ML20203A348

Notice of Nonconformance from Insp on 980105-09. Nonconformances Noted:Failure to Implement Corrective Actions Resulting from Previous Insp,Control Procedures Not Implemented & Inadequate Training on 10CFR21 Training

ML20203A348
Person / Time
Site:	07100231
Issue date:	02/04/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20203A339	List: ML20203A335 ML20203A348 ML20203A358
References
REF-PT21-98 71-0231-98-201, 71-231-98-201, NUDOCS 9802240006
Download: ML20203A348 (8)

Text

{{#Wiki_filter:, b '

 ,         S t84g g7 '           4                                   UNITED STATES g                j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30h0001 o
    %*...+/

NOTICE OF NONCONFORMANCE Chem Nuclear Systems Docket No. 710231 Columbia, South Carolina Based on the results of a U.S. Nuclear Regulatory Commission inspection performed on January 5-9,1998, it appears that certain of your activities were not conducted in accordance with NRC requirements. A. 10 CFR 71,133, ' Corrective action,' states: 'The licensee shall establish measures to assure that conditions adverse to quality, such as deficiencies, deviationi, defective material and equipment, and nonconformances, are promptly identified and corrected." Contrary to the above, CNS's corrective actions resulting from a previous NRC inspection were not implemented. CNS's response letter, dated October 8,1991, to NRC Inspection Report No. 71-0231/9107 states the following for nonconformances D, F1, G2, and G3:

             'The procedures for the leak testing of casks will be co' $ oared against the requirements of the apolicable Safety Analysis Report (SAR) and coirwed as required. The procedures will be updated to include test gauge range, accuracy and sensitivity along with test pressure, tolerance and duration. , , , Specific test report forms will be developed for each type of cask and will be incorporated into the applicable test procedure.' However, CNS procedure QA.TP 008," Air Pressure Soap Bubble Test Procedure,' Revision 5, did not contain test gauge ranges, accuracles, and sensitivities; test pressures, tolerances, and durations, and specific test reports were not developed for each cask B. 10 CFR 71.131, ' Nonconforming materials, parts, or components," states: "The licensee shall establish measures to control material, parts, or components that do not conform to the licensee's requirements to prevent their inadvertent use or installation. These measures must include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations."

Contrary to the above, the follov.ing instances were identified in which the nonconformance control procedure was not implemented: (1) A nonconforming item was not comrolled in accordance with CNS procedure CNS procedure Cw AD 015,' Nonconforming item and Corrective Action Procedure,' Revision 8, paragraph 3.1.1, states: 'An NCR [nonconformance report), Appendix A, shall be initiated by any CNSI employee who observes any part, component, structure, system, activity or facility that does not conform to applicable procedures, specifications, drawings . . . .* However, a % inch carbon steel cask insert shield marked ' egg l shaped' was found adjacent to nonconforming items. An NCR was not written for the nonconforming shield and, the shield did not have a nonconforming item identification attached (i.e., red tag).  ;

                                                                                                               )

I Enclosure 2 1 9002240006 900204 PDR C ADOCK 07100231 PDR

Notice of Nonconformance Docket No. 710231 (2) A nonconforming item was not controlled in accordance with the CNS procedure. CNS procedure CN AD-015,' Nonconforming item and Corrective Acuon Procedure,' Revision 8, paragraph 3.1.1, states: 'An NCR [nonconformance report), Appendix A, shall be initiated by any CNSI employee who observes any part, component, structure, system, activity or facility that does not conform to applicable procedures, specifications, drawings . . . .' However, an NCR was not written documenting the repair of a seal weld crack on cask 8120A unit #5. (3) Red tags were missing on several casks. CN AD-015,' Nonconforming items and Corre:tive Action Procedure,' Revision 8, paragraph 3.1.2, states: 'CNSI QA is responsible for . . . . Segregation and tagging / labeling of nonconforming items as appropriate to preclude inadvertent use of the item." However, several casks did not have red tags even though NCRs were written against them and documentation indicated that the casks were red tagged, C. 10 CFR 71.105, " Quality assurance program" states: *(d) The licensee shall provide for indoctrination and training of personnel performing activities affecting quality, as necessary to assure that suitable proficiency is achieved cnd maintained." l Contrary to the above, the following instances were identified indicating inadequate training on 10 CFR Part 21 requirements: (1) Records were not available to the team demonstrating that personnel had received training on the requirements of 10 CFR Part 21. CNS procedure CN AD-004,

• Defect Reporting Procedure,' Revision 8, Section 3.2, ' Indoctrination and Training
• requires that: 'CNSIindoctrination and training programs required for personnel performing activities governed by US NRC . . . shallinclude defect reporting responsibilities."

