterized Allegation I as: 'You stated that a vendor"....(US Tool and Die)... "modified spent fuel storage casks during the fabrication process by making repairs and/or accepted discrepancies "as is" without obtaining the required review and approval of the cask designer"... (Holtec).... "You were concerned that this was contrary to Exelon's (ComEd) procedures".
The alleger's description of the allegation included:....ComEd should have documentation of their review of the dry cask storage dispositions of Use-as-is and Repair that Holtec was sending to them.
Region I letter to NMSS characterized Allegation 8 as: "You are concerned about the inadequate QA/QC oversight by the spent fuel storage cask design organization" (Holtec)..."and that this inadequate oversight has resulted in indeterminate quality and structural integrity of the casks. You stated that the fabricator's disposition of nonconformance condition as use-as-is, rework, and repair was a violation of the QA program for design control as specified in 10 CFR 71 and 10 CFR 72. You stated use-as-is and repair dispositions are design changes and should be evaluated and documented by engineering analysis. In addition, the fabricator dispositioned nonconformance conditions under its QA program without the design organizations consent".
The alleger's description of the allegation included: I suspect whether Mr. Soler of Holtec performed any design reconciliation and documentation for all the drycask storage containers and associated parts impacted by disposition of.use-as-is, repair, and rework at UST&D that were already built and delivered to nuclear plants.
BACKGROUND:
The alleger made contact with Region Ill. Region Ill Initiated Allegation File RiII-2002-A-005 which consisted of 10 allegations. Allegations 1 and 8, described above were assigned to SFPO.
SFPO performed a routine inspection of US Tool and Die in February 2002. During that inspection the team examined the question of repair, rework, and use-as-is dispositions for CY 2001 and found the area adequate. SFPO did not look at the NCR dispositions or procedures in place at the times cited in the allegation, i.e. 1999-2000.
POTENTIAL SAFETY SIGNIFICANCE: Medium Basis: If technically Inadequate changes were made to the casks fabricated and delivered to licensees for spent fuel storage, then Inadequate casks may be loaded with spent fuel and there may be a potential for release or accelerated fuel degradation. Also the nternal spent fuel canisters may be used later in transportation containers for shipment to other repositories, posing a potential transportation risk.
GENERIC ISSUES: None NEED FOR 01 INVESTIGATION AND PRIORITY (High/Medium/Low): N/A for SFPO, done by Rill SEPI FR FO 1W 6 DIS CLOSURE
SE IVE PREl ISIONAL INFORMATION - NOT FOR PUBLIC DISCLOSURE NMSS-2002-A- 0002 PROPOSED TECHNICAL REVIEW PRIORITY:
(1) High Priority (immediate action required)
X (2) High Priority Near Term (short term action required)
(3) Low Priority (longer-term action required)
NON-NMSS ISSUES (REGION, OGC, OE, ETC.)
Interface with Region I required since some actions will involve Excelon (ComEd), Dresden site.
PROPOSED RESOLUTION PLAN:
- 1. SFPO perform an inspection at Holtec International. Determine the nature of the Dry Storage Quality Group (DSQG) Audit findings at UST&D from CY 2000 related to the allegations. Review the Holtec and UST&D corrective actions for adequacy of defining the extent of the condition, immediate corrective action, and action to prevent recurrence.
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- 2. Region perform an inspection at ComEd, Dresden and determine the code and procedure requirements for reviewing and approving Supplier Deviation Requests (SDRs), and Nonconformance reports (NCRs) in regards to the obligations of the cask owner to review and approve use-as-is, and repair dispositions. Determine if ComEd is and was complying with the requirements during the period of the allegations.
SENSIT RE SIR N -
M-af UBQUFE
AMERICAN NATIONAL STANDARD QUALITY ASSURANCE TERMS AND DEFINITIONS ANSI N45.2.1D1973
- Procurcient Docuzents - ContrictualIy binding
'documents that idcntify and dcrinec the requiremcnts which items or services must meet in order to be considered accecptablc by the purchaser.
~_Tr(jccr - A planned sries of activities including all actions neccssary to provid.. utilize, and maintain a facility or portion thereof.
,Air'Ihaser -
The oreanization or organizations responsible for issuance and administration of a contract.subcontract, or purchaic order.
.Qltitcatinri (Pcrsronnel) - The characteristics or abilities gained throudi training or expericncc or both 1ilt cnable an individual to perfonn a required tiection.
alijled Partr - A person or org-aniiation conpc:
tent nd rcoenizcd
- as knowliedc3ble to perfonn certait! lunctiolis.
