ML20151H427
| ML20151H427 | |
| Person / Time | |
|---|---|
| Issue date: | 04/22/1983 |
| From: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jesse Rollins GESELLSCHAFT FUER NUKLEAR SERVICE, MBH |
| References | |
| REF-PROJ-M-34 NUDOCS 8305040092 | |
| Download: ML20151H427 (53) | |
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copy to be returned to FBrown SS 396 Project _M-34 FSturz FBrown (LA)
APR 2 2 EB3 - run NMSS R/F bcc: MSchwartz, LLNL FCAF R/F OSmith LCRouse Project M-34 JPRoberts NDavison PBrooks DHurt Gesellschaft fuer Nuklear Service, abH i
ATTN: Jack D. Rollins U.S. Representative 340 Six Branches Court Roswell, Georgia 30076 Gentlemen:
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In response to your submittal, docketed February 24, 1983 under Project l
No. I'-34, we have reviewed your submitted Topical Report (TR) entitled,
" Topical Safety Anaysis Report for A Castor Cask Type Independent Spent Fuel Stora.;e Installation (Dry Storage)." Our detailed comments are enclosed.
i This revision of the GHS TR is a significant improvement to the originally submitted report. Consequently, most of the connents we have made concern requests for adequate information, test data and results, analyses, etc.,
to allow us to complete our safety review. However, with respect to sone topics the report still lacks adequate definition principally with respect to design requirements and objectives. While our comments on these are included in the enclosure, four items are discussed briefly below.
The existing report does not clearly address seismic criteria and the Design-Earthquake (DE). Although a number of values for horizontal ground motion are used, only the minimum value allowed in 10 CFR Part 72, 0.1 g, is cited for the DE.
Even assuming one wished to preclude cask tipover, j
this seens an overly restrictive value. However, if it is the value l
chosen, this should be made clear throughout the TR.
l With respect to tornado winds, the value for maxin:um wind speed cited in the submitted report,140 meters per second (m/s), is low for most of the i
United States where a maximum wind speed of 360 miles per hour (161 m/s) is i
identified by Regulatory Guide 1.76.
Again, the.value chosen seems overly l
restrictive for a Topical Report which should encompass a broad range of independent spent fuel storage installation (ISFSI) sites.
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- 1933 Gesellschaft fuer Nuklear Service, rhH With respect to the spent fuel contained in a Castor Ic cask, the report should cite a specific set of boiling water reactor spent fuel parameter limits that envelope those potential ISFSI storage license applicants and utilize such a set throughout the report rather than citing differing values.
If you wish, choose that set of spent fuel parameters which is expected to be used in a future license application for Castor Ic ISFSI storage.
Having defined the cask environment, address the combinations of structural loads on the cask for the envelope of site parameters chosen. Also demonstrate that nodular cast iron is a material adequate to preclude failure of cask confinements under such con,litions.
Finally, a Quality Assurance Program, that meets the requirements of Appendix B to 10 CFR Part 50 must be established and committed to by GNS.
Sincerely, j
Orici n Zo h n P. E c'; az.g [ ~
Leland C. Rouse, Chief hAdvancedFuelandSpentFuel Licensing Branch Division of Fuel Cycle and Material Safety
Enclosure:
Detailed Conments on TR Of0.C&]
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DETAILED COMMENTS ON TOPICAL REPORT 1
INTRODUCTION AND GENERAL DESCRIPTION OF INSTALLATION 1.2 General Descriptien of Installation 1.2.2 Principal Design Criteria 1.
GNS gives the gamma shielding dimensions as 34 to 38 cm of cast iron.
Tab. 1.2-1 gives the wall thickness as 44 cm; the lid thickness as 55 cm (34 cm primary, 13 cm secondary, and 8 cm protective) and no dimensions are given for the cask bottom, moderator rods, or bottom and cover moderator material. What are the appropriate gamma shielding dimensions?
2.
Are differences at the wall, for example, due to the presence of the moderator rods?
3.
Dimensions critical to the shielding calculations must be adequately
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described, preferably in Section 3.3.5.2 (Shielding) or Section 7.3.2 (Shielding).
Tab. 1.2-1 and Tab. 1.2-2 should immediately follow this section.
4.
This section says " cask structures are designed... according to... the ASME code"; How do the structural specification calculations (Section 4) relate specifically to the ASME code?
1.2.4 -Structural Features 1.
There appear to be two different protective covers:
one that provides for the insert cover (Fig. 1.2-1) and one that does not (Fig. 1.2-3).
The confusion continues in Section 3.3.2.1 (Confinement Barriers and Systems).
The protective cover of Fig. 3.3-1 does not provide for the insert cover; the protective cover of Fig. 3.3-2 does.
This discrepancy should be clarified.
Fig. 1.2-1 thrcugh Fig. 1.2-8 should immediately follow this section.
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2.
This section mentions a shock absorber.
Is a shock absorber a component of the CASTOR Ic cask as used for storage purposes? If, as stated, it is used only for cask transportation, describe the procedures for its use and removal when cask emplacement is accomplished.
3.
This section mentions an " inlet and outlet channel." Is this the flushing connection specified on p. 1.2-8?
4.
P. 1.2-4, Sect 1.2.4 mentions a gas intake and exhaust opening.
Where are these on p. 1.2-8, Fig. 1.2-2?
1.2.7 Special Features that are Safety Related 1.
Regarding Tab.1.2-1, is the unit Mg given under the classification
" Weights" a force unit, namely, Mg x gforce x 109 2.
Are the cask mass and weight numerically the same? In Table 1.2-1 the weights of the empty cask and the loaded cask are given as 76.6 Mg and 81.1 Mg, respectively.
3.
Tabs. 1.2-1 and 1.2-2 summarize the cask main design characteristics, including specific " cask features" and corresponding " Design values."
On Tab.1.2-2 a design value of } 7 x 106 Nm is given for "possible mechanical load impact." The units of Nm are for work or energy while impact is measured in Ns.
How is this feature and its value used in the structural design elsewhere in the report?
l 1.4 Identification of Aaents and Contractors This section mentions RWTH:
Technical University of Aachen, Aachen - Structural
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cask analysis.
This agent or contractor is not mentioned anywhere as a refer-ence. What structural cask analysis have they done?
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2 SITE CHARACTERISTICS 2.2 Meteorology
-1.
With respect to extreme winds caused by tornadoes, see Comments 1 and 2 of Section 3.2.1.
2.
Earthquake accelerations and response spectra are not adequately discussed here.
In Section 3.2.3, " Seismic Design" (page 3.2-5) the design earth-quake is stated to have a horizontal acceleration of 0.lg, the minimum required for the ISFSI-DE in 10 CFR Part 72 (S 72.66(a)(6)(iii)).
At the same time a " maximum potential earthquake" with horizontal acceleration of 0.2g is used to demonstrate that the cask will remain upright for this acceleration. We believe that 0.2g is improperly chosen to make this case.
See 10 CFR Part 72, S 72.66(a)(6)(ii).
Note that east of the Rccky Mountain front in the U.S., the ISFSI-DE is " described by an appropriate response spectrum anchored" at 0.25g (see also Regulatory Guide 1.60,
" Design Response Spectra for Seismic Design of Nuclear Power Plants"),
unless the site has been evaluated under the criteria of Appendix A of 10 CFR Part 100 in'which case the ISFSI-DE shall be equivalent to the safe shutdown earthquake (SSE) for a nuclear power plant (S 72.66(a)(b)(i)),
or the site-specific ISFSI-DE may be determined by using the criteria and level of investigations required by Appendix A of 10 CFR Part 100.
For sites west of the Rocky Mountain front in the U.S., this latter method must be used (see S 72.66(a)(2)).
We suggest that the applicant not choose the minimum horizontal ground motion for the ISFSI-DE (i.e., 0.1g).
A higher horizontal ground motion value than 0.lg could allow the applicant to encompass a broader range of sites in the U.S.
If the applicant is choosing to preclude cask tipover then this may set an upper limit (see Comments on Section 3.2.3).
The choice is the applicant's to make.
(We also note that in Section 1.2.2 (p. 1.2-1) of the report values of 0.25g and "...in the range of 100g" are cited.)
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3 PRINCIPAL DESIGN CRITERIA 3.1 Purposes of Installation 3.1.1 Material to be Stored 1.
In view of the fact that the reference for the physical, thermal, and radiological characteristics of the spent BWR fuel to be stored are based on an average burnup of 27,000 mwd /MTU at a specific power of 22 MW/MTU (Wurgassen), what is the significance of the information presented in the first paragraph?
2.
Results presented in Tab. 3.1-2 are taken from NUREG-0404, Vol. 2 and are generated from an ORIGEN calculation of typical BWR fuel.
Is this fuel one of the types described in Section 1.1.2.5 (Spent Fuel Identification) and Tab. 1.1-1?
3.
What is the fuel enrichment and loading for this fuel?
4.
If burnups of 32,000 to 34,000 mwd /MTU are expected, include ORIGEN runs for these rates. This would serve to substantiate the reference to a 30%
increase in long-lived fission product and transuranic activity.
5.
For the reference fuel, provide ORIGEN results in tabular form similar to Tab. 3.1-2 as well.
Is this reference fuel one of the types described in Tab. 1.1-1? If so, the specific fuel type and enrichment should be given along with any other relevent irradiation conditions.
