ML20203A358

Insp Rept 71-0231/98-201 on 980105-09.Nonconformances Noted. Major Areas Inspected:Activities Associated W/Transportation of Radioactive Matl to Determine If Executed IAW Requirements of Parts 21 & 71 of 10CFR Cocs,Sars & QAPs

ML20203A358
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 9802240009
Download: ML20203A358 (19)

See also: IR 07100231/1998201

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Inspection Report

Docket No. 71-0231

i

U.S. NUCLEAR REGULATORY COMMISSION

Office of Nuclear Material Safety and Safeguards

Spent Fuel Project Office

inspection Report

Docket No.:

71 0231

Report No.:

71-0231/98-201

Certificate Holder:

Chem Nuclear Systems

140 Stoneridge Drive

Columbia, SC 29210

Inspection Locations:

140 Stonoridge Drive

Columbia, SC 20210

Low Level Waste Site

Barnwell, SC 29812

Dates:

January 5-9,1998

inspection Team:

S. O'Connor, ~ som Leader SFPO

J. Spets SFf v

S. McDuffie, SFPO

G. Roberts, INEEL

H. Stromberg, INEEL

NRC Observer:

P. Eng, Chief

Trar,sportation and Storage Inspection Section

Approved by:

Susan F Shankman, Chief

Transportation Safety and Inspection Branch

Spent Fuel Project Office, NMSS

Enclosure 1

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Inspection Report

Docket No. 710231

EXECUTIVE SUMMARY

NRC Inspection Report No. 71-0231/98 201

On January 5-9,1998, the U.S. Nuclear Regulatory Commission performed an announced

inspection of Chem Nuclear Systems (CNS) at its offices in Columbia and Barnwell, S.C.

The team inspected CNS's activities associated with the transportation of radioactive material to

determine if they were executed in accordance with the requirements of Parts 21 and 71 of

Title 10 of the Code of Federal Regulations (10 CFR), certificates of copliance (CoCs), safety

analysis reports (SARs), :.nd the NRC approved quality assurance (QA) program. The team

inspected CNS's management and maintenance controls.

The team concluded that CNS's management and maintenance controls were generally

acceptable. However, the team found that CNS failed to meet certain NRC requirements. The

team identified a total of eight nonconformances (Table 1) with twenty-one noncompliances as

supporting examples. Most of the noncompliances occurred in the areas of nonconformance

control, documentation control, and maintenance activities. All the nonconformances identified

were of moderato to low safety significance.

Of the twenty-one noncompliances identified, the team found a total of thirteen noncompliances

in the area of manegement controls. Specific noncompliances in the area of management

controls include a failure to implement corrective actions resulting from a previous NRC

Inspection, several instances of inadequate control of nonconforming items, inadequate training

in 10 CFR Part 21 requirements, severalinstances of failure to ensure that changes to

documents were properly controlled, and failure to properly review, approve, release, and

distribute a procedure. These noncompliances were of moderate to low safety significance. The

noncompliances of special concern to the NRC are CNS's inadequate training in 10 CFR Part 21

requirements and failure to implement corrective actions resulting from o previous NRC

insper: tion.

Eight of the twenty-one noncompliances were in the area of maintenance controls. In several

instances, activities affecting quality were not adequately prescribed by instructions, procedures,

or drawings; QA records were inadequate; and QA personnel did not adequately document

inspections, in one instance, procurement documents did not present adequate quality

requirements. These noncompliances were of moderate to low safety significance. The

noncompliance of special concern to the NRC was CNS's failure to translate SAR requirements

into instructions, procedures, or drawings.

The team did not find any issues that affected the capability of packagings to perform their

intended safety function. in addition, the team found that CNS's staff was knowledgeable of

maintenance requirements and processes and was proactive in resolving problems and other

issues. Furthermore, the team found that most of CNS's procederes reviewed were of good

quality.

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Inspection Report

Docket No. 71-0231

Table 1

Summary of Inspection Finding

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71.105

Quality assurance program

1(3)

2.3.2

71.109

Procurement document control

1

3.2.2

71.111

Instructions, procedures, and

1 (4)

3.2.2

drawinas

I

71.113

Document control

1 (6)

2.4.2

71.121

Intemalinspections

1

3.2.2

71.131

Nonconforming materials, parts, or

1 (3)

2.3.2

components

71.133

Corrective action.

