ML20203K546
| ML20203K546 | |
| Person / Time | |
|---|---|
| Site: | 07100231 |
| Issue date: | 03/02/1998 |
| From: | Campbell R CHEM-NUCLEAR SYSTEMS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RA-0017-98, RA-17-98, NUDOCS 9803050131 | |
| Download: ML20203K546 (19) | |
Text
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6 HEM NUCLEAR SYSTEMS 140 Sto.widge Drive e columbia, south carohna 29210 * (803) 256-0450 March 2,1998 RA-0017-98 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
REPLY TO A NOTICE OF NONCONFORMANCE Ref:
NRC Inspe: tion Report No. 71 0231/98 201
Dear Sir / Madame:
This letter addresses the items of nonconformance identified during the January 5 9, 1998 USNRC inspection of Chem Nuclear Systems and documented in the referenced inspection report. Each nonconformince was evaluated and actions taken to correct the specific issue as well as actions to prevent recurrence.
The following is Chem-Nucles a reply to each nonconformance:
Nonconformance:
A.
10 CFR 71.113, " Corrective Action," states: "The licensee shall establish measures to assure that wonditions adverse to quality, such as deficiencies, deviations, defective material and equipment, and nonconfonnances, are promptly identified and corrected."
1 Con'.rary to the above, CNS's corrective actions resulting from a previous NRC inspection 3
were not implemented.
CNS's response letter, dated October 8,1991, to NRC Inspection Report No. 71-0231/91 07 states the following 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 Report (SAR) and corrected as required. The procedures will be updated to include test gauge range, accura and sensitisity along with test pressure, tolerance and duration.
Specific test rer
'orms will be developed for each type of cask and will be incorporated into the applicabk..st procedure." However, CNS procedure QA TF-008, " Air Pressure Soap Bubble Test Procedure," Rmision 5, did not contain test gauge ranges, accuracies, and sensitivities; test pressures, tolerances, and durations, and specille test reports wete not developed for each cask.
Reason for Nonconformance:
The above activities were being performed to informal controls.
Thia nonconformance was caused by inattention to the details of criteria 10 CFR 71.111 which requires quality activities to be prescribed by instructions, procedures or drawings.
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Corrective stens that have been taken:
The accuracy, frequency, test gauge ranges, sensitivities, test pressures, tolerances and acceptance criteria were incorporatcd into QA TP 008, Resision 6.
Training on this revised procedure was provided to QA inspectors on Febmary 9,1998.
, Corrective steps that will be taken to avoid further noncomollances:
Training was provided on February 9,1998 to responsible parties to assure personnel are aware of the requirements for quality activities to be prescribed by instructions, procedures and/or drawings.
Cprrective Action Comnietion Date:
l February 9,1998 Nonconformance:
- a. 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 indade, as appropriate, procedures for identification, documentation, segregation, dispositinn, and notification to affected organizations."
Contrary to the above, the following instances were identified in which the nonconformance control procedure was not implemented:
(1) A nonconforming item was not controlled in acco+ce with CNS procedure. _ CNS procedure CN-AD-015, " Nonconforming item an, vective Action Procedure,"
Revision 8, paragraph 3.1.1, states: "An NCR, Appeno.,
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.
Ilowever, a % inch carbon steel cask insert shield merked " egg shaped" was found adjacent to nonconforming items. An NCR was not written for the nonconforming shield and, the shi:ld did not have a nonconforming item identification attached (i.e., red tag)
Reason for Nonconformauce:
This nonconformance was caused by personnel failing to follow thr: programmatic requirements for documenting nonconfoaming items.
Corrective steps that have been taken:
NCR N 98 001 was issued to document this condit on and the cask insert shield was red tagged as required by Procedure CN-AD-OlS.
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forrective stens that will be taken to avoid further noncompilances:
Training on CNS program requirements for documenting and tagging of nonconforming items was provided to QA/QC personnel on Febmary 9,1998.
Corrective Action Completion Date:
February 9,1998 Nonconformance:
(2) A nonconforming item was not controlled in eccordance with the CNS procedure. CNS proculure CN.AD-015, " Nonconforming item and Corrective Action Procedure,"
Revision 8, paragraph 3.1.1, states: "An NCR, 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.
