ML20034H020
| ML20034H020 | |
| Person / Time | |
|---|---|
| Site: | 07100760 |
| Issue date: | 03/10/1993 |
| From: | Bryce J, Jankovich J, Matula T IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20034H019 | List: |
| References | |
| 71-0760-93-03, 71-760-93-3, NUDOCS 9303150084 | |
| Download: ML20034H020 (13) | |
Text
_-
9 4.
i t
I I
-i CONTAINER SUPPLIER INSPECTION PROGRAM i
Inspection Report ORGANIZATION:
Department of Energy ADDRESS:
Waste Isolation Pilot Plant Carlsbad, New Mexico CONTACT:
Mr. Alton D. Harris, III TITLE:
Transportation and Emergency
]
Preparedness Manager WIPP Project Division Office of Waste Management Environmental Restoration i
and Waste Management U.S. Department of Energy Germantown, MD TELEPHONE:
(301)903-8466 ACTIVITY:
Design,-fabrication, use, and maintenance of Model No. TRUPACT-II packaging.
INSPECTION REPORT NO.:
710760/93-03 i
Inspection Location:
Inspection Dates:
Inspection Onsite Carlsbad, New Mexico January 12-14, 1993 Person-Hours:
96 INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 71 and Certificate of Compliance No. 9218.
B.
SCOPE: To determine whether procedures have been established, documented, and executed, at the Department of Energy's Waste Isolation Pilot Plant, that meet the quality assurance requirements of 10 CFR Part 71, and determine e
whether packagings were fabricated and maintained in-accordance with the design approved by the Commission.
I f
930315CK)B-4'930310
[M ADOCK 07100,600 g
g
4 i
CONTAINER SUPPLIER INSPECTION PROGRAM INSPECTION REPORT NO.: 710760/93-03 FINDINGS:
Procedures have been established, documented, and executed, at the Department of Energy's Waste Isolation Pilot Plant, that meet the quality assurance requirements of 10 CFR Part 71.
INSPECTION TEAM LEADER:
wmON/
b DATE: 3[P/93
~;
o Thomas 0. Ma 6 a NM S/ W B O
INSPECTOR:
DATE-gjhnP.Jankdjich m4SS/IMTB 3
INSPECTOR: /
sO Eb DATE:
2[P/93 aus H. BryctP INSPECTOR:
w+1 O )t d
DATE:
MD/93 Boyd W. Brown
INEL 44 DATE:
230/91 REPORT APPROVED BY:
/
Charles E! MacDonald Chief, Iransportation Branch, HMSS i
1
Inspection Report 3
Docket No. 71-0760 I
1.
SUMMARY
A U.S. Nuclear Regulatory Commission inspection team conducted an announced
[
inspection of the Department of Energy's (DOE) Waste Isolation Pilot Plan' (WIPP) in Carlsbad, New Mexico, on January 10-14, 1993.
f The DOE has the overall responsibility for the implementation and operation of i
the WIPP Project. The DOE is supported by Westinghouse Electric Corporation which has the authority and responsibility to implement a program, delegated by DOE, to procure, maintain, ' inspect, repair, and if necessary, modify Model No. TRUPACT-II packaging. However, overall responsibility for quality assurance remains that of the D0E.
Pursuant to the Waste Isolation Pilot Plant Land Withdrawal Act, no transuranic waste may be transported to or from WIPP, except in packages ~that' have been determined by the NRC to satisfy its quality assurance requirements.
This inspection was conducted to determine whether procedures have been established, documented, and executed at WIPP that meet the quality assurance requirements of 10 CFR Part 71, " Packaging and Transportation of Radioactive Material."
The inspection team reviewed quality assurance'(QA) activities to determine whether QA procedures have been established, documented, and executed in
_.t accordance with the requirements of 10 CFR Part 71.
Inspection results are based on data collected through inspection of Model No. TRUPACT-II packagings, review of procedures and controls, inspection of selected documents and records, and interviews with personnel.
The inspection team concluded that quality assurance has been satisfactorily implemented and the quality assurance requirements of 10 CFR Part 71 have been met.
b e
Inspection Report 4
Docket No. 71-0760 L
2.
DETAILS The Nuclear Regula.ory Commission conducted an announced inspection of DOE WIPP in Carlsbad, Naw Mexico, on January 12-14, 1993. The objectives of the NRC inspection were to verify that the QA functions were accomplished in compliance with regulatory requirements and to verify that the Model No. TRUPACT-II packagings were fabricated and maintained in accordance with Certificate of Compliance (C0C) requirements. The DOE is supported by Westinghouse Electric Corporation to procure, maintain, inspect, r epair, and if necessary, modify Model No. TRUPACT-II packaging.