Qulllfled Procedure - A.procedure which incorpo.
ritzb all 3pplicablc codes ad stand3rds. nanu-raciurcrs prameters. and engincering specifications and has been proven dequate for its intcnded purpose.
.-Qmwlij',Assitraire -
All thos^ planned and ss-tem3tic actions necessary to prOvide adequate con-fience that an item or a facility will perform satisfactorily in servie.
Qualiny Conirid - Those quality assurance actions which providc a mcans to control and measure the characteristics of n item. process. or facility to established requirements.
,-'Rcceiring -
Taking delivery of an item at a designated location.
-Repair - The process of restoring a nonconforming characteristic to a condition such that the capability or an item to function reliably and safely is unim-paired, even thougi th2t item still may not conform to the original requirement.
requirements to be satisfied by a product, a material or process indicating. whenever appropriate, the pro.
cedure by means of which it may be determined whether the requirements givcn are satisfied.
-standard - The result of a particular standardiza-tion effort approved by a recognized authority.
_-Storag -
The act of holding items at the con-struction site or in an area other than its permanent location in the plant.
-Subsystein - A group of assemblies or components or both combined to perform a single unction.
Slystem - A group of subsystems united by some interaction or interdependence, performing many duties but functioning as a single unit.
.S.stcm Perfonna:ce Test - A test performed on a completed system including electric, instrumentation, controls, fluid and mechanical subsystems under normal or simulated nornial process conditions such as tempcrature. low, level, and pressure.
- Testing - The determination or verification of the capability o an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental or operating conditions.
-Trnsir - A state of being conveyed or transported from one place to another.
-Transit Carrier (Open) - Trucks, trailers, railroad cars, barges, aircraft or ships which do not afford items protection frorm the environment.
Transit Cartier (Closed) - Trucks, trailers. railroad cars, barges, aircraft or ships which do provide pro-tection of items from the environment by nature of their closed design.
- Trip-Pnfnt -
A predetermined critical level at which a bistoble device changes state to indicate that the quantity under surveillance has reached the selected value.
.- Report - Something (document) that gives infor-
-mation for record puriposes.
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- ,Us-as-fs -
disposition -which mav be ifposed for a nonconformance whcn it can bc established
,-Rework - The process bv which a nonconforming that the discrepancy will result in no adverse condi-item is made to conform to a prior specified require-tions and that the item under consideration ill ment by compIetion. remachining, reassembling or contintle to meet all enginecring functional require-other corrcctive means.
ments including performance.maintainability. fit, and Scthirce Surrefilance -
A review, observation, or safety.
inspection fr the purpose or vcrifying that an action hs been accomplished as specified at the location of material procurement or manufacture.
-.Specifi;Cti-n - A concise statement of a set of
- Verificatioz -
An act of confirming, substanti-ating and assuring that an activity or condition has been implemented in conformance with the specified requirements.
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NCA.9200 2001 SECTION m, DIVISION I -
NCA CA-9200 Qualified Procedure. A procedure that has been demon-strated to meet the specified requirements for its intended purpose.
Quality Assurance. As used in this Section, quality assurance comprises all those planned and systematic actions necessary to provide adequate confidence that all items designed and constructed are in accordance with the rules of this Section.
Quality Assurance Manual. A wvritten document which describes a Quality Assurance Program.
Quality Assurance Program A controlled system of planned and systematic actions required to provide adequate confidence that items designed and constructed are in accordance with the rules of the Code.
Quality System Certificate. A Certificate issued by the Society which permits an organization to perform specified Material Manufacturer or Material Supplier activities in accordance with Code requirements.
Quality System Program. A documented system of actions required to provide adequate confidence that materials conform to the requirements of the material specification and the rules of Section m.
Regulatory Authority. A Federal Government Agency, such as the United States Nuclear Regulatory Comris-sion, empowered to issue and enforce regulations con-ceming the design, construction, and operation of nu-clear power plants.
Repair. The process of physically restoring a noncon-formance to a condition such that an item complies with Code requirements.
Rework Refer to Repair.
Senice. An activity performed by a subcontractor such as designing, rigging, temporary bolting, and nonde-structive examination.
Service Limits. Stress and stress intensity limits applica-ble to Service Loadings given in the Design Specifi-cation.
Shop and Field Drawings. Drawings provided by the Constructor or Fabricator (Division 2) which describe construction, fabrication, and installation details, physi-cal dimensions, arrangements, and any significant engi-neering features needed to establish conformance to the Design Drawings, Construction Specification, and this Section.
