ML093060395
| ML093060395 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Monticello, Oconee, Nine Mile Point, Palisades, Kewaunee, Oyster Creek, Cooper, Susquehanna, Brunswick, Limerick, Ginna, Fort Calhoun, 07200006, 07201004 |
| Issue date: | 10/30/2009 |
| From: | Neider T AREVA, Transnuclear |
| To: | NRC/FSME |
| References | |
| E-28731, FOIA/PA-2011-0115 | |
| Download: ML093060395 (24) | |
Text
A AREVA TRANSNUCLEAR, INC.
E-28731 Report to the US Nuclear Regulatory Commission (USNRC)
UnsubstantiatedCertified MaterialTest Reports Hwa Shin Bolt Industrial Co., Ltd.
October30, 2009 PURPOSE OF REPORT Pursuant to the requirements of 10 CFR 21, Transnuclear, Inc. is providing the enclosed thirty day written report as provided for in 10 CFR 21.21 (d)(3)(ii).
On October 1, 2009, the President and Chief Executive Officer of Transnuclear, Inc. provided phone and follow-up written notification to the NRC Operations Center of a potential deviation and failure to comply associated with unsubstantiated certified material test reports (CMTRs) for certain small parts utilized in products fabricated in accordance with the requirements of 10 CFR 72.
Information required to be reported by 10 CFR 21.21 is provided as follows:
Name and address of the individual informing the commission Tara J. Neider President and Chief Executive Officer Transnuclear, Inc.
7135 Minstrel Way, Suite 102 Columbia, MD 21045 10 CFR 21.21(d) (4) (ii)
Identification of the facility and the basic component supplied to such facility This information is presented in the section of this report titled "Extent of Impact and Current Status."
Identification of the firm supplying the basic component which fails to comply or contains a defect Transnuclear Inc., 7135 Minstrel Way, Suite 300, Columbia, MD 21045 The NRC 10 CFR 72 Certificate Holder and supplier of the Dry Shielded Canisters discussed in this report.
Hitachi Zosen (HZ) Corporation, Ariake Works, Nagasu-Machi, Tamana-Gun, Kumamoto-Pref, Japan The Transnuclear sub-contractor responsible for material procurement and fabrication of Dry Shielded Canisters (DSCs) and Transfer Cask discussed in this report.
Nature of the defect or failure to comply and the safety hazard which is created or could be created Transnuclear has conducted the necessary evaluations and review and determined that the defect or failure to comply discussed in this report does not and cannot result in loss of safety function such that a substantial safety hazard could be created. Information supporting this statement is presented in the sections of this report titled "Engineering Evaluations and Significant Safety Hazard Determination" and "List of Impacted Items."
The date on which the information of such defect or failure to comply was obtained This information is presented in the section of this report titled "Issue Chronology."
In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, beingq supplied for, or may be supplied for...
This information is presented in the section of this report titled "Extent of Impact and Current Status."
The corrective action which has been, is being, or will be taken: the names of the individual or organization responsible for the action: and the time that has been or will be taken to complete the action This information is presented in the section of this report titled "Corrective Action That Has Been / Is Being I Or Will Be Taken."
Any advice relative to the defect or failure to comply about the facility, activity, or basic component that has been, is beingq taken, or will be .qiven to purchasers or licensees Transnuclear has notified all users (licensees) of the Dry Shielded Canisters subject to this report of the defect or failure to comply discussed within this report. Additionally, Transnuclear has notified other suppliers utilized by Transnuclear for the fabrication of products required to meet the requirements of 10 CFR 72 of the condition discussed in this report and confirmed that these TN subcontractors have not procured materials and items from the source of supply discussed herein.
This report is provided to the USNRC by Transnuclear on October 30, 2009:
Tara J. Neider President nd (ChiefExecutive Officer Transnuclear, Inc.
7135 Minstrel Way, Suite 300 Columbia, MD 2104 E-28731 Page 2 of 24
Executive Summary BACKGROUND Transnuclear Inc. (TN), utilizes Hitachi Zosen (HZ) Corporation, Ariake Works in Nagasu, Japan, as a fabricator of Dry Shielded Canisters (DSC's) for supply by TN to multiple 10 CFR 50 licensees for the dry storage of spent nuclear fuel assemblies under the provision of 10 CFR 72. In general, DSC's consist of an outer stainless steel shell (canister assembly) with a welded lid that serves as the confinement boundary for the radioactive materials being stored. Internally, a DSC utilizes a welded stainless steel frame (basket) to position and hold the spent nuclear fuel elements along with any necessary neutron poison material. The basket has shaped segmented "rail" assemblies that are bolted to this frame to shape the basket into a cylindrical form that is designed to fit inside the canister assembly. The fabrication process generally requires the use of materials procured from multiple suppliers and includes products and items such as stainless steel plate and forgings (dependent upon the design) for the canister, basket and rails along with nuts, bolts, studs and screws that are used to attach the rail assembly to the basket and form the basket assembly.
IDENTIFICATION AND REPORTING OF UNSUBSTANTIATED CERTIFIED MATERIAL TEST REPORTS In August 2009, a Quality Assurance (QA) representative from Progress Energy (PGN) was at the HZ, Ariake Works for the purposes of conducting oversight of TN and HZ controls for fabrication of DSCs intended for use at the PGN Brunswick Nuclear Plant (these DSCs are still in fabrication and have yet to be delivered for use).
On September 9, 2009, TN was informed by PGN that two panhead screws had been removed from the HZ shop by the PGN QA Representative and that PGN had subjected them to testing at the PGN Harris Energy & Environmental Center. The PGN report of this testing indicated that the material of composition for these screws appeared to be something other than what was represented in the Certified Material Test Report (CMTR) provided to HZ by the Hwa Shin Bolt Industrial Company of Busan, South Korea.