Consequently, the inspection team reviewed Westinghouse's implementation of QA requirements.
For the implementation Westinghouse developed the document, " Waste Isolation Division Quality Assurance Plan for the Procurement, Use, Maintenance ana Repair of TRUPACT-II," which was also utilized by the inspection team to l
assess the implementation of the QA program. The inspection team focused on management, fabrication, repair, and maintenance activities concerning Model No. TRUPACT-II packagings.
2.1 Persons Contacted An entrance meeting was held on January '2,1993, to present the objectives of I
the NRC inspection.
An exit meeting was held on January 14, 1993, to present the preliminary findings of the inspection. The individuals present at the entrance and exit meetings are listed in Table 1.
2.2 Management Controls The review of management controls focused primarily on the extent to which Westinghouse has implemented quality assurance and the independence and proficiency of QA personnel responsible for fulfilling QA commitmer The inspection team reviewed management controls covering the QA program, personnel, documentation, and the audit program. The inspection team interviewed personnel, reviewed procedures and instructions, and inspected records.
Procedures were reviewed to ensure that effective QA has been implemented and is being practiced. The inspection team verified that the QA organizatien responsibilities and authority were defined and that the QA organization was established as an independent unit. Personnel qualification and training programs were reviewed to ensure that requirements were identified and met.
The inspection team reviewed the implementation of QA for the Model No.
TRUPACT-II packagings in the areas of reporting and docucenting nonconformances. Specifically, for the years of 1991 and 1992, Nonconformance Reports, the Nonconformance Report Log, the Hold Tag Control Log, and the Corrective Action Status and Trending system were reviewed. The Corrective Action Status and Trending system includes Corrective Action Requests, Audit Finding Reports, Nonconformance Reports, and Quality Deficiency Reports. The.
l relevant procedures, which specify how these reporting systems are implemented, were also reviewed.
i 9
a
i i
Inspection Report 5
Docket No. 71-0760 j
i Table 1 Entrance / Exit Meeting Attendees I
t J. Atchenson Principal Engineer, TRU Waste Technical
[
Programs, Waste Isolation Division Westinghouse Electric Corporation (WID)
J. Bulman Associate Staff Member, BDM Federal, Inc.
V. Cannon Manager, Quality Assurance Engineering, WID W. Caplinger Manager Quality Assurance, WID K. Donovan Manager, TRU Systems Integration, WID D. Gray Environmental Specialist, Environmental Evaluation Group, State of New Mexico A. Harris Transportation and Emergency Preparedness Manager, WIPP Project Division, DOE C. Kelley Manager, Waste Handling, WID T. Lewis Senior Engineer, Regulatory Assurance, WID C. Morissette Manager, Packaging and Transportation, WID D. Roberts Senior Engineer, Packaging and Transportation, WID i
R. Spooner Transportation Manager, Wipp Project Site Office (WPS0), DOE P. Weddle Manager, Project Management and Regulatory Assurance, WID M. Bennington Quality Assurance Specialist, Quality and Regulatory Assurance, WPS0, DOE
.l J. Colties Environmental Engineer Specialist, New Mexico Environmental Department J. Channell Environmental Engineer, Envirowsental Evaluation Group, State of New Mexico P. Sanchez Geologist, New Mexico Environmental Department.
(continued)
4
,z.
l Inspection Report 6
Docket No. 71-0760 l
Table I Entrance / Exit Meeting Attendees (Continued) i I
i T. Ward Senior Engineer, Packaging and Transportation, WlD j
i M. Bock Secretary, Packaging and Transportation, WID C. Conway Manager, Engineering, WID T. Dittsworth Team Leader, Procurement Oversight and Quality, WID J. Firkins Special Projects Coordinator, Energy, Minerals and Natural Resources Department, State of New Mexico P. Gregory Principal Engineer, Packaging and Transportation. WID R. Lark Program Manager, Quality Assurance Section, WPSO, P')E C. MacDonald Chief, Transportation Branch, Division of Industrial and Medical Nuclear Safety, NMSS, NRC T. Madden Senior Congressional Liaison Officer,' Office of Congressional Affairs, NRC i
I R. Neill Director, Environmental Evaluation Group, State of New Mexico J. Waddilove NDE Level III, X-Ray, Inc.
C. Wentz Co-coordinator Senior Policy Analyst, i
Radiological Waste Task force, State of New Mexico W. Arthur Project Director, WIPP Project Integration i
Office, DOE Present at. entrance and exit meetings.