6.
Place all relevant tables and figures so as to immediately follow this section. Moreover, Fig. 3.1-3 through Fig. 3.1-6 should be annotated with pertinent irradiation condition / calculational information so as to stand alone (e.g., enrichment, loading, specific power, irradiation time, burnup, etc.).
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m 3.2.1 Tornado and Wind Loadings 1.
If tornado windspeeds can be "more than 140 m/s," why is the analysis limited to 140 m/sec? We suggest that you reference Regulatory Guide 1.76, " Design Basis Tornado for Nuclear Power Plants." Note that in Regulatory Guide 1.76, the maximum windspeed (occurring in Region I of 3
the United States) equals 360 mph (161 m/s).
2.
The geometry factor (aerodynamic force coefficient), Cw, is given as 1.56.
How.-was this particular number chosen,and how are we assured it is a reasonable choice?
3.
Using the methodology of Section 3.2.1 (Rayleigh's equation), a windspeed of 167 m/s can tip the cask.
The methodology using Rayleigh's equation to calculate the cross wind force, Fw, assumes a steady aerodynamic force on the cask.
In reality, unsteady aerodynamic forces will exist due to turbulence of the air flow and cask cross-sectional shape.
Also, there will be air flow effects due to the presence of a number of casks rather than just one.
How is it assured that the simple static analysis for wind load using Rayleigh's equation is conservative and that dynamic-effects' may be ruled out?
4.
A = 9.8 m2 is not the cask ground area but the projected area of the cask vertical face, equal to cask height times cask diameter.
5.
G = 81.100 kg is an error.
It should be G = 81.100 Mg where Mg is a mass unit.
3.2.3 Seismic Design See the Comments on Section 2.2, item 2.
1.
What are the relevant seismic loads on the cask?
2.
How are they depicted on a free-body diagram?
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3.
How is the seismic tipping (or overturning) moment, Mk, calculeted and what is its value? State assumptions in the analysis.
4.
Is vertical acceleration discounted?
3.2.5 Combined Load Criteria 1.
Tornado wind forces and tornado missiles are not discussed under Section 3.2.2 (see page 3.2-3).
2.
What are the assumptions, analyses and conclusions regarding the load combinations mentioned in Section 3.2.5? The applicant should systematically address applicable load combinations, dead, live, thermal, natural phenomena, and off normal.
3.
Where is it demonstrated that " Flooding in combination with cask tipping will not create a cask leakage"?
3.3 Safety Protection Systems 3.3.2 Protection by Multiple Confinement Barriers and Systems 3.3.2.1 Confinement Barriers and Systems 1.
As noted in Section 1.2.4 (Structural Features), there appear to be two different protective covers:
one that provides for the insert cover (Fig. 3.3-2) and one that does not (Fig. 3.3-1).
Their use should be clarified.
2.
Section 1.2.2 (Principal Design Criteria) gives the primary and secondary cover thicknesses as 340 mm and 130 mm, respectively.
In this section the respective cover thicknesses are given as 350 mm and 150 mm:
some 30 mm more.
Why is there a difference?
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3.
Address in this section criteria for protection against postulated accidents, design criteria for backup confinement, and the extent to which the design is based on minimizing releases. cThis information appears tojba lacking.
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4.
Fig. 3.3-1 through Fig. 3.3-4 should immediately follow this section.
5.
The following statment is made in paragraph 5 (p. 3.3-2), "For longer- '
term storage only the metal seal is evaluated." What is meant by
" evaluated" and where is the evaluation?
6.
Where is the " metal joint seal of the insert cover" mentioned in paragraph 1 (p. 3.3-3)?
7.
The " control connection" shown in both Figs. 3.3-1 and 3.3-2,is not referenced in the text. What is the control connection and what is its-function?
3.3.2.2 Activity Release 1.
How were the guaranteed He-standard lea,k rate for each seal, the total
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leak rate of both seals at loading after 1 year, and the double seal leak rate vs. storage time (Fig. 3.3-5) determined?
~iscuss also the 0
potential for diffusion through the nodular cast iron cask material and thereby loss of the He atmosphere either between lids or from the cask interior.
2.
There is an inconsistency in the leak. rate data given here.
It is stated that the leak rate of both seals combined is 5 x 10 8 nbar 1 sec 1 after 1 year, yet the leak rate shown in Fig._3.3-5 has not reached 5 x 10 9 mbar 1 sec 1 in 100 years.
3.
Is the gas temperature inside the cask of 423 K (150 C) the maximum to be expected?
If not, what is the maximum gas temperature and how will the release fractions be affected-(Tab. 3.3-1)?
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4.
Discuss why only 3H, asKr, 1291, W Cs, and 137Cs Were Considered to be the most active and longest lived volatile fission products.
5.
Describe the bases for the release fractions and sources of activities.
The release fraction data appear to come from WASH-1400 and the cavity inventory data from an ORIGEN run with a burnup of 27,000 mwd /MTU, 2.4%
enrichment, and 1 year cooling time (Appendix 1).
If these assumptions are correct, Tab. 3.3-1 should be so annotated and the ORIGEN run results referenced, assuming they are the same results presented in Section 3.1.1 (Material to be Stored).
Otherwise, the ORIGEN results should be presented and an explanation given as to wny they differ from the results presented in Section 3.1.1.
6.
If Appendix 1 is the source for the cavity inventory data of Tab. 3.3-1, then the release basis appears to be L% of cladding tubes damaged (s10 rods) and not 100%, as stated.
This discrepancy should be clarified.
7.
How were the annual activity releases computed? A sample calculation is appropriate here.
8.
The results in Tab. 3.3-2 imply that the annual activity release is constant.
However, Fig. 3.3-6 and Fig. 3.3-7 show a variation in the release with time (as does the leak rate).
This inconsistency should be clarified.
Is decay being considered? Are the releases computed at the cask surface?
9.
The relevant tables and figures should immediately follow this section.
Furthermore, Fig. 3.3-6 and Fig. 3.3-7 as well as Tab. 3.3-2 should also be annotated with the fuel enrichment, specific power, burnup, decay time, and all other information necessary to support the calculational result presented.
10.
Is the diaphragm-type pressure gauge specified a standard design instrument available from an outside vendor? What are its specifications?
8
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Figure 3.3-8 (p. 3.3-25) gives the schematic of the pressure gauge. What are the pressures in areas 1, 2, 3, and 4? These pressures should correlate with the actual pressure differences mentioned in paragraph three, p. 3.3-12.
3.3.3 Protection by Equipment and Instrumentation Selection 3.3.3.2 Instrumentation The requirement to discuss " features to provide testability" is not met.
How is the tightness surveillance system tested for proper operational function?
Fig. 3.3-8 and Tao. 3.3-3 should immediately follow this section.
3.3.4 Nuclear Criticality Safety 3.3.4.3 Verification Analysis Fig. 3.3-9 and Tab. 3.3-4 should immediately follow this section.
3.3.4.3.3 Criticality Calculations Fig. 3.3-10 and Tab. 3.3-5 should immediately follow this section.
Reference should be made to the fact that the results are for BWR fuels.
A confirmatory analysis for criticality requires the following additional information:
1.
Spacing between outer layer of pins and interior of fuel can.
2.
Spacing between top and bottom of fuel pins and interior of fuel can.
3.
Thickness of walls on top and bottom of fuel can.
4.
Material used for fuel can.
5.
Location of poison rods in bundle.
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6.
Complete specification of material used in poison rods (density, isotopic abundance, weight percent of each component).
7.
Geometric specification of poison rods.
8.
Complete specification of inserts between fuel bundles (material, geometry).
9.
Location of missing pins, if any.
3.3.5 Radiological Protection 3.3.5.2 Shielding The information required here is design criteria and estimates of the collective dose in man-rem per year for various operations, e.g., inspection, maintenance, and repair, etc. What is provided, for the most part, seems more appropriate for Section 7.3.2 (Shielding).
Much of the information in Appendix 2 is appropriate and should be brought forward.
However, the following additional information is required:
1.
Where are Figs. 1, 2, and 3?
2.
How was the mean neutron spectrum determined for ORIGEN?
3.
Provide details of the effective polyethylene layer thickness calculation.
4.
Provide precise descriptions of the source terms for the cask and end-piece calculations.
5.
Provide more details for the ORIGEN, ANISN, and 00T code calculations giving specific input / output and full documentation of assumptions and computational results.
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6.
There needs to be some clarification of the cask dimensions.
In Appendix 2, the wall thickness is 48.3 cm and the bottom and cover thicknesses are 45 cm each.
Section 1.2.2 (Principal Design Criteria)
Tab. 1.2-1 gives a wall thickness of 44 cm, a cover thickness of 47 cm (34 cm primary and 13 cm secondary) without the 8 cm protective cover,' and no bottom thickness.
Section 3.2.1 (Confinement Barriers and Systems) gives a cover thickness of 50 cm (35 cm primary and 15 cm secondary).
What are the correct dimensions for the cask, including the moderator rods and end plates? A tabulation of the dimensions critical to the shielding calculations is appropriate here.
In lieu of this, engineering drawings should be supplied.
7.
How was the measured surface dose rate experiment conducted to obtain the data shown in Fig. 3.3-12? Were the fuel conditions in the experiment the same as those in the shielding calculation?
