ML20141J260
| ML20141J260 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/1997 |
| From: | Shankman S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Amer A AFFILIATION NOT ASSIGNED |
| References | |
| REF-QA-99901292 99901292-97-01, 99901292-97-1, NUDOCS 9705280019 | |
| Download: ML20141J260 (2) | |
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1 UNITED STATES s
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enana mani May 21, 1997 Mr. Ahmad E. Amer, President Amer Industrial Technologies, Inc.
1000 South Madison Street Wilmington, DE 19801
SUBJECT:
NRC INSPECTION AT AMER INDUSTRIAL TECHNOLOGIES, INC.
j REGARDING FABRICATION OF MODEL 30B URANIUM HEXAFLUORIDE CYLINDERS
Dear Mr. Amer:
Between April 9-11,1997, the U.S. Nuclear Regulatory Commission performed a joint inspection with the U.S. Department of Transportation at your facility to verify that fabrication and testing activities, regarding Model 30B uranium hexafluoride cylinders, were performed in accordance with American National Standards Institute (ANSI) Standard N14.1," Uranium Hexafluoride -- Packaging for Transport," 1990 edition, Section Vill, Division I, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, and 10 CFR Part 71.
During the inspection, the team identified nonconformances regarding failures to perform work in accordance with ANSI Standard N14.1 and the quality assyrance program required by the standard. Please find the specific findings and references to the applicable requirements in the enclosed inspection report (Enclosure 1). We also sent the inspection report to DOT for their review and follow up. Based on the inspection findings, NRC issued, in coordination with DOT, Information Notice 97-20 (Enclosure 2) informing NRC licensees that the cylinders are not authorized for transport.
We acknowledge receipt of your letters dated April 15 and May 7,1997. In your April 15,1997, letter, you stated that you are (1) requalifying the welding procedure (No. WS-956), documented on the route sheets as used in the fabrication of the cylinders, and performing impact testing at
-50 *F, and (2) reviewing other issues identified by the team during the inspection and have started training and documenting solutions to prevent recurrence of the issues. In your May 7, 1997, letter, you provided impact test data indicating that Welding Procedure No. WS-956 was
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requalified at the correct temperature. Please note that NRC staff is continuing its review of the l
applicable requirements in the ANSI Standard N14.1 and the ASME Code.
t Should you have any questions about this inspnction, we will be pleased to discuss them with you.
Sincerely, i
i usan rant Shankman, hief Transportation Safety and Inspection Branch Spent Fuel Project Office, NMSS Docket No.:
99901292
Enclosures:
2.
NRC Information Notice 97-20 j
1.
NRC Inspection Report No. 99901292/97-01 cc:
Mr. Richard W. Boyle i
Chief, Radioactive Materials Branch Research and Special Programs Administration U.S. Department of Transportation 400 Seventh Street S.W.
DHM 23 Washington, DC 20590-0001
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Reviewed by:
R. Sanders G. Bennington
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4/24/97 4/24/97 l
4 Distribution:
NRC f/c SFPO r/f PUBLIC NMSS r/f JLieberman, OE WReamer, OGC GJackson, OC WKane CHaughney ELeeds SO'Connor PNarbut JSpets FSturz RChappell EEaston MRaddatz KBurke, OlP WBrach, FCSS RO'Connell, IMOB FCostello, RI BLetts, RI MAnderson, RI GCaputo, Of GRoberts, INEL GMcGinnis, DOT GCwalina, NRR WSchwink, FCEB
- See previous concurrence 1
I-OFC SFPO E
01RGNI E
SFPO E
SFPQh p _E SShh m n NAME TMatula/ tom
- MAnderson*
JJankovich*
DATE 5/1/97 5/15/97 5/15/97 6 M /97 C = COVER E = COVER & ENCLOSURE N = NO COPY 1
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INSPECTION REPORT Spent Fuel Project Omce Office of Nuclear Material Safety and Safeguards
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Docket No:
99901292 i
l Report No:
99901292/97-01 l
Organization:
Amer Industrial Technologies, Inc.
Facility Location:
1000 South Madison Street Wilmington, DE 19801 I
Dates:
April 9-11,1997 i
i inspectors:
Thomas Matula, NRC, Team Leader 1
Gary Roberts, INEEL, inspector i
I Observers:
Keith Logan, NRC, Region l Mark Anderson, NRC, Region l l
Gary McGinnis, Department of Transportation i
Approved by:
Susan Frant Shankman, Chief i
Transportation Safety and Inspection Branch Spent Fuel Project Offic NMSS j
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1 ENCLOSURE 1
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l EXECUTIVE
SUMMARY
l Amer Industrial Technologies, Inc.