110 wever, an NCR was not written documenting the repair of a seal weld crack on cask 8-l 120A, unit #5.
l Reason for Nonconformance:
This nonconformance was caused by personnel failing to fol'ow programmatic regt:rements for documenting nonconforming items.
Corrective stens that have been taken:
NCR N 98-004 was issued on January 13,1998 to address this issue. A 1995 Engineering memo -
Wds prOVided to the InspCCtion Team which indicated that the seal weld crack did not compromise the integrity of the cask and did not affect hs use as a licensed package.
Corrective steps that will be taken to avohl further noncompliances:
Training en CNS program requirements for documenting nonconforming items was provided to appropriate personnel on February 9,1998.
Corrective Action Completion Date:
February 9,1998 Nonconformance:
- 0) Red tags were missing on severai casks.
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 3
appropriate to preclude inadvertent use of the items." liowever, several casks did not have red tags even though NCRs were written against them and documentation indicated that the casks were red tagged.
Reason for Nonconformance:
It was CNS's understanding and observation, during the NRC inspection, that only one cask v as missing the red tag. There were approximately forty casks required to be tagged at the time of this inspection and red tags had been issued and attached to the casks. The cause for the missing red tag was attributed to wind which broke the tag securing wire.
Corrective stens that have been taken:
A new tag was attached as noted below. The cask in question would v.ot have been used since the cask status was noted as being " Red Tagged" on the Cask Maintenance Data Matrix and a gate pass signed by QA is required for casks exiting the site.
Corrective steps that will be taken to avoid further noncompliances:
We now use plastic tie wraps '.o secure the tags or will use a hard plastic tag with a stainless steel bails to secure the tags to the cask trailer glad hand. For casks that are sitting on the ground, the red tag will be attached to the cask lining lug with a plastic tie wrap.
Correctlye Action Completion Date:
January 9,1998 Nonconformance:
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 and maintained." Contrary to the above, the.
following instances were identified indicating inadequate training on 10 CFR Part21 requirements:
(1) Records were not available to the term demonstrating that personnel had received training on the requirements of 10 CFR Part 21. CNS procedure CN-AD-604," Defect Reporting Procedure," Revision 8, Section 3.2, " Indoctrination and Tiaining," requires that: "CNSI indoctrination and training programs required for personnel performing activities governed by US NRC..
shall include defect reporting responsibilities."
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Recion for Nonconformancei The training for 10 CFR Part 21 was not comprehensive and was conducted informally.
Contributing to this nonconformance was a reliance on individuals' c :perience in the nuclear industry.
Correttive stens that have been taken:
A comprehensive lesson plan will be developed for 10 CFR Part 21 training. Training sessions will be conducted for employees who have the potentici of observing or detecting a reportable defect.
Corrective steps that will be taken to avoid further noncompliances The Manager, Quality Systems & Audits will place this training requirement in the QA Training tracking system and the refresher training will be cor. ducted annually.
l Corrective Action Completion Date:
l April 1,1998 Nonconformance:
(2) An NCR was incorrectly ider.tified as being "10CRF 21 applicable." CNS procedure CN-AD 015, " Nonconforming item and Corrective Action Procedure," Revision 8, paragraph 3.1.2A, states: "CNSI QA is responsible for..
. P.:rferming a preliminary 10 CFR 21 applicability review to determine if Reference 2.2 (CN.AD-004, " Defect Reporting Procedure"j applies." An NCR, associated with the transfer of FSW1 documentation from Public Service Company of Colorado to CNS, was identified as being "10 CFR 21 applicable" when it was not.
CNS procedure CN AD-015 did not have established criteria for performing a pre,liminary 10 CFR Ptrt 21 review.
Reason for Nonconformance:
The individual that rnarked the NCR as "10 CFR 21 applicable" misunderstood the space on the NCR. lie thought the space was asking whether or not the item fell under the scope cf Part 21 requirements. The labeling of this space and the training issue addressed in item 1 above were the reasons for this nonconformance.
Corrective stens that have been taken:
T he NCR was corrected and the individual was briefed on the meaning of the space on the NCR.
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Correttive stens that will be taken to avoid further noncomnllances Training will be held as discussed in item 1 above. Additionally, the NCR form is being revised to clear up the confusion associated with the Part 21 review space. CNS Procedure CN AD-015 will be revised to I, Jude criteria for performing a preliminary 10 CFR Part 21 review.