Specifically, the HZ purchase order required that panhead screws meet the requirements of ASME SA193, Grade B8 (or equivalent) and that a Certified Material Test Report must be provided to substantiate satisfaction of this requirement.
Figure 1: Panhead Screw Installed in DSC On September 10, 2009, TN provided HZ with the information received from PGN and requested that HZ assess the concern raised and to provide TN with any actions necessary to address the identified concern. TN also notified PGN of this communication with HZ on the same day.
E-28731 Page 3 of 24
On September 18, 2009, HZ provided TN with a copy of a letter that they had received from Hwa Shin Bolt Industrial Company (the supplier of the panhead screws for the PGN - Brunswick project) that stated that the panhead screws provided were not manufactured from the material that had been certified to in the CMTR. Upon receipt of this information, TN requested that HZ initiate an internal Corrective Action Report and identify all material procured by HZ from Hwa Shin. Additionally, on September 18, 2009, TN notified PGN of the information received from HZ and that HZ had been requested by TN to initiate a Corrective Action Report to establish the extent of condition.
During the week of September 19, 2009, HZ initiated its review of procurement history with Hwa Shin Bolt Industrial Company. On September 22, 2009 HZ also visited the Hwa Shin facility in Busan, South Korea.
As a result of the trip to Hwa Shin, HZ determined that documentation provided by Hwa Shin to substantiate the material provided was suspect. This determination was provided by HZ to the TN representative at HZ who then passed this information to TN personnel in the Columbia, MD offices on September 25, 2009.
On September 24, 2009, TN issued Supplier Finding Report (SFR) No. 2009-058 to HZ for the purposes of requesting corrective action for the condition identified with the panhead screws and to also identify the extent of the condition (all material procured from Hwa Shin). TN also initiated an internal Corrective Action Report (CAR) No. 2009-086 to start the internal review processes for determining if the condition was potentially reportable under the provisions of 10 CFR 21. At this time, TN also initiated discussions with NRC staff from the Division of Spent Fuel Storage and Transportation to notify them of the identified condition and discuss reportability requirements. These discussions were held on September 24 and 25, 2009 with information associated with the condition being provided by email. At this point, TN understood that the condition did impact DSCs that were being fabricated for PGN - Brunswick and that none of these DSCs had been delivered for use. The extent of condition determination on the part of HZ for projects other than PGN - Brunswick was still being developed.
On October 1, 2009, a TN management representative visited the HZ facility in Japan to review corrective actions being taken or planned and the status of the extent of condition determination. The initial HZ extent of condition review was provided to TN at that time and based on a review of the information it was determined that Hwa Shin had provided items that had been utilized in multiple projects and included a large number of DSCs and one Transfer Cask that had been provided by TN to several NRC licensees.
This information was provided to senior management at the TN Columbia offices and on October 1st, 2009, the TN President and CEO provided verbal notification to the NRC Operations Center of the potential for a reportable condition under the requirements of 10 CFR 21. This verbal notification was also followed-up with a written confirmation of the phone call. As part of this notification to the NRC, TN stated that "Transnuclear is in the process of performing a 10 CFR 21 but does not believe that the issue has safety significance. TN is reporting this issue because Hwa Shin may have supplied parts to others that may have safety significance."
Between the notification to the NRC on October 1, 2009 and the date of this report, TN has conducted reviews and evaluations of technical and licensing requirements for the DSC models and Transfer Cask impacted by this condition, worked with HZ to develop and institute a testing program in order to obtain additional information on the material properties of the items supplied by Hwa Shin, and initiated or implemented other corrective actions determined necessary to address the potential for impact on safety as a result of this event.
Although many of the planned corrective actions are incomplete at this time, and TN and its subcontractor HZ have yet to complete the root cause(s) determination such that appropriate preventative actions can be identified and implemented, TN has been able to conclude that:
- 1. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into loaded DSC Models 61 BT and 32PT do not and cannot create a condition that results in a loss of safety function such that a Substantial Safety Hazard could be created. TN has made this conclusion E-28731 Page 4 of 24
based on a review of design calculations, testing of available Hwa Shin materials and review of licensing documents.
- 2. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into Transfer Cask Model OS-197H delivered to Constellation - Ginna Nuclear Power Plant will be replaced by TN prior to first use. As such, the condition does not create a condition that results in a loss of safety function such that a Substantial Safety Hazard is created. Replacement of these parts will be controlled under the TN NRC approved Quality Assurance Program. Constellation.
approval of the replacement plan will be obtained before implementation.
- 3. Items provided by Hwa Shin Bolt Industrial Company to HZ that have not been incorporated by fabrication activities into a DSC will be replaced with items procured from a different HZ audited and approved source. Disposal of these items will be controlled under the TN approved HZ Quality Assurance Program.
- 4. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into a DSC by fabrication activities will be replaced and disposed of if replacement of the items does not raise the potential of damage to the DSC. Replacement of these items will be controlled under the TN approved HZ Quality Assurance Program and/or the TN NRC approved Quality Assurance Program. Necessary approvals will also be obtained from the NRC 10 CFR 50 licensee prior to implementing the replacement plan.
- 5. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into a DSC and cannot be removed due to concerns with damaging the DSC will not be removed. Approval and justification for use for the items not removed will be provided to HZ by TN as required by the TN NRC approved Quality Assurance Program. In addition, TN will provide the documented justification for not removing these items from each DSC to each affected NRC 10 CFR 50 licensee for its approval prior to implementing the disposition and recertification of the DSC to the conditions of the applicable 10 CFR 72 NRC Certificate of Compliance. This applies to DSCs that have been delivered (both loaded and not loaded) and DSCs that are still at the HZ facility in Japan.
