ML20202B909
| ML20202B909 | |
| Person / Time | |
|---|---|
| Site: | 07109196, 07100192 |
| Issue date: | 02/09/1998 |
| From: | Campbell R CHEM-NUCLEAR SYSTEMS, INC. |
| To: | Spets J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| RA-0055-98, RA-55-98, NUDOCS 9802120122 | |
| Download: ML20202B909 (4) | |
Text
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71 911(o HEM-NUCLEAR SYSTEMS 140 ptonoridge Dihe
- Columtna. South Carolina 29210 * (803) 256-0450 February 9,1998 RA 00$$ 98 James E. Spets Transportation and Storage Inspection Section Spent Fuel Project Office Office of Nucicar Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Ref:
(1) Letter from William H. Ilouse, Chem-Nuclear Systems, to Cass R. Chappell, US NRC, dated January 9,1998.
(2) U. S. Nuclear Regulatory Commission Inspection Report No. 71-0192/97-202, dated March 6,1997 (3) VECTRA Reply to Notice of Nonconfonnance, U.S. Nuccar Regulatory Commission in-spection Report 71-0192/97 202, dated April I s,1997.
Dear Mr. Spc.
Chem Nu:Icar has applied to the Nuclcar Regulatoiy Commission to have the CertiGcate of Compliance No. 71-9196 for the UX 30 transferred from VECTRA Technologies, Inc. to Chem Nuclear (Ref.1).
Prior to our purchase of the UX.30 business from VECTRA, the NRC had conducted an audit of VECTRA and its UX.30 fabricators (Ref. 2) and VECTRA subsequently committed to certain corrective actions (Ref. 3). Chem Nuclear has reviewed References 2 and 3 and developed our position on the commitments VECTRA made to the NRC in Refereace 3. Each NRC Finding and the associated VECTRA corrective action was reviewed to determine if Chem-Nuclear should accept the corrective action as presented or modify the commitment. De attached table provides the results of this review and corre.
sponds to the finding numbers and specific corrective actions defmed in Reference 3. The long term or ge-neric corrective actions which were defined in VECTRA's response to the NRC DFl me not addressed in the table and furthermore, are not applicable to Chem Nuclear's Quality Assurance Program.
Most of the commitments are actions that Chem Nuclear would fulfill as part of our normal business and quality approach. For those items that are classified "CNS QA will verify" there may be actions that will have to be completed by CNS should our verification efforts not have positive results.
If you have any questions or comments please let me know.
Sincerely, CilEM-NUCLEAR SYSTEMS
.L' As-9902120122 900209 Richard E. Campbell ADOM OMO 2
(DR General Manager Quality Assurance l
- . a v v I 3 -
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Finding l No.
Brief Description of VECTRA's Conanitted Corrective Action Chem-Neclear Position Date to be Compicted I(a)
Review and modifv UX-30 SAR to clarifv data CNS QA to serify this was done Complete (b)
' Develop QC inspection and QA suncillance plans for fabricaten CNS will do Complete (c)
Revise QC and QA checklists associated with excrpacks CNS wiH do.
' Compkte (d)
Conduct fabrication readmess review and suncillance CNS will di 4/1/98 (c)
Increase QC/QA stafTmg CNS wiH do by ustue of addmg fabricaton Complete mspectors l
(f)
Add QA audits for inspection /suntillance activitics to Audit Schedule CNS addmg to 1998 Audit Schedule Complete 2
Quahfy UX-30 fabricators to perform sisual inspection of wclds; or use 3'*
Approach is sound and will be used by Complete party; or VECTRA mspect CNS 3
Revise QC inspection checklist for work done byjig or form. Use sampling CNS will do. We will go one step further 6/1/94 l
approach by destlopmg an apprmed sampimg plan.
4 Audit fabrication inspectwo ac <
e activLs Seeitem I (f) 6/1/93 l
5 Resemd signature authority delegau.
Not applicable to CNS n/a 6
Estabid. material control system to s sure material traceability at sub-CNS QA will strify this was done. Also Complete suppliers la ion. Confirm by sunr: Hance our program will insure this through the procurement process.
7 Obtain authorization to enter General Plastics facility for purpose of QA andzt CNS will obtam this access and mH re-6/1/93 quire it through our prAmm.cra docu-ments 8
Perform readmess review at ymmg of each rew project to ensure approval CNS wdl appro e fabricator procedures.
4/1/98 of procedures to be used by fabricator This may or may not be by th r u re-view.
9
' VECfRA Activity Schedule will track inspector re-qualification
. CNS QA will use our process Complete 10 (a)
In:k pin part number will be called out on the fabricatmn drawing CNS QA will verify Complete (b)
Fabrication drawings will be reviewed and revised to assure that critical char-CNS QA wiH verify Completc acteristics from the SAR areidentified (Note !)