8.
There is a significant difference between the maximum measured dose rate in Figure 3.3-12 (18.5 mrem /hr neutron + gamma) and the maximum calculated dose rate in TaDie 3.3-6 (10.4 mrem /hr neutron + gamma).
(The reference to Appendix 3 in the last line of p. 3.3-10 should refer to Appendix 2.)
To what is this difference attributed?
9.
The results presented for direct radiation and sky-shine in Fig. 3.3-14 would be more useful if the input data were included (e.g., fuel type and loading, specific power and burnup, cooling time, etc.).
Also the calculations are presented for a single cask with no attempt to model a line array or a rectangular array of casks (as shown in Figure-1.1-1).
Further, for curves b) and c) input data on earth wall and concrete building wall and roof thicknesses and compositions and densities are not given.
We also strongly suggest that, since arrays of casks may be placed at sites where erection of an earth wall or' building is not desired, calcula-tions also be performed for 5 year old spent fuel.
Arrays storing older 11 m. m.
i spent fuel can result in significantly lower dose rate versus distance values.
Older spent fuel (with 5 to 10 years' decay) is readily avail-able at reactors in the U.S.
10.
All relevant tables and figures should immediately follow this section.
In addition, they should be annotated with sufficient design bases /
calculational information so as to stand alone.
I 3.3.5.3 Radiolooical Alarm System 3.3.5.3.3 Cask Monitoring Calculational results presented in this section on pressure gauge behavior vs.
storage time, and detailed in Appendix 3, cannot be verified.
Information referenced and used in the appendix to determine the temperature in the pressure gauge is not currently available.
3.3.6 Fire and Explosion Protection 3.3.7 Materials Handling and Storage 3.3.7.1 Spent Fuel Handling and Storage 1.
Where do the maximum external contamination limits come from?
2.
The idea "that the maximum cladding temperature in dry storage casks should be comparable with values during reactor operation" is not valid l
for long-term dry storage.
The integrity of the cladding is the issue.
It must be demonstrated that the cladding temperature, over long storage periods, would not be expected to compromise the integrity of the fuel cladding.
l We note that in Section 5.1.3.6, in the last paragraph of page 5.1-11, reference is made to Section 2.7 of Appendix 4, " Shipping Cask Storage Site Gorleben Safety Analysis Report." Inclusion of Appendix 4 is i
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permissible for information purposes only, since it addresses legal and safety requirements of the Federal Republic of Germany.
This does not preclude abstracting Section 2.7 for use in this report. Whether this is done, or whether the information of Section 2.7 is presented elsewhere in this report, further information is needed regarding fuel cladding integrity. With respect to establishing that the temperature discussed, 425 C, is acceptable for fuel storage for a period of 20 years, more detailed explanation is needed than that provided in Section 2.7.3,
" Cladding Integrity."
(The applicant may wish to demonstrate a less stringent limit than a constant 425 C taking into account fuel temperature decrease.
The reviewer's concern here is simply to establish what design limits are being specified by the applicant and that these are adequately verified by tests and/or analyses.)
Tests referenced cq page 49 of Appendix 4, fifth full paragraph, i.e.,
" Extensive tests (pp. 2.7-3, 2.7-4) have shown that cladding integrity is not threatened provided the creep referred to the cladding circumference does not exceed 1%," should be detailed.
Provide details on the Exxon GAPEX 2 code and the calculations made using i t.
Discuss creep rupture.
In Section 2.7.3.1, " Corrosion of Cladding" on page 50 the statement is made, "The filling of the shipping cask with inert gas (helium) prevents external corrosion" (pp. 2.7-3, 2.7-4).
Explain the procedures for assur-ing that gaseous impurities and residual water are removed.
Give limiting values.
Demonstrate that no significant corrosion can result.
Provide more detailed discussion of stress corrosion cracking induced by fission products (iodine) and hydrogen embrittlement (Appendix 4, Section 2.7.3.1, pp. 50-51).
The objective of this effort is to adequately demonstrate that dry storage under the conditions described does not cause degradation and 4
gross rupture of spent fuel.
I 13 i
While fuel known to be defective is precluded from storage, discussion of crack propagation (Appendix 4, Section 2.7.3.1, p. 51) should be included in detail since presumably some small fraction of fuel rods may have defects which escape detection at storage and the potential consequences of this should be considered (see comments, Section 3.5.1, item 6).
In summary, potential mechanisms for fuel cladding failure including creep rupture, stress corrosion cracking induced by fission products, hydriding and oxidation should be addressed.
Design bases should be established with respect to these mechanisms such that over long storage periods fuel cladding failure is not expected, and it should be demonstrated that these design bases are met.
3.
Since the heat output of the assemblies and the ambient air temperature will affect the maximum cladding temperature, provide justifiable design limits for these parameters.
4.
Provide a description and results of calculations and/or tests that determine the fuel cladding storage temperature limit.
Provide enough calculational detail to allow an evaluation as to adequacy.
5.
What are the surface contamination levels specified in the " transport regu-lations?" Are these the maximum external contamination limits presented (y/p 10 4 mci /cm2 and a 10 s mci /cm )? Do all references to the " transport 2
regulations" imply 49 CFR Part 173?
6.
In this report the statement is made (p. 3.3-15), "The handling and dry storage of defective fuel assemblies involves no restrictions beyond those for intact fuel assemblies."
In the U.S. there is no need to place spent fuel known to be defective in dry storage.
Therefore, no fuel known to be defective should be accepted for cask storage.
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3.3.7.2 Radioactive Waste Treatment Substantiate and clarify the claim that the " casks remain permanently sealed" and that the containment " securely prevents the escape of radioactive materials."
3.5 Decommissioning Considerations 3.5.1 Storage Casks 1.
Assumption 2 implies that the neutron source (spent fuel) was only present for 10 years.
Assumption 3 implies that the neutron source can be present for the full 40 years.
The former would appear to be incorrectly stated based upon the results presented.
It should be clarified.
2.
How was the thermal neutron flux in Fig 3.5-1 determined?
3.
What is the activation thickness used and the volume of material assumed?
Were the cover and bottom included in the calculations?
4.
How were the ORIGEN activation calculations performed.with the assumed thermal neutron flux? Was the variation in the flux accounted for via finite irradiation times? What was the material composition assumed?
4 5.
Are there activation products other than 54Mn, ssFe, and ssFe of any significance?
6.
At time of decommissioning spent fuel will be unloaded from the cask (s).
Describe the capability of the cask, as designed, and the procedures to be followed to sample for the possible failure of spent fuel cladding integrity.
In the event of any failed fuel, what steps can be taken to avoid contaminating the cask unloading area when spent fuel is removed from the cask?
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4 INSTALLATION DESIGN 4.2 Storage Structures Chapter 1 is an introduction.
Chapter 3 covers principal design criteria and is a more appropriate reference.
4.2.1 Structural Soecifications It is implied that the proportions of the components are not dictated by allow-able stress levels but rather by shielding requirements.
Nevertheless, analyses to determine stress levels are performed,and it is necessary to compare the results with acceptable limits.
1.
Provide stress or deformation limits for all components that are analyzed for structural adequacy.
2.
Provide the source or rationale for the limits on stress or deformation.
4.2.1.1 Calculation of the Cask Body Comments relating to this subparagraph apply to the analysis of all structural components.
1.
What is the objective of this analysis?
2.
Describe the components or reference to a drawing or an idealized diagram.
3.
Describe the loading on the component with the aid of a free-body diagram.
4.
State the source of the loads and the degree of conservatism assumed.
5.
Describe the failure mode for which the component is analyzed.
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6.
Provide the applicable stress or deformation limits associated with the assumed failure modes.
7.
State the governing equation for the analyses and define its terms.
8.
List the values for the parameters of the governing equations making sure that their source is obvious.
9.
Record the numerical results.
It is not necessary to rewrite the equations with numerical substitutions.
i 10.
Compare the results with the assumed stress limits and record the margin of safety.
11.
Describe how the results relate to the objective of the analysis.
State the conclusion of the analysis.
- 12. All drawings, graphical results, and tables should follow their reference in the analysis.
4.2.1.2 Calculation of the Primary Lid 1.
The primary lid presents a very thick plate geometry.
How is thin plate theory justified for the primary lid calculations?
2.
What are the edge boundary conditions?
3.
What is the " hypothesis of the maximum work of shape alteration" (p. 4.2-4 and p. 4.2-6) and its reference?
4.
Describe the " computer program" mentioned on page 4.2-4.
5.
What is meant by " strains in the radial direction increase analogically
(?) with the reduction in the cross section"?
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4.2.1.3 -Calculation of the Secondary Cover 1.
Although the secondary cover is.a much thinner " plate" than the primary lid, is it " thin" enough to justify thin plate theory?
2.
What are the edge boundary conditions?
4.2.1.4 Ca'lculation of the Primary Cover Bolts 1.
What is meant by the specification M42x3 for the size of the bolt?
2.
How is the mass of the cover, 2175 Kg, and the number of bolts, 36, used in the design calculations?
3.
How is the pretensioning force, 92,873N, and the operating force on the bolt, 21,305N, calculated?
4.
What is the " Force ratio for centric initiation of the axial force," and how is its value, 0.11, calculated?
5.
What are values for a and y'?
6.
Provide a graphical illustration of both the root thread and the core diameter.