E-28731 Page 5 of 24
Extent of Impact and Current Status EXTENT OF IMPACT Dry Shielded Canisters HZ performed an extent of condition review as required by TN SFR 2009-058 and HZ CAR No. C-09-C-12.
From this review, HZ provided the following table detailing all projects undertaken for TN with identification of those projects for which HZ had procured items from the Hwa Shin Bolt Industrial Company.
Note: 61 BT-M is HZ's internal type designation for the TN Model 61 BT DSC (for Short Damaged Fuel)
Attaho0ment I
Status ofAllTNProjects related to HWASHINBOLTMaturials(Reference TNSFR No.2009-058, HZCARNo.C-00-C-12) 774520010,0.DS~sa8760164 NO.16F2311W.29.20o 001000 IN. Wm'uedo ca SHP*d "Pe TNN U., rý -N. N. M.ý6.1 CMTRoN. O~o RrNo.
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76.246*4 3 217AM 60 SiA0Type SH 304
- 00 09-006.212 61170 A 2 7N-I02 1WOMaW.1- 219 RA Typ3041 Don"*0) NUH6t144000 Tellftt*plng 014 GAM79 Ty'p304 c9-Hics11 ilmH4-;po4 A 312BP.NCR-15 ISF3120 e aadf SH 0100- 21 S13EB ý $HM2 91CR15 V&9 618THP-7 ,12D"P54
- T.. No1"w10 " (0-"010). NUID1TH40,2Pmkec 8.-1 (005"010) NlI4418114D-492 H.0NA4 I 47..44S- 231A 0A194 Gr 403.240 60011.TP-706 A N $61114T,40 LCckWmh0m5 216 ATm&saaTp344 2009.4-220 61070r1--P7-090I
" opO6.N6mnOS 7T. 67 25.4180Ill4 20-5.06M-034 610M1T-P-P10A 004
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NodUodri) 03104386U11-30-2 (03"B4) Flat2066
ýeNu 40R 46S SA a4OTy 30044 09-11C1,1 1 317-P-702 A 31722.-00R40 1E-*.W.R Mk7Tp30 037-0 l0-30-1 _ V__ or1005. 60 SA479Tysou 0900C12 317.P,, 4 VftW saw48P SAU Type3D4 1SP017 P2004-4408 UWp~l 51ST 001143 Not U4edV-) - 001"OU) 2 0-3018 109140W 1 .1R7A24D Nyft 01tw Type304 0040040,00317-7-7 A 1091.-30-16 SVMWS 40 4A477945T0e304 0MHCM-022 317-7 A 1632 P ue 0051-09 10 F103W76,0 WMSetu5d 460 40P 014240 Type 37704 0-H0062 01--t2-P2 A 479Type304 0680716 4as 00.67144.00M 1SF322 72*03.070 10.6640.7266
[685ob04 628'r 03-e22 I 01ur0710 - 400*106479175837
,__A4T00y-416 0 1"A 10400-05-16 74en6th2 Po7b S444Typo 304 05-70CM-9006-7.726 (1) : H4Z6-06o65O0e46ma0(rbl hor 4I54e6t l52k.7 Table 1: Extent of Condition for DSCs fabricated by Hitachi Zosen E-28731 Page 6 of 24
OS 197 Transfer Cask The materials provided to HZ by Hwa Shin also included items incorporated into one transfer cask that was delivered to Ginna. TN has confirmed that this Transfer Cask has not been put into service by Constellation Energy. These parts will be replaced.
HZ TN 14105 Type ý ShO UnlP~ed~ p 7 Rd-o 16F72 25040557D..mO NO' 577 S 1-2 759 W40 ___
IGFV3 42M0 COPPO FaCto OS197L 05197L-N ote 15F035 25050120otfi~m LMýs OSISIS 0519515 NOV0 t5Fo43 P25090&5 FF9. siýoe 0S50 797-I N0U5UW___
16F301 P2504-574 EhNO Le-a OS1N7H 05997744 54490 _____
167394M P357.39 0519714-7PI 01 41Do.5 SCoo..B 00S19794 B04 Cw.1,4 -1F - 14050 SS44)o 34H&-lM9.4449 74417 49 Table 2: Extent of Condition for Transfer Casks fabricated by Hitachi Zosen CURRENT STATUS Dry Shielded Canisters and Transfer Cask The items in question affect a total of 59 DSCs that are either still at the HZ facility in Japan, have been delivered for use but not put into service or have been put into service by a 10 CFR 50 licensee in the United States. Of the 59 DSCs with Hwa Shin items, 39 have been delivered with 17 of these having been loaded and placed in the NUHOMS Horizontal Storage Modules (HSM) and the remainder (22) in storage waiting to be loaded. The one Transfer Cask with Hwa Shin parts has been shipped to its US licensee but has not been put into service.