Coirective Action Completion Daln April 1,1998 Nonconformance:
(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 iriternal i
defect or deficiency report is presented to the CNSI hafety Review Board...." 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 j
required.
Reason for Nonconformance:
The individual who marked the NCR as "Part 21 applicable" never intended that the NCR be a potentially reportable condition. See response to item 2 above. Therefore, the NCR was not submitted to the General Manager, QA for presentation to the Safety Review Board.
Corrective steps that have been takem The NCR was corrected to show that the item is not potentially reportable under Part 21.
A memo was submitted to the Safety Review Board Chairman on January 16,1998 to inform the Board of this issue and to explain that :he NCR was not reportable under Part 21, Corrective stens that will be taken to avoid further,p;ncompliances The training and procedure revision discussed in items 1 and 2 above will also prevent further noncompliance in this area.
Colrective Action Completion Date; April 1,1998 i
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. 4-Nonconfonnance:
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-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 prescribc all activities affecting quality.
These measures rnet l
assure that documents, including changes, are reviewed for adequacy, approved for release by authorized personnel, and distributed and used at the location where the prescribed activity is performed."
1 Contra.ry to the above, the following instances were identified in which CNS failed to ensure i
E that changes to documents were appropriately controlled:
- I (1)' CNS Cask Book marked as " Controlled Copy #10" contained an out-of-date proct ue i
- CNS procedure CN-AD-002, "Documen* Storage and Control," Revision 17, Secti 2
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" Document Distribution," states: " Controlled copies of revised documents sh -
distributed in a timely me.ner, 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 #10, contained an out of date revision of TR-OP-008, " Handling Pr~
..c n Transport u
Cask Numbers CNS 14-195H Certificate of Compliance Number b 94." 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, e
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cask books for Model Nos. CNS 8-120A and 8-120B contained incorrect SAR revisions.
, Reason for Nonconferriance:
Documem Control was issuing two copies of prG:edures to our Controlled Copy #10 with the
' intention that the copies would be used to update two separate binders in difTerent locations. The individual responsible for updating these binders was not adequately trained in the methods to be -
used for Contri Copy #10. As a result both topies were being placed in one binder. There was also a lack of understanding by the recipient on how SAR's were required to be up-dated.
Corrective sters that have been taken:
. NCR # N-98-002 was issued to document this condition. Corrected, complete cask books were re issued by_ Document Control to replace all the Control Copy #19 cask books.
These newly issued books were rechuked by QA and no discrepancies were nated..
Corrective steps that will be taken to avoid further noncomoliances Document control training was provided to responsible personnel on February 2,1998.
Document Co7 trol now only issues I copy of casic procedures _to control copy #10. We have placed a page in the associated procedure binder that <.tates the pudure is maintained in the cask book.
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Corrective Action Ceppletion Date:
February 4,1998 Nonconformancet (2) All operating and maintenance procedures received from outside organizations (cask suppliers) and used by CNS were not controlled by CNS in accordance with their 1
procedure.
CNS procedure QA-AD-001, Section 6.1, " Document Types Centrolled,"
states: " Controlled Documents include, but are not limited to, procedures, plans, design drawings, specifications, and instructimis."
Furthermore, paragraph 6.3.2 states:
" Controlled documents are distributed in accordance with a documents distribution list" and paragraph 6.3.3 states: "Proceaures and their changes are distributed on a formal
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basis and are of standard format." However, CNS did not distribute documents rect.
from outside organizations, or related changes, in accordance with a documcat distribution list or in a prescribed manner.
Reason for Nonconformance:
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The Molten Metal Technology 3rd party cask book containing the NUPAC Leak Test procedure LT04 is issued to Barnwell Quality Assurance and maintained in the QA Department The copy of LT04 used in the Cask Maintenance Building was copied, in violation of CNS procedures, from this controlled 3rd Party cask book resulting in this nonconformance.
Corrective steps that have been taken:
The procedure in the Cask Maintenance Building was replaced with the current revision (revision
- 8) of this procedure.
CNS Documunt Control has performed an inventory of outside organizations' (cask suppliers) operating and mr.intenance procedures.
These identiced documents will be entered into the CNS Document Control distribution system and will be issued under a CNS controlled copy number assigned to the Cask Maintenance Building where the work is performed.
Corrective stens that will be taken to avoid further noncompliances:
Documents from outside organizaf ms, including revisions will be issued to CNS employees under controlled distributiori by Chd D :uraent Control using distribution lists.