U.S. Nuclear Regulatory Commission inspection Report No. 99901292/97-01 The team performed an inspection at Amer Industrial Technologies, Inc. (Amer), regarding the fabrication of Model 30B uranium hexafluoride cylinders (cylinders). Amer fabricated 130 cylinders for Korea Nuclear Fuel Company, Ltd. (KNFC), in 1995 and 1996. Amer shipped 33 completed cylinders to the United States Enrichment Corporation at the Portsmouth Gaseous Diffusion Plant in Piketon, Ohio, and the remaining cylinders to intemational locations.
The cylinders were transported in Model Nos. GE-21PF-1, UX-30, and NCl-21PF-1 overpacks as described in NRC Certificate of Compliance (COC) Nos. 4909,9196, and 9234. The COCs required that the cylinders be fabricated in accordance with American National Standards institute (ANSI) Standard N14.1, " Uranium Hexafluoride - Packaging for Transport," 1990 edition, and Section Vllt, Division I, of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code, and be ASME Code stamped. ANSI Standard N14.1 i
requires that fabrication, inspection, and testing activities be conducted in accordance with a quality assurance (QA) program that conforms to the requirements of 10 CFR Part 71, Subpart H. Amer supplied certifications to KNFC, as required by ANSI Standard N14.1 and KNFC's Purchase Order (PO) Specification No. PS-43-3, stating that the cylinders were fabricated in accordance with the requirements of ANSI Standard N14.1 and the ASME Code.
Paragraph No. 4, " Quality Assurance," of ANSI Standard N14.1 states that fabrication, inspection, and testing activities may be satisfied by obtaining certifications from cylinder i
fabricators stating that their activities were conducted in accordance with a QA program that conforms to the requirements of 10 CFR Part 71, Subpart H. Amer supplied certifications to KNFC regarding the fabrication and testing of the cylinders in accordance with the requirements of ANSI Standard N14.1. The certifications state that the cylinders were fumished by Amer under PO Nos. 95-2-019 and PC-41-259 in accordance with Amers QA program, the requirements of PO Specification No. PS-43-30 (Revision 1 or Revision 2), and ASME Boiler and Pressure Vessel Code Section Vill, Division 1,1992 Edition,1994 Addenda.
The team identified concoms about Amers cylinder test and fabrication controls and the QA program.
Test Cont _rol: Amers testing of the cylinders was unacceptable. The team determined that Amer performed impact testing to qualify its fabrication welding procedures (WPs) at
+10 *F instead of at -50 *F, as required by American Society for Testing and Materials (ASTM) A20, " Standard Specification for General Requirements for Steel Plates for Pressure Vessels." Amer used the unqualified WPs to perform all of the welding operations on the 130 cylinders fabricated for KNFC, as documented in its fabrication route sheets. Amer also did not receive KNFC's approval of the WPs as is required by ANSI Standard N14.1 and KNFC's PO Specification No. PS-43-30. Furthermore, Amer did not present documentation showing that the cylinder air tests, required by ANSI Standard N14.1, were performed, even though Amer management stated that all of the air tests were performed. These findings were significant because Amers records show that the cylinders were not welded using a qualified WP, and not all the required testing was performed; these shortcomings can affect the performance and safety of the cylinders.
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' Fabrication Control: Amers control of the fabrication process for the cylinders was j
unacceptable. The team determined that there is a general lack of documentation showing that the cylinders were fabricated, inspected, and tested in accordance with
' ANSI Standard N14.1 and the ASME Code. Amers fabrication route sheets did not record the inspection procedures, acceptance criteria, or air test procedure for the j
cylindars; Amer developed and used an incomplete procedure to perform hydrostatic testing of the cylinders; and Amer did not record all of the material identification information required for traceability.
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Qualiti Assurance: Amers QA prcgram used for the fabrication and test of the cylinders i
was ur acceptable. The team determined that Amers Quality Control (QC) Manual, Revision 6 (July 7,1994) did not cover every essential criteria specified in 10 CFR Part 71, Subpart H; Amers QC Manual did not contain, or make reference to, implementing i.
procedures; Amers QA staff did not sign off on many of the inspection points on the route sheets; and many of the ASME Code-required Authorized Inspectors (Al's) hold points were not completed on the route sheets. These findings were significant because there is a lack of documentation showing that the cylinders were fabricated, inspected, and tested in accordance with ANSI Standard N14.1 and the ASME Code.
