ML19259D572
| ML19259D572 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/1979 |
| From: | Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19259D565 | List: |
| References | |
| REF-QA-99900331 99900331-79-1, NUDOCS 7910250121 | |
| Download: ML19259D572 (6) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900331/79-01 Program No. 51300 Company:
Excelco Developments, Incorporated Post Office Box 230 Silver Creek, New York 14136 Inspection Conducted:
July 31-August 3, 1979 8.8////
Inspector:
W. M. McNeill, Contractor Inspector Date ComponentsSection I Vendor Inspection Branch O.hk )Ah 6
e/ziM J. T. Conway, NRR
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Quality Assurance Branch J
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Approved b :
. E. Whitesell, Chief Da'te ' '///
l ComponentsSection I Vendor Inspection Branch Summary Inspection on July 31-August 3, 1979 (99900331/79-01)
Areas Inspected: A special inspection of the records of the spent fuel shipping casks was performed in response to an action item.
The inspection involved fifty-six (56) inspector hours on site by two (2) NRC inspectors.
Results: The following three (3) deviations and one (1) unresolved item were identified.
Deviations: Records Review - records documenting certain NDE results were missing and radiographs were not in compliance with the ASME Code as required by the QA Manual and Criterion 5 of Appendix E (Notice of Deviation, Item A);
Records Review - the records did not demonstrate that certain tests were performed in full compliance the detailed written procedure, and that the acceptance limits specified in the design documents, were achieved as required by ASME Code and Criterion 5 of Appendix E (Notice of Deviation, Item B);
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2 Records Review - records were not on file which would attest that certain materials conformad to the specification, as required by the QA Manual and Criterion 5 c Appendix E (Notice of Deviation, Item C).
Unresolved Items: Records Review (Details Section, paragraph B.4.b.)
Other Significant Findings:
Nuclear Assurance Corporation has identified to the NRC that Excelco is the fabricator of spent fuel shipping casks with serial numbers A, B, C, D, and E.
Nuclear Assurance Corporation has stated in its Certificate of Compliance and Safety Analysis Report that Excelco would comply with the Quality Assurance requirements of Appendix E to 10 CFR 71.
The requirements of Appendix E to 10 CFR 71, was invoked on Excelco by the Nuclear Assurance Corporation procurement documents and design specification.
Casks serial numbers A thru D, were fabricated in 1974, and cask number E was fabricated in 1978.
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3 DETAILS SECTION A.
Persons Contacted W. D. Abbott, Chief Engineer, Excelco
- L. A. Brooks, President, Excelco G. P. Mcdonald, Records Clerk, Excelco M. M. Pulawski, QA Manager, Excelco
- C. H. McDonnell, Chief, Nuclear Engineer, United States Testing Co.
- D. A. Webster, Quality Assurance Manager, Nuclear Assurance Corporation
- Denotes those attending the Exit Interview.
B.
Records Review 1.
Background Information Recent findings indicate that some spent fuel shipping casks are not ira conformance with their Certificates of Compliance. An audit of the manufacturing records was requested. The memo concerning this item requests that the fabrication records be reviewed to establish whether objective evidence exists that will demonstrate tha t the casks vere built, inspected, and tested, in accordance wit.t approved drawings and with the certificates of compliance.
2.
Objectives The objectives were to verify that the fabrication records, demonstrate that the spent fuel shipping casks were manufactured and tested in conformance with their Certificates of Compliance and approved drawings.
All repair and rework performed were verified as having been properly evaluated and approved, and any deviations from the Certificate, were properly reviewed and approved and such approval documented.
3.
Method of Accomplishment The preceding objectives were accomplished by:
Review of the Nuclear Assarance Corporation data packages on a.
each cask Nos. A thru E, to ascertain whether the data packages included such items as the cask release, acceptance test reports (hydro, thermals, etc), certified material test reports, as built drawings and tabulations of materials, inspection reports (receiving, inprocess, and final), reports of the nondestructive examination results, veld parameter sheets, bill of material lists, inspection reports of nonconformances (IRNs), master logs of customer supplied documents, and drawings.
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4 b.
Review of the Nuclear Assurance Corporation purchase order and design specifications, and the Excelco manufacturing drawings and procedures, including the approval forms for the approval of drawings, procedures, and any waviers or changes.
c.
Review of the reader sheets and technique cheets, and radiographic films of the cask assemblies for all of the casks Nos. A thru E.
4.
Findings a.