Present at entrance meeting.
Present at exit meeting.
f**
i
- ' Exit meeting via speaker phone.
,n Inspection Report 7
Docket No. 71-0760 Docum?ntation controls were reviewed to ensure the ability to control documentation within the QA program. Documentation controls regarding procurement, fabrication, hold points, procedure development, and records storage were reviewed.
The inspection team reviewed the QA audit program to ensure that audit procedures were documented, approved, and implemented; audit schedules were documented and met; audits were performed covering all aspects of the QA program both internally and for suppliers; audit results were documented and reviewed by management; all discrepancies were corrected; and corrective actions were taken, when appropriate.
All elements of management controls were found to be acceptable.
- However, supplier audit records were not available for the inspection team's review.
The inspection team was informed that all supplier audit records were held by Pacific Nuclear systems, Inc., and were not readily available. After the inspection, on January 27, 1993, the NRC was informed that the supplier audit records were available at Westinghouse.
The inspection team informed Westinghouse that the supplier audit records will be subject to review during the next NRC inspection.
2.3 Fabrication Controls The inspection team reviewed the implementation of control measures regarding the Model No. TRUPACT-II fabrication processes, test and inspection, and tools and equipment.
At the time of the inspection, fabrication 'and final acceptance of packagings (Unit Nos.125 through 139) were completed.
No new packagings were being fabricated. The inspection team focused on the examination of fabrication records, including indeoendent review of radiographs for welds.
2.3.1 Fabrication Records Fabrication records are compiled into " data packages"; one for each unit. The inspection team selected Unit Nos. 125, 126, 130, 134, and 138 for review.
The inspection team reviewed the fabrication travellers for these units.
Areas that were extensively reviewed include witness and hold points, the drawing retrieval system, nonconformance control test reports (leak tests, pressu e tests, load tests), and certified material _ test reports.
The inspection team found the QA records to be complete and no nonconformances were identified.
2.3.2 Nondestructive Testing Model No. TRUPACT-II packagings were inspected by the inspection team for adequate wall thickners and containment weld integrity.
This was accomplished by sample-based ultrasonic thickness measurements and weld radiograph review.
Thickness measurements were taken using a Krauthkramer Branson DME-DL Ultrasonic Thickness Gauge. Measurements were generally taken at areas that had evidence of repairs or surface conditioning.
. e-Inspection Repcrt 8
Docket No. 71-0760 a
Unit No.131 was measured on the inside containment vessel (ICV)' body and lid, as well as the outside containment vessel (OCV) assembly (OCA) body and lid.
Over 100 ultrasonic thickness measurements were taken on various areas of this unit. The minimum material thickness, as measured by the inspection team, is shown in Table 2.
Table 2 Minimum Material Th;ckness Model No. TRUPACT-II, Unit No. 131 Nominal Minimum
- Minimum Wall fin.) Allowed (in.) Measured (in.)
ICV Body Bottom Knuckle Area -
0.250 0.240 0.272 ICV Body Bottom Weld Area 0.250 0.240 0.270 ICV Body Vertical Seam Area 0.250 0.240 0.274 ICV Lid Knuckle Area 0.250 0.240 0.272 OCA Lid Knuckle Area 0.250 0.240 0.270 OCA Lid Circ. Weld Area 0.375 0.365 0.407 OCA Body 0.250 0.240 0.270 OCA Body 0.375 0.365 0.400 0CV Bottom Circ. Weld Area 0.188 0.178 0.181 Refer to Pacific Nuclear Drawing 2077-500SNP.
Ultrasonic thickness measurements were also taken on OCA bodies and lids of Unit Nos. 127, 129, 130, 132, and 133.
In addition, cord welds on the-lid of Unit Nos. 127 and 129 were taken.
Ultrasonic measurements were generally taken in areas where there was evidence of repairs or surface conditioning.
Approximately 100 thickness measurements were taken on these five units. The minimum material thickness for all five units, as measured by the inspection team, is shown in Table 3.
Table 3 Minimum Wall thickness Model No. TRUPACT-II, Unit Nos. 127,129,130,132, and 133 Nominal Minimum
- Minimum Wall (in.) Allowed (in.) Measured (in.)
OCA Bodies 1/4 in. Matl.
0.250 0.240 0.276 0CA Eadies 3/8 in. Matl.
0.375 0.365 0.398 OCA Lid Knuckle Area 0.250 0.240 0.273 No. 127 Cho m ";.d Area 0.250 0.240 0.262 No. 129 Choid Weld Area 0.250 0.240 0.257 Refer to Pacific Nuclear Drawing 2077-500SNP.
i
a ~~ ~.