Exelon 61 BT 009 OCG61 B-009-C YES YES YES 1004 1098 161F231 YES YES Oyster Creek DSC 010 OCG61B-010-C YES 011 OCG61B-011-C YES YES YES 012 OCG61B-012-C YES YES YES 013 OCG61B-013-C YES YES YES Exelon 1004 61BT 10982 16F018 014 OCG61B-014-C YES YES YES Oyster Creek DSC 015 OCG611B-015-C YES YES YES 016 OCG611B-016-C YES YES YES 017 OCG61B-017-C YES YES NO On Site 018 OCG61B-018-C YES YES NO On Site DOM- 1004 32PT 16F306 MPS32PT-S100-11066 Millstone DSC HZ01 0 A-HZ010 YES YES YES MPS32PT-S1 00-HZ011 A-HZ011 YES YES YES MPS32PT-S100-HZ012 A-HZ012 YES YES NO On Site MPS32PT-S100-HZ013 A-HZ013 YES YES NO On Site MPS32PT-S100-HZ014 A-HZ014 YES YES NO On Site E-28731 Page 7 of 24
bS32P -S1 HZ01 5 A-HZ015 YES YES NO On Site MPS32PT-S100- Fabrication HZ016 .. A-HZ016 NO NO NO Complete MPS32PT-S100- Fabrication HZ017 I A-HZ017 NO NO NO Complete MPS32PT-S100- Fabrication HZ018 A-HZ018 NO NO NO Complete 025 SSE61B-025-A YES YES YES 026 SSE61 B-026-A YES YES YES 027 SSE61 B-027-A YES YES YES PPL- 1004 61BT 10963 16F308 028 SSE61B-028-A YES YES NO On Site Susquehanna DSC 029 SSE61B-029-A YES YES YES 030 SSE61 B-030-A YES YES YES 031 SSE61B-031-A YES YES NO On Site 032 SSE61 B-032-A YES YES NO On Site PPL- 1004 61BT 10964 16F312 033 SSE61B-033-A YES YES YES Susquehanna DSC 034 SSE61 B-034-A YES YES YES 001 CNS61B-001-A YES YES NO On Site 002 CNS61 B-002-A YES YES NO On Site 003 CNS61 B-003-A YES YES NO On Site Fabrication' NPPD- 1004 61B 11203 16F311 004 CNS61B-004-A NO NO NO on Hold Cooper DSC B0 Y YSO i 005 CNS61 B-005-A YES YES NO On Site 006 CNS61B-006-A YES YES NO On Site 007 CNS61 B-007-A YES YES NO On Site
___ ___ 008 CNS61 B-008-A YES YES NO On Site 019 OCG61B-019-C YES YES NO On Site Exelon- 1004 61BT 10983 16F312 020 OCG61B-020-C YES YES NO On Site Oyster Creek DSC 021 OCG61B-021-C YES YES NO On Site 022 OCG61 B-022-C YES YES NO On Site Not Yet 035 Assigned NO NO Not Yet PPL- 1004 61BT 10965 16F317 036 Assigned NO NO Susquehanna DSC Not Yet 037 Assigned NO NO Not Yet 038 Assigned NO NO Not Yet 001 Assigned NO NO Not Yet Progress- 1004 61BTH 11171 16F312 002 Assigned NO NO Brunswick DSC Not Yet 003 Assigned NO NO Not Yet 004 Assigned NO NO ---
Constellation- 1004 I 32PT 11202 16F313 1 001 REG32PT-S125-Ginna I DSC A-16-001 YES YES NO On Site 002 1 REG32PT-S125-A-16-002 __ES YES
-YES YES ] NO NO On Site E-28731 Page 8 of 24
k.saus 003 A-i16-003 NO NO REG32PT-S125-004 A-16-004 NO NO ---
REG32PT-S125-005 A-16-005 NO NO ---
REG32PT-S125-006 A-16-006 NO NO ---
REG32PT-S125-007 A-16-007 NO NO ---
REG32PT-S125-008 A-16-008 NO NO ---
REG32PT-Si25-009 A-1 6-009 NO NO REG32PT-S125-010 A-1 6-010 NO NO OS197H 1 9 1r Constellation- Transfer Ginna 1004 Cask 11203 16F314 OS197H-7 OS197H-7 YES YES NO On Site E-28731 Page 9 of 24
Engineering Evaluations and Significant Safety Hazards Determination ENGINEERING EVALUATIONS Justification for Continued Operations In order to support operability determinations on the part of licensee with loaded DSCs subject to the condition described in this report, TN provided the following information:
Transnuclear Memo E-28630, dated 10/09/09, Justificationfor Continued Operabilityfor Loaded NUHOMS 32PT DSCs Serial Numbers MPS32PT-S100-A-HZ010 and -HZ01 I at Dominion Nuclear Connecticut's Millstone Power Station Transnuclear Memo E-28634, dated 10/08/09, Justificationfor Continued Operabilityfor Loaded NUHOMS 61BT DSCs at PPL Electric Steam Utilities Corp's Susquehanna Steam and Electric Station Transnuclear Memo E-28726, dated 10/29/09, Justificationfor Continued Operabilityfor Loaded NUHOMS 61BT DSCs Serial Numbers OCG-61B-009-Cthru -016-C at Exelon's Oyster Creek Generating Station These memos concluded that that the subject DSCs remain capable of performing the design functions of confinement, heat removal, shielding and criticality control associated with the safe storage of spent nuclear fuel.
Significant Safety Hazard Determination (The following is an attachment to TN CAR 2009-086 and is being provided in its entirety)
Attachment to CAR 2009-086 October 30, 2009 Substantial Safety Hazard Determination The subject corrective action report resulted from the identification that small screws supplied to one of Transnuclear's canister fabricators, Hitachi Zosen, by Hwa Shin Bolt Industries is suspected of being a different material than that specified and certified. Hwa Shin supplied studs, screws, nut and washers. In addition, they provided material for the test port plugs, tool sockets and alignment legs. Until determined otherwise, all materials supplied by Hwa Shin are being treated as indeterminate by Hitachi Zosen and Transnuclear.
The following NUHOMS DSCs are affected by this situation: 32PT, 61BT, and 61BTH Type 2. Plants that are affected are Exelon/Oyster Creek, Dominion/Millstone, PPL/Susquehanna, NPPD/Cooper, Progress Energy/Brunswick, and Constellation/Ginna. In addition, the Transfer Cask, 0S197H-7 purchased by Nine Mile Point and delivered to Ginna is also affected by this CAR. DSCs affected range from some with loaded fuel to some in varying stage of fabrication.