The team found nine instances of nonconformance conceming the requirements of 10 CFR i
Part 71. These nonconformances are summarized in Table 1.
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Table 1 j-Summary of Nonconformances l
10 CFR Report
.l Section Description of Nonconformances No.
Section 71.105 Quality assurance program 1
3.3 4
j 71.111 Instructions, procedures, and drawings 4
3.2, 3.3 71.121 Intemalinspection 1
3.3 l
71.123 Test control 3
3.1 The team presented its inspection findings on April 11,1997, to members of Amers management and staff. Amer management acknowledged the findings presented by the team and outlined corrective actions that they planned to take. Amor management also stated that they will perform an analysis of the nonconformances in accordance with 10 CFR Part 21,
" Reporting of Defects and Noncompliance."
PERSONS CONTACTED The team held an entrance meeting on April 9,1997, to present the scope and objectives of the NRC inspection. On April 11,1997, at the conclusion of the inspection, the team held an exit meeting to present the findings of the inspection. Individuals present at the entrance and exit meetings are listed in Table 2.
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g Table 2 Entrance / Exit Meeting Attendees l
A. Amer Amer, President M. Anderson NRC, Region i A. Elsawy Amer, Production Manager M. Fazier Amer, QA Manager H. Hamdan Amer, Project Engineer W. Kane NRC, Director, SFPO K. Logan NRC, Region 1 J
J. Madden Amer, Marketing Manager G. McGinnis DOT T. Matula NRC, Team Leader G. Roberts INEEL, inspector 4
Present at entrance meeting only.
Present at exit meeting only.
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REPORT DETAILS 1.
INSPECTION OBJECTIVES AND SCOPE The team performed an inspection at Amer regarding 130 cylinders fabricated by Amer for KNFC in 1995 and 1996. Amer shipped 33 completed cylinders to the United States Enrichment Corporation at Pct:; mouth Gaseous Diffusion Plant in Piketon, Ohio, and the remaining cylinders to intemational locations.
2.
BACKGROUND KNFC issued contracts to Kolon intemational Corporation (Kolon) under PO No. 95-2-019 (February 1995) and to Shinku Intemational Corporation (Shinku) under PO No. PC-41-259 (December 14,1995) for the fabrication and testing of 78 and 52 cylinders, respectively. Kolon and Shinku subcontracted the fabrication and testing of the 130 cylinders to Amer.
NRC issued COC Nos. 4909, 9196, and 9234 regarding Model Nos. GE-21PF-1, UX-30, and NCl 21PF 1 overpacks, respectively, for transport of cylinders. Paragraph No. 8 of COC No. 4909, and Paragraph No. 6 of COC Nos. 9196 and 9234, state that the cylinders must be fabricated, inspected, tested, and maintained in accordance with ANSI Standard N14.1,
" Uranium Hexafluoride - Packaging for Transport" (1990 edition); must be fabricated in accordance with Section Vill, Division I, of the ASME Boiler and Pressure Vessel Code; and must be ASME Code stamped. ANSI Standard N14.1 requires that fabrication, inspection, and testing activities be conducted in accordance with a QA program that conforms to the i
requirements of 10 CFR Part 71, Subpart H.
Paragraph No. 4, " Quality Assurance," of ANSI Standard N14.1 states that fabrication, inspection, and testing activities may be satisfied by obtaining certifications from cylinder I
fabricators stating that their activities were conducted in accordance with a QA program that j
l conforms to the requirements of 10 CFR Part 71, Subpart H. Amer supplied certifications to l
KNFC regarding the fabrication and testing of the cylinders in accordance with the requirements l
of ANSI Standard N14.1. The certifications state that the cylinders were fumished by Amer under PO Nos. 95-2-019 and PC-41-259 in accordance with Amer's QA program, the requirements of PO Specification No. PS-43-30 (Revision 1 or Revision 2), and ASME Boiler l
and Pressure Vessel Code Section Vill, Division 1,1992 Edition,1994 Addenda.
3.
INSPECTION RESULTS 3.1 TEST CONTROL Inspection Scooe The team examined activities to verify that the testing of the cylinders was controlled, verifiable, and traceable. The team reviewed the procedures controlling testing to verify that they were l
documented, approved by management, and implemented. The scope of the inspection of tests included the review of test requirements, acceptance criteria, test conditions, test documentation, and nondestructive examination controls.