Inspection Report 9
Docket No. 71-0760 All ultrasonic thickness measurements taken by the inspection team were within the minimum material thickness.
2.3.3 Radiograph Review Radiographs of Model No. TRUPACT-II packagings were stored in a secured area, with a specific file cabinet drawer containing only the radiographs for the specified unit. A radiograph inventory was performed on Unit Nos. 125 through 139.
Radiographs were on file for all 26 welds requiring radiography for each of the units.
During a previous NRC inspection, conducted on August 21-22, 1990, selected radiographs for Unit Nos.125 and 127 were reviewed and found acceptable.
Therefore, the inspection team excluded these two units from the sampling of radiographs reviewed during this inspection.
Unit No. 135 was selected for a random review of radiographs.
Radiograph Reader Sheets were reviewed and eight radiographs were selected for welds showing evidence of indications or repairs.
Unit No. 137 was randomly selected for a comprehensive' review of the j
radiographs on all 26 welds. This review included the additional radiographs that were required because of reported artifacts or unacceptable radiograph techniques.
Random radiographs on Unit No. 138 were selected for review because this unit was reported to have been fabricated last.
Examination reports or radiographs were reviewed for 21 of the 26 welds on this unit.
Over 500 radiographs were reviewed by the inspection team during the inspection.
It was noted that all radiographs reviewed were free from fingerprints, scratches, and other handling artifacts. All indications, both Code acceptable and Code unacceptable, were recorded on the Radiograph Reader Sheets and dispositioned properly.
2.3.4 Personnel Qualifications All Radiograph Reader Sheets reviewed by the inspection team were signed by one of two Radiography Level IIA inspectors. Nondestructive examination certifications were also reviewed for six other-individuals who where reported to have performed examinations on the Model No. TRUPACT-II packagings. These certifications included leak testing, ultrasonic digital thickness measurements, liquid penetrant examinations, and magnetic particle examinations. The certification records for these individuals, including visual acuity examination results, were found to be in order.
Welding procedures identified as being applicable to the Model No. TRUPACT-Il packagings are Nos. W0003NP, W0004NP, W0005NP, and W0007NP. Welding operator qualification records were-reviewed for the personnel listed in Table 4 and were found to be in order.
r l
Inspection Report 10 Docket No. 71-0760 l
qualification records were reviewed for the personnel listed in Table 4 and were found to be in order.
Table 4 Welding Operator Qualifications Model No. TRUPACT-II Welding Operator Approved for Procedure (s)
Operator ID W0003NP W0004NP W0005NP WOOO7NP BG W3 X
X X
X JN W5 X
X X
X JS*
W7 X
X X
X JW*
W8 X
X X
X EE W9 X
CL*
W10 X
X X
X GS*
Wll X
X These operators were identified in the reviewed work packages ys having made welds on the Model No. TRUPACT-Il shipping containers.
lne certifications were current for all of the welding performed by these welders.
2.4 Maintenance Controls The inspection team reviewed the implementation of the QA Program in the performance of Model No. TRUPACT-II packaging maintenance.
Maintenance documents were inspected for completeness and adequacy of scheduled maintenance, actual maintenance performed, and maintenance program controls.
Compliance with packaging maintenar e, testing, and inspection requirements was verified. Documents were revieiad for completeness, adequacy, and appropriate approvals. The inspection team focused on five specific areas of maintenance controls; requirements identification, procedures, personnel, materials, and tools and equipment.
The inspection team verified that the Safety Analysis Report packaging maintenance requirements were identified in the Model No. TRUPACT-ll Maintenance Program Plan. This plan documented detailed procedures for packaging maintenance, component repair and replacement, required documentation, and the procedures to be followed to maintain the integrity of the packagings.
Procedures to conduct all required maintenance activities were approved, controlled, and in place.
The inspection team reviewed the system used to develop, validate, and distribute procedures necessary for operation and maintenance of the packagings.
Procedures for documentation and change control were found to be adequate. Controlled documents are supplied to all user activities.
A
Inspection Report 11 Docket No. 71-0760 Maintenance records were reviewed by the inspection team. To date, two Model No. TRUPACT-Il packagings have been used. All required maintenance was completed on these packagings. A system to track scheduled and completed maintenance was in place.