(c)
Quality Category Assessment Forms wiH be reviewed and revised to include CNS QA will develop Quahty Classifica-Complete missing critical characteristics tions for these -,wed>
(d)
PO's for ball lock pms will require ces tification for double shear requirement CNS will include in our purchase order Note 2 II(a)
SAR will provide a general reference to 'KCIRA QA Program C of C transfer to CNS wiH take care of n/a i
EksersksalMIw%x3(To055-98 doc l
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this item (b)
Up date VECTRA QA Program references Not applicable to CNS n/a l
12 (a)
Roiew General Plastics QA Manual to verify.ypupuate Category B quahty CNS QA willdo this as part ofputtmg 4/I68 i
requirements General Plastics on our AVL (b)
General Plastics will update their QA Manual Same as 12 (a) 4/IS8 i
(c)
Review General Plastic QA Manual and confirm impicmentation Same as 12 (a) 4/188 13 (a)
Inspect nonconformmg items and confirm nonconformance wP.1 be tagged and CNS QA will verify 4/168 segregated per VECTRA QA Program b
t)
Provide instructions to fabricators that items found nonconforming be properly CNS will do through procummet docu-4/1S8 t
tagged and identified. Specify in procurement documents ments
[
(c)
Venfy that hold areas have been established and that nonconfomung items have CNS QA will vertfy 4/1S8 1
j been tagged 14 (a)
Olunpic corrected problem bv s.ided reference to outending ECN's CNS QA will wrify 4/168 (b)
Verify that Olpnpic is effectrvely implenv nting this new system for controlling CNS QA will verify 4/168 drawings and ECN's during readmess resiew (c)
Specify document and configuration control requirements in prammet CNS will do through piuc-met docu-4/168 documents ments 15 (a)
A reised foam specification will be issued to address these concems CNS OA will wrifv Complete (b)
General Plastics travelcrs will be revised consistent with the new foam specifi-CNS C will wrify Complete cation and ASTM standaMs (c)
General Plastics travelers will be roiewed and approved in wTiting by CNS will do this imt ally untd an accept-4/168 i
VECTRA able confidence level is obtanrd by HLW and QA 16 Same as 15 Same as 15 4/168 17 (a)
Revise the fabrication specification and/or fabrication drawings to indicate the CNS QA will wrify 4/IS 8 required levels of material traccability and acceptable methods for Category B parts of the UX-30 overpack.
(b)
Venfy that the fabricators haw established acceptable merivvh for material CNS QA willwrify 4/168 traceability and control during readiness roiew 18 (a)
Determme which welds should be left in the as-welded condition and which CNS QA willwrify Complete wcIds require grmdmg to pcmut function of the unit. Einnmate grmdmg as much as possible. Drawing will require an additional inspection when welds are i
ground. Inspection enteria will be specified in the pendiv SAR resision
)
(b)
Issue a " Required Action" that requires a similar review and revision to other Not vplicable to CNS ria EhasershisadNdwhrx30V)055-98. doc
4 e
product fabncation drawings.
19 (a)
Revise foam Specificaton to clearly detad ASTM.wouww discussed in Sameas 15 (a)
Complete Findmg 15.
(b)
General Plastics will revise their travelcr to gisc speciSc requi.unents on tem-Same as 15 (b)
Complete perature measurements (c)
Review and approve General Plastics trawlers prior to use Same as 15 (c)
NISS 20(a)
Revise SAR a.nup weld caII outs to reflect the quah5 cation tested configu-CNS QA will wrify Comp!cte ration of the UX-30 (b)
Submit revised SAR drawings to NRC for approul CNS QA willwrifv Complete 21 General Plastics will modify their traveler to include wufu uution that the re-Will be wnfied durmg review and approval NISS quired moisture protection is included of trawlers by CNS 22 Revise the foam specification to cIcarly detail the requirements that need to be Same as 15 Ulstt met and incorporate into General Plastics travelcr 23 Clarify the fabrication spect5 cation and drawing requirements for matenals CNS QA will wrify Complete commg into contact with the UX-30 **1m stecI surfaces durmg fabncation.
Verify fabricators have implemmred controls.
24 Revise foam specification and General Plastic travelers Same as 15
- 163 25 General Plastics revise the test record form to require the Kaneur, of M&TE CNS QA will wrify. This is required by 4/163 used for testmg. Identification ofequipment out of cal will imtiate an investiga-our program tion of all UX-30 units fabricated since the previous calibration Notes:
- 1. This Corrective Action was completed by VECTRA. However, Chem-Nuclear Ir.s dduuma during its review of VECTRA's 44-ov that i
some revisions should be made to the fabrication drawings. These will be completed by 6/163.
- 2. This action will be completed when Chem-Nuclear next purchases matenals for UX-30s.
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