Society. The American Society of Mechanical Engineers, Three Park Avenue, New York, NY 10016.
Source MateriaL For Section m, metallic products used for conversion to or qualification as material by a Certificate Holder or Material Organization.
Special Process. A process, the results of which are highly dependent on the control of the process or skill of the operator, or both.
Standard Support. A support consisting of one or more units usually referred to as catalog items and generally mass produced.
Supplier. Any individual or organization that furnishes materials or services in accordance with a procurement document.
Support. A metal element, excluding an intervening element, which transmits loads between nuclear power plant components and the building structure. A support may be either a component support or a piping support.
Survey. A documented evaluation of an organization's ability to perform Code activities as verified by a determination of the adequacy of the organization's quality program and by a review of the implementation of that program at the location of the work.
Testing. An element of verification for the determination of the capability of an item to meet specified require-ments by subjecting the item to a set of physical, chemical, environmental, or operating conditions.
Traceability. The ability to verify the history, location, or application of an item by means of recorded identifi-cation.
Unqualified Source Material. Source material not pro-duced by a Certificate Holder, Material Organization, or approved supplier in accordance with the require-ments of Section m, NCA-3800.
Use-as-is. A disposition assigned an item previously identified as nonconforming after reconciling Design Output Documents with the item's as-built condition and verifying that applicable requirements of this Sec-tion have been met.
Verification. A review to ensure that activities have been performed and documented in accordance with applicable requirements.
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INCA-35;2 NCA-3000 -
RESPONSIBILITIES AND DUTIES NCA-3561 NCA-3952 Deri1n output Documents for Parts When the N Certificate Holder purchases parts from an NPT Certificate Holder, it is the responsibility of the N Certificate Holder to provide or cause to be provided the calculations for the parts and to incorporate them into the Design Output Documents.
NCA-3553 Design Output Documents for Appurtenances The Design Output Documents for each appurtenance which is to be attached to a completed component shall be provided unless they are already included in the component Design Output Documents.
NCA-3554 Modification of Documents and Reconciliation With Design Report
\\! z Any modification of any document used for construc-tion, from the corresponding document used for design analysis, shall be reconciled with the Design Report by the person or organization responsible for the design.
A revision or addenda to the Design Report shall be prepared and (if required by NCA-3551.1) certified to indicate the basis on which this has been accomplished.
All such revised documentation shall be filed with the completed Design Report.
NCA-355 Certification of Design Report (a) The Design Report for Class I components and component and piping supports, Class CS core support structures, Class MC essels and Class MC component supports, Class 2 vessels designed to NC-3200 (NC-3131.1), or Class 2 or Class 3 components designed to Service Loadings shall be certified by one or more Registered Professional Engineers competent in the applicable field of design and qualified in accordance with the requirements of ANSI/ASME N626.3-1988, Qualifications, and Duties, of. Specialized Professional.
Engineers. The Design Report shall be certified only' after all design requirements of this Section have been met. Such Registered Professional Engineers shall be other than the individuals certifying the Design Specifi-cations (NCA-3255) but are not required by these rules to be independent of the organization holding the Certificate.
(b) It is the intent of this Section that the certification of the Design Report shall in no way relieve the N Certificate Holder of the responsibility for the structural integrity of the completed item for the conditions stated in the Design Specifications.
NCA-3556 Submittal of Design Report for Owner Review The N Certificate Holder shall submit to the Owner or his designee a copy of the completed Design Report for all components and supports for review and docu-mentation of review to the extent required by NCA-3260.
NCA-3557 Availability of Design Report The N Certificate Holder shall make a copy of the completed Design Report, Load Capacity Data Sheets, Certified Design Report Summaries, and the drawings used for construction available to the Inspector.
NCA-3560 RESPONSIBILITY FOR QUALITY ASSURANCE NCA-3561 Scope of Responsibilities (a) The N Certificate Holder shall be responsible for surveying, qualifying, 'and auditing suppliers of subcontracted services (NCA-3125), including nonde-structive examination contractors, Material Suppliers, and Material Manufacturers. Material Suppliers or Mate-rial Manufacturers holding Quality System Certificates (Materials), and Certificate Holders whose scope in-cludes supply or manufacture of materials, need not be surveyed nor audited for work or material covered by the scope of their Certificate. Subcontractors holding an appropriate Certificate of Authorization need not be surveyed nor audited for work within the scope of the subcontractor's Certificate. N or NV Certificate Holders may supply replacement material without material sup-ply being shown in the scope of their Certificate provided supply of replacement material is included in their Quality Assurance Program, the replacement material conforms to all applicable requirements of this Section, and are exclusively for incorporation into items originally manufactured or fabricated and furnished by the N or NV Certificate Holders under their Certificate.