1

1.3.2

71.135

. Quality assurance records

1 (2)

3.2.2

'Numbera in parentheses indicate the number of supporting examples.

The results of the inspection are depicted in the inspection Results Summary in the figure that

follows (reference NUREGICR-6314, " Quality Assurance inspection for Shipping and Storage

Containols"). This summary shows that, overall, CNS's activities were found to be adequate

primarily because the team did not identify any issues that affected the capability of packagings

to perform their intended safety function. However, this is not to say that CNS's overall QA

program met regulatorj requirements. Specifically, the team found that CNS's documentation

control, nonconformance controls, and maintenance activities did not meet regulatory

requirements, as indicated by an "R' in the performance element block.

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Inspection Report

Docket No. 71-0231

LIST OF ACRONYMS USED

10 CFR

Title 10 of the Code of Federal Regulations

CNS

Chem-Nuclear Systems

CFR

U.S. Code of Federal Regulations

INEEL

Idaho National Engineenng and Environmental Lab

NCR

nonconfor. nance report

NMSS

Office of Nuclear Material Safety and Safeguards

NRC.

Nuclear Regulatory Commission

NDE

nondsstructive examination

PDR

Pubhc Document Room

QA

quality assurance

SAR

Safety Analysis Report

SFPO

Spent Fuel Project Office

INSPECTION PROCEDURE USED

86001, " Design, Fabrication, Testing, and Maintenance of Transportation Packagings"

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Inspection Report

Docket No. 714231

PERSONS CONTACTED

The team held an entrance meeting vdth CNS on January 5,1998, to present the scope and

objectives of toe NRC inspection. On January g,1998, the team held an exit meeting with CNS

- to present the preliminary findings of the inspection. The individuals present at the entrance and

exit meetings are listed in Table 2.

Table 2

Persons Contacted

+

G. Brant

CMS, Fabncation Lead

J. Braun

CNS, Vice President Nuclear Services

R. Campbell

CNS, General Manager, QA

+

G. Crwch -

CNS, QA Inspector ll

P.Eng

NRC, Chief. Transportation & Storage inspection Section

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B. House

CNS, Vice President Regulatory Affairs

+

J. Hutto

CNS. Cask Maintenance Technician

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W. Inabinitt

CNS, Site Lead Teen of Operators

S. Kintner

CNS, Manager Document Control

G. Mancuo

CNS, QA Project Manager, UX-30 Project

M. Mohundro

CNS, Manager Quality Systems & Audits

M. Morgan

CNS, Quality Assurance Supervisor

S. McDuffie

NRC, inspector Under Instruction

S. O'Connor

NRC, inspection Team Leader

P. Paquin

CNS, General Manager High Level Waste & Spent Fuel

G. Roberts -

INEEL, inspector

J. Spets

.

NRC, inspector

H. Stromberg

INEEL, inspector

L. Toner

CNS, General Manager, Transportation Services

R. Voit

CNS, President

M. Whittaker

CNS, Senior Analyst

C. Witt

CNS, Principal Engineer

Not present at entrance meeting -

Interviewed during inspection (Not present at entrance or exit meeting)

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inspection Report

Docket No. 714231

REPORT DETAILS

1.

Inspection Scope

The team inspected CNS's management and maintenance controls to determine whether

they were executed in accordance with the requirements of 10 CFR Parts 21 and 71, CoCs,

SARs, and the NRC approved QA program. The team reviewed documentation, interviewed

personnel, and observed some activities and facility areas.

.

2.

Management Controls

2.1 General

The inspectors reviewed CNS's practices and procedures, and their implementation, to

determine the effectiveness of management controls. The team assessed the adequacy of

management controls on the basis of requirements in CNS's NRC-approved QA program.

The inspectors focused on QA program implementation, nonconformance controls,

documentation controls, and audit programs, in addition, the inspectors reviewed CNS's

actions to prevent computer software problems resulting from the change to year 2000.

2.2 Quality Assurance Proaram

2.2.1

Sguta

'

The inspectors reviewed CNS's QA program to determine the effectiveness of plans and

procedures to implement the program. The inspectors focused on QA program goals,

objectives and practices, personnel responsibilities, QA organizational independence,

delegations of authority, management involvement, and staffing levels.

