ML18127A058
| ML18127A058 | |
| Person / Time | |
|---|---|
| Site: | 07201004, 07100250, 07109358 |
| Issue date: | 03/23/2018 |
| From: | Jon Woodfield NRC/NMSS/DSFM/IOB |
| To: | TN Americas LLC |
| Woodfield J | |
| References | |
| IR 2018201 | |
| Download: ML18127A058 (16) | |
Text
NRC FORM 691S PART 1 I(~ U.S. NUCU:ARREGUIATORY COIIIIISSIOli
=lait \'!i?) __SAFETY INSPECTION REPORT AND COMPLIANCElNSPECTION
- 1. CERTIFICATE/QUALITY ASSURANCE PROGIWl(QAP) HOI.DER: 2. NRC/RE.GIONAL OFFICE TN Americas u.ctomno Headquarters 7135 Minstrel Way. Suite 300 Ti. s. NncbrRegulatory Commission Cobunbia, Maryland 21045 Mail Slop TWm 48-34 Wasbi~ DC 20SSS-0001 072-1004/2018-201
- 8. canFICATBQAPDOCKErNUMBER(S) 4. INSPB:TlON l.OCAllON 5. MTE{S) OF INSPECTION CoCs 72-1004, 71-93S8 Larsen & Toubro limited Ranoli Wi Mareh 19-23, 2018
. QAP71--02SO Vadodara, India The inspedion was an examina11on of the activiies conduded under your QAP as lleY lalale to CDqll"iance wilh the Nuclear RegulalDly Cammi&sion (NRC) rules and ,egutations and Iha aindilions ofyour QAP Approval and/or_Certificafe(s) af Cornpliance_ The lnspedion conslsled of seleclive examinations of procedures and repsesentallve l8CORls, interviews wilh peisomel, and obsefvalions by lhe inspedar_ 1be inspec:IIDn lindings am as fallows:
D 1. Based on 111e inspediDn 1incfings. .., vlolalions were identified.
D 2.. Previous violalion(s> dosed.
IZ13. TIie viOlatlons(s), apecifically descrlled to you by the ilspecb' as non-ded Vlofations, are not being died beeause llley wem seJJ.ldenlffied, non-repetitive. aid mnedive action was or Is being taken, and lhe remaining c:rileria in the NRC Enfon:ement Poley, to axan:ise dlsaelion, 1111818 $8lisfied.
1
- - - Non-died violalion(s) was/went disaissed involving the following n,quiremenl(s) and Conac:6ve Adions(s):
Title 10 CFR 72.1S4, "Cootrol ofpurchased marerial, equipment. and services,* slates in pamgmph (b). io part.
1hat 1be certificate holder shall have available documentary evidence that maJrrial and equipment confimn to 1he procurement specifications prior to installation or use ofthe material and equipment. The catificate holder shall ensure 1hat1he evidence is sufficient to identity the specific iequiremellfs met by the purehased marerial aod equipment.
(Continued on Next Page)
Owing this inspedion, c:edam ofyour adlvltfes, as descliJed below andfor allached, were in violalion of NRC requirements and an, being cilBd In acconlanoe wilh NRC Enl'omement Policy_ This bm is a NOTICE OF VIOI.ATION, whith may be subjedfo postmg in accordance wi1b 10CFR 19.11.
(YlolatJons and Conedive Adions)
Statement of Garrective Actions I hereby stale that, wilhin 30 days, the actions desaiJed by me ID Ille Inspector will be taken lo conec:t 1he violations idenlilied. This sl8femenl of conediue actions is made in accordance with lhe requirements of 10 CFR 2.201 (coneclille steps already ta1r8n, conec:live slaps whic:h will be taken, dafe~.~ *~-..._IMt adlieved). I u ~ that no furtberwriUen RISpOIIS81D NRC will be required, unlesS spec:llcally reque !ded.
NRC INSPECTOR Jon N. Woodfield BRANCH CHIEF NRC FORM 591S PART 1 (10-Z013}
NRC FORM 591S PART 2 U.S. NUCLEAR REGULATORY COMMISSION
~10-g,~~.201 SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
- 1. CERTIFICATE/QUAl..llY ASSURANCE PROGRAM (QAP) HOLDER: 2. NRC/REGIONAL OFFICE 1N Americas LLC/Orano Headquarters 7135 Minstrel Way, Suite 300 U. S. Nuclear Regulatory Commission Columbia, Maryland 21045 Mail Stop TWFN 4B-34 Washington, DC 20555-0001 REPORT NUMBER(S) 072-1004/2018-201
- 3. CERTIFICATE/QAP DOCKET NUMBER(S) 4. INSPECTION LOCATION 5. DATE(S) OF INSPECTION CoCs 72-1004, 71-9358 Larsen & Toubro Limited Ranoli Works M h _23 201 8 QAP71-0250 19 Vadodara, India arc '
(Continued)
Contrary to the requirements of 10 CFR 72.154, during an inspection conducted March 19-23, 2018, the NRC identified the following example where 1N Americas did not have available documentary evidence that material conformed to the procurement specifications.