(b) An N Certificate Holder may qualify vendors of subcontracted services (NCA-3125) other than those requiring a Certificate of Authorization, such as Material Manufacturers or Material Suppliers, for another Cer-tificate Holder doing work for that N Certificate Holder.
The qualification documentation shall be supplied to the other Certificate Holder prior to their use of the subcontracted service, Material Manufacturer, or Mate-rial Supplier.
(c) An N Certificate Holder may subcontract furnace brazing operations involving uniform heating to an I1I1 27
NCA 3254 NCA-3000 -
RESPONSIBILITIES AND DUTIES INCA 3260 NCA-3254 Boundaries of Jurisdiction In order to define the boundaries of components with respect to adjacent components and.other structures, the Design Specifications shall include:
(a) the locations of each such boundary; (b) the forces, moments, strains, or displacements which are imposed at each such boundary; (c) the structural characteristics of the attached com-ponents or structures, whether or not they are within this Section's jurisdiction when such components or structures provide constraints to the movement of com-ponents or appurtenances; (d) when the foundation support is constructed as an integral part of the concrete reacior vessel or concrete containment, it shall be included within this Section's Division 2 jurisdiction to the extent required by NCA-2132.
NCA-3254.1 Definition of.Division 1 Boundaries (a) The boundaries for Class I components are given in NB-1130.
(b) The boundaries for Class 2 components are given in NC-1130.
(c) The boundaries for Class 3 components are given in ND-1130.
(d) The boundaries for Metal Containment Vessels are given in NE-1132.
(c) The boundaries for Component Supports are given in NF-1130.
(fi The boundaries for Core Support Structures are given in NG-1 130.
NCA-3254.2 Definition of Division 2 Boundaries.
The Design Specification shall define the boundaries of Division 2 in accordance with the limits defined in NCA-I 120; it shall also show the external boundaries of the component with respect to its supporting structures.
Where the support is constructed as.an integral part of the concrete vessel or the concrete containment, it shall be included within the jurisdiction of Division 2 to the extent required by NCA-1120. The Design Specification shall include the.specific dimensional loca-tion of each boundary, including the boundaries for parts and appurtenances designated to meet the require-ments of Division 1.
NCA-3255 Certification of the Design Specifications The Design Specifications shall be certified to be correct and complete and to be in compliance with the requirements of NCA-3250 by one or more Registered Professional Engineers, competent in the applicable field of design and related nuclear power plant require-ments and qualified in accordance with the requirements of ANSI/ASME N626.3-1988, Qualifications and Duties
.of Specialized Professional Engineers. These Registered Professional Engineers are not required to be indepen-dent of the organization preparing the Design Specifica-tions. Document distribution for Division 2 construction is shown in Table NCA-3200-1.
NCA-3256 Filing of Design Specifications (a) The Design Specifications in their entirety shall become a principal document governing design and construction of items. A copy of the Design Specifica-tion shall be made available to the Inspector at the manufacturing site before fabrication begins, and a copy shall be filed at the location of the installation and made available to the enforcement authorities having jurisdiction over the plant installation before components or appurtenances are placed in service. In the case of parts, piping subassemblies, appurtenances, and compo-nent and piping supports, the Design Specifications need not be made available to the Inspector at the fabrication site (NCA-3251). However, the'applicable data from the Design Specifications which form the basis for fabrication shall be made available to the Inspector at the fabrication site. Document distribution for Division 2 construction is shown in Table NCA-3200-1.
(b) For pumps and valves 4 in. nominal pipe size and less, for linear supports used as mechanical snub-bers, and for standard supports, the Certificate Holder may provide his own Design Specification in accordance with NCA-3252 as a basis for construction. Prior to installation, the Owner or his designee shall be responsi-ble for reconciling the Certificate Holder's Design Specification with his own Design Specification.
NCA-3260 REVIEW OF DESIGN REPORT (a) The Design Report which the Certificate Holder or the Designer provides shall be reviewed by the Owner or his designee to determine that all the Design and.Service Loadings as stated in the Design Specifica-tion have been evaluated, and that the acceptance criteria explicitly provided for in this Section, or additional acceptance criteria permitted by this Section when established in the Design Specification, associated with the specified Design and Service Conditions, have been considered. The responsibility for the method of analysis and the accuracy of the Design Report remains with the Certificate Holder or the Designer.
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