The reviewers may not be familar with German thread standards.
7.
How is the loading of the bolts at fitting, 136N/mm, calculated and how does it relate to the expression given for s ?
y 8.
What is the rationale behind the expressions (and their sources) for the maximum bolt force per bolt, Fs max, and s ?
4.2.1.5 Calculation of the Secondary Cover Bolts See questions and comments on Section 4.2.1.4.
i 18
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4.2.1.6 Material Properties 1.
This section should either be entitled " Ductile Cast Iron Material Properties" or provide properties of all material used for each major component.
2.
How does material ductility relate to qualifying the cask against brittle failure?
3.
Describe the role of fracture mechanics and provide appropriate fracture toughness data.
4.
What is the reference (Appendix or other published results) for the
" positive tests with the prototype CASTOR cask" mentioned on p. 4.2-15?
5.
How do the results of these tests help to assure "the actual values established for the CASTOR prototype apply as nominal values for the mass produced casks of the CASTOR-family?"
6.
What is the reference (Appendix or other published results) for the
" positive results of drop tests with the prototype CASTOR cask"?
7.
Regarding the 9m free drop test, where is the description of this test?
8.
The ratio of yield to ultimate strength serves only to provide a narrower dispersion of the ductility parameters.
However, elongation and reduction of area are significant material parameters only when some degrees of plastic deformation is allowed.
How do they relate to qualification of the cask against brittle failure?
9.
In view of the wide dispersion of material properties listed in Tab. 4.2.1 (e.g., 1% to 24.5% elongation) how is it possible to consider a factor of safety of at least unity (or margin of safety of zero) as adequate for safety?
In the drop test, one or even several prototype casks may not fail because critical stress did not coincide with the critical strength 19
~
~ ~ ~,
parameter. With such a large dispersion of properties and a factor of safety of 1, how can it be assured that mass produced casks will not fail, if one or even several prototype casks do not fail?
- 10. What is the source for the "more than 120 material tests" (p. 4.2-16) and the data listed in Tab. 4.2.1?
- 11. Where is page 1 of Appendix 5?
4.2.2 Installation Layout While Appendices 1 and 4 are not considered a part of this review and are considered to be included for informational purposes only, we note that Appen-dix 4 indicates an optimum distance (for handling purposes) of 2.80m from cask center-to-center.
In Section 8.1.1.3. (Analysis of Effects and Consequences),
a cask center-to-center spacing "in the range of 3.00m" is advocated to elimi-nate the DOMINO effect of cask tipping. Which criterion governs the spacing of
[
the casks?
4.3 Auxiliary Systems 4.3.7 Communications and Alarm Systems There is a need to " describe the functioning of the... alarms in response to normal and off-normal operations and under accident conditions." The discussion-in Section 3.3.5.3.3 (Cask Monitoring) contains no such description, nor is it included here.
Is there a difference in'the functioning of the alarms in response to the various cond!tions?
4.5 Shipping Cask Repair and Maintenance The statement " cask repair is not necessary" is contradicted by the subsequent statement " restoration of double confinement in the improbable case of failure of one of the sealing systems will be executed...."
This requires clarification.
20
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5 OPERATION SYSTEMS 5.1 Operation Description 5.1.1 Narrative Description 1.
There is a need in this section to " describe the means that will be routinely used during storage to evaluate the condition of the casks."
From the GNS discussion, it appears that the tightness surveillance system and periodic inspection are the only evaluation methods under consideration.
There is mention of temperature control for the arriving cask.
Is routine monitoring of the internal / external cask temperatures contemplated?
2.
There is mention that eventual maintenance may be necessary.
Yet, in Section 5.1.3.5 (Maintenance Techniques) GNS states that " maintenance tasks... are not foreseen," only the possibility of repair (installation of an insert cover).
This requires clarification.
5.1.2 Flow Sheets 1.
GNS states that "the time necessary for handling procedures described in Fig. 5.1-1 is approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />." Does this time include both the storage area and loading area procedures?'
2.
How was the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> determined?
3.
.How long are the work periods for the various procedures listed, and are two people required for each procedure?
4.
How was the dose calculation performed?
5.
Fig. 3.3-12 does not seem relevant here since it represents the measured surface dose rate while a mean distance of 1 meter has been assumed.
From Tab. 3.3-6, the average dose rate for the side and middle of the cover at 1 meter is 0.005 rem /hr.
Using this average and the other information 21
-~W 'P"'
currently available, the dose at 1 meter would appear to be 2 men x 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> x 0.005 rem /hr = 0.04 manrem--not 0.08 manrem.
The number of personnel, time period, and dose rate used for each handling procedure must be given.
6.
Fig. 5.1-1 should immediately follow this section.
Furthermore, the personnel and time periods required for each should be added.
7.
Appendix 6 refers to fracture toughness evalulation and is an incorrect reference for this section. Where is the proper reference?
5.1.3.6 Heat Transfer Design 1.
It is stated that a limit on cladding temperature is to be maintained during dry storage.
Provide a description and results of calculations and/or tests that determine this limit.
Provide enough calculational detail to allow an evaluation as to adequacy.
The temperature limit determined should later be applied as a criterion for determining the maximum fuel decay heat that the cask must dissipate.
2.
It is stated that Appendix 7 gives results for cask surface temperature.
It is unclear how this information is intended to relate to calculations presented in Appendix 8 and in later parts of this section.
3.
Appendix 8 heat transfer calculations show a 370 maximum cladding tempera-ture for 18.144 kw of fuel decay heat and 20* ambient air conditions.
This data does not appear to be consistent with the numerical values of Figs. 5.1-4 and 5.1-5 and Tab. 5.1-2.
4.
On page 5.1-11 it ;is stated that the cask can dissipate 30 kw of power.
In addition, a maximum allowable cladding temperature of 425 has been assumed.
However, it appears that, from Fig. 5.1-5 and Tab. 5.1-2, this 425 cladding temperature will be exceeded and that the cask can only dis-sipate ~27 kw without exceeding the maximum allowable cladding temperatures.
22 w
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5.
Provide the source of the information of Figs. 5.1-4 and 5.1-5, and Tabs. 5.1-1 and 5.1-2, with sufficient detail to allow an independent evaluation.
6.
Figure 5.1-4 presents data from calculations of fuel cladding temperature for higher ambient air temperatures than those of Appendix 8.
- However, the fuel cladding temperature is calculated to be lower than in Appendix 8.
Resolve.this discrepancy.
7.
Figure 5.1-6 presents surface temperature profiles for a square array of casks.
Provide details of calculations and/or experiments that provide the basis for the data in sufficient detail to allow evaluation as to adequacy.
Include information as to assumed cask square array spacing.
Additionally provide detailed information about calculations and/or data that forms the basis of the single cask temperature profile.
5.3.2 Component / Equipment Spares This paragraph has not been addressed. There should be a discussion relating to replacement of the secondary cover in the event that it fails, and addition of the insert cover in the event that the primary cover fails.
Reliability of the tightness surveillance system is also of interest here.
Design provisions to minimize exposure to radiation during repair operations should also be addressed.
6 WASTE CONFINEMENT AND MANAGEMENT 6.1 Waste Sources 1.
Cite the transport regulations referred to here.
2.
In Section 3.3.7.1 (Spent Fuel Handling and Storage), the surface activ-ities are given in terms of mci; here they are in terms of Ci.
The units should be consistent.
23
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6.5 Radiological Impact of Normal Operations 1.
This paragraph states that the total annual activity release is on the order of 10 9 Ci/y, yet Tab. 3.3.-2 shows the annual 3H release to be 1 x 10 8 Ci/y alone.
Reference to-Section 3.3.2.2 (Activity Release) and the ORIGEN results from which the referenced figures and table were generated should satisfy the source description requirements of this section.
2.
It is not apparent how the dose calculation was performed. Where does the diffusion factor come from,and how was it determined? Were the nuclides of Tab. 3.3-2 used in the calculation? Were flux-to-dose conversion factors used and, if so, how were they established?
7 RADIATION PROTECTION 7.1 Ensuring That Occupational Radiation Exposures Are As low As Is Reasonably Achievable (ALARA) 7.1.1 Policy Consideration 1.
The requirements of this section are, for the most part, site specific.
In addition, Regulatory Guides 8.8 and 8.10 center on management policies, administrative procedures, and design features associated with an instal-lation.
To the extent that the guides may be used, the GNS comments seem appropriate.
However, each statement made by GNS in this section should be documented, where necessary, and should cite the specific guide and requirement it responds to.
2.
The claims that "the double confinement system assures the absence of any measurable release under normal, abnormal, or accident conditions," and that " double containcent can be restored by simple methods witnout release i
of activity" must be substantiated.
24
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4 3.
Section 3.3.2.2 (Activity Release) discusses releases during normal opera-tions for 100% (?l%) cladding tube failure.
Section 8.1.1.3 (Analysis of Effects and Consequences) discusses releases during off-normal operations involving primary or secondary cover failure with 1% or 100% cladding tube failure.
Does not Section 8.1.1.3 contradict the later claim by its exist-ence? See also Table 3.3-1-(for 100% cladding damage) and Table 8.1-2 (for 1% cladding rupture).
4.
More detail on the policies regarding " unavoidable maintenance work and routine optical inspection" of the casks should be-furnished.