1N Americas' procurement ofHelicoils and washers classified as important-to-safety Category A components was incomplete. Specifically, verification of critical characteristics and objective evidence in the test report did not contain sufficient evidence that critical characteristics were adequately verified through the inspection and tests (method 1) dedication report process.
To address this issue 1N Americas initiated corrective action report (CAR) number 2018-067.
The NRC inspection team determined this violation to be within the traditional enforcement process. Th~ results of the Helicoil and washer critical characteristics evaluations were informally reported by the vendor but not verified, so if one accepts the critical characteristics evaluation provided, the Helicoils and washers appear satisfactory 4nd this issue is of low safety significance. When 1N Americas retests the Helicoil and washer critical characteristics, if the results are below acceptable values, the issue would be more safety significant. The issue will probably become just a documentation issue where the commercial grade dedication package will be more complete with further test results.
The inspection team evaluated the violation in accordance with Section 2.3 of the NRC Enforcement Policy and dispositioned the finding as a non-cited Severity Level IV violation.
NRC FORM 591S PART 2 (10-2013)
INSPECTOR NOTES COVER SHEET Licensee/Certificate Holder TN Americas LLC/Orano (name and address) 7135 Minstrel Way, Suite 300 Columbia, Maryland 21045 Licensee/Certificate Holder Douglas Brownson, Senior Manager of Quality Assurance contacts and phone number 410-910-6963(0ffice)
Docket No. 72-1004 Inspection Report No. 72-1004/2018-201 Inspection Date(s) March 19-23, 2018 Inspection Location( s) Larsen & Toubro Limited Ranoli Works, Vadodara, India Inspectors Jon Woodfield, Team Leader, Safety Inspector Earl Love, Senior Safety Inspector c.P.~--
Jeremy Taco, Safety Inspector t J}31 Summary of Findings and This inspection was a routine periodic assessment of TN Actions Americas' (TN) Quality Assurance Program (QAP}
implementation at TN's NUHOMS System Dry Shielded Canister and transportation packaging steel fabricator Larsen & Toubro (L&T).
The team assessed L&rs management controls, design controls, and fabrication controls for compliance to 10 CFR Parts 21, 71 & 72, and TN's NRC approved QAP; as related to TN CoCs 72-1004 (NUHOMS 24PTH-S-LC} and 71-9358 (TN-LC).
Overall, the team assessed that TN through L&T was adequately and effectively implementing their NRC approved QAP subject to 10 CFR Part 71 & 72 with regard to QA, Management Controls, Design Interface Controls, and Fabrication Controls.
One Non-cited Severity Level IV violation was identified by the team and described in these inspector notes. Contrary to the requirements of 10 CFR 72.154, TN did not have documentary evidence that material conformed to the procurement specifications. TN's procurement of Helicoils and washers classified as important-to-safety Category A components was incomplete. Verification of critical characteristics and objective evidence in the test report did not contain sufficient evidence that critical characteristics were adequately verified through the inspection and tests dedication report process. TN captured the issue in their corrective action proaram.
Lead* inspector Signature/Date Jon N. Woodfield~ - - ? ' ;J/Y'~ ~ /3fit
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Inspector Notes Approval Branch Chief Signature/Date Meraj Rahimi ))'1 UcJL
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Page 1 of 14
Inspection History The NRC conducted the first inspection of L&T in February, 2015 (Inspection Report 072-1004/2015-201 and ADAMS ML15086A109). The inspection team performed an inspection of selected fabrication activities for spent fuel dry storage and transportation casks being manufactured in India for use in the United States. The team examined the activities at two L&T fabrication sites, Ranoli Works and Powai Works, located in Vadodara and Mumbai India, respectively. Work at both facilities was being performed for TN at the time.
The team examined welding, nondestructive examination activities, leak testing, design control, documentation control, material controls and quality assurance (QA) controls. In addition, the team reviewed numerous quality documents such as inspection reports, corrective action and nonconformance reports, procurement documents associated with commercial grade dedication (CGD) of ITS related components, audits, and design documents. Additionally, the team examined the adequacy of fabrication oversight activities by the reactor licensees (TN clients) and the Certificate of Compliance (CoC) holder TN.
Overall, the quality of fabrication, quality controls, and QA oversight by the CoC holder and the licensees at both facilities were determined to be adequate with no violations identified by the inspection team. The 2018 inspection was only conducted at Ranoli Works since fabrication is no longer performed at Powai Works for TN.
Inspection Purpose The purpose of the inspection was to assess TN's compliance with 10 CFR Parts 21, 71 & 72 using L&T's Ranoli Works as a fabricator, and to verify that the storage systems and transportation packagings for which TN is the holder of CoC's 1004 and 9358, respectively; can be verified to comply with Part 72 & 71 in design, procurement, and fabrication requirements, as applicable. The focus of the inspection was to determine whether TN activities associated with the storage and transportation of radioactive materials are in accordance with their NRC approved QA program requirements.