2.2.2

Observations and Findinas

The inspectors found that CNS's QA program goals, and its objectives and practices,

were clearly specified in procedures and plans. The inspection team noted that CNS hao

established adequate QA organizational independence and management involvement in

implementing the NRC-approved QA program, in addition, the inspectors noted that

personnel responsibilities and delegations of authority were adequately documented and

implemented.

2.3 Nonconformance Control

2.3.1

Scope

The inspectors reviewed CNS's nonconformance control orogram to assess the

effectiveness of measures established to control materials, parts, or components that did

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Docket No. 71-0231

not conform to requirements. The inspection of nonconformance controls focused on

how CNS identified, segregated, trheked, and controlled nonconforming items and any

program deficiencies. The team looked at (1) nonconformance reports, (2) red tagged

components, and (3) measures used to keep track of the status of tagged components.

The inspectors also reviewed 10 CFR Part 21 training, implementing procedures, internal

postings, supplier notifications, reporting processes, and program controls in accordance

with the provisions of 10 CFR Part 21, Reporting of Defects and Noncompliance."

2.3.2

Observations and Findinas

The team identified a nonconformance regarding 10 CFR 71.133, ' Corrective action."

This section states: "The licensee shall establish measures to assure that conditions

adverse to quality, such as deficiencies, deviations, defective material and equipment,

and nonconformances, are promptly identified and corrected." The team identified an

instance where CNS's cerrective actions resulting from a previous NRC inspection were

not implemented.

CNS's response letter, dated October 8,1991, to NRC Inspection Report

No. 710231/91-07 stated for nonconformances D, F1, G2, and G3: "The procedures for

the leak testing of casks will be compared against the requirements of the applicable

Safety Analysis P.eport(SAR) and corrected 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, the team

found tnat CNS procedu.e QA TP-008, Pair Pressure Soap Bubble Test Procedure,"

Revision S, did not contain test gauge ranges, accuracies, and sensitivities; test

pressures, tolerances, and durations; and that specific test reports were not developed

for each cask.

At the location where maintenance was performed, the team found an uncontrolled

matrix titled "CNSI Cask Fleet Leak Test Information;" this matrix contained much of the

required test information. In addition, the team found that test report sheets, for various

casks, were modified to incorporate test requirements (i.e., acceptance criteria) end

copied for repeated use. It is important to note that the matrix and modified test report

sheets had not been appropriately reviewed and approved, and were not part of the

approved procedure.

One of the modified test report sheets listed the wrong pressure specification reference.

Specifically, the mod,fied test report sheet for Model CNS 8-120A referenced SAR

paragraph 8.2.2.2, not paragraph 8.1.3, which should have been referenced.

'

Paragraph 8.2.2.2 does not exist in the SAR for Model 8-120A. It is important to note

that even though the wrong reference was sited, tne correct pressures and liold times

were recorded and used for the air leak tests inspected.

The team identified a nonconformance regra1ing in CFR 71.131, " Nonconforming

materials, parts, or components." This sectior, states: "The licensee shall establish

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Inspection Report

Docket No. 71-0231

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." The team identified the following

instances in wnich CNS's nonconformance control procedure was not implemented:

A. The team found two nonconforming items that were not controlled in accordance with

the CNS procedure. CNS procedure UN 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 [ Chem-Nuclear -

Systems, Inc.] employee who observes any part, component, structure, system,

activity or facility that does not conform to applicable procedures, specifications,

drawings . . . .' However,

(1) The team found a % inch carbon steel cask insert shield that was marked as " egg

shaped" and located adjacent to other nonconforming items. Furthermore, the

team found that no NCR was written for the nonconforming shield and that the

shield was not identified as a ncnconforming item (i.e., red tagged). As a result of

the team's finding, CNS issued NCR Report No. N-98-001.

(2) On June 22,1995, while cask 8-120A unit #5 was at a non-CNS facility, CNS was

informed that water was found in two cask lid bolt holes. CNS responded in

writing on June 22,1995, that the water likely resulted from a crack in a seal -

weld, and the cask would be repaired when it was retumed to Bamwell. CNS

corrected the problem after the cask was retumed on June 30,1995, but an NCR

documenting the weld crack was not written. The weld in question was non-

structural and did not affect package safety during transport.