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Corrective Action Completion Date:
May 1,1998 Nonconfermance:
(3) A nondestructive examination (NDE) report referenced an out-of-date drawing.
CNS procedure QA-AD-001, " Quality Assurance Program", Revision 10, paragraph 6.6.3.2, states: " Obsolete documents are removed from work locr.tions or identified as obsolete to preclude their use in Important to Safety activities." llowever, completed NDE Report No 07-065, dated October 14,1997, referenced Drawing No. E-189-101, Revision A-F, although the current revision of Drawing No. E-1-189-101 was actually A-G, dated August 12,1985.
Reason for Nonem]fo rmance:
The cask book did not contain the current drawing.
This nonconformance was caused by irattention to detail and inadequate training.
Corrective stene that have been takeni The NDE Report was corrected to reflect revision A-G. The only chanFe between revisions A-F r
and A-G was :he addition of a burgundy painted stripe around the center of the cask with no impact on the NDE performed.
Corrective steps that will be taken to avoid 'urther noncompliances:
Training on cask book maintenance and use was provided to personct.. responsible for updating cur Control Copy #10 on February 4,1998.
Corrective Action Completion Date:
r February 4,1998 Nonconforman_cn e
(4) An out-of-date procedure was at the location at which work was performed.
CNS prccedure QA-AD-001, " Quality Assurance Program," Revision 10, paragraph 6.3.2, states: " Obsolete doc ments are removed from work locations or identified as obsolete to preclude their use m Important to Safety activities." However, LT-04, " General Procedure for Soap Eubble (Low Pressure) Leak Test," Revision 5, was at the location at which work was performed although the currant revision to the procedure was revision 8.
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Reason for Nonconformance:
The Molten Metal Technology 3rd partj cask book containing the NUPAC Leak Test procedure LT04 is issued to Barnwell Quality Assurance and maintained in the QA Department. The copy of LT04 used in the Cask Maintenance Building was copied, in violation of CNS procedures, from this controlled 3rd Party cask book resulting in this nonconformance.
)
Corrective steps that have been taken:
The procedure in the Cask Maintenance Building was replaced with the current revision (revision
- 8) of this procedure.
CNS Document Control has performed an inventory of outside organizations' (cask suppliers) operating and maintenance procedures.
These identified documents will be entered into the CNS Document Control distribution system and will be issued under a CNS controlled copy number assigned to the Cask Maintenance Building where the work is performed.
Cm rective steps that will he taken to avoid further noncompliance;:
Documents from outside organizations including revisions will be issued to CNS employees under j
controlled distribution by CNS Document Control using distribution lists.
Corrective Action Completion Date:
May 1.1998 Nonconformance:
(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 description included in the document accurately describe the equipment that will be utilized" Howevu, 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, contamed Drawing No.
MOD-139-1, Revision J, although the current revision was Revision K.
Reason for Nonconformance:
During the last revision of thn procedure an inadequate review was conducted by the reviewer to er.sure all referenced drawi. v!apaendix figures were correct. The cause of this nonconformance was the improper preparation an? +
ew of tids procedure.
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Corrective steps that have been taken:
CNS Procedure TR-OP-019 will be revised to remove drawing revision levels.
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6 Corrective steps that will he taken to r, void fudher noncompliances:
Petsonnel who conduct procedure reviews will be instructed to review the entire procedure for comimance to program and regulatory requirements, and anytime a revision L made to a procedure, ensure all informatica contained in the procedure is correct. Also, drawing revision levels will not be included in the procedure, the procedure will only reference the drawing title and name.
Corrective Action Compleilon Date:
March 27,1998 Nonconformance:
(6) A procedure was not reviewed for adequacy, was not approved for release by authorized persennel, 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 prescrit.ed by documented instructions, procedures.
All instructions and procedures are maint.
.i current with a documented method of revision.
Procedures, instructions and drawir, are prepared, reviewed and appt aved 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, revi.on number, or revi:nv and approval signatures.
Reason for Nonconformance:
The 3-55 relief valve was b6ag tested per the requiremente of the SAR and documented on a form that was signed by the person conducting the test end CNS QA. The testing was being performed per written guidelines and not an approved woik instruction or procedure.