Primary Inspection Procedures/Guidance Documents IP-60852, "ISFSI Component Fabrication by Outside Fabricators" IP-86001, "Design, Fabrication, Testing, and Maintenance of Transportation Packagings" NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety" NUREG/CR-6314, "Quality Assurance Inspections for Shipping and Storage Containers" Regulatory Guide 7.10, "Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material" Page 2 of 14
INSPECTOR NOTES: APPLICABLE SECTIONS FROM IP 60852 and IP 86001 WERE PERFORMED DURING THE INSPECTION WITH RESULTS DOCUMENTED BELOW UNDER THE BASIC HEADINGS OUTLINED IN NUREG-6314.
4.1 Management Controls 4.1 .1 Quality Assurance Policy The team reviewed L&T's corporate Nuclear Safety Quality Assurance Manual (NSQAM)/Nuclear Quality Assurance Manual (NOAM), Issue 1, Revision 2 and associated quality procedures; and assessed the effectiveness of the OAP implementation at L&T's Ranoli Works. The team conducted reviews of L&T's quality program, policies, and procedures, and discussed portions of the reviewed documents with selected personnel to determine whether activities subject to 10 CFR Part 71 and 72 were adequately controlled and implemented under TN Americas' NRG-approved QA program at L&T. The team reviewed nuclear quality assurance procedure NQAP-01-01, "Organization," Revision 2, L&T organization charts, and interviewed QA personnel to evaluate their organizational independence from cost, schedule, and production activities. The team also reviewed NQAP-02-04, "Quality Assurance Program,"
Revision 2, to assess the .overall OAP requirements imposed, such as annual management reviews and QA surveillance programs. The last annual management review performed January 17-18, 2018, was assessed. Further, the team reviewed NQAP-02-05, "Indoctrination,"
Revision 1, to evaluate the adequacy of L&T's training program for new employees working under the NSQAM/NQAM. The team noted this was a new requirement since the previous inspection.
The team found that since the previous inspection in 2015, all L&T locations performing 10 CFR Part 71 and 72 work for TN now worked under L&T's corporate NSQAM/NQAM. This was implemented in April 2015 at Powai Works, Ranoli Works, and Hazira. In addition, the L&T quality department is now run out of Hazira rather than Powai. The NSQAM/NQAM still contained a management statement of policy signed by L&T's Executive Vice President responsible for Quality Assurance. The team also noted that the last annual management review was performed in accordance with the procedural requirements and identified the same issues as the NRC inspection team did in their nonconformance report (NCR) and corrective action report (CAR) reviews which follow. The main issues were in the areas of dimensional controls, welding, and lead pours; and the team determined that actions were being taken by L&T to reduce issues in those areas, among others.
The team assessed that the new corporate NSQAM/NQAM conformed to the applicable requirements. Overall implementation of L&T's OAP was assessed to be adequate.
4.1.2 Nonconformance and. Corrective Action Controls The team reviewed L&T's non-conformance program at Ranoli Works to assess the effectiveness of measures established to control materials, parts, components, and services Page 3 of 14
that have been identified by L.& T as not conforming to specified requirements. The team also reviewed Ranoli Works' corrective action program (CAP) to assess the effectiveness of the measures established to identify and correct issues, and if required, prevent recurrence.
The team reviewed the following L&T quality procedures at Ranoli Works:
- NQAP-15-01, Control of Nonconforming Items, Revision 6
- NQAP-16-01, Corrective Action Reporting, Revision 5 The team assessed that the quality procedures provided adequate guidance for the processing of nonconforming items and corrective actions. However, the team noted that NQAP-16-01 did not contain provisions or a process for corrective action report due date extensions. Since the procedure requires all CAR responses within 30 days, it's not always possible to meet that time constraint as identified by the team during the CAR review. By implementing a due date extension process, going beyond the 30 day requirement would be controlled and a timely response based on significance would be maintained. L&T entered this observation into its CAP as CAR No 356 to improve the procedure.
The team reviewed a selection of both Nonconformance reports (NCRs) and CARs issued since the previous inspection in 2015 for fabrication of the TN-LC and TN NUHOMS dry storage canisters (DSCs) at Ranoli Works. The team assessed that for the 16 NCRs reviewed, the dispositions were appropriate. Where one NCR had not yet been dispositioned, a red hold tag was verified to be attached to the affected component in the shop. The team noted that one NCR's engineering evaluation for a use-as-is disposition was lacking a complete description/evaluation in the documentation. The team determined through an interview of knowledgeable L&T personnel that their disposition was justified and it was only a documentation issue. L&T entered this observation into its CAP as CAR No 355 to enhance the procedural guidance in this area.