The requirement to indicate how the regulatory guides will be followed is not addressed.
7.1. 2 Design Considerations Many of the design considerations are site specific.
However, with respect to the cask, some discussion of the maintenance procedures and time periods required to perform the various functions that lead to occLpational exposure is appropriate.
It should be made clear how the design reduces the occupational exposure during maintenance.
The need is to indicate how position 2 (with the exception of the shielding reference) of Regulatory Guide 8.8 will be fulfilled.
It is suggested that each section of regulatory position 2 be addressed separately and sequentially.
Those sections that are site specific or irrelevent can be so identified.
7.2 Radiation Sources 7.2.1 Characterization of Sources The sources described in Section 3.1.1 (Material to be Stored), Tabs. 3.1-1 and 3.1-2, are for a " typical" BWR whose fuel enrichment, loading, etc., are not defined.
Sources associated with the referenced Wurgassen fuel are not provided.
It is required that "the sources of radiation... be described in the manner needed as input to the shielding design calculations." Furthermore, the guide states that "the description should includa a tabulation of all sources 25 i
. - m -. - -.m_ s:
by isotopic composition, X-and gamma-ray energy groups, strength (curie content), and geometry and should provide the basis for the valtos." In this section and Section 3.1.1, the information presented is inadequate.
We suggest that the applicant may wish to choose a specific U.S. reactor BWR spent fuel and provide information related to it for various decay times and burnups.
7.2.2 Airborne Radioactive Material Sources 1.
The information requested in this section refers to airborne concentrations, and the activity releases are cited in Section 3.3.2.2.
Is there not some working volume of air that surrounds the cask that can be assumed for a concentration calculation? The models and parameters for calculating the airborne concentrations should be provided.
2.
Describe the " provisions made for personnel protective measures." If none are required eit.;er be tuse the exposure periods (inspection or mainte-nance) are relatively short, or the activity release is extremely low, it should be so stated.
7.3 Radiation Protection Design Features 7.3.1 Installation Design Features 1.
Provide specific activity, physical and chemical characteristics, and expected concentrations for all sources in Section 7.2.
2.
Provide projected radiation dose rates for the storage area (for a single cask and representative arrays) that personnel can be expected to encounter during maintenance and repair and surveillance activities.
3.
Comments presented above in Section 7.1.2 (Design Considerations) are also relevant here.
26
~.
- -. ~..
4 7.3.2 Shielding Comments associated with Section 3.3.5.2 (Shielding) are even more appropriate here. Whether in this section or Section 3.3.5.2, the information available is inadequate.
7.3.4 Area Radiation and Airborne and Radioactivity Monitoring Instrumentation For a generic installation consisting of a single cask (loaded) with no struc-tures and AR storage, referencing the comments under Section 3.3.3.2 and Sec-tion 3.3.5.3 of this report may be adequate once the deficiencies noted earlier in those sections are, corrected.
7.4 Estimated Onsite Collective Dose Assessment 1.
Ilow were the two reported doses (0.01 ren and 0.05 rem) computed?
2.
In the case of the optical inspection, is an average dose rate assumed?
3.
What is the dose rate assumed for an individual at, say, 1 meter from the cask side, the surface of the cask cover, or some combination of location and distance?
4.
How was the 1-hour time period for the optical inspection determined?
5.
How was the time for control of cask confinement including tightness testing determined?
6.
What fraction of the 4-to 6-hour period is dedicated to tightness testing alone?
7.
Are there any other procedures involved, and how many people are required for each?
8.
Provide the details and bases for all the above calculations.
27
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. nuu
8 ACCIDENT ANALYSIS 8.1 Off-t!ormal Operations 8.1.1 Event 8.1.1.1 Postulated Cause of the Event 1.
If an off-normal condition for a seal failure can be postulated, describe the failure mechanisms involved such as material degradation, faulty installation, etc.
2.
What are the possible failure mechanisms for the pressure gauge components and monitoring system?
8.1.1.2 Detection of Event 1.
In Section 8.1.1.1 (Postulated Cause of the Event) GNS states that "a hypothetical failu*e of the pressure gauge components (i.e., diaphragm membrane) or interruption of the electrical energy supply for the monitor-ing system can be considered." Yet their only discussion appears to be the references to Section 3.3.3 (Protection by Equipment and Instrumenta-tion Selection) and Section 3.3.5 (Radiological Protection).
Reference to more specific sections, i.e., Section 3.3 3.2 (Instrumentation) and 3.3.5.3.3 (Cask Monitoring),- or, better yet, summaries of the pertinent information from the more specific sections, would be appropriate.
2.'
How is detection of a failure of the pressure gauge itself and its monitor-ing system accomplished?
8.1.1.3 Analysis of Effects and Consequences l
1.
Since the references for activity release are to material presented in Section 3.3.2.2 (Activity Release), many comments presented there will l
remain appropriate here until the noted deficiencies are corrected.
l l
28
-...n..
2.
On page 8.1.4, cases C, D, and E are indicated to be off normal operations requiring corrective action. Why is case E omitted in the first paragraph discussion?
3.
In Tab. 8.1-3, case E is the only one identified with corrective action required (**).
What about cases C and D?
4.
Do the releases presented for cases C and D assume no corrective action during the specified storing time? See Section 8.1.1.3 (pp. 8.1-4-8.1-5).
5.
Why are the case D and E releases for 3 H different by 1000, when the difference for all other isotopes is a factor of 100?
6.
Provide the details of the activity calculations in Tab. 8.1-3 including an example.
7.
Are the case E releases truly undetectable?
l 8.
There is no discussion of the consequences of the failure of the pressure gauge components or interruptica of the electrial energy supply for the monitoring system.
Even though there may be no consequences, it should be stated.
9.
Tab. 8.1-1 through Tab. 8.1-3 should immediately follow this section.
They should also be appropriately annotated with sufficient reference information so as to stand alone.
10.
Is Tab. 8.1-1 an exhaustive list of off-normal events?
8.1.1. 4 Corrective Action Fig. 8.1-1 should immediately follow this section.
It would also be useful to have the time periods associated with each action step added to the figure.
29
,----,.77.
Figure 8.1-1 is not a summary of " Corrective Action for all Off-Normal Operation (s)," as the title suggests, but a summary of corrective actions for the off-normal event of seal failure only. What are summaries for corrective actions for all off-normal events?
8.1.2 Radiological Impact from Off-Normal Operations The GNS statement that "it can be seen from Tab. 8.1-3 that no radiological effect will occur beyond the controlled area" is intuitive.
Even though the activity releases are low, without the limits of the controlled area defined, and a dilution factor assumed, the statement cannot be proven.
Furthermore, the activity releases should be presented in terms of dose, as requested.
For the corrective action dose rate calculations, we question the use of an average surface dose rate of 10 mrem /hr. Would not the surface dose rate at the middle of the cover (16.8 mrem /hr) be more appropriate? Also, how was the time period for the corrective action determined?
8.2.1.2 Accident Analysis 1.
All structural analyses associated with accident loadings should be organized in accordance with recommendations shown in Section 4.2.1.1.
2.
Claims for maintaining structural integrity under a 9m drop are made based upon the survival of a prototype cask subjected to this test and the assertion that Castor Ic, because of its weight, geometry etc., will be subjected to smaller loads.
The prototype test was conducted in such a way that the trunnions impacted first, generating a bending stress in the center of the cask.
GNS claims that this is the most critical configura-tion.
However, it appears to us that this test does not measure the ability of the ductile cast iron to survive impact on the hard unyielding surface.
The relatively ductile trunnions deform and serve to mitigate the shock.
Is there no other orientation for the cask to assume in an accident where direct impact on the iron is possible? We believe that GNS will have to demonstrate that the trunnion impact configuration is truly the most critical.
30 n-
If, while the cask is being transported, shock absorbers are in use on the cask, the trunnion impact may be a worst case.
However, the shock absorbers are removed when the cask is emplaced for storage.
Is the trunnion impact with shock absorbers worse than a cask tipover impact at some orientation without shock absorbers? Discuss and demonstrate with calculations (see comments Sec 1.2.4, item 2).
3.
The discussion in Appendix 5 argues against the practicality of using linear elastic fracture mechanics to qualify the cask for resistance to brittle fracture.
Yet Appendix 6 presents a detailed analysis and a record of sophisticated fracture toughness tests to show that the cask will not fail by brittle fracture.
These two appendices must somehow be reconciled.
4.
The large allowable flaw sizes indicated in Appendix 6 are based on stress levels that need to be justified by an analysis of the cask for its most critical impact configuration.
5.
Reference is made to fire tests and a test simulating burial of the cask.
Provide details of the tests and/or calculations for the above to allow evaluation as to adequacy.
10 OPERATING CONTROLS AND LIMITS In general there has been no response to our previous comments with respect to this chapter (see pages 39-42 of the enclosure to the September 9, 1982 letter from Leland C. Rouse, Chief, Advanced Fuel and Spent Fuel Licensing Branch, to Gesellschaft fur Nuklear Service mbH).
Accordingly, our comments herein repeat those previously made with scae modifications including format changes to follow Revision 1 to the submitted report.
We will expect each applicant for site-specific use of the cask to specify j
operational controls and limits that apply to the individual case.
- However, GNS should identify and provide in this section the bases for any generic controls and limits for use of the cask that they determine are applicable.