This nonconformance was caused by inattention to the require;nents of 10 CFR 71.111 and QA-AD-001, Quality Assurance Program, revision 11, Section 5.0.
Corrective steps that have been taken:
A detailed procedure (QA-TP-014) was written, approved, and released on February 12,1998 for performance ofleak testing of the 3-55 reliefvalve.
Corrective steps that will be taken to avoid further noncompliances:
CNS personnel that perform testing / maintenance of casks will be instruc ed that testing / maintenance must be in accordance with approved work instructions or procedures. Training was provided on February 9,1998 to Quality Assurance personnel to assure that they are awar2 of the requirements for quality activities to be prescribed by instructions, procedures and/or drawings.
Corrective Action Completion Date:
March 27,1998 11 u
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Nonconformance:
E.
10 CFR 71.111, "Instiuctions, procedures, and drawings," states: "The licensee shall prescribe activities affecting quality by documented instructions, procedures, or drawings, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followed."
h 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,
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" Quality Assurance Prog"m," Revision 10, Section 5.0, " Instruction, Procedures, and Drawings," states: "Importa " Safety activities are prescribed by documented instructions, procedures They.. lude quantitative andk.r 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 h
8.3.4, "Maintcance," states: "A maintenance schedule shall be establishe ' 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 will indicate the c
frequency of the maiitenance 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.
Reason for Nonconformance:
m The Cask Maintent:e Data Matrix was being used as a guideline and tool to track required leak testing, gasket changes, annuai inspections, special testind, and casks out of sersice as required by cask SAR's. Use of this matrix assisted in assuring that no cask was released from the Barnwell Facility without the cask testing and maintenance being current. Inattention to the requirements of 10 CFR 71.111 and QA-AD-001, Quality Assurance Program, revision 11, Section 5.0 was the reason for the matrix not being a formal procedure.
Corrective siens that ha ve been taken:
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The Cask Maintenance Data Matrix was incorporated into CNS Procedure QA-QI-005, Revision 11.
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t Corrective steps that will be taken to avoid fudher noncompliances:
Training was provided on February 9,1998 to appropriate personnel (QA/QC, Coinplir.nce, site persormel) to a::sure these personnel are aware of the requirements for quality activities to be prescribed by instructions, procedures and/or drawings.
Corrective Action Coneletion Date:
February 9,1998 Nonconformance:
(2) An inspection / repair activity was inadequately prescribed by either a work instruction or procedure.
CNS procedure CN-AD-003, " Procedure for Document Preparation,"
Revision 24,. paragraph 3.1.4, " Maintenance Procedures," states: " Maintenance procedures included instructicas 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 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' 8-120B cask impact limiter without the use of either a procedure or instruction.
Lesson for Nocconformance:
This nonconformance was the result of personnel not following programmatic requirements and performing a repair activity without a w itten approved instruction.
Corrective steps that have been taken:
No specific corrective steps are required since the repair activity is completed and the documented evidence was presented during the inspection that indicated the repairs were properly completed.
CNS Engineering concurred and approved the repairs on NCR #N-96-020.
Corrective steDs that will be taken to avoid further noncompliances:
Training of QA personnel on the programmatic requirements for performing repair activities to written instructions was accomplished on February 9,1998.
QA will ensure through their inspection process that repairs are accomplished using written instructions or procedures. The Manager, Quality Systems & Audits will issue a memo to other applicable CNS personnel to reiterate these requirements.
Co.rrective Action Completion Date:
March 6,1998 I
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Nonconformanc,n (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 instructic,ns, procedures.
They include quantitative and/or qualitative acceptance criteria for determination that the prescribed activities have been satisfactorily l
performed." Furthermore, the SAR for cask model CNSI 14-215H requires that, when I
the cask is sandblasted for repainting, the cask welds and members must be visually inspected and that magnetic particle testing be performea on any indication.
- However, l
CNS maintenance procedures and lists, including CNS procedure S20-OP-005, l
" Sandblasting Facility Operations," Revision 7, did not addreas the required inspections or requirements for magnetic particle testing.
Reason for Nonconformance:
Based on discussion with personnel, the above activities were being performed during cask efurbishment and documented on the cask supplemental inspection report.
This nonconformance was caused by inattention to the criteria of 10 CFR 71.111 and QA-AD-001, Quality Assurance Program, revision 11, Section 5.0 which requires quality ac,ivities to be prescribed by instructions, procedures or drawings.