The team assessed that for the 15 CARs reviewed, they had been adequately documented, actions were timely, and the corrective actions taken were adequate. The team noted that L&T had implemented a new web-based CAP system to enter CARs, which also allowed them to track and trend data. Also, at the time of the inspection only five CARs were open and almost all issues were being responded to within 30 days. These observations were an improvement since the 2015 inspection and overall, the CAP was identified as a strength.
The team concluded that the quality procedures being implemented at Ranoli Works provided adequate guidance for the processing of nonconforming items and corrective actions.
The team reviewed L&Ts procedure NQAP-16-02, "Reporting of Defects and Noncompliances,"
Revision 1 and determined the procedure adequately implemented the requirements of the 10 CFR Part 21 regulation. The team asked L&T if any Part 21 Reports had been written for the fabrication work performed for TN and L&T stated that that no Part 21 Reports had been written. The team also verified that L&Twas meeting the posting requirements of 10 CFR Part Page 4 of 14
- 21. The team reviewed document QA/APP-A3, "Distribution List- NQAP-16-02," Revision 10 which provided a sequential numbered controlled copy list for the Part 21 postings and the associated posting location in the Ranoli fabrication facility. The team verified that the required controlled copy postings at the specified locations were available in the fabrication facility and employees could readily see them. No issues were identified by the team regarding 10 CFR Part 21 program controls or implementation at L&T.
4.1.3 Documentation Controls The team reviewed section 6, "Document Control," Issue 1, Revision O and section 17, "Quality Assurance Records," Issue 2, Revision 1 of the L&T NSQAM. In addition, the team specifically reviewed the following procedures associated with document controls and records:
- NQAP-06-01, Document Control on Intranet, Revision 2
- NQAP-06-02, Document Distribution, Revision 3
- NQAP-06-03, Procedure for Control of Documents, Revision 3
- NQAP-17-01, Procedure for Control of QA Records, Revision 2 L&T uses its intranet computer system to ensure that its Nuclear QA Manual, Nuclear QA Procedures, Approved Suppliers List, and list of authorized holders of hard copies of its Nuclear QA Manuals are available to all its employees electronically at their computers. L&T demonstrated to the team at a computer screen how all these documents could be accessed electronically. Hard copies of these documents are prepared, reviewed and approved by authorized personnel and scanned into the intranet and secured with a password to prevent editing. Once the documents are uploaded they are considered controlled documents. The team chose one individual from the intranet list of Nuclear QA Manual controlled hardcopy holders and verified his controlled copy revision and reviewed the transmittal and return receipt for when he received the latest controlled copy revision.
The team verified the distribution methods for the DSC basket assembly fabrication drawings to various fabrication facility locations in accordance with procedures NQAP-06-02 and NQAP 03. L&T had the documentation (Document Issue Note forms and Drawing/Document Issue Slips) showing that drawing hard copy revisions had been distributed to the designated facility locations and the previous drawing revisions removed and destroyed. The team specifically checked the current DSC basket assembly fabrication drawing revisions were in the planning, welding, and QA/QC areas on the fabrication shop floor. The team determined the procedures gave detailed document distribution instructions and the distribution requirements were being followed.
NQAP-17-01 describes the requirements and process to control receipt, identification, verification, maintenance, storage, and classification as lifetime or nonpermanent of QA records.
Each quality record is to be numbered and be traceable to the item(s) or operation(s) to which it applies and accurately reflect the work accomplished or information required. All records are to be initialed or signed with a date by authorized personnel. All records generated as part of the Page 5 of 14
fabrication process are to be forwarded to L&T quality control {QC) and maintained in a project specific folder. The team verified that as quality records for fabrication of DSCs were being completed, they were maintained by L&T QC in a project folder.
TN specification NUH24PTH-0105, "Procurement Specification for the NUHOMS 24PTH Dry Shielded Canisters, Revision 4 {which is further discussed in Design Control and Fabrication fl Control) requires L&T to submit to TN for review and approval a list of Quality Records that L&T will provide in the final document package {FDP) for each DSC it fabricates for TN. The team reviewed L&T document 32PTH/24PTH/FDP "Final Documentation Package Format, Revision fl 6 which was submitted by-L&T and approved by TN. The team verified the approval correspondence. Although not shipped yet, the team reviewed two final document packages for the first two completed DSCs. The team reviewed the common FOP and specific component FOP for the two DSCs and found them compliant with 32PTH/24PTH/FDP. In addition to all the material records and fabrication records, the FOP for each DSC contains As-built fabrication drawings showing the exact fabrication drawing revisions that particular DSC was constructed to. The As-built drawings also show reference to NCRs associated with that DSC. The team traced the process of QC personal preparing mark-up prints for the As-built fabrication drawings. These mark-up prints were then forwarded to L&T Design and Engineering which was ultimately responsible for preparation, review and approval of the As-built drawings. In the individual DSC FDPs, L&T certifies that the DSC was fabricated in accordance with the As-built drawings.