, (2) An NCR was incorrectly identified as being '10 CFR 21 applicable." CNS procedure ) CN AD-015,

• Nonconforming item and Corrective Action Procedure,' Revision 8, paragraph 3.1.2.4, states: 'CNSI QA is responsible for . . . . Performing a preliminary 10 CFR 21 applicability review to determine if Reference 2.2 (CN AD-004, ' Defect Reporting Procedure'] applies." An NCR, associated with the transfer of FSV 1 documentation from Public Service Company of Colorado to CNS, was identified as beir.g *10 CFR 21 applicable
• when it was not. CNS procedure CN-AD-015 did not have established criteria for performing a preliminary 10 CFR Part 21 review.

(3) An NCR was not controlled as required. CNS procedure CN AD-015,

• Nonconforming item and Corrective Action Procedure,' Revision 8, paragraph 4.2.5, states: 'The Director of Quality Assurance shall be responsible for . . . . Ensuring that the intamal defect or deficiency report is presented to the CNSI Safety Review Board . . . .' An NCR, associated with the transfer of FSV 1 documentation from Public Service Company of Colorado to CNS, was r.0t p.esented to 0 e Safety Review Board as required.

2-1

   .z 1

Notice of Nonconfortnance Docket No. 710231 D. 10 CFR 71.113, ' Document control," states: 'The licensee shall establish measures to control the issuance of documents such as Instructions, procedures, and drawings, including changes, which prescribe all activities affecting quality. These measures must assure that documents, includ!ng changes, are reviewed for adequacy, approved for release by authorized personnel, and distributed and used at the location where the prescribed activity is performed " Contrary to the above, the following instances were identified in which CNS failed to ensure that changes to documents were properly controlled: (1) CNS Cask Book marked as ' Controlled Copy #010" contained an out of-date procedure. CNS procedure CN AD-002,

• Document Storage and Control," Revision 17, Section 4.3,

               ' Document Distribution,' states: ' Controlled copies of revised documents shall be distributed in a timely manner, normally within ten (10) working days . . . .* However, CNS Cask Book,

• Procedures, License, and Safety Analysis Report for CNS Systems, Inc. CNS 14195H Type A Radwaste Shipping Cask USA /9094/A,' Control Copy # 010, contained an out of date revision of TR OP 008,' Handling Procedures for Transport Cask Numbers CNS 14195H Certificate of Compliance Number 9094.* The cask book contained Revision 11 of TR OP 008, dated June 6,1997, but the current revision was Revision 12, dated October 10,1997, (approximately four months out of date). Similarly, cask books for Model Nos. CNS 8120A and 8120B contained incorrect SAR revisions.

(2) All operating and maintenance procedures received from outside organizations (cask suppliers) and used by CNS were not controiled by CNS in accordance with their procedure. CNS procedure QA AD-001, Section 6.1,' Document Types Controlled," states: ' Controlled Documents include, but are not limited to, procedures, plans, design drawings, specifications, and instructions.' Furthermore, paragraph 6.3.2 states:

               ' Controlled documents are distributed in accordance with a document distribution list

• and paragraph 6.3.3 states: ' Procedures and their changes are distributed on a formal basis and are of standard format." However, CNS did not distribute documents received from outside organizations, or related changes, in accordance with a document distribution list or in a prescribed manner.

(3) A nondestructive examination (NDE) report referenced an out of-date drawing. CNS procedure QA AD-001, ' Quality Assurance Program,' Revision 10, paragraph 6.3.2, states: ' Obsolete documents are removed from work locations or identified as obsolete to preclude their use in important to Safety activities.' However, completed NDE Report No. 97-065, dated October 14,1997, referenced Drawing No. E 1 189101, Revision A F, although the current revision of Drawing No. E-1 189-101 was actually A-G, dated August 12,1985. (4) An out-of-date procedure was at the location at which work was performed. CNS procedure QA-AD-001,

• Quality Assurance Program,' Revision 10, paragraph 6.3.2, states:
• Obsolete documents are removed from work locations or identified as obsolete to preclude their use in important to Safety activities.' However, LT-04, ' General Procedure for Soap Bubt:le (Low Pressure) Leak Test " Revision 5, was at the location at which was performed although the current revision to the procedure was Revision 8.

3

y _ _ -. Notice of Nonconformance Docket No. 710231 (5) A procedure contained an incorrect revision of a drawing. CNS procedure CN AD 003,

           ' Procedure for Document Preparation,' Revision 24, Appendix B, ' Operational Procedure Criteria," Criterion 3, states: ' Ensure any equipment descriptions included in the document accurately describe the equipment that will be utilized.' However, CNS procedure TR-OP-019, ' Handling Procedure for Chem Nuclear Systems (CNS) Transport Cask CNS 3 55 Certificate of Compliance Number 5805," Revision 13, Appendix A, contained Drawing No. MOD 1391, Revision J; although the current revision was Revision K.