The parts which are affected by Hwa Shin for the canisters loaded with fuel are described in detail and listed in the reference [1].
Hitachi Zosen is performing material testing (chemistry and hardness) on materials from Hwa Shin that were in Hitachi Zosen's inventory, waiting to be used for the DSCs or Hwa Shin materials left over from previously fabricated DSCs. Hitachi Zosen provided TN with the test results and based on this information TN has concluded that all materials exhibit the chemistry of 300 series stainless steel except for lock washers which exhibit the chemistry of 200 series stainless steel. The vent (test) port plug and the weld studs exhibit hardness characteristic of E-28731 Page 10 of 24
annealed material; washers, screws, and nuts exhibit hardness characteristic of cold-worked materials. All materials were tested in accordance with Hitachi-Zosen Material Verification Procedure MVP-01, Rev 2.
Based on these test data, Hwa Shin did not supply grossly deficient material from a technical point of view. That is, the alternate materials provided are austenitic stainless steels with corrosion resistance and strength similar to that of the specified material. It is reasonable to assume that materials already installed in the DSCs are also stainless steel.
If materials were not stainless steel, indication of this difference in material would most likely have been identified during fabrication process as a result of visual inspection, weldability issues, corrosion, liquid penetration examination, etc.
An evaluation was performed on the parts supplied by Hwa Shin [1]. A summary of the evaluation is provided below:
A. The failure of the parts will not affect the public health and safety.
B. The basket rail weld studs, nuts, screws, and washers are used to hold the basket together during fabrication. Once the basket is assembled and installed in the DSC these parts are not required. No credit was taken for them in the normal, off-normal and accident loading conditions.
C. As long as the materials are any grade of austenitic stainless steel the parts will perform as well as the originally specified material, and it will not affect the safety function of the DSC.
D. The test port plugs are used to seal the test port in the outer top cover plate and are not part of the confinement boundary, and substitution of an alternate austenitic stainless steel would not affect its function. This part is subject to visual and liquid penetration examinations following welding.
E. The shoulder screw is used to assemble the spacer disk to the top shield plug. The spacer disk's function is to minimize the gap between the top shield plug and the basket. After installation, the spacer disk will perform its function as it will be captured between the basket and the top shield plug and the function of the shoulder screw is not required.
In consideration of items A - E cited above, Transnuclear determines that this condition does not and cannot result in the loss of safety function such that a Substantial Safety Hazard is created.
References:
- 1. CAR 2009-086, Condition Evaluation Prepared By$t 1
, L. P. Shih, Director of Engineering and Licensing F
Reviewed By: 1
- J. Bondre, VP of Engineering Approved . .,x* R. Grubb, Chief Operating Officer E-28731 Page 11 of 24
List of Impacted Items IMPACTED ITEMS Listing of Items Supplied by Hwa Shin This section of the report contains a listing of the items that are affected for each type of DSC and the Transfer Cask. The applicable drawings are also listed in the table with the part (item) number and original material that was specified in the system design.
NUHOMS 32PT DSC Hex Nut, TN item 49 (HZ item 349), Quality Category A, material ASTM F594 Group 1, shown on drawings 11064-30-3 and NUH32PT-2003.
NUHOMS 61BT DSC Quality Mtra pcfe HZ Item Number TN Item Number Description Category Material Specified 46P 46P Weld stud A SA 479 type 304 46R 46R Flat washer A 304 SST 46S 46S Hex nut A 304 SST 60 60 Vent (test) port plug A SA 479 type 304
Reference:
Transnuclear drawings 10961-30-2 & 1098-30-2 Additional parts for damaged fuel option (61 BT)
HZ Item Number TN Item Description Quality Number Category Material Specified 79D 79D Top Cap, Tool Socket A SA 479 type 304 80E 80E Bottom Cap, Tool Socket NITS 304 SST 83 83 Shoulder Screw C AISI 304 or 316 84 84 Machine Screw NITS SST
Reference:
Transnuclear drawings 1098-30-27 NUHOMS 61BTH Type 2 DSC HZ Item ult SNumber TN Drawing-Item Number Description Quality Material Specified 215A/B NUH61 BTH-4002-15 Stud A SA 479 type 304 216 NUH61BTH-4002-16 Hex Nut C SST 217A/B NUH61BTH-4002-17 Flat Washer C SST 219 NUH61BTH-4002-19 Oval Washer NITS SST 014 NUH61BTH-4000-14 Test Port plug A SA 479 type 304 231 NUH61BTH-4002-31 Panhead Screw A SA 193 B8 231A NUH61BTH-4002 Hex Nut A SST (DWG Note 29) 218 NUH61BTH-4002-18 Lock washer NITS SST 602J NUH61 BTH-4006-2J Alignment Leg A SA 479 type 304 E-28731 Page 12 of 24
NUHOMS OS197H Transfer Cask HZ Item TN Drawing-Item Number Description Quality Material Specified Number Category 410 NUH-06-8021-10 Hex Bolt B SA 193 B7 325 NUH-06-8003-25 Washer NITS ASTM F436 327 NUH-06-8003-27 Washer NITS ASTM F436 314 NUH-06-8003-14 Cap Screw NITS 17m4 SS Sy = 90ksi Table 4: List of Affected Parts Pictures or Graphic of Impacted Items Some of the items that are affected and installed are accessible and can be removed. Several of the DSCs in various stages of fabrication at HZ have these parts installed. Where possible pictures were taken of the part to show what the part looks like and generally where it is located.
