ML20034A981
| ML20034A981 | |
| Person / Time | |
|---|---|
| Site: | 07100192 |
| Issue date: | 04/24/1990 |
| From: | Cannon V, Temus C PACIFIC NUCLEAR SYSTEMS, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9004250174 | |
| Download: ML20034A981 (4) | |
Text
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United States Nuclear Regulatory Commission April 24,1990 I
Division of Safeguards and Transportation g
Washmgton, D.C. 20555 gyy gg ATTENTION:
Mr. C.E. Mcdonald, Chief Transportation Branch i
SUBJECT:
Pacific Nuclear Systems, Inc. Response to NRC Inspection Report No. 710192/90-04
Dear Mr. Mcdonald:
In response to the subject Inspection Report, the Nuclear Packaging Division of Pacific Nuclear Systems Inc. (PNSI) offers the following response.
We have structured our response in accordance with the instructions contained in your report. Additionally, for the purpose of clarity, we have restated parts A.,
B., and C. of the Notice Of.
Nonconformance from the subject inspection Report.
Part A.
"10 CFR 71.119 requires that special processes be accomplished using-procedures in accordance with applicable codes.
Contrary to the above, Pacific Nuclear Systems, Inc. (NUPAC), had not investigated an unacceptable linear indication on Weld No. 042-W11 on Cask No.118 (Radiograph View 7-8)."
PNSI Response - As noted in the subject NRC Inspection Report, we have taken several actions to enhance our radiographic review capability. These actions were taken as a result of the NRC inspection conducted at the TAF during September,1989. - Subsequent to our implementation of these enhancement actions we have reviewed approximately 2300 radiographs. Also contained in the subject report was the statement that NuPac was applying a conservative approach to radiograph interpretations and that all indications, including acceptable and unacceptable indications, were being recorded on the reader sheets.
We completely concur with your assessment concerning the unacceptable linear indication on Weld No. 042 W11. Even though this indication was proven during your inspection to be insignificant to the weld (either a film artifact or a scratch on the lead intensifying screens),it should have been recorded on the film reader sheet. Based on the number of film reviewed and the fact that upon completion of a re-review by NuPac personnel we could find no other examples of this type'of deficiency, we believe this error is fully attributable to human error and represents an isolated case. We have reinstructed our radiography personnel concerning the importance of recording all indications on the reader sheet. As we previously committed to the NRC, we will ' monitor compliance with this requirement through the performance of regularly scheduled internal audits and periodic informal surveillance activities.
9004250174 900424 PDR ADOCK 07100192 0
1 PDC Pacific Nuclear Systems, Inc. 1010 South 336th Street Federal Way. Washington 98003 (206) 874-2235 Fax (206) 874-2401
Part B.
"10 CFR 71.111 requires that instructions, procedures, and drawings affecting quality be prescribed, and must be followed.
Contrary to the above, NUPAC had not given the [ General Examination) portion of Procedure 0116.4 to a radiography Level IIA inspector before certifying the individual."
PNSI Response - The individual in question (Les Hutsell) was hired after the NRC inspection of September 1989 to enhance the company's radiography expertise. Mr. Hutsell was certified as a level IIA radiographer which qualified him only to read and interpret radiographs provided by others.
Since Mr. Hutsell has approximately 18 years of '
radiographic experience and had previously been certified as a level 11 radiographer, NuPac personnel mistakenly assumed that it was not necessary to administer a general examination.
Mr. Hutsell did receive and achieve a passing score on a specific and practical examination prior to his certification.
NuPac's intent for the certification of level IIA personnel was that the certification is for a more limited level of qualification than a level II and therefore did not require a testing.
program as extensive as for a level II. We recognize that our procedure for NDE personnel certification did not adequately describe this intent. To provide immediate resolution to this deficiency, a general examination in accordance with NuPac procedure OI-16.4'was administered to Mr. Hutsell while the NRC inspection was still in process. Mr. Hutsell achieved a passing score on this examination.
To prevent recurrence of this situation, 0116.4 was revised to explicitly state that for radiographic level IIA certificativ only a practical examination need be administered to
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l demonstrate the persons ability to correctly interpret radiographs. -An informational copy c
of the revised section of 01-16.4 is included as an attachment to this response.