1 Personnel training and qualification procedures were reviewed by the inspection team. Qualification expiration dates are tracked, and supervisors are informed of requalification due dates. Knowledge and performance factors are documented on personnel qualification cards. Overall, personnel training and qualification programs were well-documented and maintained.
i The inspection team reviewed material procurement procedures and-storage of material. Both systems ensure that the correct material is available for maintenance. Material traceability was integrated into the maintenance procedures. Centrolled material for packaging maintenance was stored separately in limited access areas in both the warehouse and the maintenance areas'. Material control used to support the maintenance activities was. found to be adequate.
Control of maintenance tools and equipment was reviewed by the inspection team.
Calibrated tools and equipment used to support the maintenance and operations of the packagings were available and controlled.
Calibrated equipment was adequately controlled under a calibration recall system.
Other calibrated equipment used in maintenance and operations systems was controlled through the preventive maintenance program.
f No nonconformances were identified.
1 i
E
a Inspection Report 12 Docket No. 71-0760
- 3. DOCUMENTS REVIEWED 3.1 Procedutes, Specifications, and Drawings-13-004, Auditor Training and Lead Auditor Certification, Revision No. 2, dated 06/28/91.
A-10, Waste Handler Operations Qualific tion Card, Revision No. 2, dated j
05/22/92.
- }
A-27, Waste Handling Maintenance Procedure Qualification Card, Revisio.1 i
No. O, dated 10/15/92.
DOE /WIPP 88-026, TRUPACT-II Container Maintenance Program Plan, Revision No. 2, dated May 1991.
Drawing Nos.
2077-051, Revision A.
2077-163, Revision E.
t 2077-170, Revision D.
2077-054, Revision F.
2077-174, Revision F.
2077-041, Revision A.
MC 2.6.6, Publications and Procedures, Revision No. 1, dated 07/30/92, MC 5.4.1, Technical Training, Revision No. O, dated 03/12/92.
MC 6.9.5, Instrumentation and Calibration, Revision No. O, dated 07/30/92.
NUPAC TRUPACT-II SAR, Revision No. 3, dated July 1989.
OM-0134, Operations and Maintenance Manual for TRUPACT-II Packages.
Revision No. 5, dated 10/22/90.
Q 1-7, Discrepancy Reporting, Revision No. O, dated 01/17/89.
QAI 15-1, Quality Assurance Trend Analysis, Revision No.1, dated 11/11/91.
QPNP 15-1, Control of Nonconformances, Revision No. O, dated 05/10/91.
WEC/TRUPACT-87/0020, Specification for Type B Transuranic Waste l
Transportation, Revision No. 2, dated 07/16/87.
1 WP 04-306, Validation and Verification of WIPP Operating Procedures, Revision No. 2, dated 11/09/90.
WP 05-013, RH Tru Waste Receipt, Revision No. O, dated 03/11/88.
i
~ a Inspection Report 13 Docket No. 71-0760 WP 05-1, Waste Handling Operations Manual, Revision No. O, dated 06/03/87.
WP 05-TM3001, TRUPACT-II Maintenance Program, Revision No. O, dated 08/25/92.
WP 05-WH1015, WIPP Waste Handling Operations Normal Operating Procedures l
Manual, Revision No. O, dated 05/09/91.
I WP 10-301, Maintenance Instruction Validation, Revision No. O, dated 05/13/91.
WP 10-302, Maintenance Instruction Change Request, Revision No. O, dated 02/07/92.
WP 10-303, Maintenance Instruction LC0/OSR Impact Review, Revision No.
O, dated 03/18/92.
WP 13-003, Nonconformance Item Control, Revision No. 4, dated 10/10/91.
WP 13-007, Hold Tag Issuance, Revision No. 1, dated 06/13/88.
]
WP 14-TR3307, Qualification Programs, Revision No. O, dated 05/05/92.
WP 14-TR3401, WIPP Training Records, Revision No. O, dated 05/05/92.
WP 15-10, Transport Pat.kaging Fleet Management Plan for the Westinghouse Waste Isolation Division, Revision No. O, dated 07/16/91.
3.2 Logs, Files, and Reports Hold Tag Control Log. 1991, 1992.
Nonconformance Report Log, 1991, 1992.
Nonconformance Report Nos.91-025, 91-045.
Nonconformance Reports:
Unit No. 130: Nos. 1624, 1662 1666, 1667, 1673, 1676.
Unit No. 125: Nos. 1297, 1335, 1507, 1527, 1550, 1583, 1584, 1585, 1615, 1733.
Unit No. 138: Nos. 1713, 1724, 1738, 1771, 1773.
QA Stamp Log, HUPAC.
TRUPACT-II QA Data Packages, Unit Nos. 125, 126, 130, 134, 138.
L__.____
___._____.___________1___________________