(6) A procedure was not reviewed for adequacy, was not approved for release by authorized personnel, and was not properly distributed. CNS procedure QA AD-001," Quality Assurance Program " Revision 10, Section 5.0, ' Instructions, Procedures, and Drawings," states: 'important to Safety activities are prescribed by documented instructions, procedures . . . . Allinstructions and procedures are maintained current with a documented method of revision. . . . Procedures, instructions and drawings are prepared, reviewed and approved in accordance with established procedures by cognizant department personnel." However, the instruction used for testing CNS 3 55 pressure relief valves for cask CNS 3 55 had no document number, revision number, or review and approval signatures. E. 10 CFR 71.111,

• Instructions, procedures, and drawings," states: 'The licensee shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followed."

Contrary to the above, the following instances were identified in which activities affecting quality were not adequately prescribed by instructions, procedures, or drawings: (1) CNS had no procedure or instruction for defining which maintenance activities were required for each specific cask or specifying the maintenance frequency. CNS procedure QA-AD-001,

• Quality Assurance Program,' Revision 10, Section 5.0, ' Instructions, Procedures, and Drawings,' states: 'important to Safety activitia are prescribed by documented instructions, procedures . . . . They include quantitative and/or qualitative acceptance criteria for determination that the prescribed activities have been satisfactorily performed.' Furthermore, *SAR for CNS, Inc. Model CNS 3-55 Type B Radwaste Shipping Cask,' Revision 0, Section 8.3.4, 'Maintunance,' states: 'A maintenance schedule shall be established to keep the cask in a full operable condition.

Procedures shall be established which will indicate the routine inspections and maintenance steps which will be taken. The procedures willindicate the frequency of the maintenance operations and inspection . . . ." However, CNS used an uncontrolled Cask Maintenance Data matrix to determine what maintenance was required for each specific cask, the maintenance frequency, and cask use. (2) An inspection / repair activity was inadequately prescribed by either a work instruction or procedure. CNS procedure CN AD-003,' Procedure for Document Preparation,' Revis'en 24, paragraph 3.1.4,

• Maintenance Procedures," states:
• Maintenance procedures include instructions for prevention and correction of a failure or deterioration

                                                      -4

. 4 Notice of Nonconformance Dockat No. 71-0231 as well as alteration or modification of equipment or structures.' Furthermore, paragraph 3.12.1 states: "An instruction is formally documented and used to control a specific unique activity.' However, a detailed inspection / repair was made (NCR N 96-020, dated February 5,1996) to a CNS 8120B cask impact limiter without the use of either a procedure or instruction. (3) CNS maintenance procedures did not address all cask maintenance. CNS procedure QA AD-001, ' Quality Assurance Program,' Revision 10, Section 5.0,

• Instructions, Procedures, and Drawings," states: *important to Safety activities are prescribed by documented instructions, procedures . . . . They include quantitative and/or qualitative accsplance criteria for determination that the prescribed activities have been  ;

satisfactority performed." Furthermore, the SAR for cask model CNSI 14 215H requires ' that, when the cask is sandblasted for repainting, the cask welds and members must be visually inspected and that magnetic particle testing be performed on any indications. However, CNS maintenance procedures and lists, including CNS procedure S20-OP 005,

• Sandblasting Facility Operations," Revision 7, did not address the required inspections or requirements for magnetic particle testing.

(4) A CNS cask handling procedure did not address all required steps. Certificate of Compliance 9094, Revision 4, Model No. CNS 14195-H, Condition 9. (b), states: 'TM package shall be prepared for shipment and operated in accordance with Section 7.0, Operating Procedures . . . ." Section 7.1.7 of the document states: " Visually inspect cask cavity to verify integrity.' However, the associated CNS operating procedure, TR OP-008, ' Handling Procedure for Transport Cask Number CNS 14195H Certificate of Compliance Number 9094,* Revision 12, does not address the step presented in Section 7.1.7. F. 10 CFR 71 135,

• Quality assurance records,' states: "The licensee shall maintain sufficient written recorw to describe the activities affecting quality. The records must include the instructions, procedures, and drawings required by 10 CFR 71.111 to prescribe quality assurance activ! ties and must include closely related specifications such as required qualification of personnel, procedures, and equipment. The records must include the instruction and procedures which establish a record retention program . . . . The licensee shall retain these records for three years beyond the date when the licensee last engages in the activity for which the quality assurance program was developed, if any portion of the written procedures or instructions is superseded, the licensee shall retain the superseded material for three years after it is superseded."