31
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i 10.1 Proposed Operating Controls and Limits 10.1.1 Contents of Operating Controls and Limits What about operating controls and limits on cask leak rates?
What about fuel characteristic limits?
What about siting limitations?
Describe in more detail the cask surface temperature limits.
10.1.2 Bases for Operating Controls and Limits For any new areas identified under Section 10.1.1, a description of the bases should be provided.
10.1.2.1 Cask Surface Temperature Limit Provide the maximum cask surface temperature limit.
(Fuel specific power and applicable site parameter limits should be used in the analysis performed for Section 5.1.3.6 to determine this limit.)
10.1.2.2 Cask Surface /Of f-Surface Dose Rate Limit The analysis performed for Section 3.3.5.2 should be referenced here.
10.1.2.3 Cast Tightness Control The 10 CFR Parts 72.72 and 72.74 requirements referenced here should be so stated, where applicable.
10.1.2.4 Fuel Characteristic Limits Provide the specific power from the reference fuel assembly.
32
~--
Provide the maximum fuel clad temperature reached by fuel in storage (this value should have been obtained from analysis in Chapter 5, Section 5.1.3.6, for fuel assembly specific power and external phenomena extremes, i.e.,
maximum ambient temperature and maximum solar insolation).
10.1.2.5 Siting Limitations Provide siting limitations used in tl.e cask design analysis includir;g maxi-mum and minimum ambient temperature and, if relevant, their periods of dura-tion, maximum solar insolation, temperature transient information on maximum expected site temperature decreases or increases over minimum periods of time, i.e., minutes, hours, or a day. While site data should be discussed in detail in Chapter 2, operating limits should be summarized in this section.
(These should be related to the analysis performed in Section 5.1.3.6 as to their use in establishing a maximum fuel clad temperature.)
10.2 Development of Operating Controls and Limits For any new areas identified under Section 10.1.1, a description should be provided under Equipment (Section 10.2.2.1), Technical Conditions and Character-istics (Section 10.2.2.2), and any other subsections of 10.2 that are pertinent.
10.2.1 Functional and Operating Limits, Monitoring Instruments, and Limiting J
Control Settings 10.2.2 Limiting Conditions for Operations 10.2.2.1 Equipment The pertinent material referenced in this section should be consolidated and brought forward from the appendices.
Note:
there is no Appendix 15 (as referenced) and Appendix 11 does not seem to apply.
See comments, Sec-tion 3.3.2.2, item 11, and Section 3.3.3.2.
What are limits specified?
33
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10.2.2.2 Technical Conditions 10.2.2.2.1 Cask Surface Temperature 4
Describe conditions for the Castor Ic cask only.
Give the time to thermal equilibrium for the cask after the fuel is loaded.
The measured surface cask temperature should not exceed the predicted cask surface temperature for the conditions under which actual measurement is made.
Provide in tabular form predicted cask surface temperatures at specified locations, for the reference fuel and ambient temperatures, solar insolation values, etc., for comparison with measured values.
10.2.2.2.2 Cask Exterior Dose Rate Limits 1.
Provide in tabular form cask surface and off-surface dose. rates at various distance from a single cask and from representative cask arrays.
These predicted values should not be exceeded by measured values under the same conditions.
If the maximum allowable dose rate (200 mrem /hr) on the cask surface is the design dose rate, then it should be so referenced.
2.
Are the transport regulations referred to in the second paragraph 49 CFR Part 173?
10.2.2.2.3 Fuel Characteristics Provide specifications on the quantity, type, and characteristics of the fuel 9
that may be loaded in the cask such that the thermal, criticality, and radiation dose rate design limits established for the cask in this report will I
not be exceeded (e.g., the initial enrichment, weight of uranium, maximum burnup, and minimum decay time since removal from the reactor core for spent fuel assemblies stored).
i l
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34 i
r
10.2.2.2.4 Siting Limitations Specify applicable siting limitations.
While such limitations are site Specific, listing them will provide any potential applicant with a means to compare this information with a potential site and to determine if the site is enveloped by these limitations or if modifications are needed before the cask design and fuel specified can be used.
10.2.3 Surveillance Requirements Generally, GNS comments seem adequate.
However, further information about the maintenance operations may be appropriate.
10.2.4 Design Features 10.2.5 Administrative Controls Little can be r, aid here because of the site specific nature of the requirements.
All material presented should be generic.
Using any information that is specific to Gorleben is not appropriate here.
s 10.2.6 Operating Controls and Limits In this section GNS need only address the installation conditions chosen.
Regulatory Guide 3.48 suggests a format for specifying the controls and limits.
It is strongly recommended that this format be followed.
11 QUALITY ASSURANCE The description of a Qualit Assurance (QA) Program presented in Chapter 11 and Appendix 11 cannot be adequately reviewed.
Accordingly, we are including with our comments on Chapter 11 and Appendix 11 a QA checklist which our Quality Assurance Branch, Division of Quality Assurance, Safeguards and Inspection Programs, Office of Inspections and Enforcement, has established for the review 35
. +a-
~=
of a QA program for the design and fabrication of dry spent fuel storage casks.
The attached QA checkli,st follows our comments.
It is not clear whether the applicant is GNS USA or GNS Germany. We understand that GNS USA presently may not be equipped to follow through on the QA program described in the handbook.
Thus, the statement in 0.3 of the handbook that
" Responsibility for the quality of the casks... is accepted by GNS USA" does not appear to have a solid foundation.
We need a description of the applicant's QA program which will as'sure the quality of the delivered casks.
Chapter 11 of the topical report states that Appendix 11 is "an example for a Quality Assurance Handbook," and Appendix 11 is marked "Draf t:
August 18, 1981."
Such words a*e not acceptable in that the QA program description should be a
~
commitment,of what will be done to meet regulatory QA requirments.
The handbook is organized in accordance with the 18 criteria of 10 CFR Part 50 Appendix B (referenced in 6 72.80) and 10 CFR Part 71 Appendix E and appears to address a number of the checklist items.
However, the information in the handbook should be presented as commitments, and each of the checklist items should be addressed.
If work is proceeding on the design and manufacture of' GNS dry storage casks for use in the USA, a QA program which meets each of the checklist items should be operational covering such work in process.
To summarize, the following clarification is required before we make a detailed review of the QA program description for GNS spent fuel storage casks:
1.
Who is the applicant? We need a description of the applicant's QA program to assure cask quality.
l 2.
If the applicant is not the designer / manufacturer, then we also need a description of the designer / manufacturer's QA program to assure cask quality.
36
\\
,m.
l i
3.
Each QA program description should address each item in the QA checklist and tell how the involved organizations will meet.the regulatory requirctents.
Please revise Chapter 11 and Appendix 11 in accordance with the above comments and the attached QA checklist.
i 37
-.-..-..---.:,.-- - ~ ':"'~ 2 z >^*
QA Checklist for Dry Storage Casks The applicant must establish a QA program for design and fabrication in accordance with 10 CFR Part 50, Appendix B. " Quality Assurance Criteria for Nuclear Power Plant.s and Fuel Reprocessing Plants." This program must be described to the extent of demonstrating hok each. criterion of Appendix B will be met.
The acceptance criteria used by the QAB in its evaluation of this program are listed in the following eighteen subsections.
If the QA program meets these acceptance criteria, the program is considered acceptable.
I.
The Organization elements responsible for the QA program are acceptable if:
1.
The responsibility for the QA program is retained and exercised by the applicant.
2.
The QA/QC functions, perfonned by the applicant's QA organization or delegated to other organizations, are identified and described, providing controls to ass' re all elements of Appendix B will be u
implemented.
3.
Clear and effective lines of communication between the QA organiza-tions of the applicant and his suppliers are established to assure proper direction of the QA program and resolution of QA probleins.
4.
Organization charts demonstrate adequate management control' over quality.
5.
A high level of management is responsible for establishing the cor-porate or company QA policies, goals, and objectives and this manage-ment level maintains a continuing invo.lvement' in QA matters.
Communication through any intermediate levels of management between this position and the Manager (or Director) of QA must be shown to be effective.
6.
The applicant designates a position, to La filled by a qualified individual, to retain overall authority and responsibility for the QA program.
7.
The authority and independence of the individual responsible for managing the QA program are such that he can direct and ~ control the organization's QA/QC program, can effectively assure the conformance to quality requirements, and is independent of undue influences and responsibilities for schedules and costs.
An acceptable organizational structure would have this individual report to at least the same organizational level as the highest line manager directly responsible for perfonning activities affecting quality.
w 5%
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^ 8.
Positions or groups responsible for defining and controlling the content of the QA program and related manuals and the management level responsible fcr final review and approval have appropriate organizational position and authority.
9.
The qualification requirements for the principal QA/QC management positions demonstrate competence comensurate with the responsi-bilities of these positions.
~~
- 10. Verification of confomance to established requirements is accomplished by individuals or groups who do not have direct responsibility for perfonning the work being verified.
11.
Persons and organizations performing QA/QC functions have direct access to management levels which will assure accomplishment of quality-l affecting activities. These personnel have sufficient authority and organizational freedom to perform their QA/QC functions effectively and without reservation. They can:
.a.
Identify quality problems.
b.
Initiate, recommend, or provide solutions through designated cha nnels.
I c.
Verify implementation of solutions.