B. The team found several nonconforming casks without red tags which were used to

identify nonconforming parts. CNS procedure CN-AD-015," Nonconforming items

and Corrective 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, the team found

several casks that had no red tags, even though NCRs were written against the -

casks and the Cask Maintenance Data matrix indicated that the, casks had been red

tagged (e.g., Model FSV-1). As a result cf this finding, CNS attached red tags to the

nonconforming casks.

The team identified a nonconformance regarding 10 CFR 71.105, * Quality assurance

program." This section states: *(d) The licensee shall provide fcr hdoctrination and

training of personnel performing activities affecting quality, as necessary to assure that

suitable proficiency is achieved and maintained." The team identifed the following

instances where training on 10 CFR Part 21 requirement- was unacceptable:

A. CNS could not provide records to the team demonstrating that required personnel

had received trairdag on the requirements of 10 CFR Part 21. Specifically, CNS

procedure CN-AD-004, " Defect Reporting Procedure," Revision 8, Section 3.2,

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Docket No. 71-0231

' Indoctrination and Training,' requires that: 'CNSI indoctrination and training

programs required for personnel performing activities govemed by US NRC . . .

shall include defect reporting responsibilities."

B. An NCR was incorrectly identified as being "10 CFR 21 applicable." CNS procedure

CN-AD-015, ' Nonconforming item and Correct.ve Action Procedure," Revision 8,

paragraph 3.1.2.4, states: "CNSI QA is respons',', 'or . . . . Performing a

preliminary 10 CFR 21 applicat,ility review to detem..no if Reference 2.2

[CN AD-004,' Defect Reporting Procedure") applies." The team found an NCR,

associated with the transfer of FSV-1 documentation from Public Service Company of

Colorado to CNS, that was identified as being "10 CFR 21 applicable." CNS

informed the team that the NCR was incorrectly marked as being "10 CFR 21

applicable" because the individual who completed the NCR was confused as to the

purpose of the "10 CFR 21 epplicable" section of the NCR. The team also found that

CN-AD-015 did not define the criteria for performing a preliminary 10 CFR Part 21

review. CNS informed the team that personnel will be trained on when an item

should be marked as *10 CFR 21 applicable."

C. The team found an NCR that 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 , , . ." However, the team found that an NCR, associated

with the transfer of FSV 1 documentation from Public Service Company of Colorado

to CNS, was not presented to the Safety Review Board as required. CNS informed

the team that personnel will be trained on the selection criteria and method for

forwarding issues 'o the Safety Review Board.

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2.4 Documentation Controls

2.4.1

Scone

The inspectors reviewed CNS's documentation control program to determine the

offectiveness of the QA program in controlling quality-related documentation. The

inspection team reviewed instructions, procedures, and drawings, including revisions

thereof, for adequacy, approval signatures, reicase by authorized personnel, and

availability. The team reviewed such documents as cask handling procedures,

insp:ction and test procedures, maintenance and test results, nonconformance reports,

QA procedures, cask manuals, SARs, and cask drawings.

2.4.2

Observations and Findinas

in general, the team found that CNS procedures were detailed, well written, and

encompassed all required QA areas.

However, the team identified a nonconformance regarding 10 CFR 71.113, " Document

control." This section states: "The licensee shall establish measures to control the

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issuance of documents such as instructions, procedures, and drawings, including

changes, which prescribe all activities affecting quality. These measures must assure

that documents, including changes, are reviewed for adequacy, approved for release by

authorized personnel, and dictributed and used at the location where the prescribed

activity is performed.'

A. The inspectors found that in the following instances, CNS failed to ensure that

changes to documents were property controlled:

(1) The team found that the CNS Cask Book marked as " Controlled Copy #010"

contained an out-of date procedure. CNS procedure CN-/.D-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 (1C) working days . . . ." However, the team found that CNS

Cask Book, " Procedures, License, and Safety Analysis Report for CNS 9ystems,-

Inc. CNS 14-195H Type A Radweste 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 14-195H Certificate of Compliance

Number 9094." The cask book contained Revision 11 of TR-OF-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 8-120B contained incorrect SAR revisions. As a resuit of the

finding, CNS took immediate corrective action and issued NCR N 98 002 to

address the Ysue. It should be noted however, that the copy of TR-OP-008 at

the location where maintenance wcs performed was current.