Corrective steps that have been taken:
CNS Cask Model 14-215H SAR, Section B, references performing a visual inspection of cask welds post s md blasting and prior to painting. The supplemental cask inspection documents were generated while refurbishment activities were performed on CNS Casks and provided documented ev;dence of weld inspections. Section 3.3 of procedure QA-QI-005 was revised (Revision 11) to include the requirements for cask refurbishment activities, including visua' and magnetic particle inspection aller sand blasting and prior to painting.
Corrective steps that will be taken to avoid further noncompliances:
Training was provided en February 9,1998 to responsible personnel on the requirements for quality activities being prescribed by instructions, procedures and/or drawings.
Corrective Action Campletion Dates:
February 9,1998 Nonconform mce:
(4) A CNS cask-handling procedure did not ad fress all required steps. Certificate of Compliance 9094, Revision 4, Model No. CNS 14-195H, Condition 9. (b), states: "The package shall be prepared for shipment ud operated in accordance with Section 7.0, Operatirg Procedure.
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" Section 7.1.7 of the document stetes: " Visually inspect cask cavity to verify integ4" 110 wever, the associated CNS operating proceduce, TR-OP-002, "liandling Procedure for Transport Cask Number CNS 14-195H Certificate of Compliance Number 9094," Revision 12, does not address the step presented in Section 7.1, Reason for Nonconformance:
The procedures contained in the SAR, section 7, were written as generic procedures. The daily operations and use of the cask (loading' unloading) are performed by procedures that are more detailed than the generic procedures in the SAR. When the detailed procedures were written and appcoved it was not the practice to include all the steps listed in the SAR generic procedure. The NRC Inspection Team has indicated that all steps in the generic proce.L c must be included in the detailed procedures.
This nonconformance was caused by a different approach to implementing procedural controls than the interpretation provided during the NRC inspection.
Corrective steps that have been taken:
The CNS detailed cask handling procedure (TR-OP-008) is being compared to the SAR generic procedure to cr.sure that the requirements of the SAR generic procedure are included in the CNS Jctailed procedu.e. CNS also intends to review all of the CNS detailed cask handling procedures to ensure that the requirements of the SAR procedure are incorporated into the detailed procedures.
This action will occur over the next several months and procedures will be revised as discrepancies are noted.
Corrective steps that will be taken to avoid further noncompliances:
CNS personnel that prepare and approve CNS cask handling procedures have been instructed to review the cask SAR procedure prior to preparing and/or approving the CNS dett.iled cask handling procedure. These personnel will ensure that the appiopriate requirements of the SAR procedures are included in the CNS detailed procedure prior to final approval and distribution of the procedure.
Corrective Action Completion Datei Revise TR-OP-008 - March 27,1998 Review and revise, as necessary, all CNS cask handling procedures - October 2,1998 Nonconformance:
F F.
10 CFR 71.135, " Quality assurance records," states: The licensee shall maintain suflicient written records to describe the activities affecting qua'ity The records must include the instmctions, 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 procedures which establish a record retention program.
The licensee shall retain these records for three years beyond the date when the !!censee last engages in the 15
activity for which the quality assurance program was developed. If ar.y portion of the written procedures or instmetions is superseded, the licensee shall retain the superseded ma,erial for thre: years after it is superseded."
Co.itrary to the above the following instances were identified in which QA records were insuflicient:
(1) Training records were insullicieat to describe activities afTecting quality. CNS procedure CN-AD-023, " Certification on Nondestructive Testing Personnel," Revision 8, paragraph 6.1, states. "A statement of certificction 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 centain a statement of certification, and examination records were unavailable.
Reason for Nonconformance:
This norconformance was caused by inattention to detail by the individual responsible for completing and filing the training records.
Corrective stens thst have been taken; The individual, whose file was incomplete, was retested on January 20,1998 and passed. The certification was placed in the einployee's training record. A claridcation note was included on the retest that the previous test was lost.
Corrective steps that will be taken to avoid further noncompliances:
The remaining Inspector NDE training records were reviewed with no other deficiencies noted.
The individuals providing the testing, completing the certification form and filing the training records were counseled on the importance of properly completing and filing training recoros as the training is completed.
Corrective Action Completion Date:
January 20,1998-Nonconformance:
i (2) Quality assurance records were not retained as required.