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D Observations and Findinos The team determined that impact testing was not performed at the temperature required by ASTM Specification A20. Paragraph No. 6.10.2 of ANSI Standard N14.1 requires at least one test weld representing each WP to be used in the fabrication of the cylinder be impact tested at the test temperature specified in ASTM Specification A20 for the type and grade of steel to be used in fabrication of the cylinder. The results of the impact test must be submitted to, and approved by, the purchaser before cylinder fabrication. Table A1.15, " Generally Available Grade-Thickness-Minimum Test Temperature Combinations Meeting Charpy V-Notch Requirements Indicated (Normalized or Quenched and Tempered Condition)," of ASTM Specification A20 requires a test temperature of-50 'F for the steel plate used for the cylinders.
Likewise, PO Nos. 95-2 019 and PC-41-259 reference PO Specification No. PS-43-30 which calls for the same impact test requirements as ASTM Specification A20.
The team identified nonconformances with the requirements of 10 CFR 71.123, "Tect control."
i This section requires that a test program be established to assure that all testing required, to demonstrate that the packaging components will perform satisfactorily in service, is identified and performed in accordance with written test procedures that incorporate the acceptance lim!ts contained in the package approval. The test provisions must include provisions for assuring that all prerequisites for the given test are met. The test results must documented and I
evaluated to assure that test requirements have been satisfied. The team identified instances where test requirements were not met.
i 1.
Amer performed impact tests while qualifying its WPs at the incorrect temperature.
Specifically, Amer specified on its fabrication route sheets the use of WP No. WS-956, Revision 1, for all welding operations for cylinders under PO No. 95-2-019. However, the "Charpy V Notch Impact Test" data sheet attached to WP No. WS-956, Revision 1, i
states that the impact test was performed at a temperature of +10 'F instead of at
-50 *F as is required by ASTM Specification A20.
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Likewise, Amer specified on its route sheets the use of WP No. WS-956, Revision 2, for i
all welding operations for cylinders under PO No. PC-41-259. But in this instance, the "Precedure Qualification Record"(PQR), attached to WP No. WS-956, Revision 2, states that the irnpact test for this procedure was performed at -50 'F as is required by
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ASTM Specification A20. However, the team noted that the impact test results listed on the PQR were identical to those values listed in the test results attached to WP j
No. WS-956, Revision 1, which was impact tested at +10 'F. The team concluded that the impact test for WP No. WS-956, Revision 2, was not peiformed at -50 'F, but was j
tested +10 *F instead. Amer management confirmed this conclusion and stated that they made an error in recording the test temperature on the PQR.
4 The team noted that other WPs were listed on the route sheets. However, Amer management stated on April 10,1997, that WP No. WS-956 was used exclusively to i
perform all welding operations on the cylinders.
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4 On April 11,1997, Amer brought in the project er.gineer who was formeriy responsible I
for the fabrication of the cylinders; he was no longer employed at Amer. That project engineer contradicted Amer management by stating that WP No. WS-956, Revisions 1 4
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and 2, had never been used in the fabrication of the cylinders; WP No. SAW-954 was used instead. The project engineer also stated that all of the route sheets were wrong in listing WP No. WS-956 even though Amer personnel had signed off on many of the welding operations as being performed using WP No. WS-956. The team noted that the POR attached to WP No. SAW-954, Revisions 0 and 1, showed that the impact test was performed at -50 'F. However, WP No. SAW-954 is listed in only a few of the welding steps on the route sheets, Amer fabrication personnel, QA staff, and the Al signed off on the completed route sheets as being correct, and Amer management stated on April 10, 1997, that WP No. WS-956 was used exclusively to perform all welding for the cylinders.
Amer did not receive KNFC's approval of the WPs but proceeded to fabricate the 2.
cylinders in violation of the requirements of ANSI Standard N14.1. Specifically, Amer submitted WP No. WS-956, Revision 0, to Kolon on March 20,1995, and Revision 2 of that same procedure to Shinku on January 16,1996, for KNFC's review and approval, as is required by ANSI Standard N14.1. Amer management stated that they did not receive approval from KNFC for the weld procedures. The team pointed out to Amer management that they should have submitted Revision 1 of WP No. WS 956 instead of Revision 0. Amer management replied that Revision 0 had been submitted in error.
ANSI Standard N14.1 requires an air test at 100 psig following the cleaning operation 3.
and valve installation. Amer did not list an air test as an operation on the route sheets for PO No. PC-41-259 but did list an air test on the route sheets for PO No. 95-2-019 as Operation No. 34A. Amer management stated that all of the cylinders had been air tested. However, Amer inanagement did not show the team a test procedure or documented test results for the air test, and had not signed off on the air test operation on any of the route sheets for PO No. 95-2-019 as being completed.