(2) The team found that not all opeiating and maintenance procedures received from

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outside organizations (cask suppliers) and used by CNS were appropriately

controlled by CNS in accordance with the pertinent administrative procedure.

CNS procedure QA-AD-001, Section 6.1, " Document Types Controlled," states:

' Controlled Documents include, but arc not limited to, procedures, plans, design

drawings, specificaSons, 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, the team found that

documents and document changes, which were provided by outside

organizations for CNS use, were not distributed by CNS in accordance with a

document distribution list or in a formal raanner.

(3) The team found a nondestructive examination (NDE) report that 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, the team found that completed NDE Report

No.97-065, dated October 14,1997, referenced Drawing No. E-1-189-101,

Revision A-F although the current revision of Drawing No. E-1-189-101 was

actually Revision A-G, dated August 12,1985. Furthermore, the team found that

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Inspection Report

Docket No. 710231

the associated CNS Cask Book, " Procedures, License, and Safety Analysis

Report for CNS Systems, Inc. CNS 14-195H Type A Radweste Shipping Cask

- USA /9094/A," Control Copy # 010 contained both Revision A F and Revision A G

of Drawing No. E-1-189101. CNS informed the team that the individual who

performed the NDE consulted the associated CNS Cask Book to determine the -

appropnate drawing revision.~ However, the individual referenced the wrong

l

revision because both revisions were in the book and the difference was not

noted. it should be noted that Revision A-G was minor in nature and did not

affect the test results. As a result of this finding, CNS corrected the NDE report

and removed the out-of dats drawing from the cask book.

(4) The team found an out-of date procedure at the location where 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." The team found that the current revision of LT-04, " General

Procedure for Soap Bubble (Low Pressure) Leak Test," was Revision 8; however,

Revision 5 was at the location where work was performed

(5) The team found a procedure that contained an incorrect revision of a drawing

and, therefore, did not accurately describe the cask. CNS procedure CN-AO-003,

" Procedure for Document Preparation," Revision 24, Appendix B," Operational

Procedure Criteria," Criterion 3, states: " Ensure any equipment descriptions -

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includou in the document accurately describe the equipment that will be utilized."

However, the team found that 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-139-1, Revision J.1he current revision was Revision K, which -

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incorporated dimensional changes to the cask. The changes were of low safety

significance, and Appendix A of TR OP-019 was not even addressed in the body

of the procedure.

B. The team found an instance in which a procedure had not been reviewed for

adequacy, approved for release by autt orized personnel, or properly distributed.

CNS pacedure QA-AD-001, " Quality Assurance Program," Revision 10, Section 5.0,

"Instrucdons, 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 team found that the CNS 3-55 pressure relief valve test procedure had

no document number, no revision number, no review or approval signatures, and did

not comply with the requirements of CN-AD-003, " Procedure for Document

Preparation," Revision 24.

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2.5 Audit Program

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2.5.1

EG9De

The inspectors reviewed CNS's audit program to determine whether plans, procedures,

and records were available. The inspection of the audit program focused on determining -

whether CNS scheduled and performed intomal QA audits and vendor audits in

accordance with approved procedures o socklists; whether qualified, independent,

personnel performed the audits, whether CNS manegement reviewed audit results, and

whether CNS took appropriate follow-up actions in those areas found deficient.

- 2.5.2 - Observations and Findinas

The inroection team found that the CNS's intomal audit program was well documented

.and we, ..plemented. .The inspectors noted that CNS scheduled and performed

comprehensive annual intomal and vendor audits to assess the implementation of the

NRC-approved 10 CFR Part 71 QA program. The inspectors also noted that audits were

performed using qualified auditors.

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2.6 Year 2000 Software Evaluation Proaram

-2.6.1

Scope

The inspectors reviewed the CNS software evaluation program to determine whether the

'. year 2000" effect was being addressed. The inspection of the software evaluation

program focused on determining whether CNS was aware of the NRC generic .

communications and whether CNS was reviewing software applications for potwi.oal

problems.

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~2.6.2

Observations and Findinas

The inspection team found that CNS staff were aware of NRC Information Notices 96-70

and 97-61 addressing the year 2000 issue. CNS had identified three computer systems

vulnerable to the year 2000 problem. Two of the systems were potentially safety-related,

and one of these systems had been made year-2000 compliant. The remaining safety-

related system was transportation package-based software, which required a separate

corrective action for each package.' The correctivs actions were being coordinated with

the individual CNS package customers on an ongoing basis. CNS staff informed the

team that they foresaw no potential hindrances to completing the correction before 2000.

