ML20028B855
| ML20028B855 | |
| Person / Time | |
|---|---|
| Issue date: | 11/16/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20028B854 | List: |
| References | |
| REF-QA-99900794 NUDOCS 8212070117 | |
| Download: ML20028B855 (2) | |
Text
APPENDIX A Ridihalgh, Eggers, and Associates Docket No. 99900794/82-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection on October 4-5, 1982, it appears that certain of your activities were not conducted in accordance with NRC l
requirements as indicated below:
Section V of Chapter 11 of the Ridihalgh, Eggers, and Associates (REA)
Topical Report states in part:
" Instructions and procedures for activities affecting quality in the design and fabrication of the REA 2023 Dry Storage Car.k have been, in large part, documented in the REA Quality Assurance Manual... and in this Quality Assurance Plan... All activities affecting the quality of structures, systems, and components shall be accomplished in accordance l
with these written, controlled instructions, procedures, or drawings as l
appropriate to accomplish the desired purpose. These documents shall include necessary quality standards so that the satisfactory accomplishment of quality related activities and services may be determined.
Nonconformances with these requirements are as follows:
A.
Quality Assurance Procedure (QAP) 06.2, " Control of Design," requires that a design control checklist be used in reviewing design activities and that applicable logs be maintained of calculations.
Completion of design reviews is to be indicated by the signing of the applicable logs.
Contrary to the above, the design control procedure was found to be not fully implemented, as evidenced by:
(1) Design control checklists had not been used in the design reviews performed to date on the REA 2023 independent spent fuel storage cask design; (2) Logs were not fully maintained in that five of the seven weight calculations and the 30-foot drop calculations had not been entered; and (3) Although shielding calculations for the REA 2023 were signed in f
the logs, the design review, in fact, had not been performed.
8212070117 821116 PDR GA999 EECRIDL 99900794 PDR L
Ridihalgh, Eogars, and Associates B.
Section 03.1 of the REA QA manual, paragraph 3.1 states in part, "It is the policy of REA that design shall be accomplished within the framework of a system of design control.
This system shall be structured to provide assurance of design adequacy through the planned, controlled, and documented application of reviewing, checking, reevaluating, or verifying process... "
Contrary to the above, the reviewing, checking, rernaluating, and verifying process for the REA 2023 design did not appear to be fully structured and planned, as evidenced by fabrication having been permitted to start on the REA cask without verification of the adequacy of the last 12 structural calculations which dated back as far as February 25, 1982.
C.
The " Introduction" of the REA Topical Report states in part, "The REA QA Plan and support documents identify systematic actions necessary to provide confidence that components of the REA 2023 Dry Storage Casks meet the design criteria...." Further, the customer contract, DE-AC09-82SR10965, requires in its design criteria that the external dose rate shall not exceed 20 MR per hour at the surface of the cask.
Contrary to the above, necessary actions were not taken to provide confidence that the cask meets the shielding design criteria, as evidenced by the identification by the NRC inspectors that shielding calculations had failed to take into account a void that would be present after filling of the neutron shield water jacket.
The presence of this void would allow a dose rate greater than the design criteria of 20 MR.
D.
Section IV of the REA Topical Report states in part, " Suppliers...
will receive controlled procurer 0ent documents which contain or reference... appropriate design bases...."
Contrary to the above, the REA procurement documents to its supplier, Brooks and Perkins, for the REA 2023 cask did not contain or reference the appropriate design bases such as the design drawings, or the specifications referenced on the drawings.
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