ML20028B861

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QA Program Insp Rept 99900794/82-01 on 821004-05. Noncompliance Noted:Design Control Procedure Not Fully Implemented & review,check,re-evaluation & Verification Process for Rea 2023 Design Not Fully Planned & Structured
ML20028B861
Person / Time
Issue date: 11/08/1982
From: Barnes I, Mcneill W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20028B854 List:
References
REF-QA-99900794 NUDOCS 8212070122
Download: ML20028B861 (7)


Text

t ORGANIZATION:

RIDIHALGH, EGGERS, AND ASSOCIATES COLUMBUS, OHIO REPORT INSPECTION INSPECTION NO.:

99900794/82-01 DATE(S) 10/4-5/82 l ON-SITE HOURS: 24 CORRESPONDENCE ADDRESS:

Ridihalgh, Eggers, and Associates ATTN:

Mr. P. E. Eggers Vice President 2219 Summit Street Columbus, Ohio 43201 ORGANIZATIONAL CONTACT:

Mr. J. Adams, Quality Assurance Manager TELEPHONE NUMBER:

(614) 267-6522 PRINCIPAL PRODUCT: Independent Spent Fuel Storage Cask Design l

NUCLEAR INDUSTRY ACTIVITY: Independent spent fuel storage cask design and other casks for transportation purposes.

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/1/8/82.

ASSIGNED INSPECTOR:

E e/

Wm. M. McNeill, Reactive and Component Date l

Program Section (R& CPS)

OTHER INSPECTOR (S): P. Sakowski, Reactor Systems Section

// /r/g 2.

APPROVED BY:

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I. Barnes Chief, R& CPS Date l

j INSPECTION BASES AND SCOPE:

A.

BASES:

Ridihalgh, Eggers, and Associates Quality Assurance Plan, REA 2023, l

Chapter 11, dated May 6, 1982.

B.

SCOPE:

Design control and procurement document controls.

PLANT SITE APPLICABILITY:

.g yp 0310 Not identified.

,m ggt,u m 0212070122 821116 PDR GA999 EECRIDL 99900794 PDR

ORGANIZATTON.:

RIDIHALGH, EGGERS, AND A5SOCIATES COLUMBUS, OHIO z

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REPORT INSPECTION NO.:

99900794/82-01 RESULTS:

PAGE 2 of 4 i

A.

VIOLATIONS:

l None B.

NONCONFORMANCES:

1.

Contrary to Section V of the Ridihalgh, Eggers, and Associates (RCA)

Topical Report and the design control procedure QAP 06.2, the dasign control procedure was found not to be fully implemented, as evidenced by:

(a) design control checklists had not been used in the design reviews performed to date on the REA 2023 independent spent fuel storage cask design; (b) logs were not fully maintained in that five of the seven weight calculations and the 30-foot drop calculations had not been, entered; and (c) although shielding calculations for the REA 2023 were signed in the logs, the design review, in fact, had not been performed.

2.

Contrary to Section V of the REA Topical Report and Section 03.1 of the REA QA manual, paragraph 3.1, the reviewing, checking, reevaluating, and verifying process for the REA 2023 design did not_aopear 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.

3.

Contrary to Section V of the Topical Report, the Introduction of the Topical Report, and the customer contract design criteria, necessary actions were not taken to provide confidence that the cask meets the shielding design criteria, as evidenced by the identification by the l

NRC inspectors that shielding calculations had failed to take into account a void that would oe present after filling of the neutron I

shield water jacket.

The presence of this void would allow a dose rate greater than the design criteria of 20 MR.

s 4.

Contrary to Section V of the REA Topical Report and Section IV of the l

Topical Peport, the REA procurement documents to its supplier, Brcoks and Perkins, for the REA 2023 cask did not contain or reference i

the appropriate design bases such as the design drawings, or the specifications referenced on the drawings.

