ML20150C089
| ML20150C089 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/1978 |
| From: | Jerrica Johnson, Mcneill W, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20150C063 | List: |
| References | |
| REF-QA-99900081 44010, NUDOCS 7811100088 | |
| Download: ML20150C089 (13) | |
Text
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O VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900081/78-02 Program No. 44010 Company: Exxon Nuclear Company, Inc.
Nuclear Fuels Department 2101 Horn Rapids Road Richland, Washington 99352 Inspection Conducted: August 28-31,:1978 Inspectors: . -
/ / 8 W. M. McNeill, Contractor Inspector, Vendor Date Inspection Branch
- l. A 0 /
J. M. Johnson, Contract (r/ Auditor, Vendor / Ddte Inspection B anch Approved by:
D. E. Whitesell, Chief, Compogn,ts Secticn I, /Dat6 Vendor Inspection Branch Summary Inspection on August 28-31,1978(99900081/78-02)
Areas Inspected: Implementation of 10 CFR 50, Appendix B and other appli-cable codes and standards, including: controls of special process; enrich-i ment and impurity controls; records; audits; nonconformances and corrective actions and action on previous inspecticn findings. The inspection involved fifty-six (56) inspector hours on site by two (2) NRC inspectors.
Results: -
No unresolved items or deviations were identified in one area.
The Ellowing five (5) deviations and two (2) unresolved items were identified in the following areas.
Deviations: Controls of Special Processes - penetrant testing was not in accordance with the ASTM as required by NRC and the QA procedure (Enclosure, ItemA.). Controls of Special Processes - records of past performance were 781110 0085
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2 not maintained in'accordance with flRC and the QC procedure (Enclosure, ItemB.). Enrichment and Impurity Controls - balances used were not calibrated as required by NRC and the QA Program (Enclosure, Item C.).
Records - implementing records procedures did not address all the require-cents in accordance with flRC, ANSI, and the QA procedure (Enclosure, Item D.).
Nonconformances and Corrective Action - required preventative action was not established for correction of rod spacing on a recent project (Enclosure, Item E.).
Unresolved Items: Controls of Special Processes - radiographic qualifi-cation data was not available (DetailsSection I, C.3.b.). Records - an inconsistency was identified on the handling of radiographs as records ' DetailsSection II, B.3.b. ).
DETAILS SECTION I (Prepared by W. M. McNeill) i A. Persons Contacted W. A. Baker, Process Control Supervisor H. D. Bell, Metrology Engineer
- B. R. Black, QC Engineering Supervisor
- T. L. Davis, QA Manager, Nuclear Fuels H. N. DeGooyer, Spectroscopist A. K. Hageman, Lead Technician
- E. N. Harbinson, Inspection Supervisor J. A. Hays, Lead Technician
- D. K. Perry, QA Engineer
- J. A. Perry, QA Manager J. A. Shurts, Analytical Lab Supervisor R. A. Ziler, Spectroscopist
- Denotes those attending the Exit Interview.
B. Action on Previous Inspection Findings (Closed) Deviation (Report No. 78-01): Design verification effort was not auditable. The design control procedure has been revised, QA procedure No. 3, Revision 5, and provides for an audit trail.
Future design verification will be auditable by following this audit trail.
(Closed) Deviation (Report No. 78-01): Records of training were not maintained. Records have been established on the training of design coordinators.- It appears all design coordinators are now trained and records support such activities.
(Closed) Deviation (Report No. 78-01): Vacuum gaging was not calibrated. 'The -vacuum gaging in question has been placed under the Instrument Repetitive Maintenance System, XN-NF-P63,004, has been approved and issued as- preventative action.
C. C'ntrols o of Special Process
- 1. Objectives The objectives of.this area of the inspection were to verify '
that special processes are properly qualified and controlled in accordance with Criterion IX, Appendix B,10 CFR 50 and.
the Quality Assurance Manual.
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- 2. ' Method of Accomplishment The preceding objectives were accomplished by:
- a. Review of the Quality Assurance Program, XN-NF-1, Revision 1, l Section 9, which established the general requirements of NDE controls,
- b. Review of the Technician Certification Standards, XN-NF-64, Revision 9, Section 2.1, which established the certifica-tion requirements of NDE. personnel.