Part C.
"10 CFR 71.107(c) requires that design changes, including field changes, be subjected to design control measures commensurate with those applied to the original design and that changes in conditions specified in. the package I
approval require NRC approval.
Contrary to the above, NUPAC had not subjected wall thickness field changes to design control measures commensurate with those applied to the original j
l design nor was an NRC approval requested for the deviations from. the j
approved package design."
PNSI Response - During fabrication of the TRUPACT II packages, the application of-a standard industry fabrication practices led, in some cases, to-a localized thinning of plate thickness. The fabrication methods used on the production units were identical to those used on the test units. The resultant localized thinning condition was not considered to be a design change or a field change since the NRC approved Safety Analysis Report for 1
TRUPACT 11 did not provide any thickness tolerances for the fabricated plate material.
The localized thinning did exceed the tolerances established by the NuPac fabrication i
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drawings and was considered to be a discrepancy. This condition was duly recorded by the Quality Assurance organization using several Quality Discrepancy Reports (ODR's).
The approved disposition for these ODRs established minimum wall dimensions based on I
an extensive computer analysis using a finite element analysis methodology and comparison to the dimensions of the prototypical test units. This disposition was approved using a Material Review Board as defined by the NuPac Quality Assurance program. The Material Review Board was attended by representatives from the NuPac Engineering, Licensing, Analysis and Quality Assurance organizations. During a meeting with the NRC in late -
February, this approach was disallowed.
Subsequent to receiving the NRC's ruling, NuPac has resolved to affect either or both of the following corrective actions:
1.
Repair the units to achieve the minimum wall tolerances contained in the i
plate material rolling specification.
2.
Establish and obtain NRC approval on new minimum wall dimensions based -
on existing and/or additional package testing data.
NuPac will make no attempt to release any TRUPACT 11 units for use under NRC-l Certificate of Compliance number 9218 until this issue is fully resolved to the satisfaction l
l of the NRC.
l We believe that the cause of this perceived discrepancy stems from inadequate quantification of the TRUPACT 11 requirements in the-licensing documentation. To prevent recurrence of this type of problem, we commit to continuing our efforts to clarify l
the licensing documentation..We recognize that the evaluation of this committal requires j
subjective criteria by the NRC but believe that this action represents the best approach by our corporation to avoid these interpretative differences in the future.
Should you desire to further discuss any information in this letter, please feel free to contact 4
l either of the undersigned.
Sincerely, QA Concurrence, 5
]
^
Chuck J. Temus Vallie K. Cannon l
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e.
ATTACHMENT 1
QI 16.4, REV. 1 PAGE 5 0F.9 i
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8,2.2 The Soecific portion covers the equipment, procedures, specifications,. codes, techniques, 'and Nuclear Packaging-i acceptance criteria necessary for the specific examination method and consists of tne. following minimum number of questions.
Access to NDE procedures is permitted _in some cases, when approved by the examiner.
Method Number of Quantiona laval I laval II Radiography 20 20-Magnetic Particle 20-15 --
Ultrasonics 20
~20 Liquid Penetrant 20-15 Leak Testing 15 15 1
8.2.3 The Practical portion demonstrates proficiency in operation of the test equipment and in using and implementing ' the applicable NDE procedures provided (the Level II practical examination shall include selection of the NDE procedure).
At least ten (10) difference check points requiring an understanding of the test variables and Nuclear Packaging's procedural requirements shall be included in this practical.
examination.
Level II examinations shall also include an evaluation of the results of the examination. The description
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of the specimen, the ' test procedure (including check points) i-and the results of the examination shall be recorded in the l
applicant's flies by the examiner.
I Examination requirements for a Level IIA NDE Radiographer need l
only consist of a practical examination where the candidate successfully demonstrates the ability to interpret the results of an NDE examination (i.e. interpretation of radiographs).
8.3 Level III Technical Framination 8.3.1 Basic Examination (required only once when more than one method of examination is taken).
l 8.3.1.1 Twenty (20) questions-relating-. to
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understanding the ASNT SNT TC-1A document.
l 8.3.1.2 Fifteen (15) questions relative to applicable materials, fabrication, and product technology.
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