2.7 Conclusions on Manaaement Controls

The team concluded that ONS's management controls were generally acceptable. However,

the team found tl.at CNS failed to meet certain NRC requirements. The team identified a

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total of thirteen noncompliances in the area of management controls. Specific

noncompliances in the area of management controls include failure to implement correctis e -

- actions resulting from a previous NRC inspection, several instances of inadequate control of

nonconforming items, inadequate training in 10 CFR Part 21 requirements, several instance:

of failure to ensure that changes to documents were property controlled, and failure to

property review, approve, release, and oistribute a procedure. These noncompliances were-

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of moderate to low safety significance. The noncompliances of special concem to the NRC

are CNS's inadequate training in 10 CFR Part 21 requirements and failure to implement

corrective actions resulting from a previous NRC inspection. In addition, the team found that

most of CNS's procedures reviewed were of good quality.

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3.

Maintenance Controls

3.1 General

. The inspectors reviewed CNS's maintenance controls to determine whether required

maintenance was identified and performed, appropriate materials were used, maintenance

personnel were trained and qualified, appropriate tools and equipment were used, failure

trending analysis was performed, and hold points were appropriately established.

3.2 Maintenance Activities

3.2.1

SGent

The team reviewed CNS's maintenance requirements, procedures, records, personnel -

records, and materials. The team specifically looked at cask SARs, CoCs, and QA

program requirements; operating, handling, test, maintenance, and inspection

procedures, completed mair,tenance packages, personnel training and qualification

- record % purchase orders, material storage areas, material shelf life, approved vendors

list, and maintenance areas.

3.2.2 . Qbservations and Findinos

The team identified a nonconformance regarding 10 CFR 71.111. " Instructions,

procedures, and drawings." This section states: 75e 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." The team identified the following instances in which activities

affecting quality, were not adequately prescribed by instructions, procedures, or

drawings:

A. The team found that CNS did not have a procedure or instruction for defining what

maintenance activities were required for each specific cask or for specifying a

maintenance frequency. 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/oi qualitative acceptance criteria for

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determination that the prescribed activities have been satisfactorily perfon&d?

Furthermore, *SAR for CNS Mode! CNS 3-55 Type B hadwaste Shipping Cask,'

Revision 0, Section 8.3.4, " Maintenance,' states: "A maintenance schedule shall be

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established to keep the cask in a full operable condition. Procedures shall be

established which will in.Weata the routine inspections and maintenance steps which

will be taken. The procedures willindicate the frequency of the maintenance

operations and inspection . .

? However, the tea"n found that CNS used an

uncontrolled Cask Maintenance Data matrix to determine what maintenance was

required for each specific cask, the maintenance frequency, and cask status for use.

B. The team found an instance in which an inspection / repair activity was not adequately

prescribed by either a work instruction or a procedure commensurate with the

component's importance to safety. CNS procedure CN AD-003, * Procedure for

Document Preparation," Revision 24, paragraph 3.1.4, " Maintenance Procedures,"

states: ' Maintenance procedures include instructions for prevention and correction of

a failure or deterioration as well as alteration or modification of equipment or

structures? Furthermore, paragraph 3.12.1 states: 'An instruction is formally

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documented and used to control a specific unique activity? However, the team found

1st an inspection / repair was performed on a Model CNS 8120B cask impact limiter

(NCR N-96-020, dated February 5,1996) without the use of either a procedure or

instruction. The impact limiter was damage' during use and was subsequently

inspected / repaired to ensure it was acceptable for future use. The impact limiter

inspection / repair involved: (1) cutting holes in the side of the impact limiter, (2)

inspecting the interior foam, (3) evaluating the inspection results, (4) accepting or

rejecting the equipment, (5) weiding patches over the inspection holes while ensuring

that excessive heat did not damage the foam, and (6) performing NDE of the welds.

The entire sequence was only documented on an NCR with an attached memo. In

addition, the NCR described the steps as an after-the-fact description of the work

performed rather than as a procedure to perform the work.