12.
Designated QA individuals have the responsibility and authority '
delineated in writing, to stop unsatisfactory work and control further processing, delivery, or installation of nonconfonning material.
II.
The Quality Assurance Program description is acceptable if:
1.
Measures are provided by the applicant that demonstrate how the QA program meets 10 CFR Part 50, Appendix B criteria.
2.
Management regularly assess the effectiveness of the QA program.
3.
Measures are provided by the applicant to assure that trained, quali-fled personnel within his organization are assigned to detennine that functions delegated to his contractors are being properly accomplished.
4.
A brief summary of the Company's corporate QA policies, goals, and objectives is given and a meaningful channel for transmittal of these policies, goals, and objectives down through the levels of management is established.
5.
QA/QC responsibilities are designated for the implementation of the major activities contained in the QA manuals.
6.
Provisions are established to control the distribution of the QA manuals and revisions thereto.
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Provisions are established for communicating to all responsible organizations and individuals that quality policies, QA manuals, and procedures are mandatory requirements.
8.
A. listing of the QA procedures plus a matrix of these procedures cross referenced to each criterion of Appendix B to 10 CFR Part 50 demon-s trate that Appendix B provisions are fully implemented by documented procedures.
9.
The safety-related structures, systems, and components controlled by
.the QA program are identified.
- 10. The applicant reviews and documents agreement. with the QA program l
provisions of his suppliers to the extent that he can be assureo that Appendix B will be implemented.
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- 11. Provisions are established for the resolution of disputes involving quality, arising from a difference of opinion between QA/QC personnel and other department (engineering, procurement, manufacturing, etc.)
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- 12. An indoctrination and training program is established such that:
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a.
Personnel responsible for performing quality-affecting acti ities are instructed as to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures.
b.
Personnel performing quality-affecting activities are trained and qualified in the principles and techniques of the activity being performed.
c.
Proficiency of personnel perfoming quality-affecting activities is maintained by retraining, reexamining, and/or recertifying.
III. Activities related to Design Control are acceptable if:
1.
Measures are established to carry out design activities in a planned, controlled, and orderly manner.
2.
Measures are established to correctly translate the applicable regula-tory requirements and design bases into specifications, drawings, written procedures, and instructions.
3.
Quality standards are specified in the design documents, and deviations and changes from these quality standards are controlled.
4.
Designs are reviewed to assure that (1) design characteristics can be controlled, inspected, and tested and (2) inspection and test criteria are identified.
7 4
5.
Internal and external design interface controls are established.
These controls include the review, approval, release, distribution, and revision of documents involving design interfaces with participating design organizations.
6.
Proper selection and accomplishment of design verification or checking processes such as by design reviews, alternate calculations, or qualifi-cation testing are tperfoaned. When a test program is used to verify the adequacy of a design, a qualification test of a prototype unit under adverse design conditions shall be used.
7.
Individuals or groups responsible for design verification are other than the original designer and the designer's immediate supervisor.
8.
Design and specification changes are subject to the same design controls and approvals that were applicable to the original design.
9.
Errors and deficiencies in the design, including the design process,- that could adversely affect safety-related structures, systems, and components are documented; and corrective action is taken to preclude repetition.
- 10. Materials, parts,.and equipment which are standard, comercial (off the shelf) or which have been previously approved for a different application are reviewed for suitability prior-to selection.
- 11. The positions or groups responsible for design reviews and other design verification activities and their authority and responsibility are identified and controlled by written procedures.
- 12. Measures are established for the selection of suitable materials, parts, equipment, and processes for safety-related structures, systems, and components which include the use of valid industry standards and specifi-cations.
f IV. Activities related to Procurement Document Control are acceptable if:
1.
Procedures are established that clearly delineate the sequence of actions to be accomplished in the preparaticn, review, approval, and control of procurement documents.
2.
A review and concurrence of the adequacy cf quality requirements stated j
in procurement documents is perfonned by qualified personnel.
This review should determine that quality requirements are correctly stated, inspectable, and controllable; there are adequate acceptance and rejection criteria; and the procurement document has been prepared, reviewed, and approved in accordance with QA program requirements.
3.
The review and approval of procurement documents are documented prior to i
release and available for verification.
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Procurement documents identify the applicable QA requirements which must be compiled with and described in the supplier's QA program.
This QA program or portions thereof shall be reviewed and concurred with by the applicant.
5.
Procurement documents contain or reference the regulatory requirements, ths design basis, and other technical requirements.
6.
Procurement documents identify the documentation (e.g., drawings, speci-fications, procedures, inspection and fabrication plan's, inspection and test records, personnel and procedure qualifications, and chemical and physical test results of material) to be prepared, maintained, and sub-mitted to the purchaser for review and approval.
7.
Procurement documents identify those records to be retained, controlled, and maintained by the supplier, and those delivered to the purchaser prior to use or installation of the hardware.
8.
Procurement documents contain the procuring agency's right of access to supplier's facilities and records for source inspection and audit, i
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Changes and revisions to procurement documents are subject to at least the same review and approval as the original document.
j L Activities related to Instructions, Procedures, and Drawings are accehtable if:
1.
Activities affecting quality are prescribed and accomplished in accordance with documented: instructions, procedures, or drawings. -
2.
Provisions are established which clearly delineate the sequence of actions to be accomplished in the preparation, review, approval, and control of instructions, procedures, and drawings.
3.
Methods for complying with each of the 18 criteria of 10 CFR Part 50, Appendix B are specified in instructions, procedures, and drawings.
4.
Instructions, procedures, and drawings include quantitative (such as dimensions, tolerances, and operating limits) and qualitative (such as workmanship samples) acceptance criteria to verify that important activities have been satisfactorily accomplished.
5.
The QA organization reviews and concurs with inspection plans; test, calibration, and special process procedures; drawings and specifications; and changes thereto.
VI. Activities related to Document Control are acceptable if:
1.
The review, approval, and issue of documents (such as listed in item 8 below) and changes thereto, prior to release, are procedurally controlled to assure they are adequate and the quality requirements are stated.
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"' 2.
Provisions are established which identify those individuals or groups responsible for reviewing, approving, and issuing documents and revisions thereto.
3.
Changes to documents are reviewed and approved by the same organizations that perfomed the original review and approval or by other qualified responsible organizations delegated by the applicant.
4.
Approved changes are included in instructions, procedures, drawings, and other documents prior to implementation of the change.
5.
Obsolete or superseded documents are controlled to prevent inadvertent use.
1.
6.
Documents are available at the location where the activity will be per-
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formed prior to connencing the work.
7.
A master list or equivalent is established to identify the current revision number of instructions, procedures, specifications, drawings, and procurement documents.
This list is updated and distributed to i
predetemined, responsible personnel to preclude use of superseded documents.
8.
The documents that are controlled under this subsection are identified.
As a minimum this should include:
a.
Design specifications.
b.
Design and fabrication drawings.
c.
d.
QA manuals.
e.
Design criteria documents.
f.
Fabrication, inspection, and testing instructions.
g.
Test procedures.
VII. Activities related to Control of Purchased Material, Equipment, and Services are acceptable if:
1.
Qualified personnel evaluate the supplier's capability to provide acceptable quality services and products before the award of the procure-ment order or contract.
The QA and engineering groups participate in the evaluation of those suppliers providing critical components.
i 2.
The evaluation of suppliers is based on one or more of the following:
a.
The supplier's capability to comply with the elements of 10 CFR Part 50, Appendix B that are applicable to the type of material, equipment, or service being procured.
b.
A review of previous records and performance of suppliers who have provided similar articles of the type being procured.
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A survey of the supplier's facilities and QA program to determine his capability to supply a product which meets the design, manu-facturing, and quality requirements.
d.
IE confirming letter, e.
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f.
ASME "N"-stamp survey.
3.
The results of supplier evaluations are documented and filed.
4.
Surveillance of suppliers during fabrication, inspection, testing, and shipment of materials, equipment, and components is planned and performed in accordance with written procedures to assure conformance to the pur-chase order requirements.
These procedures provide for:
a.
Instructions that specify the characteristics or processes to be
- l witnessed, inspected or verified, and. accepted; the method of sur-veillance and the extent of ' documentation required; and those responsible for implementing these instructions.
1
- l b.
Audits and surveillance which assure that the supplier complies with the quality requirements.
Surveillance is performed on those,, items where verification of procurement requirements cannot be determined upon receipt.
.f 5.
The supplier furnishes -Una following records as a minimum to,the purchaser:
Documentation that identifies the purchased material or equipment and a.
the specific procurement requirements (e.g., codes, standards, and specifications) met by the items.
b.
Documentation that identifies any procurement requirements which have l
not been met together with a description of those nonconformances l
dispositioned " accept as is" or " repair."
l The review and acceptance of these documents shall be described in the purchaser's QA program and as a minimum shall be undertaken by a responsible QA individual.
6.
Supplier's certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure they are valid.
7.
Receiving inspection of the supplier-furnished material, equipment, and services is performed to assure:
a.
The material, component, or equipment is properly identified and corresponds with the identification on receiving documentation, l
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b.
Material, components, equipment, and acceptance records are inspected and judged acceptab'e in accordance with predetermined inspection instructions prior to installation or use.
c.
Inspection records or certificates of.conformance attesting to the acceptance of material, components, and equipment are available at the nuclear power plant prior to, installation or use.
d.