- c. Review of the product specifications BWR Fuel Rod Assembly, XN-S30 303, Revision 15, Tie Plates, XN-S30073, Revision 8, which established technical requirements of NDE processes.
- d. Review of NDE procedures, Radiographic Procedure, 7.24, Revision 3, Fuel Cladding Ultrasonic Test Stations, 7.10, Revision 13, Liquid Penetrant Inspection Dio Tank Method, 7.48, Revision 1, which established the work instructions. )
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- e. Verification that NDE inspector qualification records were l
- on file certifying the qualification verification that
. records identify personnel responsible and methods of qualification by review of exams, certifications, eye tests of a sample of seven inspectors. These inspectors were found to be engaged in NDE inspections at the time.
- f. Verification that the above NDE procedures were at the work stations,. adequate, and being implemented by inspectors by witnessing some NDE processing for each of the above procedures,
- g. Verification that the NDE equipment was calibrated and
- materials used certified by checking the equipment and materials used during the above operations.
- 3. - Findings Item A: -
It was noted that the ASTM E 165-65 has been revised to ASTM E 165-74. Exxon will consider this when revising the procedure.
This penetrant process is used at Exxon for verification of the material integrity of components such as tie plates and nozzles after machining. .
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Item B:
The personnel qualIficatic,n system is based on SNT-TC-1A. The Exxon procedure parallels SNT-TC-1A in requiring the maintainance i of continuing competency of personnel. One method to do such is to maintain some evidence of continuing satisfactory perfor-mance. This assures competent personnel are used in performance of NDE tests.
- a. Deviations '
See Enclosure, Item A and B.
- b. Unresolved Item Exxon product specifications require the radiographic
. process to detect voids of a minimum absolute size. Data which would demonstrate this capability under conditions of maximum material, maximum test sensitivity, was not available at this time. Exxon will make this data available for the next inspection.
D. Enrichment and Impurity Controls
- 1. Objectives The objectives of the inspection were to verify that:
- a. Material flow procedures and practices cover manufacturing eperations for all inputs of material in any fonn from UF6 to completed pellets.
- b. Enriched material is controlled, inspection and checked at each stage during manufacturing and processing to prevent enrichment mixup or contamination,
- c. Sufficient final enrichment checks and chemical analyses are made on pellets or rods to detect any significant enrichment deviations or contamination and to give reason-able assurance that the pellets and rods meet specifications and contractural requirements.
- 2. Method of Accomplishment The preceding objectives were accomplished by:
- a. Review of the Quality Assurance Program, Revision 1, Section 5, which established the general requirements.
- b. Review of the product specifications, Uranium Dioxide Pellets, XN-S30061, Revision 23, Equivalent Boron Content, JN-S30100, Revision 0, which established the technical requirements.
- c. Review of the analytical procedures manual, XN-NF-103, in particular pro'cedures Training Technologists, P69203, Revision 2, Procedure Development, P69202, Revision 1, Control Chart, P69426, Revision 5, Laboratory Standard and Referee Program P69426, Revision 5, Standard Preparation, P69428, Revision 0, which established laboratory practices.
- d. Review of QC Standard Pellet Processing and Certification, XN-NF-P68152, Revision 22, which established the sampling plan, enrichment identification, color codes, and etc. which are subject to inspection,
- e. Review of analytical procedures Gravimetric Percent Uranium and Oxygen to Uranium Ratio, 2.1.1, Revision 4, Determination of Isotopic Composition by Mass Spectrometry, 2.2.1, Revision 3, Carbon in Uranium Dioxide Samples, 2.3.1, Revision 2, Fluoride and Chloride by Pyrodrolysis, 2.4.1, Revision 3, Spectrochemical Determination of Impurities in Uranium, 2.5.4, Revision 4, Total Nitrogen in Uranium Dioxide, 2.7.1, Revision 2, which established the work instructions.
- f. Verification that the above analytical procedures were implemented by witnessing and reviewing the methods.
Verification that measures for determination of precision and accuracy are established by review of control charts and standards data.
- g. Verification that the sampling plan above was implemented by review of the analytical reports,
- h. Verification that the training procedure above was imple-mented by review of the training records for five technicians found engaged in the above analysis.