FIGURE 2: 32PT Hex Nut (Item 49)
Top Shield Plug Modified Canister Shell Top Spacer Shoulder Screw -
Fuel Compartment Extension Fuel Basket Figure 3: 61 BT (for Short Damaged Fuel) Shoulder Screw (Item 83)
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Figure 4: 61 BT Weld Stud (Item 46P), Flat Washer (Item 46R), and Hex Nut (Item 46S)
Figure 5: 61 BT Vent (Test) Port Plug (Item 60), and 61 BTH Test (Vent) Port Plug (Item 14)
Figures 6 & 7: 61BTH Stud (TN Item 15 / HZ Item 215A/B) (61BT Stud is Similar)
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Figure 8: 61BTH Weld Stud (Item 15), Flat Washer (Item 17), Oval Washer (Item 19) and Hex Nut (Item 16)
Figure 9: 61BTH Panhead Screw (Item 31) Figure 10: 61BTH Hex Nut (DWG Note 29)
Figure 11: 61 BTH Alignment Leg for Top Grid Assembly (TN Item 2J / HZ Item 602J)
E-28731 Page 15 of 24
MATERIAL CONTROL Control of Non-Conforming Items HZ has collected all Hwa Shin items that remained unused, has placed the unused items in a controlled area away from the area where fabrication is being performed and has tagged the items to prevent further use. These items are under the control of the HZ nonconformance system until dispositioned.
Figures 12 & 13: Hwa Shin Items- Tagged with NCR and in Segregated Storage E-28731 Page 16 of 24
ISSUE CHRONOLOGY The following provides the sequence of events starting at the point TN became aware of the potential issue with material supplied to HZ by Hwa Shin and to the point of TN's notification to the NRC Operations Center (10/1/09) of a condition that may be reportable under the provisions of 10 CFR 21.
09/09/09 TN received information from Progress Energy (PGN) that analysis of two panhead screws (item 31, TN Drawing NUH61 BTH-4002; Sheet 1 of 8, Part List; and Sheet 3 of 8, Detail 1) indicated that the material of composition may not be as required by ASME SA193 B8. The panhead screws were obtained by PGN oversight personnel at the Hitachi Zosen facility during the assembly of the initial 61BTH DSCs for PGN Brunswick Station / TN Project No. 11171. No DSCs have been delivered under this order by TN to PGN at this time 09/10/09 TN notified Hitachi Zosen of the information provided by Progress Energy and requested a Hitachi Zosen evaluation and response 09/18/09 Hitachi Zosen notified TN of the results of their follow-up discussions with Hwa Shin Bolt Industrial Company. Hwa Shin states by letter to HZ that the material they supplied was not the material that they certified 9/18/09 TN notified Progress Energy of the HZ evaluation. Copies of the Hwa Shin Bolt Industrial Company letter and material specification requirements provided 09/23/09 Discussions held between TN and HZ on actions being planned by HZ in response to the Hwa Shin letter of 9/17/09 09/23/09 HZ visit to Hwa Shin to discuss the letter provided to HZ by Hwa Shin on 9/17/09 09/24/09 Supplier Finding Report (SFR-2009-058) issued to request HZ to provide extent of condition and corrective action for materials supplied to by Hwa Shin Bolt Industrial Company 09/24/09 TN initiated CAR 2009-086 (Level 1) in order to obtain a reportability determination. TN Procedures TIP 7.13, 16.1 and 15.1 provide procedural instructions to determine 10 CFR 21 reporting 09/24/09 TN initiated and held a telecon with the Director and several staff of the USNRC Division of Spent Fuel Storage and Transportation to discuss the identified condition and potential reportability under 10 CFR 21. TN participants in this phone call were President, Chief Operating Officer and Director, Corporate Quality Assurance 09/25/09 The TN oversight representative at HZ provided TN Columbia with a summary of the results of the HZ visit to Hwa Shin. The HZ visit confirmed that the CMTR provided by Hwa Shin was false and that this condition applied to all small parts provided by Hwa Shin. HZ indicated that larger parts did have CMTR traceability 09/25/09 A phone call was initiated by NRC Director, Division of Spent Fuel Storage and Transportation and the TN Chief Operations Officer. NRC requested and TN provided a copy of the Hitachi Zosen purchase order to Hwa Shin for the panhead screws E-28731 Page 17 of 24
10/01/09 A meeting was held between HZ and TN personnel at the HZ facilities in Japan. The purpose of the meeting was to understand the HZ status with respect to corrective actions associated with Hwa Shin and determine if HZ had completed its determination of the extent of condition with respect to the procurement of materials and items from Hwa Shin 10/01/09 10/1/09 - email / TN personnel at HZ notify senior management at TN Columbia offices that the HZ extent of condition for parts procured by HZ from Hwa Shin extend beyond the Progress Energy Project and include DSCs delivered 10/01/09 HZ issues Nonconformance Reports for all Hwa Shin Parts and segregates the parts.
NCR's were also initiated for each HZ job with DSCs or other components that contain suspect parts (both shipped or at HZ) 10/01/09 TN determined that the condition is potentially reportable under the provisions of 10 CFR 21.21 and the NRC Operations Center is notified via telephone call by T. Neider. Follow-up email is provided to the NRC to confirm the call E-28731 Page 18 of 24
Corrective Action That Has Been / is Being / or Will Be Taken Transnuclear Actions The following TN corrective action plan details known corrective actions that have been, are being or planned to be taken as a result of the condition discussed in this report. TN expects that this corrective action plan will to be modified as more information is developed. These actions are current as of the date of this report and are being controlled and tracked under TN CAR 2009-086.