Items accepted and released are identified as to their inspection
'j status prior to forwarding them to a controlled storage area or releasing them for installation or further work.
8.
The effectiveness of the control of quality by suppliers is assessed i
by the applicant at intervals consistent with the importance, com-l plexity, and quantity of the item.
VIII.
Activities related to Identification and Control of Materials, Parts, and Components are acceptable if:
1.
Procedures are established to identify and control materials, parts, and components including partially fabricated subassemblies.
2.
Identification requirements am determined during generation of speci-
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fications and design drawings.
3.
The identification and control procedures assure that identification is maintained either on the item or on records traceable to the item I
to preclude use of incorrect or defective items'.
4.
Identification of materials and parts important to the function of safety-related structures, systems, and components can be traced to the appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical arid chemical mill test reports.
5.
The location and the method of identification do not affect the fit, function, or quality of the item being identified.
6.
Correct identification of material, parts, and components is verified and documented prior to release for fabrication, assembling, shipping, and installation.
IX. Activities related to Control of Special Processes (17.1.9) are acceptable if:
1.
Special processes such as welding, heat treating, nondestructive testing, and cleaning are procedurally controlled.
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Procedures, equipment, and personnel connected with special processes are qualified in accordance with applicable codes, standards, and specifications.
3.
Special processes are performed by qualified personnel and accomplished in accordance with written process sheets or
. equivalent with recorded evidence of verification.
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4.
Qualification records of procedures, equipment, and personnel associated wi.th special processes are established, filed, and kept current.
X.
Activities related to Inspection are acceptable if:
1.
An inspection program which verifies conformance of quality-affecting activities with requirements is established, documented, and accomplished in accordance with written controlled procedures.
2.
Inspection personnel are independent from the individuals performing.
l the activity being inspected.
3.
Inspection procedures, instructions, and check lists provide for the
,j following:
a.
Identification of characteristics and activities to be inspected.
b.
Identification of the individuals or groups responsible for performing the inspection operation.
c.
Acceptance and rejection criteria.
d.
A description of the method of inspection.
e.
Recording evidence of completing and verifying a manufacturing, inspection, or test operation.
f.
Recording inspector or data recorder and the results of the inspection operation.
4.
Inspection procedures or instructions are used with necessary drawings and specifications when performing inspection operations.
5.
Inspectors are qualified in accordance with applicable codes, standards, and company training programs; and their qualifications and certifications are kept current.
6.
Modifications, repairs, and replacements are inspected in accordance with the original design and inspection requirements or acceptable al te rnative.
7.
Provisions are established that identify mandatory inspection hold points for witness by an inspector.
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i 8.
The individuals or groups who perform receiving and process veri-fication inspections are identified and shown to have sufficient 1
independence and qualifications.
9.
Provisions are established for indirect control by manitoring processing methods, equipment, and personnel if direct inspectica
' is not possible.
XI. % Activities related to Test Control are acceptable if:
1.
A test program to demonstrate that the item will perform satis-factorily in service is established, documented, and accomplished in accordance with written controlled procedures.
2.
Written test procedures in' rporate or reference:
The requirements and acceptance limits contained in applicable a.
design and procurement documents.
b.
Instructions for performing the test.
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Test prerequisites.
t d.
Mandatory inspection hold points.
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e.
Acceptance and rejection criteria.
l f.
Methods of documenting or recording test data and results. -
t 3.
Test results a're documented, evaluated, and their acceptablility determined by a qualified, responsible individual or group.
XII.
Activities related to Control of Measuring and Test Equipment are acceptable if:
1.
Provisions, contained in procedures, describe the calibration technique and frequency, maintenance, and control of the measuring l
and test equipment (instruments, tools, gages, fixtures, reference and transfer standards, and nondestructive test equipment) which is used in the measurements, inspection, and monitoring of safety-related components, systens, and structures.
2.
Measuring and test equipment is identified and traceable to the calibration test data.
3.
Measuring and test equipment is labdled or tagged to indicate date of the next calibration.
4.
Measuring and test instruments are calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement..
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5.
Measures are taken and documented to determine the validity of previous inspections performed when measuring and test equipment is found to be out of calibration.
6.'
Calibrating standards have an uncertainty (errur) requirement of of no more than 1/4th of the tolerance of the equipment being
- calibrated. A greater uncertainty may be acceptable when limited by the " state-of-the-art."
7.
The complete status of all items under the calibration system is recorded and maintained.
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8.
Reference and transfer standards are traceable to nationally recognized standards, or, where national standards do not exist, provisions are established to document the basis for calibration.
XIII.
Activities related to Handling, Storage, and Shipping are acceptable if:
1.
Special handling, preservation, storage, cleaning, packaging, and shipping requirements are established and accomplished by qualified individuals in acc.urdance with predetermined work and inspection j
instructions.
2.
Procedures are prepared which control the cleaning, handling,, storage, packaging, shipping, and preservation of. materials, components, and systems in accordance with design and specification requirements to
'l preclude damage, loss, or deterioration by environmental conditions such as temperature or humidity.
XIV. Activities related to Inspection, Test, and Operating Status are acceptable if:
6 1.
Identification of the inspection and test status of structures, systems, j
and components is known throughout fabrication.
2.
The application and removal of inspection and welding stamps and status l
indicators such as tags, markings, labels, and stamps are procedurally controlled.
3.
Bypassing of required inspections, tests, and other critical operations is procedurally controlled under the cognizance of the QA organization.
4.
The status of nonconfonning, inoperative, or malfunctioning structures, systems, or components is identified to prevent inadvertent use.
XV.
Activities related to Nonconforming Materials, Parts, or Components are i
acceptable if:
l 1.
The identification, documentation, segregation, review, disposition, and notification to affected organizations of nonconforming materials, parts, components, or services are procedurally controlled.
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2.
Documentation identifies the nonconforming item; describes the non-conformance, the disposition of the nonconfomance, and the inspec-tion requirements; and includes signature approval of the disposition.
1 3.
Provisions are established identifying those individuals or groups
, delegated the responsibility and authority for the disposition and approval of nonconfoming items.
4.
Nonconforming items are segregated from acceptable items and identi-fied as discrepant until properly dispositioned.
5.
Acceptablity of rework or repair of materials, parts, components, systems, and structures is verified by reinspecting and retesting the item as originally inspected and tested or by a method which is at least equal to the original inspection and testing method.
Inspection, testing, rework, and repair procedures are documented.
6.
Nonconfomance reports dispositioned " accept as is" or " repair" are made part of the inspection records and forwarded with the hardware to the utility for review and assessment.
7.
Nonconformance reports are periodically analyzed to show quality trends, and the results are reported to management for review and assessment.
a XVI.- Activities related to Corrective Action are acceptable if:
1.
Evaluation of conditions adverse to quality (such as nonconformances, failures, malfunctions, deficiencies, deviations, and defective material and equipment) is conducted to determine the need for corrective action in accordance with established procedures.
2.
Correction action is initiated following the detemination of a condition adverse to quality to preclude recurrence.
l 3.
Follow-up reviews are conducted to verify proper implementation of l
corrective actions and to close out the corrective action documen-tation.
4.
Significant conditions adverse to quality, the cause of the conditions, and the corrective action taken are reported to cognizant levels of management for review and assessment.
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XVII.
Activities related to Quality Assurance Records are acceptable if:
l 1.
Sufficient records are maintained to provide documentary evidence of the quality of items and the activities affecting quality.
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QA records include operating logs; results of reviews, inspections, tests, audits, and material analyses; monitoring of work perfomance; qualification of personnel, procedures, and equipment, and other documentation such as drawings, specifications, procurement documents, calibration procedures and reports; nonconfomance reports; and
. corrective action reports.
3.
Recceds are identified and retrie0able.
4.
Requirements and responsibilites for record transmittals, retention (such as duration, location, fire protection, and assigned responsi-bilities), and maintenance subsequent to completion of work are consistent with applicable codes, standards, and procurement documents.
5.
Inspection and test records contain the following where applicable:
i a.
A description of the type of observation.
i j
b.
The date and results of the inspection or test.
-l c.
Information related to conditions adverse to quality.
d.
Inspector or data recorder identification.
e.
Evidence as to the acceptability of the results.
6.
Record storage facilities are constructed, located, and secured to prevent destruction of the records by fire, flooding, theft, and deterioration by environmental conditions such as temperature or humidity.
XVIII. Activities related to Audits are acceptable if:
i 1.
Audits are perfomed in accordance with preestablished written pro-cedures or check lists and conditeted by trained personnel not having direct responsibilities in the areas being audited.
2.
Audit results are documented and then reviewed with management having responsibility in the area audited.
3.
Responsible management takes the necessary action to correct the deficiencies revealed by the audit.
4.
Audits are perfomed by the QA organization to:
a.
Provide a comprehensive independent verification and evaluation of quality-related procedures and activities.
b.
Verify and evaluate suppliers' QA programs, procedures, and activities.
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5.
Audits are regularly scheduled on the basis of the status and safety importance of the activities being perfonned and are initiated early enough to assure effective quality assurance during the design, procurement, and contracting activities.
6.
Audit data are analyzed and the reports, which indicate quality trends
. and the effectiveness of the QA program, are reported to management for review and assessment.
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