Contrary to the above the following instances were identified in which QA records were insufficient: (1) Training records were insufficient to describe activities affecting quality. CHS procedure CN-AD-023,'Certif; cation on Nondestructive Testing Personnel,' Revision 8, paragraph 6.1, states: 'A statement of certification for successful examinees shall be placed in the examinee's personnel file

• However, personnel files of an individual performing magnetic particle examination and bubble tests did not contain a statement of certification, and examination records were unavailable.

, s Notic6 of Nonconformance Docket No. 71-0231 (2) Quality assurance records were not retained as required. CNS procedure QA AD-010,

• Quality Assurance Record Keeping and Storage Procedure,' Appendix A, Revision 7, indicates that the Quality Assurance Cask inspection Records and Cask Maintenance records have a required retention period of three years; after that time, they can be discarded. Records generally reflect the routine replacement of consumable parts such as gaskets which are changed every year. However, replacement of reusable parts such '

as bolts and fasteners was not appropriately documented. i G. 10 CFR 71,121, *Intemal inspections,' states: 'The licensee shall establish and execute a program for inspection of activition affecting quality by or for the organization performing the activity, to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity. The inspection must be performed by individuals other than those who performed the activity being inspected." Contrary to the above, CNS's quality assurance personnel did not adequately document inspections. An Air Leak Test inspection Form was not completed as required. CNS , procedure QA TP 008, ' Air Pressure Soap Bubble Test Procedure," Revision 5, l paragraph 4.15, states: " Complete the Air Leak Test inspection Form (Appendix A)." However, a completed Air Leak Test inspection Form, dated g/17/97, for container type CNS 3-55 did not have a required

• Test Conducted By* signature, but was approved by QA.

In addition, the team found that many cask inspection forms were not completed (i.e., check boxes were not marked as satisfactory or unsatisfactory) and several boxes marked as unsatisfactory hac io further documentation as to corrective or follow-up actions. Similarly, the cask inspection forms were not completed but were approved by an inspector. H. 10 CFR 71,109, " Procurement document contrrd " states: 'The licensee shall establish measures to assure that adequate quality is re. l ted in the documents for procurement of material, equipment, and services, whether purenased by the licensee or by its contractors or subcontractors.' Contrary to the above, CNS was unable to provide procurement documents for paint specified in the SAR. The SAR for CNS 14170, Section 6.5.2.1 A.2 and A.3, specified that cask surfaces were to be primed with a good commercial-quality red oxide primer or Mobil Chem 89W9, or Tnemec 66-AA90 self priming epoxy and painted with Tnemoc Series 73 AA90 Endura Shield high build polyurethane or equivalent. CNS painting operations were contracted and the contractor was responsible for procuring the paint. However, procurement documents for the contractor did not specify the required paint. Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C 20555 with a copy to Susan F. Shankman, Chief, Transportation Safety and inspection Branch, Spent Fuel Project Office, Office of Nuclear Material Safety and Safeguards, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should include for each nonconformance: (1) the reason for the nonconfo nance, or if contested, the basis for disputing the nonconformance, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to

  . o Notice of Nonconformance                                                          Docket No. 710231
         - avoid further noncompliances, and (4) the date when your corrective action will be completed.

Where good cause is shown, consideration will be given to extending the response time. Because your response will be placed in the NRC Public Document Room (PDR), to the extent pcssible, it should not include any personal privacy, proprietary, or safeguards information to that it can be placed in the POR without redaction if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information, if you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information) If safeguards information is necessery to provide an acceptable response, please provide the level of protection, described in 10 CFR 73.21 Dated at this day ofM. 1998 l l

                ~

7 u

1 In accordance with 10 CFR 2.700 of the t'9C's " Rules of Practice," a copy of this letter, its enclosures, and your response will be plat,A in the NRC Public Document Room. Sincerely. Original /s/ by: Susan F. Shankman, Chief Transportation Safety and inspection Branch Spent Fuel Project Office, NMSS

Enclosures:

1. NRC Inspection Report No. 71 0231/98 201

2. Notice of Nonconformance Docket No.: 71 0231 Reviewed by: R. Sanders 1/27/98 Dlatribution:

  ~ NRC f/c!             Public )              NMSS r/f                SFPO r/f CHaughney, SFPO       GJackson, OC          JLieberman, OE          WReamer, OGC ELeeds, SFPO          FSturz, SFPO          RChappell, SFPO         CHosey, Ril BSpitzberg, RIV       TSIS Route            FCostello, RI           JMadera, Rill HStromberg,1NEEL      S:\TSISQA\ Reports \710231.rpt OFC          SFPO    E       SFPO       E         d           E       SF h,E IJAME       O JSpets       b Yb'Connor                  k             SS h an DATE         t/LE/98           l[t T [14        .) 8[k                          k C = COVER            E = COVER & ENCLOSURE                        N ='NO COPY

=_}}