CNS procedure QA-AD-010,
" Quality Assarance Record Keeping and Storage Procedure," Appendix A, Revision 7, l
ir.dicates that the Quality Assurance Cask Inspection I;ecords and Cask Maintenance l
records have a required retention period of thme years; after that time, they can be i
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.
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Reason for Nonconformaxe:
This nonconformance was caused by incorrectly not considering inspection reports addressirg fasteners when the three-year retention period was assigned for inspection records.
Con ective steps that have been taken:
CNS Precedure QA-AD-010, the applicable records procedure, was revised to classify these inspection records as lifetime.
Corrective steps that will be taken to avoid further noncompliances:
QA AD-010, Revision 8, now specifies retention efinspection records as lifetime. No inspection reports were discarded even though retention periods had exoired.
Drrectise Action Completion Date; February 10,1998 Nonconformance:
G.
10 CFR 71.121, " Internal inspections," states: "The licenr.ee shall establish and execute a program for inspection of activities affecting quahty 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 A
inspections.
An Air Leak Test Inspection Form was not completed as requiied.
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 Inspection Form, dated 9/17/97, for contair.er-type CNS 3-55 did not have required " Test Conducted By" signature, but was approved by QA. In addition, the
'eam found that many cask ir.apection forms were not completed (i.e., check boxes were not marked as satisfactory or unsatisfactory) and several boxes maAed as unsatisfactory had no fiirther documentation is to corrective or follow-up actions. Similarly, the cask inspection forms were not completed but were app roved by an inspector.
Reason for Nonconformanm This nonconformance was caused by inattention to detail by those individuals responsible for the data entry.
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s Corrective steps that have been taken:
The deficiencies identified during the course of the inspection we.e corrected. Additionally, a detailed review was performed of these types of records generated since 1994 and errors were corrected, as necessary.
Corrective stens that wdl be taken to avoid rudher noncompliances:
s The individuals responsible for data entry were counseled on February 9,1998 on the importance of assuring that QA recceds are properly completed.
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[orrectit.-, Action Completion Date:
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February 9,1998 Noncenformance:
H.
10 CFR 71.109, " Procurement document control," states: "The licensee shall establish measures I
to assure that adequate quality is required in the documents for procurement of material, a
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equipment, and services, where purchased by the licensee or by its centractors or subcontractors."
Contrary to the above, CNS was unable to provide procurement documents for paint spec tied in the SAR. The SAR for CNS 14-170, Section 6.5.2.1 A.2 ard A.3, specified that cask smfaces were to be primed Ah a good commercial-quality red-oxide primer or Mobil Chem 89W9, or Tnemec 66-AA90 self-priraing epoxy and painted with Tnemcc Series 73-AA90 Endura-Shield high-build polyurethane or equivalent.
CNS painting operations were contracted and the contractor was responsible f.: procuring the paint.
However, procurement documents for the contractor did not specify the required paint.
Reason far Nonconfonnance:
The person that performs all cask painting is under contract to CNS and uses or.ly CNS supplied paint.
The paint is ordered by CNS and is the proper paint as required by the SAR. The Purchase Order used t y CNS to contract the painting has not specified to the painter that only certain paint can be used.
Therefore, the painter could have used the wrong paint. This nonconformance was caused by incomplete instructions being imposed via the CNS Purchase Order.
Corrective steps that have been taken:
m CNS will continue to order cask paint and provide detailed instructions to the painter on which type of paint to use. This information will be specified on purchase orders for cask painting services.
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I8 t
Corrective stens that will be taken to avoid further noncompliances:
Painter will be instructed via CNS purchase orders on types of paint to use. CNS Procedure QA-Ql-005 was revised to include checking that the proper paint is used for painting casks.
Corrective Action Completbn Date:
Febmary 5,1998 Chem-Nuclear Systems is confident that these actions will adequately resolve the specific items of nonconformance and will provide overall improvements to our quality program.
If you have any questions regarding this reply phase do not hesitate to call me at (803) 758-1808.
Sincerely, CHEM-NUCLEAR SYSTEMS
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- ?hs-Richard E. Campbell General Manager, Quality Assurance cc: Susan F. Shankman U.S.NRC Chief, Transportation Safety & Inspection B an h Spent Fuel Project Office Office Nuclear Material Safety and Safeguards Regan Voit Bill House Jim Braun Len Toner Jim Latham 19
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