Transnuclear Corrective Action Plan Action Responsible Due Date Comments Organization or Position 1 Brief all TN staff on the Hwa Shin issue COO 9/10/09 Complete See Note 1 2 Initiate SFR to request Hitachi Zosen Corrective QA 9/24/09 Complete Action and Extent of Condition for Hwa Shin items See Note 2 3 Initiate CAR to ensure 10 CFR 21 reportability QA 9/24/09 Complete considerations are addressed and obtain any necessary internal corrective actions See Note 3 4 Notify NRC Operations Center of the potential President & 10-1-09 Complete for a reportable condition under 10 CFR 21 CEO See Note 4 5 Notify all impacted customers of the Hwa Shin Sr. Mgmt. 10/14/09 Complete issue and support operability determinations as requested. See Note 5 6 Notify the TN Users Group of the Hwa Shin Management 10/15/09 Completed issue.
See Note 6 7 Complete substantial safety hazards COo 10/30/09 Complete determination.
See Notes 7 & 8 8 Provide written report to NRC as required by 10 President & 10/30/09 Complete CFR 21.21 (d) (3)(ii). Report to be transmitted as CEO required by 10 CFR 21.5 9 Provide User Group with the report provided to Management 10/30/09 Complete the NRC See Note 20 10 Provide written notification to all current TN QA 10/7/09 Complete fabricators regarding the Hwa Shin issue.
See Note 9 11 Perform oversight of the second visit to Hwa QA 10/7/09 Complete Shin by HZ.
See Note 10 12 Request all current major TN fabricators provide QA 10/20/09 Complete written descriptions of procedural controls utilized for the detection of Counterfeit and See Note 11 E-28731 Page 19 of 24
Transnuclear Corrective Action Plan
- Action Responsible Due Date Comments Organization or Position Fraudulent Items (C/Fl) 13 Determine if Hwa Shin was utilized by other QA 12/3/09 Working fabricators of TN equipment.
See Note 12 14 Perform oversight of HZ audit to qualify a new QA 10/23/09 Complete supplier to replace Hwa Shin See Note 13 15 Review TN fabricator controls for Counterfeit QA 11/30/09 Waiting on and Fraudulent Items (C/Fl). responses from fabricators Determine if any corrective action is needed 16 Develop language to be inserted into TN QA 11/19/09 Not Started as of procurement specification requiring supplier to 10/28/09 provide TN with material sample (at TN's discretion) for testing to determine acceptability of material supplied. Obtain internal agreement on the language 17 Develop language to be inserted into TN QA 11/19/09 Not Started as of procurement specification (fabricators of major 10/28/09 equipment) requiring supplier to institute a random screening program for material suppliers for the purpose of periodically substantiating material certifications provided. Use of tools such as XRF analyzers or qualified laboratories should be provided as an option.
The requirement should include language requiring the supplier to submit the random testing program to TN for its review and approval.
Obtain internal agreement on the language 18 Identify specifications and schedule for Engineering 12/8/09 Not Started as of implementing revised TN Procurement 10/28/09 Specification language for C/Fl controls 19 Review TN procurement controls against QA 12/04/09 Not Started as of information provided in NRC GL 82-02 and other 10/28/09 generic communications provided by the NRC to determine if the procurement controls encompass appropriate provisions for requiring TN suppliers to take actions to preclude the entry of fraudulent and substandard materials into the supply chain. As determined necessary, identify any additional corrective actions based on the results of this review.
20 Review TN supplier oversight controls against QA 12/18/09 Not Started as of information provided in NRC GL 82-02 and other 10/28/09 generic communications provided by the NRC to determine if the controls provide for appropriate E-28731 Page 20 of 24
Transnuclear Corrective Action Plan
- Action Responsible Due Date Comments Organization or Position oversight and verification of supplier controls for fraudulent and substandard items. As determined necessary, identify any additional corrective actions based on the results of this review.
21 Review and re-classify as necessary the parts Engineering 12/10/09 discussed in this report to ensure that appropriate Quality Classifications are assigned (TIP 3.6) 22 Revise all impacted TN design and fabrication Engineering 12/10/09 documents as a result of the re-classification of parts.
23 Conduct Root Cause Determination to identify QA 12/18/09 Not Started as of why this condition was identified by a TN 10/28/09 customer as part of their oversight and not by TN.
24 Based on the results of the root cause, identify QA 12/18/09 Not Started as of preventative actions necessary to preclude 10/28/09 recurrence (if not already taken) 25 Provide notification of the Hwa Shin event to QA 10/30/09 Complete AREVA Corporate for dissemination Note 19 26 Notify NIAC Organization of Event at the QA 11/6/09 November annual meeting 27 Review NIAC Audit Checklist and determine if QA 11/6/09 process controls include appropriate criteria for Counterfeit and Fraudulent Materials. Discuss review results at NIAC Meeting in November 28 Based on NIAC Meeting discussion determine if QA 11/19/09 TN needs to utilize at supplemental checklist in conjunction with NIAC checklist to ensure appropriate assessment of Counterfeit and Fraudulent Materials controls 29 Track and Verify that HZ NCRs are QA TBD dispositioned, 72.48 evaluations completed, approval provided by TN and Licensee (when required), Disposition is Implemented, TN Re-Certification Complete & Records System Updated (both TN and Licensee)
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Hitachi Zosen Actions The following HZ corrective action plan details known corrective actions that have been, are being or planned to be taken planned as a result of the condition discussed in this report. TN expects that HZ may need to modify or otherwise change this plan as more information is developed. These actions are current as of the date of this report and are being controlled and tracked under HZ CAR No. C-09-C-12. These actions are subject to TN's review and approval.