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ORGANI?ATION:

PIDIHALGH, EGGERS, AND ASSOCIATES COLUMBUS. OHIO REPORT INSPECTION NO.-

9990Q794/82-01 RESULTS:

PAGE 3 of 4 C.

UJRESOLVED ITEMS:

None D.

OTHER FINDINGS OR COMMENTS:

1.

Design Controls a.

Basic Design - The customer contract wa: reviewed and its five modifications to date.

The 17 design drawings for the REA 2023 cask were reviewed in order to establish the design base.

The design calculations of shielding, 30-foot drop capability, and weight were reviewed indepth.

Weight, dimensional envelope, seismic load, 30-foot drop capability, 20 MR max surface dose rate, and a service life of 50 years are basically the only technical requirements defined by the customer.

It was observed that the customer failed to identify significant parameters such as the burn-up characteristics of the fuel and the spectrum of seismic loads for design purposes.

The following examples of changes from the proposal which had been part of the purchase specification

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were noted:

(1) An increase in overall dimensions of 87.0" to 87.56" in the diameter and 192.37" to 192.62" in the length; (2) a decrease in the lead shield from 4 " to 4%";

(3) one less penetration for temperature measuring devices; and (4) a change in bolting material for the cover from SA-325 to SA-193.

b.

Design Activities - Design controls have been established in procedure QAP 06.2.

A nbeber of failures to fully implement this procedure were identified and this has been documented as nonconformance B.1 above.

The review and approval of drawings were found to follow the established procedure.

A tracing log was maintained and drawings were given " Document Control" numbers and logged in the print distribution log.

Release of drawings for fabrication was d';cumented on a drawing release approval form.

Fabrication has begun, yet the application or Safety Analysis Report has yet to be submitted to the NRC as of this report.

Further, the design review effort was found to be lagging the design effort and has been identified as nonconformance B.2 above.

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ORGANIZATION:.

RIDIHALGH, EGGERS, AND ASSOCIATES COLUMBUS, OHIO REPORT INSPECTION NO.:

99900794/82-01 RESULTS:

PAGE 4 of 4 c.

Unresolved Design Problem - During the design review by the NRC inspectors, it was noted that there was an unresolved shielding design problem which has been identified as nonccmformance B.3, above.

It appears that this prob 1cm resulted from a breakdown in design interfaces and communication.

The cask is designed with a water jacket tank which functions as a neutron shield.

The fill ports have a \\" internal boss which allows filling in a vertical position to its full length less %".

The storage position for these casks is designed to be horizontal, which allows the %" vertical bubble or void to become a horizontal void or bubble along the length of the neutron shield.

It appears that the resulting reduction of the neutron shield thickness from the design valve of 6 inches would then allow a greater than 20 MR dose rate.

REA roughly estimated thg resultant of this shield loss of a %" (vertical) would be a 6 window the length of the tank with a maximum 23 MR dose rate at the thinnest thickness when the cask is horizontal.

It was further noted that to allow for thermal expansion the weight calculations were based on a fill factor of 95% or 90% which would mean approximately a 7 " or 15" vertical void or bubble and even further loss of shielding.

The NRC inspectors also questioned if the effects of environmental temperatures had been accounted for in the shielding design.

In general, it was noted that the REA 2023 l

i design had not been finalized.

Fabrication has begun, yet design aspects such as trunnion design, expansion tanks, over fill tanks, environmental temperature effects, etc., had not been fully l

resolved.

2.

Procurement Document Controls - The purchase order to its subvendor, Brooks and Perkins (B&P), was inspected.

This purchase order identi-fied REA's customer specification; however, it did not identify the design drawings, nor the specifications referenced on the drawing:.

It was acted that the specifications on welding, leak testing, packaging, etc., were only in a draft form.

This has been identified as nonconformance 8.3.

REA has audited B&P and qualified them as a j

supplier.

1

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It was noted by the NRC inspectors that procurement request forms were

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not being used by REA.

This problem has been identified by an internal l

audit dated August 9, 1982.

Corrective action had yet to be established i

and implemented by REA.

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