C. The team found that CNS maintenance procedures did not address important cask

maintenance. CNS procedure QA-AD-001,"Qustity E urance Program,"

Revision 10, Section 5.0, ' instructions, Procedures, and Drawings,' states:

• 1mportant to Safety activities are prescribed by documented instructions, procedures

. . . They include quantitative and/or qualitative acceptance criteris for

determination that the prescribed activities have been satisfactorily performed."

Furthermore, the SAR for cask Model CNSI 14-215H requires that when the cask is

sandblasted for repainting, a visualinspection of the cask welds and members must

be performed, and that a magnetic particle test must be performed on a,1y

indications. However, the team found that CNS maintenance promdures and lists,

including CNS procedure S20-OP-005, " Sandblasting Facility Operations "

Revision 7, did not address the required inspections or magnetic particle testag

requirements. CNS indicated to the team that it was unaware of the SAR inspection

requirement.

D. The team found that a CNS cask handling procedure did not address all required

steps. Certificate of Compliance 9094, Model CNS 14-195-H, Revision 4,

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- Condition 9 (b) states: 'The package shall be prepared for shipment and operated in

accordance with Section 7.0, Operating Procedures . . . ." Section 7.1.7 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 did not address

the Section 7.1.7 required visual inspection.

The team identified a nonconformance regarding 10 CFR 71.135, " Quality assurance

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records." This section states: "The licensen shall maintain sufficient written records to

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describe the activities affecting quality. The records must include the instructions, _

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procedures, and drawings required by 10 CFR 71.111 to prescribe quality assurance

activities and must include closely related specifications such as required qualification of

personnel, procedures, and equipment. The records must include the instruction and -

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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

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activity for which the quality assurance program was developed, if any portion of the

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written procedures or instructions is superseded, the licensee shall retain the superseded

material for three years after it is superseded." The team identifed the following

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instances of insufficient QA records:

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A. The team found that training records were insufficient to describe activities affecting

- quality. CNS procedure CN-AD-023,"Cettification 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, -

the team found that the personnel files of an individual perfor.r.ing magnetic particle

- examination and bubble tests did not contain a statement of certification and that

examination records were not available. The team also noted that locating training

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records for personnel took a long time.. The team found that the individual in question

- had been certified earlier by a previous employer; therefore, the team had a sufficient

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degree of cenfidence in his ability to perform testing.

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B. The team found that CNS diu not retain QA records as required. CNS procedure

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QA-AD-010, " Quality Assurance Record Keeping and Storage Procedure,"

Appendix A, Revision 7, indicates that Quality Assurance Cask Inspection Records

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and Cask Maintenance records have a required retention period of three years, after

which they can be discarded. Recorde generally reflect the routine r 9 placement of

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consumable parts such as gaskets which are changed every year. h' wever,

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replacement of reusable parts such as bolts and fasteners was not appropriately

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documented.

The team identified a nonconformance regarding 10 CFR 71.121, "Intemal inspections."

This section states: "The licensee shall establish and execute a program for inspection

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of activities affecting quality by or for the organization performing the activity, to verify

conformance with the documented instructions, procedures, and drawings for

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. accomplishing the activity. The inspection must be performed by individuals other than

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those who performed the activity being inspected." The team identified instances in

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which CNS's QA personnel did not perform adequate inspection documentation,

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1 he team found that an Air Leak Test inspection Form was not completed as

required. CNS procedure QA-TP-008, ' Air Pressure Soap Bubble Test Procedure,"

Revision 5, paragraph 4.15, states: " Complete the Air Leak Test inspection Form

(Appendix A).* However, a completed Air Leak Test inspechon Form, dated

September 17,1997, 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 seve el boxes marked as unsatisfactory had no

further documentation as to corrective or follow-up actions. Similarly, the cask

inspection forms which were not completed, were nevertheless, approved by an

inspector.

The team identified a nonconfcrmance regarding 10 CFR 71.109, " Procurement .

document control." This section states: "The licensee shall establish measures to

assure that adequate quality is required in the documents for procurement of material,

equipment, and services, whether purchased by the licensee or by its contractors or

subcontractors." The team found an instance in which procurement documents failed to

contain adequate quality requirements.

CNS was unable to provide procurement documents for paint specified in the SAR.