The cover sheet of the FOP records are affixed with a QA Record stamp for authentication. The required number of sets of QA records are forwarded to the L&T project manager by quality assurance for submittal to the customer {TN). The original QA records are then sent to storage.
Final QA records are stored in steel cabinets or on shelves to prevent damage or loss from fire, moisture, water leaks, insects and dust. Electronic QA records are stored to prevent damage due to excessive light, electromagnetic fields, temperature or stacking. QA records, either hard copy or electronic form are stored at two different locations remote from each other to prevent damage to the records simultaneously due to hazards. Quality assurance maintains a list of L&T personnel having access to the permanent QA records. The team inspected one storage area of DSC quality records and found it adequate.
The team determined the document control and QA record procedures were adequate and being followed by L&T personnel. No concerns were identified by the team in the documentation control and records management areas.
4.1.4 Audit Program Internal Audits The team reviewed the internal audit program as defined in NQAP-18-01, "Procedure for Conducting Quality Audits, Revision 3. This was to verify that the program was comprehensive fl and that audits were scheduled and conducted periodically in accordance with approved Page 6 of 14
procedures by trained and qualified audit personnel who documented the audit results and followed up deficient areas via the corrective action program. The team reviewed four internal audits performed in both 2016 and 2017 for a total of eight reviewed, as well as the 2016 through 2018 internal audit schedules to verify that they were conducted in accordance with the program as previously defined. In addition, the team reviewed two surveillances performed by TN in 2017 of L&T to determine if TN's audits were comprehensive and what issues were identified. The team also reviewed a sampling of lead auditor/auditor training and qualification records to assess whether those leading and performing audits were trained and qualified as required by L&T's approved procedure, NQAP-02-01, "Procedure for Qualification of Quality Assurance Program Audit Personnel," Revision 3.
The team determined that for the internal audit reports and checklists reviewed, the audits were adequate, reviewed a representative sample of L&T's activities in the area being audited, and written in a timely manner. The team noted that for the audit reports reviewed, the QA areas at Ranoli Works were audited by the corporate QA organization from Hazira, who do not have direct responsibility for the QA work performed at Ranoli. The team also noted that L&T has implemented a lead auditor and auditor training and qualification program in NQAP-02-01 that follows American Society for Mechanical Engineers Nuclear Quality Assurance (NQA) NQA-1 guidance. All auditor and lead auditor qualifications reviewed by the team met NQAP-02-01 requirements. In addition, the team determined that the TN surveillances reviewed were comprehensive in nature and identified issues to correct and improve L&T's QAP.
Overall, the team assessed that the internal audit program was adequately being implemented through L&T performing audits of all applicable aspects of the QAP at the required frequency using trained and qualified personnel.
External Audits L&T does not have any suppliers of materials and services with adequate quality assurance programs to supply directly to L&T ITS Category A material and take Part 21 reporting responsibilities. Therefore, L&T dedicates all materials. Reference section 4.3.1 Material Procurement for the team's review of L&T's commercial grade dedication program.
4.2 Design Control 4.2.1 Design Development The team reviewed section 3, "Design Control," Issue 1, Revision 1 of the L&T Nuclear Safety Quality Assurance Manual, and L&T procedure NQAP-03-06, "Procedure for Design Control,"
Revision 2 for the quality assurance requirements for design control and to verify that they were being properly implemented, as applicable.
TN is totally responsible for DSC design development and therefore L&T does not have any design authority or design change authority. L&T is authorized only to develop fabrication Page 7 of 14
drawings and process fabrication NCRs. Therefore, the team addressed design control by reviewing the design control process between the Dry Cask Storage System (DCSS) designer TN and fabricator L&T. The team first reviewed TN specification NUH24PTH-0105, "Procurement Specification for the NUHOMS 24PTH Dry Shielded Canisters," which was sent to L&T to provide the details of the DSCs to fabricate. The specification also contained the minimum fabrication documentation requirements and submittal requirements of those documents for TN review prior to actual fabrication. The actual TN DSC design drawings for the 24PTH are not part of the specification but were attached to the original TN purchase order and revised purchase orders (as needed) to L&T.
The team reviewed the process for L&T to develop fabrication drawings from TN design drawings and the transmittal and approval of fabrication drawing revisions between L&T and TN. The team specifically reviewed a sampling of L&T fabrication drawings for the TN NUHOMS 24PTH-S-LC Dry Shielded Canister basket assembly.
The team verified that the fabrication drawings developed by L&T had received the proper L&T reviewer and approver signatures at each revision. The team verified that L&T had records of the transmittal of the fabrication drawings to TN's corporate office in Maryland or TN's on site staff for approval prior to issuance for use in fabrication.