Deviations See Notice of Deviation, Items A thru C.
b.
Unresolved Item Time did not permit a record search to be completed to locate to the qualification records of the welders used during the fabrication of the casks.
c.
Comments (1) The quality of all welding could not be determined due to missing QA/QC documents, records and radiographic film i.e. the records and radiographs of welds in the pressure boundry and its attachments i.e. C-51 and C-16.
A density problem was identified on certain radiographs which were available, for example C-1 weld on cask A.
Also the penetrameter, which is a measure of the film quality could not be found some of the films reviewed.
The lack of proper film density, and penetrameters sub-jects the radiographic technique to question. It would be possible that some indications would not be fully evaluated.
It was also noted that in the C-2 weld that there was a density change between early views i.e. 1-2, 2-3, etc. and later views i.e. 6-7, 7-8, etc. which seem to indicate that a change in the shooting parameters may have occurred.
The linear indication observed in one film, appeared to be lack of fusion.
(2) The records of the cask A did note that calibrated gages were used for the hydrostatic test. However, the records of casks B thru E did not, although the QA Manual and the procedures require that calibrated gages be used and their use be documented i.e. record of the serial number.
Photographs of the hydrostatic and thermal test set ups did not add any additional information on this problem. Test results as raw data were documented however there was no evidende that the T.A.P. computer program was used to evaluate the results. The hydrostatic and 1213 156
5 thermal tests are part of the acceptance testing listed
.in the Certificate of Compliance.
(3) Balsa wood is used in the impact limiters. The relation-ships between its crush strength and its density, is documented in the Safety Analysis Report (SAR). The material specification for the balsa wood is specified on the Certificate of Conformance (Certificate) drawing E10080.
(4) Cask A was repaired because the lead shielding apparently contained void areas. This repair was documented on Wavier No. 4 to Nuclear Assurance Corporation and approved by Nuclear Assurance Corporation (N. A.C.). However this repair, the addition of copper plates to the outer shell of the cask, was not reviewed and approved by the U. S. Nuclear Regulatory Commission. The repair resulted in a non-conformance with the cask drawings referenced on the Certificate the Certificate, and the SAR. This non-conformance has been submitted to the U. S. Nuclear Regulatory Commission, for review and comment or approval by N.A.C.
(5) A number of dimensional nonconformances to the Certificate drawings were identified.
For example, the length was documented as being undersize. The nonconformances, however, were subsequently eliminated by relaxing the tolerances on revisions 17 and 18, of drawing E10080.
The revised drawings has been submitted to the U. S.
Nuclear Regulatory Commission for approval by N.A.C.
(6) Nonconformances to the manufacturing drawings are recorded but are not documented as having been properly reviewed by N.A.C. and Excelco.
For example, the flatness of the cask lid flange surface on casks A thru C.
A review will be done to assure that there is no impact of these conditions on the SAR or Certificate.
(7) A number of material subsitutions of a minor nature were noted on casks A thru D.
For example castings were used where forged products were specified.
These are non-conformances to the drawing E10080, Revision 16.
The drawing E10080 is to be revised by N.A.C. and perhaps the SAR.
(8) Records show conflicting approval status of Excelco manu-facturing drawings.
A U.S. Testing Co., Quality Assurance Administrator for N.A.C., memo dated August 1, i213 157 1
6 1974 withheld approval of a series of thirteen (13)
' drawings which were subsequently approved on August 12, 1974, to they same revision status by N.A.C.
The out-standing comments dealt with such things as the deletion of penetrant testing of welds on the impact limiters and the cooling tanks. N.A.C. will review the records in order to establish acceptability of what was manufactured.
(9) All of the Shop Travelers on casks Nos. A thru D, were lost in a fire in October of 1975.
Much of the inform-ation contained on the travelers was transferred to other documents, logs, etc. However, such original information as traceability, operator signoff, etc. has been lost.
(10) The records do not support that the lead pour was in conformance with the approved procedure for casks Nos. B and C.
The lead pour was performed by an outside vendor, and the surveillance reports do not clearly indicate that the work was performed in full compliance with the N. A.C.
approved procedure, 748LP-201.
N.A.C. will search U. S.
Testing reports in order to assure that the lead pour was in compliance.
C.
Exit Interview The inspector met with management representatives (denoted in paragraph A) at the conclusion of the inspection on August 3, 1979. The inspector summarized the scope and findings of the inspection. The management representatives had no comment in response to each item discussed by the inspector.
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