Conclusions Amer's testing of the cylinders was unacceptable. The team determined that Amer performed impact testing to qualify its fabrication welding procedures (WPs) at +10 'F instead of at -50 'F, as required by American Society for Testing and Materials (ASTM) A20, " Standard Specification for General Requirements for Steel Plates for Pressure Vessels." Amer used the unqualified WPs to perform a'l of the welding operations on the 130 cylinders fabricated for KNFC, as documented in its fabrication route sheets. Amer also did not receive KNFC's approval of the
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WPs as is required by ANSI Standard N14.1 and KNFC's PO Specification No. PS-43-30.
Furthermore, Amer did not present documentation showing that the cylinder air tests, required by ANSI Standard N14.1, were performed, even though Amer management stated that all of the air tests were performed. These findings were significant because Amer's records show that the cylinders were not welded using a qualified WP, and not all the required testing was performed; these shortcomings can affect the perfcmiance and safety of the cylinders.
3.2 FABRICATION CONTROL Inspection Sqqpjlt The team reviewed fabrication controls to verify that all phases of the fabrication process were property controlled, implemented, and verifiable. The team reviewed procedures to verify that the fabrication procedures were documented, approved, and implemented for each step of the 6
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fabrication process. The team verified that appropriate codes, standards, and drawings were identified and implemented. The scope of the inspection of fabrication and assembly included the review of activities conceming machining, assen6ly, special processes, and cleaning.
Observations and Findinos The team identified nonconformances with the requirements of 10 CFR 71.111, " Instructions, procedures, and drawings." This sectiun requires tnat activities affecting quality be prescibed by documented instructions, procedures, or drawings and that these instructions, procedures, and drawings be followed. The instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determinine ba+ !,nportant activities have been satisfactonly accomplished. The team identified instances whera procedures were not ava>
or not followed.
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Amers route sheets do not identify associated inspection procedures or acceptance criteria. Specifically, Amers route sheets contain a column for recording the number i
and revision of the fabrication, inspection, and test procedures to be used in each of the fabrication operations. The procedures are necessary to control the fabrication j
operations and ensure that th3 results are acceptable. The team n.oted that the following inspection steps do not identify the associated inspection procedces:
Operation No. 7, " Inspect fit-up"; Operation No. 9, " Inspect long seam weld"; Operation No.12, " Inspect fit-up of 1"-cpigs"; Operation No.14. " Inspect epigs weld"; Operatico No.17, " Inspect head fit-up"; Operation No.19, " Inspect heads welding"; Operation Nc. 24, " Inspect skirts fit-up to cylinder'; Operation No. 26, " inspect skirts weld";
Operation No. 29, " Final dimension inspection"; and Operation No. 32, " Inspect per code regt's & sign data reports." Furthermore, Amer had no inspection reports documenting the inspection performed or the results of the inspections.
In addition to the missing inspection procedures noted above, one test step on the route sheets did not indicate the procedure used and the acceptance criteria. Specifically, the route sheets for PO No. 95-2-019, Operation No. 34A, specified " Air test." However, no corresponding test procedure was found and Amer had no test reports documenting the air tests performed or the results of the tests.
2 Amer did not use correct test procedures. Specifically, Amers QC Manual, Section Xill,
" Hydrostatic Testing and Final Inspection," requires that test gages be not less than 1.5 times, and not more than 4 times, test pressure. Amer uses Test Procedure No. H-601,
" Hydrostatic Test Procedure," as a template and enters the applicable minimum and maximum test gage pressure values for each specific contract, as stated above, in blank spaces in the procedure. Amer did not enter the minimum and maximum test gage pressure values in Procedure No. H-601, Revision 14, (December 7,1994) for PO No. 95-2-019. Similarly, Amer entered the minimum test gage pressure value of 1.25 in Procedurt No. H-601, Revision 9, (May 12,1994) for PO No. PC-41-259 in:;tead of the required 1 A However, the team noted that the correct gage with a range from 0 to 1000 psi wn used to perform Procedure No. H-601 on both contracts.
The team.dentified a second instance of Amer not following test procedures involving Amers QC Manual Section Xil,
- Calibration " This section requires that the identification 7
t number of gages be recorded on the route sheet. Howevar, Amer did not record on the j
route sheets the hydrostatic test gages used.
j 3.