The team then reviewed the TN correspondence documentation approving/accepting the L&T fabrication drawings and revisions. In some instances, TN accepted with comments or rejected the fabrication drawing revision with resolution of the reason for rejection required. L&T was then required to submit to TN another revision to the fabrication drawing due to the resolution of the rejection reason.
The team also reviewed how design drawing revisions from TN to L&T were incorporated into the L&T fabrication drawings and how all controlled copies of issued fabrication drawings were tracked and accounted for. When design drawing revisions were received from TN which affected fabrication, fabrication drawings would be pulled back from the shop until the fabrication drawing could be revised by procedure and issued back to the shop.
The team reviewed the education and training requirements for the L&T engineering staff that are responsible for drafting, checking, and approving the L&T fabrication drawings. The team requested that L&T provide the education and training records for the L&T design staff that had drafted, checked, reviewed, and approved the latest revisions to the basket assembly fabrication drawings. Although all the education documentation provided was from India colleges or universities, the team found all the education and training records for the individuals to be adequate and met the applicable requirements.
Based on its review, the team determined that L&T was following its design procedures, as applicable, to ensure that fabrication drawings and any associated specifications were consistent with the TN design drawings, NRC approved licensing drawings, and design requirements/commitments as documented in the CoC for the DCSS. No concerns were Page 8 of 14
identified with the transmittal of TN design drawings to L&T and L&T development, review and approval of fabrication drawings. In addition, there were no concerns with the documentation of TN's approval back to L&T so the fabrication drawings could be released for construction.
4.2.2 Modifications Modifications to the DSC design drawings could be performed under the 72.48 and design control processes of TN at their offices in the United States. All L&T would receive from TN is a revised purchase order with any revised DSC design drawings attached. L&T would then review the revised DSC design drawings for any effects on the fabrication drawings. If the L&T fabrication drawings were affected, L&T would remove those drawings from the shop floor until revised fabrication drawings incorporating the changes could go through the approval process and be re-issued back to the shop floor.
4.3 Fabrication Controls 4.3.1 Material Procurement Commercial Grade Dedication The team verified that procurement of important-to-safety, Category A (ITS-A) items and services were made only to suppliers listed on L&T's approved vendors list for that procurement scope. L&T maintains traceability from receipt of items until commercial grade dedication is complete. When a commercial-grade item is ordered, a form of traceability is established by issuance of a purchase order (PO) that identifies the item's part number and a product description. Traceability to the purchase order and line item number is the initial type of traceability in the dedication process. Additional layers of traceability are added by association with numbered commercial grade dedication (CGD) reports, receipt inspection reports, examination reports, and production/shop travelers to control work throughout the dedication process. These activities are typically identified and controlled for each purchased lot of items.
The following L&T commercially dedicated procurements were reviewed:
For Project No. 20223 (TN-LC):
Specification No. L&T/TN LC/06/MATL/09, Revision 3 Specification for Alloy Steel Bolting Material SA 540 Grade B23 Class 1 CGD Report No. L&T/20223/TN LC/RNW12/CGDR, Revision 0 Purchase Order (PO} No. RNW/220668NIDNA dated 3/25/2014 Line Items: 70 and 80 Lid and Trunnion Bolts The staff noted lid and trunnion bolts were procured to the requirements of American Society of Mechanical Engineers B&PV 2010 edition versus TN's procurement specification which requires Page 9 of 14
the 2004 Edition, including 2006 Addenda. The team noted L&T performed a reconciliation (Report No. L&T/TN LC/MRR/006, revision 1) and determined that the 2010 edition of the ASME code met the requirements of 2004 Edition, including Addenda 2006.
Specification No. L&T/TN LC/06/MATL/03, Revision 1 Specification for Stainless Steel Plates SA 240 Type XM19 CGD Report No. L&T/20223/TN LC/04/CGDR-02, Revision 0 PO No. lMP/320041NIDNAYAN DOSHI, amendment 1 TN LC Inner Shell Plate Examination and Testing on all Plates Specification No. L&T/TN LC/06/MATL/06, Revision 4 Specification for Forged Stainless Steel SA 182 Grade F XM19 CGD Report No. L&T/20223/TN LC/04/CGDR-01, Revision 0 PO No. IMP/320040NIDNAYAN DOSHI, amendment 1 Top Flange Forging Specification No. 09-10-13(N), Revision 0 Specification for ASME Sec. IIC SFA 5.9 AWS ER209 CGD Report No. L&T-TN LC-CGDR-23, Revision 0 PO No. IMP/610141/BUTE NILE, amendment 1 Stainless Steel Bare Welding Wire and Spools for GTAW TN Supplied Material CGD Report No. 2014-02-1 PO: P2014-0317 (AREVA/TN, Aiken, SC)
Silicone 0-Ring, Inner Lid Areva TN Aiken, SC PO No. P2014-0385 including Change Order Nos. 1, 2 and 3 Issued to: Columbiana Hi-Tech, NC Helicoils and Washers Drawing No. 65200-30-01-38, 7C and 1OA, Revision 6 CHT PO No. 20140752 to Trust Manufacturing, Euclid, OH Trust PO No. 308170 to MSC, Melville, NY: (distributor)
MSC PO No. 9182191 to Emhart Technologies, Danbury CT Emhart Technologies PO No. 907392 to Central Wire Industries (CWI), Ontario, CANADA CWI Certificate of Conformance North American Stainless Canada, Inc. Metallurgical Test Report (Issued to CWI)
With regards to TN's procurement of ITS-A helicoils and washers (noted above), which are used by L&T on the TN-LC, the team noted that the method of dedication selected was Method 1, Inspection and Tests. However, verification of critical characteristics and objective evidence in the report verification process was incomplete. Specifically, TN's commercial grade dedication Page 10 of 14
report lacked complete evidence that the components were appropriately dedicated. The report did not contain sufficient objective evidence that critical characteristics were adequately verified (i.e., tensile test and other critical characteristics through the dedication reporting process).