The SAR for CNS 14-170, 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

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89W9, or Tnemec 66-AA90 self-priming epoxy and painted with Tnemec Series

73-AA90 Endura Shield high-build polyurethane or equivalent. CNS told the team

that painting operations were contracted and that the contractor was responsible for

procuring the paint. Additionally, CNS told the team that the CNS's procurement .

documents for the contractor did not specify the type of paint to be used. .CNS -

informed the team that CNS had procured the last two orders of paint, for use by the

contractor, and that the CNS's procurement documents specified the paint required

by the SAR. For the last two orders of paint, the team verified that the procurement

- documents specified the required paint.

The team noted that in a material storage area, two "O'-ring seals had exceeded their shelf-

life. Aher the team found the two items exceeding their shelf life, the Cask Maintenance

Technician discarded the 'O"-rings. It is important to note that CNS had a program in place

that prevented the use of a material with an exceeded shelf life and that the team found no

material used with an exceeded shelf-life. The team reviewed shelf-life controls and found

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that a materiars shelf-life was identified when the material was procured and that the shelf-

life was recorded on a material tracking tag which was attached to the material. When CNS

collected the material for use, the shelf-life was verified and recorded on controlled

documentation (i.e., inspection sheets or NCRs).

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3.3 Tools and Eauipment

3.3.1

inanection Scone

"

The team reviewed CNS's mair:tenance tool and equipment controls to verify that tools

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and equipment were identdied, controlled, calibrated, and traceable to when and where

they are used. The team inspected calibration documentation, tools and equipment,

storage areas,- and completed test and inspection documentation.

3.3.2

Observations and Findings

The team foun' d that tools and equipment were identified by an assigned unique

identification number, were controlled, and were traceable to when and where the item

was used. Calibration information is also monitored for appropriate tools and equipment.

3.4 Conclusion of Maintenance controls

The tes'n concluded N CNS's maintenance controls w;re generally acceptable. However,

the team found that CNS failed to meet certain NRC requirements The team found a total of

eight noncompliances in the area of maintenance controls, in s-

% Mtances activities

affecting quality were not adequately prescribed by instructions,

= jurosior drawings; QA

records were inadequate; and QA personnel did not adequately cocument inspections.- In

one instance, procurement documents did not present adequate quality sequirements.,

These noncompliances were of moderate to low safety significance. The noncompliance of '

special concem to the NRC was CNS's failuro to translate SAR requirements into

instructions, procedures, or drawings. The team did not identify any issues that affected the

espability of packagings to perform their intended safety function. In addition, the team found

' that CNS's staff was knowledgeable of maintenance requirements and processes and were

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proactive in the resolution of problems and issues.

4.

Overall Conclusion

The team concluded that CNS's management mntrols were generally acceptable. However,

the team found that CNS failed to meet certain JRC requirements. The team identified a

total of thirteen noncompliances in the area of management centrols. Specific

- noncompliances in the stoa of management controls include failure to implement corrective

actions resulting from a previous NRC inspection, several instances of inadequate control of

g

nonconforming items, inadequate training in 10 CFR Part 21 requirements, several instances

of failure to ensure that changes to documents were properly controlled, and failure to

- properly review, approve, release, and distribute a precedure. These noncompliances were

of moderate to low salety significance. The noncompliances of special concem to the NRC

are CNS's inadequate training in 10 CFR Part 21 requirements and - failure to implement

corrective actions resulting from a previous NRC inspection.

The team concluded that CNS'c maintenance controls were generally acceptable. However,

the team found that CNS failed to meet certain NRC requirements. The team found a total of

eight noncompliances in the area of maintenance controls. In several instances activities

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affecting quality were not adequately prescribed by instructa .ms, procedures, or drawings; QA

records were inadequate; and QA personnel did not ads b ately document inspections. In

one instance, procurement documents did not present adequate quality requirements.

These noncompliances were of moderate to low safety signifmance. The noncompliance of

special concem to the NRC was CNS's failure to translate SAR requirements into

instructions, procedures, or drawings.

The team did not identify any issues that s'focted the capability of packagings to perform

- their intended safety function in addition, the team found that CNS's staff was

knowledgeable of maintenance rwyuirements and processes and was proactive in the

resolution of problems and issues. Furthermore, the team found that most of CNS's

procedures reviewed were of good quality,

5.

Exit Meeting

On January 9,1998, P.t the conclusion of the inspection, the team held an exit meeting with

CNS's management to preson' the preliminary inspection findings. CNS's management

acknowledged the inspection findings presented by the team.

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