Hitachi Zosen Corrective Action Plan HZ Action Responsibility Due Comments
- Date 12 Perform fact-finding visit to Hwa Shin to verify Hitachi Zosen 9/23/09 Complete issue See Note 14 14 Remove Hwa Shin from AVL Hitachi Zosen 9/30/09 Complete See Note 15 El Identify all materials from Hwa Shin for all Hitachi Zosen 10/1/09 Complete existing projects (extent of condition)
See Note 16 15 Write Non-Conformance Reports (NCRs) for all Hitachi Zosen 10/1/09 Complete Projects in shop. Identify, collect, tag and segregate all Hwa Shin parts See Note 17 13 Issued NCR on all existing DSCs and shipped Hitachi Zosen 10/1/09 Completed DSCs on which materials procured from Hwa Shin were used. See Note 17 E3 Identify all previously shipped DSCs on which Hitachi Zosen 10/1/09 Complete See materials form Hwa Shin had been used. Reference 7 17 Perform audit of lab Hitachi Zosen 10/13/09 Complete See Reference 17 Develop a testing plan for Hwa Shin Parts that Hitachi Zosen 10/22/09 Complete have been used in DSC that have been Revision 2 delivered to Utilities approved by TN Perform Audit of new vendor for Hwa Shin parts Hitachi Zosen 10/21- Complete 24/09 See Note 18 I1 Get results of material test for panhead screw, in Hitachi Zosen 10/26/09 question, from lab
-E2 Send out samples (all heats) selected from the Hitachi Zosen 10/27/09 above materials to the lab for testing and/or perform chemical analysis and hardness test (by HZ) using X-Ray Fluorescence Analyzer and handy-type hardness tester (Equo Tip)
Complete all HZ testing of parts Hitachi Zosen TBD Receive all chemical composition results from Hitachi Zosen TBD Lab Receive all mechanical test results from Lab Hitachi Zosen TBD 18 Issue report detaining all activities completed. Hitachi Zosen 11/30/09 C1 Procure new materials from other qualified Hitachi Zosen 11/30/09 supplier C2 Establish procedure to identity counterfeit Hitachi Zosen 11/30/09 materials or items E-28731 Page 22 of 24
NOTES:
1 Staff briefing held in the Columbia office with all available TN staff. This briefing was intended as informational and no attendance records or other documents were developed as a result this meeting 2 SFR 2009-058 issued to Hitachi Zosen on 9/24/09 3 CAR 2009-086 issued on 9/24/09 4 NRC Operations Center notified on 10/1/09 with follow-up confirmation of the call provided by email. Notification made as a result of the HZ extent of condition review identifying equipment subject to the requirements of 10 CFR 72 being delivered for use by TN to a 10 CFR 50 licensee.
5 Project Managers have notified each customer by telephone and operability determinations were provided to Dominion, PPL and Exelon. The operability determinations are documented under E letter Numbers E-28634 for PPL, E-28630 for Dominion and E-28726 for Exelon.
6 Discussion of the Hwa Shin condition was provided to the TN users group via Telecon on 10/15/09. Minutes of this meeting were not developed as the phone call was for informational purposes.
7 The notification made to NRC on 10/1/09 stated that "Transnuclear is in the process of performing a 10 CFR Part 21 but does not believe that this issue has safety significance. TN is reporting this issue because Hwa Shin may have supplied parts to others that may have safety significance."
As such, the final safety impact determination by TN had not been completed at the time.
8 Substantial safety hazard determination complete 10/28/09. The evaluation concluded that the condition does not and cannot create a condition that results in a loss of safety function such that a Substantial Safety Hazard is created.
9 Notification made by E-Letter with copies provided to CAR 2009-086 file.
10 SSR 2009-108 issued to document result of visit.
11 TN Letters E-28682 through E-28628 issued with copies provided to CAR 2009-086 file.
12 Request to fabricators made. Four responses received (no use of Hwa Shin) waiting on balance of responses 13 SSR-2009-110 issued to document this surveillance.
14 No report of this visit generated by HZ - trip summary provided by email 15 TN oversight has verified that HZ has removed Hwa Shin from the HZ Approved Suppliers List.
16 The HZ extent of condition review was provided to TN in the response to TN SFR 2009-058.
17 HZ NCRs are identified on the extent of condition matrix provided by HZ in response to TN SFR 2009-058.
18 TN performed oversight of the HZ audit of the new supplier. The results of this oversight activity are provided in TN SSR 2009-110.
19 Notification provided on 10/30/09 by email with copy of report attached to email.
20 Notification provided on 10/30/09 by email with copy of report attached to email.
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List of Tables and Figures TABLES Table 1: Extent of Condition for DSCs Fabricated By Hitachi Zosen Table 2: Extent of Condition for Transfer Cask Fabricated By Hitachi Zosen Table 3: Current Status of DSCs and Transfer Cask Table 4: List of Affected Parts FIGURES Figure 1: Panhead Screw Installed in DSC Figure 2: 32PT Hex Nut (TN Item 49 / HZ Item 349)
Figure 3: 61 BT (for short damaged fuel) Shoulder Screw (Item 83)
Figure 4: 61 BT Weld Stud (Item 46P), Flat Washer (Item 46R), and Hex Nut (Item 46R)
Figure 5: 61 BT Vent (Test) Port Plug (Item 60), and 61 BTH Test (Vent) Port Plug (Item 14)
Figure 6: 61BTH Stud (TN Item 15 / HZ Item 215A/B) (61BT Stud is Similar)
Figure 7: 61BTH Stud (TN Item 15 / HZ Item 215A/B) (61BT Stud is Similar)
Figure 8: 61BTH Weld Stud (Item 15), Flat Washer (Item 17), Oval Washer (Item 19) and Hex Nut (Item 16)
Figure 9: 61BTH Panhead Screw (Item 31)
Figure 10: 61BTH Hex Nut (DWG Note 29)
Figure 11: 61BTH Alignment Leg for Top Grid Assembly (TN Item 2J / HZ Item 602J)
Figure 12: Hwa Shin Items - Tagged with NCR and in Segregated Storage Figure 13: Hwa Shin Items -Tagged with NCR and in Segregated Storage E-28731 Page 24 of 24