Further, a condition/requirement within the TN PO specific to approval of CGD procurement activities appeared to be absent in the CGD report.
The inspection team determined that this was a violation of NRC requirements. Specifically, 10 CFR 72.154, "Control of purchased material, equipment, and services," paragraph (b), which states, in part, the licensee, applicant for a license, certificate holder, and applicant for a CoC shall have available documentary evidence that material and equipment conform to the procurement specifications prior to installation or use of the material and equipment. The licensee and certificate holder shall ensure that the evidence is sufficient to identify the specific requirements met by the purchased material and equipment. Contrary to these requirements, TN's implementation of a commercial grade procurement was inadequate. The team characterized the finding as a Severity Level IV non-cited violation. The NRC plans to treat the NRC identified finding as a non-cited violation consistent with section 2.3.2 of the NRC Enforcement Policy. TN entered this issue into their corrective action system for resolution as corrective action report (CAR) 2018-067.
For Project No. 20412 (24PTH Dry Shielded Canister):
Specification No. L&T/24PTH&32PTH1/005/MATL/09, Revision 7 Specification for 0.25" Thick Stainless Steel Square Tubes Stainless Steel Plate of Grade SA 240 Type 304 per ASME Section IIA 98Ed/99&2000Ad CGD Report No. L&T-24PTH-VHEW-SQT-CGDR-65, Revision 1 PO No. lMP/320040NIDNAYAN DOSHI, amendment 1 Top Flange Forging Specification No. L&T/24PTH&32PTH1/005/MATL/04, Revision 0 2.953" thick Aluminum Plates, GradeASTM 8209, Type 6061 Temper 'T651' CGD Report No. L&T-24PTH-VHEW-CGDR-51, Revision 0 PO No. IMP/320073NIDNAYAN DOSHI, amendment 0 Plate Examination and Testing With the exception of TN's procurement of helicoils and washers, the team determined there was adequate assurance that L&T's purchased material, equipment, and services conformed to the procurement documents through source evaluation, objective evidence of quality furnished, and examination of products upon delivery.
The team noted that the vendors of the above mentioned components were listed on L&T's approved commercial grade suppliers list (No. NU/ASL Issue 1, Revision 13, Part C) as qualified suppliers of ITS-A items and services {subject to commercial grade dedication). The following were noted on the list as approved commercial vendors:
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- ArcosAlloy
- M/S Fasteners and Allied Products Pvt. Ltd.
- Metallurgical Services
- M/s Bhandari Foils and Tubes Limited 4.3.2 Fabrication and Assembly Controls The team evaluated control of the fabrication process through observations, examinations, and personnel interviews in the areas of material procurement, fabrication, assembly, test and inspection. The team selected a sample of production materials and assessed compliance to applicable CoC, TN specifications, and L&T and TN procurement documents. The team examined L&Ts production drawings, specifications, CGD records, certified material test reports (CMTRs), receipt inspection records, certificates of conformance, and vendor qualifications.
With regard to procurement, the team reviewed documents associated with TN-LC ITS-A components including cask lid bolts, helicoils, 0-rings, and shell and flange materials.
Concerning the NUHOMS 24PTH DSC, the team reviewed ITS-A documents associated with basket assembly tubes, siphon & vent blocks, transition rails, and inner bottom covers. The team noted that CGD reports included CMTRs and other third party test reports. Overall, the team found that requirements of both the TN-LC Cask and 24PTH DSC specifications and quality procedures were adequately implemented for control of purchased material. The following TN specifications and drawings were reviewed:
NUHOMS 24PTH Dry Shielded Canisters
- NUH-24PTH-0105, Procurement Specification for NUHOMS 24PTH Dry Shielded Canisters, Revision 4, 08/14/2014
- 13923-4002, NUHOMS 24PTH-S-LC for Oconee Nuclear Station Configuration Drawing, Revision 7, 05/12/2017 .
