ML19259D571
| ML19259D571 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19259D565 | List: |
| References | |
| REF-QA-99900331 99900331-79-1, NUDOCS 7910250115 | |
| Download: ML19259D571 (2) | |
Text
Excelco Developments, Incorporated Docket No.
99900331/79-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on July 31-August 3,1979, it appears that certain of your activities were not conducted in accordance with NRC requirements.
Criterion 5 of Appendix E to 10 CFR 71 states:
" Activities affecting quality shall be prescribed by documented instruc-tions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. These shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Deviations from these requirements are as follows:
A.
Excelco QA llanual, Revision 0, Section 8.5.1, states in part, "NDE performed within E.D.I. is in accordance with the Code and E.D.I.
approved NDE Test Procedures.
NDE results are recorded on the applicable inspection Records and are signed by the qualified Inspector performing the test (Figures 8-3 thru 8-8).
Examination results are forwarded to the Q. A.M. f or inclusion in the Q.C. Work Package."
Contrary to the above, nondestructive examination.(NDE) was not in accordance with the ASME Code and the QA Manual. Two (2) examples of this are:
(1) The radiographs for casks A thru E were not in accordance with the ASME Code and three (3) instances of this were:
(a) the range of densities of radiographic film was not considently within the require-ments of (T-263.2(a)) minus 15% to plus 30%.
(b) a penetrameter (image quality indicator) was not found on each radiograph of the C-2 weld (T-263.2(c)).
(c) A linear indication was observed in the C-2 weld of cask C which appeared to be in excess of the ASME Code acceptance limits (NC-5320).
(2) The NDE results were not documented and maintained in accordance with the QA Manual in that certain required examination results were not included in the QC Work Package. For example, all radiographic records of wuld C-51 for cask C and D were not in the QC Work Package. Also, the results of the penetrant tests fu. welds C-16 on the cask cover in caska A thru D and the lead pour hole plug C-51 on the cask base assembly were not in the QC Work Package (See Details, B.4.c.(1)).
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2 B.
ASME Code,Section III, NA-4133.11(a), which is a commitment of the Excelco QA Manual, states in part,
" Testing shall be performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents."
Contrary to the above, the records did not demonstrate that the testing was performed in full accordance with the written test procedure and ASME Code. Two (2) examples of this are:
(1) The test procedures and QA Manual both require that calibrated gages be used and their use be documented.
It was not documented that the gages used for hydrostatic testing of casks B, C, D and E and the thermal testing of casks A thru E had been calibrated.
(2) The records did not demonstrate that the acceptance limits for the thermal test (the T.A.P. computer program used to prepare the Safety Analysis Report) were incorporated in the procedure and used to evaluate the test results for casks A thru E (See Details, B.4.c.(2)).
C.
Excelco QA Manual, Revision 0, Section 3.3.1.1.2, states in part,
" Documentation and test reports shall conform to the requirements stated on the drawing, material specification or as otherwise required by the purchase order."
Contrary to the above, records were not on file which would demonsurate that the materials of casks A thru D conform to the requirements of the specification and the purchase order. For example, the balsa wood used for impact limiters, did not have documentation on file that would attest it to conform to the density and the Mil-Standard, specified and required in the purchase order (See Details, B.4.c.(3)).
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