Amor did not record required material identification information.. Specifically, Amor used a form, " Traceability Sketch for Cylinder No. 524-1," to document material heat numbers for each cylinder component. However, in numerous instances, Amor did not enter the j
material heat numbers on tfit form. Amor management stated that they can identify the '
f material heat numbers for groups of cylinders through procurement material certification i
documentation for traceability purposes, but cannot identify the material used on specific '
l cylinders in all cases.
I The team observed that Amor did not perform the operations listed on the route sheets in the sequence specified. Amer management stated that it is acceptable to perform operatic ns out of sequence. However, performing fabrication and test operations out of sequence introd=Jces the possibility of accidentally missing critical fabrication, test, and inspection steps.
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Conclusions Amers control of the fabrication process for the cylinders was unacceptable.- The team determined that there is a general lack of documentation showing that the cylinders were fabricated, inspected, and tested in accordance with ANSI Standard N14.1 and the ASME-l Code. Amers fabrication route sheets did not record the inspection procedures, acceptance criteria, or air test procedure for the cylinders; Amor developed and used an incomplete i
procedure to perform hydrostatic testing of the cylinders; and Amor did not record all of the l
material identification information required for traceability, j
3.3 QUALITY ASSURANCE Inspection Scope
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The team inspected Amers QA program to verify that activities regarding tests and inspections were controlled, verifiable, and traceable. The team reviewed the QA program to verify that the procedures controlling testing and inspection were documented, approved, and implemented.
l The team reviewed inspection requirements, acceptance criteria, test procedures and
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documentation, nondestructive examination controls, and QA hold points.
j Observations and Findinos i
The team identified a nonconformance with the requirements of 10 CFR 71.105, " Quality assurance program." This section requires that a QA program be established that complies with the requirements of 10 CFR Part 71, Subpart H. The QA program must be documented by written procedures or instructions and the program must be carried out in accordance with those procedures. However, Amer's QC Manual was incomplete; it did not address certain requirements of 10 CFR Part 71, Subpart H. Specifically,10 CFR 71.113, " Document control";
10 CFR 71.121, "Intemal inspection"; 10 CFR 71.123, " Test contror; 10 CFR 71.127,
" Handling, storage, and shipping control"; 10 CFR 71.133, " Corrective action"; and 10 CFR 71.137, " Audits."
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The team identified a nonconformance with the requirements of 10 CFR 71.111, " Instructions, procedures, and drawings." This section requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings and that these instructions, procedures, and drawings be followed. The instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. However, Amers QC Manual does not contain, or make reference to, certain implementing procedures. Specificall, procedures for route sheet development,
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completion, and control, hiemal inspection, no1cor.onnuce tracking and root cause analysis, r
and intemal/ vendor audits were not available.
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.The team identified a nonconformance with the requirements of 10 CFR 71.121, "Intemal
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inspection." This section requires that a program be established and executed for inspection of l
activities affecting quality to verify conformance with the documented instructions, procedures, j
and drawings for accomplishing the activity. Examination, measurements, or tests of material or l
products processed must be performed for each work operation where necessary to assure quality, if mandatory inspection hold points, which require witnessing or inspecting by designated representative and beyond which work should not proceed without the consent of its designated representative, are required, the specific hold points must be indicated in appropriate documents. Likewise, Section ll, "QC Route Sheets," of the Amer QC Manual j
states that materialis considered to clear a manufacturing point when the appropriate signatures are obtained on the QC Route Sheet. Furthermore, a hold point requires an i
inspection, and work shall not proceed until the Al signs or initials the Route Sheet.
i Amers QA staff did not sign off on many of the inspection points, and the Al did not sign off on many of the Al's hold points, on the route sheets. Specifically, Amer used route sheets to i
identify the required operations, test steps, and inspection points for the fabrication of the l
cylinders. The Al also indicated specific hold points on the route sheets. However, the team identified numerous instar:es of Amer inspection points and Al hold points not being signed off on the route sheets. Amer management gave the team the Al's personal activity log, stating i
that it showed that all of the Al hold poi 6ts were witnessed and approved by the Al before fabrication proceeded. The team verified, through the use of this log, that the Al had witnessed
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many of the Al hold points, but not all. Amer did not present any additional documentation indicating that the Amer QA staff signed off on inspection points. Route sheets with missing signoffs for Amer QA inspection points and Al hold points are listed in Table 3.
The team noted that the route sheet for cylinder No. 5121-152 had yellow tags attached to it.
The tags identified the specific inspection steps that were not signed off on by Amer QA staff s
and the Al. Amer management stated that the tags had been attached to the route sheet by the previous Amer QA Manager. However, the previous Amer QA Manager did not resolve the issue.