- NUH24PTH-4001, NUHOMS 24PTH Basket Shell Assembly, Revision 6, 02/25/2016
- 65200-0102, Procurement Specification for TN-LC Transport Cask and Baskets, Revision 3, 11/11/2017
- 65200-4036, TN-LC Configuration Drawing, Revision 11, 11/21/2017
- 65200-30-01, TN-LC Cask Assembly, Revision 11, 11/21/2017
- 65200-30-80, TN-LC TRIGA Basket, Revision 09, 11/21/2017 Page 12 of 14
NUHOMS 24PTH Dry Shielded Canisters and TN-LC Transport Cask
- NUH-03-0150, Procurement Specification for Metal Matrix Composite (MMC) Neutron Absorber Material for use in Baskets, Revision 8, 09/10/2013 The team examined TN-LC and 24PTH DSC procurement specifications, license drawings, work orders (travelers) and inspection/test records; and noted that fabrication, assembly, and test processes met the requirements of the applicable CoCs. The team witnessed various shop fabrication, assembly, and tests; which included welding and nondestructive examinations (NDE). The team noted that material controls which included segregation, identification, and traceability (i.e., materials, parts, weld filler material) were well maintained throughout processing operations.
The team verified that personnel performing welding and NDE activities were qualified and were maintaining their qualification in accordance with applicable quality procedures. In addition, welding and NDE procedures were properly prepared and compliant with applicable code and regulatory requirements. The team also reviewed in-process final documentation packages to assess completed work. The packages reviewed were specific to 24PTH DSCs and a TN-LC Transport Cask and Basket Assemblies.
The team observed DSC basket spot arc welding and component fit-ups. In addition the team reviewed corresponding production weld data sheets, weld repair records (as applicable), weld procedure specifications, and welder performance qualification/proficiency records. The team noted welders, travelers, procedures, specifications, and weld consumables used were adequately qualified or written and compliant with applicable TN specifications, as well as ASME code and regulatory requirements.
The team identified components, materials, and consumables (e.g., penetrant and weld flux materials) used on the shop floor for fabrication and traced them back to their associated purchase orders and applicable design drawings. No concerns were identified in the translation of design information into procurement documents and CGD reports; and the eventual use of those purchased and qualified materials in the fabrication process. The team observed shop material in use at different production stages and noted adequate measures had been established and implemented to release and distribution the material to the shop work stations.
Fabrication items/components were properly identified which provided traceability to their inspection and/or production status and observed to be appropriately stored. Overall, the team determined material controls were adequate and no issues were identified.
4.3.3. Test and Inspection The team performed a review of in-process travelers and reviewed a radiographic examination report. In addition, the team witnessed visual/liquid penetrant examinations, a helium leak test, and a DSC shell bubble leak and pneumatic pressure test. Afterwards, the team performed a detailed assessment of post-inspection documentation and personnel qualifications. The team Page 13 of 14
reviewed certification records for NDE personnel, including associated eye exams, and no concerns were identified. Overall, the team found the quality of construction, documentation, and capabilities of inspection personnel to perform test and inspection activities to be adequate.
In observing various assembly and testing processes during fabrication, the team noted that multiple hold and witness points existed for verification of quality activities. Hold and witness points had been completed in many instances, which provided assurance to oversight personnel that activities were being properly performed. Many of the witness hold points were on travelers associated with test and inspection activities. The team determined that overall L&T and TN had adequate control of fabrication processes and ongoing work; including the testing and inspection of individual items and assemblies.
4.3.4 Tools and Equipment The team reviewed L&T procedure NQAP-12-01, "Procedure for Control of Measuring and Test Equipment," Revision 2 for the quality assurance requirements for maintenance of measuring and test equipment (M&TE) and to verify that it was being properly implemented. The team reviewed L&T's master list of M&TE associated with the TN fabrication work and selected several M&TE instruments off the list to verify proper calibration and calibration documentation.
The team reviewed calibration reports for an oxygen analyzer, load cell, feeler gauge set, torque wrench, digital caliper, pressure gauge, and helium standard leak. L&T did not perform the calibration of this M&TE, but contracted the calibration out to various calibration service companies. To qualify the calibration service providers, L&T performs a commercial grade dedication report. The calibration reports performed by the service companies are reviewed by an individual from the L&T functional area responsible for that instrument and signed off as reviewed and acceptable. The team verified that for all the calibration records reviewed that L&T personnel had approved by signature the calibration report. The team also verified that for all the M&TE sampled, by procedure they were labeled with unique identification numbers and date through which the calibration was valid. NQAP-12-01 also provides guidance on actions to be taken if any M&TE is found to be out of calibration during recalibration. Part of the corrective action is to write a NCR and assess the validity of previous measurements, inspections, or test results for which the out of calibration M&TE was used for.
The calibration of each M&TE instrument sampled was current and traceable to a recognized standard. The team determined that L&T was controlling M&TE calibration activities and records in accordance with its procedures with no concerns.
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