- 3. Findings An error in the emission spectrochemical result in inaccurate measurement of impurity levels in the. fuel. In addition, the uranium analysis uses the impurity levels as a correction in the
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' final' deterrrination of uranium assay. Exxon placed the balances in question under the calibration program. An error analysis was performed on the calibration. data to evaluate the effect of the balance errors. The corrective action appears adequate but preventative' action was not taken at this time.
- a. Deviation See Enclosure, Item C.
- b. Unresolved Items None. !
E. Exit Interview The inspectors met with management representatives (denoted in para-graph A) at the conclusion of the inspection on August 31, 1978. The inspectors summarized the scope and findings of the inspection. The management representatives had no comment in response to each item discussed by the inspectors.
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DETAILS SECTION_II (Prepared by J. M. Johnson)
A. Persons Contacted W. A. Baker, Process Control, Supervisor B. R. Black, Quality Control Engineering, Supervisor T. L. Davis, Quality Assurance Manager, Nuclear Fuels E. Haugen, Document Control, Supervisor E. T. Johnson, Quality Assurance Engineer D. K. Perry, Quality Assurance Engineer J. A. Perry, Quality Assurance Manager B. Records
- 1. Objectives The objectives of this area of the inspection were to verify that:
- a. Quality assurance records are identified, collected and stored in such a way that the fuel quality history is i documented and protected. 1
- b. The manufacturer's records system meet the requirements of Criterion XVII, Appendix B,10 CFR 50.
- 2. . Me_tJLod of Accomplishment The preceding objectives were accomplished by:
- a. Review of the Quality Assurance Pr: gram XN-NF-1, Revision 1, Section 17, QA Records, to identify program commitments.
- b. Review of Quality Assurance Procedure QA Records No. 17, Revision 1, and Document Control Standard Operating Procedures, XN-NF-365, Revision 1, to assure incorporation of program commitments in implementing procedures, and to verify that a system exists for identifying which records are to be maintained.
- c. Verification that legible, completely filled out and adequately identifiable records are maintained by sampling various types of records such as audits, test records, non-conformances and materials analyses in either satellite
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' files or central. files as applicable. Quality Control records for.two_ fuel reloads shipped'in 1978_and for one
-fuel' reload shipped in 1977 were reviewed for the_above..
Records of five QA audits were reviewed, including follow up. to assure' completion of corrective actions.
- d. Verification that there is .an _index'of records.which indicates record retention times and where records are stored.
- e. Verification that.there is a; written storage procedure with a custodian who has been given the responsibility to enforce the-procedure. The procedure includes the filing system which is used, a_ method for verifying that all records have been_ received, rules governing access to and control of the files and a method- for maintaining accountability for records removed. The list of personnel. allowed access
. to the files was~ examined.
- f. Verification that permanent storage facilities provide protection from possible destruction by fire, flooding,.
tornadoes, etc. This was also verifiea for temporary QA andQCfiles,whicharestoredinone(1)hourfire-rated file cabinets.
- 3. Findings The correction of this deviation will assure that record facility changes or modifications will not deviate from specified standards. In regard to acceptability of records, microfilming has not yet begun and therefore problems related to this procedural deficiency have not.yet occurred. Correction is
-necessary to assure acceptability of future records received by Central Files for microfilming and storage,
- a. Deviation See Enclosure, Item D.
- b. Unresolved-Item TheQA_ Program, Revision <1,'AppendixII,(ANSIN45.2.9 Applicability). indicates that radiographs are QA Records.
QA Procedure No. 17. details a list of QA Records. However, l this list does not include' radiographs. Exxon will evaluate and revise the appropriate document to resolve this inconsistency. .
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- c. Comment Exxon CAR No.154 to Audit Report FF-78-04 documents the failure to send many QA Records to the Central Files because of lack of storage space. Note that until corrective action for this CAR is complete, many Exxon Engineering records are not being maintained in fire-rated files or in duplicate files. Because of prior identification and initiation of corrective action by Exxon, including preparation for microfilming, this condition is not being documented as a deviation in this report. A complete evaluation of Exxon's total record system is contingent upon the completion of the corrective action for this CAR. Therefore, a' subsequent NRC inspection will examine the results of Exxon's corrective action.
C. Internal Audits
- 1. Objectives The objectives of this area of the inspection were to verify that;
- a. The fuel manufacturer has implemented a system of internal l audits sufficient to determine the effectiveness of the manufacturer's quality assurance program.