Conclusions Amers QA program used for the fabrication and test of the cylinders was unacceptable. The team determined that Amers Quality Control (QC) Manual, Revision 6 (July 7,1994) did not cover every essential criteria specified in 10 CFR Part 71, Subpart H; Amers QC Manual did not contain, or make reference to, implementing procedures; Amers QA staff did not sign off on many of the inspection points on the route sheets; and many of the ASME Code-required Authorized Inspectors (Al's) hold points were not completed on the route sheets. These 9
Table 3 Missing Amer QA and Al Route Sheet Operation Signoffs Cylinder No.
Amer QA Staff Signoff Missing Al Signoff Missing 524-1 2 Operation Nos. 4,12,14,19,24, 26,29, and 34A 524-1-55 Operation Nos. 3,4,9,12,14,19, 24,26,29, and 34A 524-1-64 Operation Nos. 3,4,9,12,14,19, 24,26,29, and 34A 524-1-68 Operation Nos. 3,4,9,12,14,17, 19,24,26,29, and 34A 524170 Operation Nos. 3,4,9,12,19,24, 26,29, and 34A 524-1 78 Operation Nos. 3,4,9,12,14,17, 19,24,26,29, and 34A 524-1-79 Operation Nos. 3,4,9,12,14,16A, 19,24,26,29, and 34A 5121-1-44 Operation Nos. 12,14,17,24,and Operation Nos. 22A,24,36, and 40 30 5121-1-45 Operation No.12 Operation Nos. 20,22,36, and 40 5121 1-46 Operation Nos. 12,14,17,24,and Operation Nos. 22A,36, and 40 30 5121-1-47 Operation Noc. 12,14,17,24,and Operation Nos. 22A,36, and 40 30 Operation Nos. 22A,36, and 40 5121-1-48 5121-1-49 Operation Nos. 12,14,17,24,and Operation Nos. 22A,36, and 40 30 5121-1-50 Operation No.12 Operation Nos. 22A, M, and 40 5121 1 51 Operation Nos. 12,14,24, and 30 Operation Nos. 22A,36, and 40 5121-1 52 Operation 'No. 9 Operation Nos. 21, 22A, 24, 36, 40, and 41 10 hkN
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findings were significant because there is a lack of documentation showing that the cyl were fabricated, inspected, and tested in accordance with ANSI Standard N14.1 and the ASM Code.
4.0 OVERALL CONCLUSIONS l'
The team identified concoms about Amers test control, fabrication control, and QA progra Test Control: Amers testing of the cylinders was unacceptable. The team determined l
that Amor performed impact testing to qualify its fabrication welding procedures (WPs) at
+10 'F instead of at -50 *F, as required by American Society for Testing and Materials (ASTM) A20, " Standard Specification for General Requirements for Steel Plates for Pressure Vessels." Amer used the unqualified WPs to perform all of the welding operations on the 130 cylinders fabricated for KNFC, as documented in its fabrication route sheets. Amor also did not receive KNFC's approval of the WPs as is required by ANSI Standard N14.1 and KNFC's PO Specification No. PS-43-30. Furthermore, Amor did not present documentation showing that the cylinder air tests, required by ANSI Standard N14.1, were performed, even though Amer management stated that all of the.
air tests were performed. These findings were significant because Amers records show i
that the cylinders were not welded using a qualified WP, and not all the required testing was performed; these shortcomings can affect the performance and safety of the cylinders.
i Fabrication Control: Amers control of the fabrication process for the cylinders was unacceptable. The team determined that there is a general lack of documentation -
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showing that the cylinders were fabricated, inspected, and tested in accordance with j
ANSI Standard N14.1 and the ASME Code. Amers fabrication route sheets did not record the inspection procedures, acceptant t criteria, or air test procedure for the j
cylinders; Amer developed and used an ins..iplete procedure to perform hydrostatic testing of the cylinders; and Amer did not record all of the materialidentification c
information required for traceability.
i Quality Assurance: Amers QA program used for the fabrication and test of the cylinders was unacceptable. The team determined that Amers Quality Control (QC) Manual, t
Revision 6 (July 7,1994) did not cover every essential criteria specified in 10 CFR Part I
71, Subpart H; Amers QC Manual did not contain, or make reference to, implementing procedures; Amers QA staff did not sign off on many of the inspection points on the route sheets; and many of the ASME Code-required Authorized Inspectors (Al's) hold i
points were not completed on the route sheets. These findings were significant because there is a lack of documentation showing that the cylinders were fabricated, inspected, and tested in accordance with ANSI Standard N14.1 and the ASME Code.
5.0 EXIT MEETING i
The team presented its inspection findings on April 11,1997, to members of Amers i
management and staff. Amer management acknowledged the findings presented by the team 1
J and outlined corrective actions that they planned to take. Amer management also stated that
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they will perform an analysis of the nonconformances in accordance with 10 CFR Part 21, f
" Reporting of Defects and Noncompliance "
i l
j 11 l
I
f LIST OF ACRONYMS USED Al Authorized inspector Amer Amor Industrial Technologies, Inc.
ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials COC Certificate of Compliance Cylinders Model 30B uranium hexafluoride cylinders s
KNFC Korea Nuclear Fuel Company, Ltd.
Kolon Kolon Intemational Corporation PQR Procedure Qualification Record PO' Purchase Order psi pounds per square inch psig pounds per square inch gage QA QualityAssurance i
QC Quality Control Shinku Shinku Intemational Corporation
-WP Weld Procedure J
4 12 J
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS j
WASHINGTON, DC 20555 April 17,1997 NRC INFORMATION NOTICE 97-20: IDENTIFICATION OF CERTAIN URANIUM 4
HEXAFLUORIDE CYLINDERS THAT DO NOT l
COMPLY WITH ANSI N14.1 FABRICATION STANDARDS Addressees 1
Registered users of transportation packages for uranium hexafluoride.
Purpose i
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to notify addressees that, based on NRC inspection review of available records, certain Model 30B cylinders for uranium hexafluoride do not meet the fabrication standards in American National Standards institute, ANSI N14.1, " Uranium Hexafluoride-Packaging for Transport."
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Model 30B cylinders that do not meet the ANSI N14,1 standard are not authorized for transport. It is expected that recipients will review the information for applicability to their operations. However, information contained in this notice is not an NRC requirement; therefore, no specific action nor wntten response is required.
t f
Description of Circumstances l
On April 9-11,1997, NRC conducted an inspection at Amor Industrial Technologies, Inc.
{
(AIT), in Wilmington, Delaware. The inspection involved the fabrication of cylinders for uranium hexafluoride. The fabrication records for certain Model 30B cylinders did not support i
a conclusion that the weld procedures had been qualified at the low temperatures specified in ANSI N14.1. The cylinders were fabricated by AIT, and were purchased by Korea Nuclear Fuel Co., Ltd (KNFC). The affected cylinders are:
KNFC Serial No.
Date of Manufacture 0244 to 0373, inclusive June 1995 through July 1996 Discussion The available records at AIT do not support a conclusion that Model 30B cylinders were fabricated in accordance with ANSI N14.1. U.S. Department of Transportation (DOT) regulations (49 CFR 173.420) require that packagings for uranium hexafluoride be designed, fabricated, inspected, tested, and marked in accordance with ANSI N14.1. NRC regulations require that licensees making these types of shipments comply with applicable DOT 9704170195 BK2DSURE 2 9%b477TTWS
%PP
IN g7-20 April 17,19g7 Page 2 of 2 regulations (10 CFR 71.5). NRC Certificates of Compliance for uranium hexafice.He packages also specify that cylinders must be fabricated, inspected, and tested in accordcoce with ANSI N14.1.
ANSI N14.1 specifies design and fabrication standards for uranium hexafluoride cylinders.
Among other things, the standard includes provisions for ensuring impact resistance of the Model 30B cylinder shell and heads in case of a transportation accident in a cold climate.
The standard specifies that the weld procedures for the Model 30B cylinders be qualified at
-50'E (-45'C) for the grade of steel used for these cylinders. The weld procedures used to fabricate the cylinders identified above, according to available records, were only qualified to
+10'F (-12*C), and therefore, do not conform to the ANSI N14.1 standard. Since DOT regulations and NRC Certificates of Compliance specify that cylinders used to transport uranium hexafluoride must comply with ANSI N14.1, the cylinders identified above are not authorized for transport.
This information notice requires no specific action nor written response, if you have any questions about the information in this notice, please contact one of the individuals listed below, or the appropriate regional office.
William F. Kane, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Technical Contacts: Richard Boyle, DOT (202) 366-4545 E-mail: rick.boyle@rspa. dot. gov Nancy L. Osgood, NMSS (301) 415-8513 E-mail: nio@nrc. gov William M. Troskoski, NMSS (301)415-8076 E-mail: wmt@nrc. gov i
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