- b. The manufacturer's system meets the requirements of Criterion XVIII, Appendix B,10 CFR 50.
- 2. Method of Accomplishment 1
The preceding objectives were accomplished by:
- a. Review of the Quality Assurance Program XN-NF-1, Revision 1 Audits, Section 18, to identify program commitments.
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- b. Review of Quality Assurance Procedure Quality Assurance i Audits, No.18, Revision 4, and Quality Assurance Procedure, l Qualification and Training of Quality Assurance Auditors No. 2, to assure incorporation of program commitments in implementing procedures, and to verify that an audit l system has been established and organizational responsi- l bilities and scope documented.
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- c. Verification that adequate manpower, funding and facilities appear to be provided.
- d. Verification that there is a planned schedule of audits with applicable clements audited as commited to in the Quality _
Assurance Program (which is currently being reviewed as a Topical Report by NRB). Audit schedules for 1977 and 1978 were reviewed.
- e. Verification that the audit personnel were independent of activities audited, and were qualified based on experience and training. Auditor qualifications, certifications and their basis, and annual evaluations were reviewed for seven auditors from above audits.
- f. Verification that an audit plan is utilized which identifies '
audit scope, activities to be audited, requirements, schedule and procedures or checklists. These appeared in the files for each audit.
- g. Verification that the audit reports are written which provide a description of the audit scope, identification of auditors, persons contacted, a summary of audit results including an evaluation of the effectiveness of the areas audited, details of nonconformances, and recommendations for correcting non-conformances or improving the QA program, as appropriate.
Two audit reports for 1978 were reviewed, and one audit report for 1977 was reviewed.
'h. Verification that the distribution assured that audit I results and evaluations were reported to responsible manage-ment,
- i. Verification that the responsible management had reviewed the findings, determined and scheduled appropriate corrective action.. responded as specified in procedures, and indicated scheduled data for corrective action. This was accomplished for the three audit reports reviewed.
- j. Verification that the internal. manufacturing audits, procure-ment audits and design control audits covered the appropriate scope.
- 3. Findings
- a. Deviations None.
- b. Unresolved Items None.
D. Nonconformances and Corrective Actions
- 1. .ojectives The objectives of this area of the inspection were to verify that:
- a. The manufacturer's system contains sufficient measures to provide assurance that nonconforming materials, parts, or components are not inadvertently utilized and that prompt corrective actions are taken.
- b. The manufacturer's system meets the requirements of Criteria XV and XVI Appendix B, 10 CFR 50.
- 2. Method of Accomplishment The preceding objectives were accomplished by:
- a. Review of the Quality Assurance Program, XN-NF-1, Revision 1, Nonconforming Machine Parts of Components, Section 15, Corrective Action, Section 16, and Corrective Action Follow-up, Section 18, to identify program commitments.
- b. Review of Quality Assurance Procedures, Deviating Material Control System, No. 15 Revision 5, and Corrective Action Systems, No. 16, Revision 1, to assure incorporation of program commitments in implementing procedures, and to verify that procedures exist for identification, documenta-
' tion, segregation and disposition of nonconforming items.
.c. Verification that the nonconforming items had been reviewed and accepted, rejected, repaired or reworked in accordance with the documented procedures by review of 10 Deviating Material Reports (DMRs).
- d. Verification that repaired and reworked items were reinspect-ed per procedural requirements and test report shows accept-ance of rework.
- e. Verification that items dispositioned "use as is" included acceptance of waiver and documented as-built condition.
f.
_' Verification that recent MRB'(Material Review Board) activities are documented on DMRs as required and conforms to applicable procedures.
- g. Verification that cause was determined and corrective action -
-was taken to prevent recurrence, as applicable, by. review of
.four DMRs.
- 3. Findings Approximately one-third (1/3) of the Fuel Bundles for-'one plant required rework per this DMR to provide proper spacing between center guide bars and adjacent fuel rods. Proper designation and implementation of preventative action should eliminate this problem in the fabrication of next year's assemblies. The required preventative action form was generated but not fully signed off during this inspection as a result of this finding.
- a. D_eviation !
See Enclosure, Item E. l
- b. Unresolved Items None.
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